Conference Proceedings Pollution Of Lake Michigan and Its Tributary Basin Third Session Reconvened In Workshop Sessions September 28, 29 30, October 1, 2, 1970 Chicago, Illinois Vol 5

PROCEEDINGS THIRD SESSION RECONVENED IN WORKSHOP SESSIONS September 28, 29, 3O, October 1,2, 197O. Chicago, Illinois Vol. 5, CONFERENCE Pollution of Lake Michigan and Its Tributary Basin U.S. DEPARTMENT OF THE INTERIOR . . . FEDERAL WATER QUALITY ADMINISTRATION ------- 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 V Bal Tabarin Room Sherman House Chicago, Illinois October 2, 1970 ------- 11 CONTENTS Page Telegrams and Letters (read by Murray Stein): 1720 - 1726 Pearl L. Pohl 1720 Robert Q. Kuehn 1720 Mrs. Ralph G. Dunlap 1722 George Graff 1724 John Chascsa 1726 Thomas E. Dustin 1723 Mrs. J. F. Voita 1760 Eileen L. Johnston 1761 Frank Pierson 1769 Arthur Pancoe 1775 Mrs. Lee Botts 1795 Lowell Gomes 1314 Edith McKee 1&L9 Hon. Abner J. Mikva William J. Scott John E. Bardach l£62 Hon. Robert E. Mann 1895 Joseph T. Sobota, M. D. 1923 William S. Singer 1945 Hon. Philip A. Hart (read by Murray Stein) 1950 Ted F. Miller 1954 Mrs. Louise Erickson 1957 Ron McCandlis 1962 ------- iii CONTENTS, Continued Dana Schindler 1966 Raynor F. Sturgis, Jr. 2024 Herbert P. Read 2023 Mrs. Robert A. Barber 203# Mrs. Shirley Gruen 2039 Mrs. Mary Helen Dunlop 2042 George Brown (presented by Mary Helen Dunlop) 2043 Clyde Mathews 2047 Mrs. Miriam G. Dahl 2049 Mrs. Donald Trump 2054 Russell G. Hill 206? John F. Wilson 2076 Carole Magnus 212# Mrs. Edgar Wilkinson 2129 Mrs. Catherine T. Quigg 2130 Hon. Gaylord Nelson 2132 Vance Van Laanen 2133 Ted Mac Donald 2151 Sol Burstein 2159 John C. Berghoff 2160 Mary Alice McWhinnie 2164 Mrs. Sylvia Troy 2247 Seymour AItman 2248 Mrs. L. W. Bieker 2250 Mrs. Robert McKimpton 2251 Andrew J. 0'Conor 2261 ------- iy CONTENTS, Continued John Chascsa 2289 Harold B. Olin 2298 A. J. Boehm 2304 Mrs. Paul Kaefer 2305 Mrs. Robert Herlocker 2306 James Sloss 2303 2356 Michael R. Rouse 2309 Mrs. Maynard J. Seidraon 2310 2357 Lucy M. Barr 2311 Aaron S. Wolff 2312 Closing Remarks - Murray Stein 2313 Documents Received Following Conference: Petition, Citizens of Lansing, Michigan 2324 Mrs. Richard Schnadig 2325 W. D. Mohr 2326 Adlai E. Stevenson III 2329 Grace Marie Knapp 2330 Gaylord Nelson 2333 Michigan State Chamber of Commerce 2334 F. Scammon Barry 2336 E. M. Davey 2337 Robert Dover 233# Bradley M. Glass 2339 Ted Falls 2345 ------- CONTENTS, Continued F. A. Miskimen 2350 Mrs. Maxwell McCrohon 2353 Mrs. Dan Harper 2354 Hon. Robert McClory 2355 ------- VI 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 and the Randolph Room of the Sherman House, Chicago, Illinois, on Friday, October 2, 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, B.C. CONFEREES: CLARENCE W. KLASSEN, Director, Illinois Environmental Protection Agency, Springfield, Illinois. PERRY E. MILLER, Assistant Director, Stream Pollution Control Board, Indiana State Board of Health, Indianapolis, Indiana. ALTERNATE CONFEREES: DAVID P. CURRIE, Chairman, Illinois Pollution Control Board, Chicago, Illinois. ------- vii ALTERNATE CONFEREES, Continued: JACOB D. DUMELLE, Member, 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. R. J. SCHNEIDER, Deputy Regional Director, Federal Water Quality Administration, U.S. Department of Interior, Chicago, Illinois. ROBERT P. HARTLEY, Director, Office of Enforcement and Cooperative Programs, Federal Water Quality Administration, U.S. Department of Interior, Chicago, Illinois. PARTICIPANTS: Thomas E. Dustin, Executive Secretary, Indiana Division, Izaak Walton League of America, Fort Wayne, Indiana. A. Joseph Dowd, Assistant General Counsel, American Electric Power Service Corporation, Two Broadway, New York, New York. ------- viii PARTICIPANTS, Continued: 0. K. Petersen, Senior Attorney, Consumers Power Company, Jackson, Michigan. Mrs. J. F. Voita, Oak Park, Illinois. Eileen L0 Johnston, Wilmette, Illinois. Frank Pierson, Spokesman, Campaign Against Pollution, Chicago, Illinois. Arthur Pancoe, SAVE, Campaign Against Pollution, Glencoe, Illinois. Mrso Lee Botts, Open Lands Project, Chicago, Illinois. Lowell Gomes, Senior Associate, Theodore S. Leviton & Associates, Chicago, Illinois. Edith M. McKee, Chief Geologist, Theodore S. Leviton & Associates, Chicago, Illinois. The Honorable Abner J. Mikva, u. S. House of Representatives, Washington, D,C. William J. Scott, Attorney General, State of Illinois, Springfield, Illinois. John E. Bardach, Professor of Natural Resources, University of Michigan, Ann Arbor, Michigan. Jack Hipke, Wisconsin Power and Light Company, Madison, Wisconsin0 David Do Comey, Campaign Against Environmental Violence, Chicago, Illinois. ------- IX PARTICIPANTS, Continued: H. R. Thoke, Wisconsin Southeast Chapter of Trout Unlimited. The Honorable Robert E. Mann, Chairman, Lake Michigan and Adjoining Land Study Commission, Chicago, Illinois. Joseph T. Sobota, M.D., President, TEMP, Kalamaaoo, Michigan. William S. Singer, Alderman, 43rd Ward, Chicago, Illinois. The Honorable Philip A. Hart, U. S. Senate, Washington, B.C. Ted F. Miller, Chairman, Elk River Drainage Basin Council, Elk Rapids, Michigan. Mrs. Louise Erickson, Chairman, Racine Committee for the Natural Environment, Racine, Wisconsin. Ron McCandlis, President, Pro-Tern, Michigan Steelhead and Salmon Fishermen's Association, Kalamazoo, Michigan. Miss Dana Schindler, Manistee County Anti- Pollution Organization, Manistee, Michigan. Raymond F. Sturgis, Jr., Director, Illinois Department of General Services, Springfield, Illinois. Herbert P. Read, State Director, Indiana Division, Izaak Walton League of America, Chesterton, Indiana. ------- PARTICIPANTS, Continued: Mrs. Robert A. Barber, Deerfield, Illinois. Mrs. Shirley Gruen, Wisconsin Federation of Women's Clubs, Glendale, Wisconsin. Mrs. Mary Helen Dunlop, Evanston, Illinois. George Brown, Committee on Lake Michigan Pollution, Wilmette, Illinois (presented by Mary Helen Dunlop). Clyde Mathews, Community Action to Reverse Pollution, Gary, Indiana. Mrs. Miriam G. Dahl, Izaak Walton League, Wisconsin State Division, Milwaukee, Wisconsin. Mrs. Donald Trump, Chairman, Environmental Quality, League of Women Voters of Indiana, Valparaiso, Indiana. Russell G. Hill, Executive Secretary, State Soil Conservation Committee, Lansing, Michigan. John F. Wilson, Director, Wisconsin Ecological Society, Green Bay, Wisconsin. Miss Carole Magnus, Secretary, Manistee County Anti-Pollution Organization, Manistee, Michigan. Mrs. Edgar Wilkinson, Society Against Violation to the Environment, Highland Park, Illinois. Mrs. Catherine T. Quigg, Barrington, Illinois. ------- XI PARTICIPANTS, Continued: Vance Van Laanen, President, Wisconsin Resources Conservation Council, Green Bay, Wisconsin. Ted MacDonald, West Lafayette, Indiana. John C. Berghoff, Associate General Counsel, Swift & Company, Chicago, Illinois. Sol Burstein, Senior Vice President, Wisconsin Electric Power Company, Milwaukee, Wisconsin. Mary Alice McWhinnie, Professor, Department of Biological Sciences, DePaul University, Chicago, Illinois. Ted Falls, President, Porter County Chapter, Izaak Walton League, Wheeler, Indiana. Seymour Altman, Commissioner, Highland Park Environmental Control Commission, Chicago, Illinois. Mrs. L. W. Bieker, Division Board, Indiana Division, American Association of University Women, Munster, Indiana. Mrs. Robert McKimpton, Independent Citizens' Water Pollution Research, Ind., Hammond, Indiana. Sylvia Troy» President, Save the Dunes Council, Munster, Indiana. Andrew J. 0'Conor, Attorney, of the firm of Berry and 0'Conor, Ottawa, Illinois. John D. Harper, Director, Environmental Parameters Research Organization, Chicago, Illinois. ------- xii PARTICIPANTS, Continued: Harold B. Olin, AIA, Member, Board of Directors, Lake Michigan Region Planning Council, Chicago, Illinois. A. J, Boehra, American Fishing Tackle Manufac- turers Association, Chicago, Illinois. Mrs. Paul Kaefer, Citizen, Northbrook, Illinois. Mrs. Robert Herlocker, Calumet Area Branch, American Association of University Women, Munster, Indiana, James Sloss, Glencoe, Illinois. Michael R. Rouse, Waukegan, Illinois. Mrs. Maynard J. Seidmon, Glencoe, Illinois. Lucy M. Barr, Highland Park, Illinois. Aaron S. Wolff, Chicago, Illinois. Michael Sheldrick, McGraw-Hill Publications. Mrs. Richards Schnadig, Action Acommittee, League of Women Voters, Glencoe, Illinois. D. W. Mohr, P.E., Benton Harbor, Michigan. Grace Marie Knapp, Mequon, Wisconsin. The Honorable Gaylord Nelson, U. 3. Senate, Washington, B.C. F. Scammon Barry, Glenview, Illinois. E. M. Davey. Robert Dover, Wilmette, Illinois. Bradley M. Glass, Attorney, Chicago, Illinois. T. A. Meskimen, Senior Engineer, American Electric Power Service Corporation, New York, New York. ------- Xlll PARTICIPANTS, Continued: Mrs. Maxwell McCrohon, Crete, Illinois. Mrs. Dan Harper, Crete, Illinois. The Honorable Robert McClory, U. S. House of Representatives, Washington, D.C, ------- 1720 Murray Stein PROCEEDINGS MR. STEIN: Let's reconvene. We have several telegrams here, "We believe in the present environmental crisis. We must not court further disaster by allowing any industry to return heated water to Lake Michigan, until it is precisely determined what effects added heat will have on the multiple uses for which water is used. A 3 percent increase in cost of electrical production is negligible in -solution of grave problems of water quality with which we are now faced." La Budde Memorial Chapter (Women) Izaak Walton League of America, Pearl L. Pohl, President, Milwaukee, Wisconsin. I didn't know they had female chapters. I am a member-at-large of the Izaak Walton League. I think I am going to affiliate with one of those. "The Milwaukee Chapter of the Izaak Walton League of America strongly recommends that the water temperature from water coolants used in nuclear powerplants discharged into Lake Michigan be the same temperature as that of the intake. Temperature extremes that vary widely from the norm as yet have not been fully investigated as to their effect. They could prove to be very detrimental to all aquatic life. Therefore, until sufficient research ------- 1721 Murray Stein is available concerning the effect of the temperature variation of the Great Lakes waters, future nuclear power- plants should be required to maintain the present tempera- ture level." Robert 0. Kuehn, President, Milwaukee Chapter of the Izaak Walton League. "I strongly support your efforts to establish strict and enforceable thermal pollution standards to protect the aquatic and shoreline ecology of Lake Michigan. We must not let Lake Michigan become another Lake Erie. "I endorse the United States Department of Interior proposal to limit thermal discharges to a maximum of one degree Fahrenheit higher than the natural lake temperature. "We must avoid irreparable damage to the ecology of the lake. Significantly raising water temperatures will not only kill some of the lake's fish but accelerate the growth of undesirable bacteria. "Power companies can construct cooling towers to avert the warm-water problem. Toledo Edison Electric Company plans to build a cooling tower for its powerplant on Lake Erie. The cost of such towers is small compared with the cost to our environment if Michigan becomes a dead lake. "I commend the pioneering efforts of citizens' ------- 1722 Murray Stein groups such as yours in acting in the face of substantial opposition to protect Michigan's environmental heritage, I have asked Ralph Purdy to give serious consideration to your views." This is also from Senator Sander Levin. Then, here is a letter saying: "I wish to urge as strongly as possible the adoption by the Four-State Conference on Lake Michigan of the strictest standard under consideration for control of thermal pollution in Lake Michigan: a maximum of fone degree Fahrenheit rise over ambient at the point of discharge.' "It is absolutely essential, if we are to pre- serve Lake Michigan, to take the long view; in this case, to take into consideration the long-range and cumulative effects of returning heated water to the lake. Let us not use Lake Michigan to death. Too often, we have said, 'We have no alternative;1 or 'It's too expensive;' or 'We can take care of that problem later, when it arises;' and consequently we have found irreversible damage has been done by our lack of thoughtful care and caution — by our negligence. "Something can be done now to prevent thermal pollution of Lake Michigan; The conference can adopt the strictest standard proposed by the Department of the Interior. Please use your influence to that end." ------- 1723 Murray Stein That is from Mary Helen Dunlop of 2246 Orrington Avenue, Evanston, Illinois. And we do have some longer letters and statements and with the conference's approval I would like to put them in the record as if read and I would pass these to the conferees and they can read these, and without objec- tion they will be entered into the record as if read. (The letters above referred to follow in their entirety.) ------- 1724 HIGAN STATE: CHAMBER of COMMERCE: 215 S. Washington Ave., Lansing, Michigan 48933 • Phone 517/482-0657 otfic.s September 28, 1970 Mr. Murry Stein, Conference Chairman Thermal Pollution Workshop Sherman House 100 West Randolph Street Chicago, Illinois Dear Mr. Stein: Enclosed you will find a copy of the Michigan State Chamber of Commerce's Policy on Thermal Effects which was adopted by our Board of Directors on January 21, 1970. Please enter this into the proceedings of the Department of Interior's Thermal Pollution Workshop currently underway in Chicago. Sincerely, /n . George P. Graff, Manager, Natural Resources GPG/sk Enclosure cc: Francis T. Mayo Ralph Purdy ------- 1725 MICHIGAN STATE CHAMBER POLICY ON THERMAL EFFECTS The Michigan State Chamber of Commerce has long recognized the need to protect and enhance the quality of the environment in the State of Michigan. Cooperative efforts of both the public and private sectors are necessary to effectively promote this objective. The Waters of the State of Michigan are an important segment of the environ- ment and should be so respected. The potential effects of thermal discharges to these waters are not fully understood. However, it is known that in some instances these effects are detrimental to legitimate uses, while in other instances they are beneficial^ Recognizing that there are many needs and objectives in society, and. that they cannot all be satisfied in their entirety, the State Chamber strongly recommends that the Michigan Water Management Program, with particular reference to thermal effects, be guided by the following principles: 1. That no single set of regulations is adaptable to all situations. 2. That the management program provide for beneficial water uses, with joint consideration of alternative costs to society and the objective of preserving environmen- tal quality. 3. That water quality standards regarding thermal effects adopted by the State are consistent with the water use management program which recognizes the needs of our society and further that Michigan industry will comply with all state standards. 4. That any use which has potential of causing significant environmental effects be carefully monitored to determine the extent of any effects and the possible need for corrective action. 5. That prompt corrective action be taken whenever effects detrimental to legitimate uses are detected. 6, That thermal effects research be promoted in an effort to obtain sound data from which intelligent judgments can be based regarding thermal discharges. The State Chamber commends the responsible State agency's accomplishments in the area of water quality control and pledges its continuing support and coopera- tion in efforts to provide an improved environment and high quality water in the State of Michigan. ------- 1 T2 f\ lafee Crie Cleanup Committee , Jtttcfjigan JOHN CHASCSA C. W. (TED) HOFFMAN Fmident Vice President MRS. IRENE FINCK LAWRENCE LEIBOLD Secretory Treasurer September 28, 1970 Lake Michigan Enforcement Conference Sherman House 100 West Randolph Street Chicago, Illinois Attention: Chairman, Murray Stein, Chief Enforcement Officer Interior's Federal Water Duality Administration Dear Mr. Stein: It is indeed encouraging to learn that all types of Pollution are being investigated by your Committee. We have, on many occasions, heard that one type of waste after another is responsible for the condition of our Lakes, Rivers and streams. In some instances we have condemned the use of our waters as dumping grounds or hiding places for unwanted waste sewage, refuse and hot water from large Industries. However, it took our President, Richard M. Nixon to open our eyes to the serious dangers involved in permitting Thermal Pollution to further complicate our Environmental problems. So, if Biscayne Bay can Become a living mass of Algae interspersed with dead and dying marine and bird life, this could and would create a very nauseating stench in the area, (which by the way is the location of our Southern White House, it isn't used much, but it is there.) You can imagine what could happen to Lake Michigan, Lake Erie or for that matter any of our inland Lakes. Lake Michigan is the most vulnerable though, and then Lake Erie. Lake Michigan from Muskegon to Gary, Indiana, and then on to Chicago is (as you know) the natural pocket with no place for the water to flow. This area has for many years received all sorts of waste, it has been the cause of many illnesses, much fish and wild fowl mortality, and could become a hot bed of more of the same, if permission to use Lake Michigan were granted to cool industrial or municipal hot water. Why must the general Public have to accept the loss of the use of a Public Lake, Stream or River, and be expected to pick up the tab for cleaning up the mess when it becomes too unbearable? There are, as you have pointed out, many ways to cool and purify water and there are some that have not even been considered. ------- 1727 page 2 Mr. h. Stein Sept. 28, 1970 Perhaps the state of Michigan's Fisheries Department are expecting to use the warmer water to escalate the growth of the Coho that is being planted by them, or perhaps this is a good way to get a ready cooked meal. Seriously, the Lake Erie Cleanup Committee supports your stand on pro- hibiting the use of our Lakes as a depository of Thermal Pollution, or any other form. Knowing the area around Ludington, I would suggest that these combined systems be used - such as an inland cooling Pond with spray and return canals for re-use in the plant or into the Lake. Due to unforseen circumstances I am unable to attend this conference, but would like to take this opportunity to voice the opinion of the Lake Erie Cleanup Committee, and the Monroe County Rod and Gun Club , and to thank you for this presentation. For a better Environmental tomorrow, I remain. Sincerely, 'John Chascsa, President Lake Erie Cleanup Committee, Inc. cc: Conferees: Illinois Environmental Protection Agency! Wisconsin Department of Natural Resources, Indiana Stream Pollution Control Board, Michigan Water Resources Commission ------- 1728 T. E. Dustin MR. STEIN: Now, I would like to, if we can, try to have the people who are making presentations here be as brief as possible, I know this is a public day; I also know that almost all of you — if not all of you — are here on your own time and volunteering your time for this. We have many, many speakers scheduled and I would ask you to be as brief as possible. If you have longer statements, we will be glad to put them in the record and when I ask for questions this will include the panel as well as the floor. May we have Tom Dustin first, please? STATEMENT OF THOMAS E. DUSTIN, EXECUTIVE SECRETARY, INDIANA DIVISION, IZAAK WALTON LEAGUE OF AMERICA, FORT WAYNE, INDIANA MR. DUSTIN: Thank you, Mr. Chairman, and ladies and gentlemen of the Lake Michigan Enforcement Conference. My name is Thomas E. Dustin, and I appear as the executive secretary of the Indiana Division, Izaak Walton League of America. Our organization includes 5,300 members in 1+6 chapters in the State of Indiana, distributed from the Ohio River literally to the shores of Lake Michigan. Our interest and concern are directed to all ------- 1729 T. E. Dustin phases of the natural environment, man's relationship to that environment, and the interdependencies of all living organisms with it, Our history of direct interest in the Lake Michigan environmental unit needs little preamble. We have been reading and hearing the press releases which have emanated from this conference since its convening September 2&; and they are remarkably similar to those of previous sessions — particularly those coming from industrial spokesmen. We know the Chairman of this conference has heard it all before, too. To hear the polluters tell it, you would think they were all milkmaids distributing effluents as pure as the driven snow. Yet Lake Michigan continues on its path to polluted uselessness. But in the rhetoric, denials, assertions, and carefully couched semi-scientific testimony that have been offered, the essential questions have become obscured: 1) Are we, as a society, really serious about our intent to save and restore Lake Michigan? If we are — and the Izaak Walton League answers with an unqualified "yes" to this question — then it is perfectly obvious that we will not only have to halt the increased pollution of the lake, but must roll back the sources which have ------- 1730 T. E. Dustin come into existence through most of this century. Second — 2) Are we all prepared to join together in a mighty and sustained program of active achievement, and to share among us the cost of doing it? Again, the Izaak Walton League's response is an unqualified "yes," Third — 3) Are we wise enough and perceptive enough to understand the highest and most productive purposes of Lake Michigan, and to grasp its significance in terms of all the values and dimensions, both tangible and intangible, that it holds for man, and for all of the other organisms which form its community? Again, we say that our species has this capacity for understanding, though because we have been lazy and have pursued more superficial goals, our general record has been one environmental atrocity after another. We are not here to attack devils because we recognize that all men, institutions, and corporations are bound together in a common web of ideas, trade, and inter- change of energies of one description or another. But I will say that I hope the defense of thermal pollution reported in our local Fort Wayne newspapers, on the part of Indiana and Michigan Electric Company, is not a mirror image of our society's state of conscience and ------- 1731 1732 1733 T. E. Dustin 1734 1735 environmental awareness. I want it fully understood that the Izaak Walton League supports without qualification the proposal by the Department of the Interior that thermal discharges be limited to not more than 1 degree Fahrenheit above the natural ambient temperature of Lake Michigan, This principle has been thoroughly reviewed by all of the policy-making bodies of our group, and by all of our membership. Moreover, we see the 1 degree Fahrenheit recommendation as a minimum goal to achieve; we support the effluent standards for all forms of unnatural dis- charges. From all of the press reports and all of the testimony we have seen regarding the effects of thermal discharge on Lake Michigan, we observe that the utilities — including Indiana and Michigan Electric Company and Northern Indiana Public Service Company — have created a phalanx essentially around the person of one zoologist whom they have hired to justify the increased dishcarge of waste heat to Lake Michigan. But even if Professor J. C. Ayers is right in some of his assumptions — and there is persuasive testimony to indicate he doesn't know what he is talking about — he stops far short of responding to far larger ------- 1736 T. E. Dustin questions. Much of whatever genuine field studies he under- took were at the Charlevoix Big Rock installation of some 55 megawatts capacity — almost irrelevant to the draconian questions we face here. In describing the miniscule hot water plume there, he acknowledges that organisms that may be exposed to it have other environmental choices, since that plant operates in a comparative thermal vacuum, uncomplicated by other sources of heat. Professor Ayers explains that most oxygen recharg- ing of the lake takes place in winter, when the warmed epilimnion disappears, and lake temperature is relatively uniform. He makes no effort whatever to explain what happens when a warm surface condition is perpetuated, and when there are so many sources as to influence a significant portion of all shallow water environments. No one, not even Professor Ayers, can estimate the effects over the next 30 years as the amount of waste heat rises from a mere 30 billion B.t.u.'s an hour to over 400 billiono But it will hardly be a biological health spa. Few, if any, competent aquatic biologists have stood forward to endorse his whitewash of thermal pollution for his clients. And a great many of them fully recognize ------- 1737 To E. Dustin the detrimental effects. For the record, I have thoroughly read the Interior Departments September 1970 publication, "Physical and Ecological Effects of Waste Heat on Lake Michigan,11 and find it wholly consistent with every principle we support, and consistent with the concerns of qualified limnologists and other biologists whose opinions we have sought. One such authority is Dr. John S. Bardach, of the University of Michigan, whose testimony in connection with NIPSCO's Michigan City construction application we have. If that statement has not yet been made part of the record of this conference, we request that this be done, and will provide a copy for you on request. It is at very least as competent as the views of Dr. Ayers and much more independent. (See Pp. 1737a-1737o) But there is another essential question here. Spokesmen for the utilities have laid down a challenge to prove that thermal pollution is injurious. I would state to you that it is this very formula which has necessitated this conference today, and those before it. All of those who have preceded us as Lake Michigan polluters have made the same case, asking that positive proof of damage be made before the event. I submit to you that this ploy has precisely the ------- 1737a Resume of Statement for the Record by JOHN £. BARDACH, Ph.D At a Vublic Hearing at Michigeu City, Indiana September 11, 1970 Before COL. WILLIAM G. STEWART District Engineer Chicago District, Corps of Engineers Department of the Army In the Matter of NORTHERN INDIANA PUBLIC SERVICE COMPANY Application to Construct Intake and Discharge Facilities In Lake Michigan at Michigan City, Indiana Colonel Stewart, Ladies and Gentlemen: My name is John S. Bardach and I reside in Ypsilanti, Michigan. By profession I am an aquatic ecologist with more than 20 years of teaching and research experience. I am currently a full professor in the Department of Wild Life and Fisheries in the School of Natural Resources and a full professor of Zoology in the Department of Literature, Science and the Arts at the University of Michigan in Ann Arbor, Michigan. I was born on March 6, 1915 in Vienna, Austria and I became a naturalized American in 1953. I was graduated from the Real-gymnasium in Vienna, Austria in 1933. I then attended the University of Berlin, Germany, for two years and thereafter Queens University, Kingston, Ontario, where I received a Bachelor of Arts Degree in 1946. I received a Master of Science degree in 1948 and a Doctor of Philosophy degree in 1949, both from the University of Wisconsin. My present teaching duties at the University of Michigan include a course in Functional Ichthyology concerning itself with anatomy, physiology and behavior of fishes, and the supervision of graduate students on physiology, ecology and ------- 1737b behavior of aquatic organisms. Moreover, I am involved in teaching Natural Resources Ecology, a course dealing with man's influence on and management of his natural environment. My research and publications over the last 20 years have dealt -,~ith the entire range of ny expertise and partic- ularly the physiology of aquatic organisms and the reactions of aquatic organisms to man-made and man-induced changes in lakes, streams and seas. The following statements comprise my opinion based upon my 20 years of experience, teaching and research in my area of expertise. Based upon my experience I have a scientific concern about the added heat load to the shore waters of Lake Michigan which would occur if electrical generating plants of the type of Michigan City were to discharge into the lake the waste heat in their cooling water in an unabated fashion. My opinion that heat loading of the shore waters of Lake Michigan would contribute, in a long range fashion, to the deterioration of its ecology is predicated on two grounds: 1. Present knowledge of hydrographic and meteoro- logical parameters is insufficient to make proper prognosis of the cumulative ecological effects of several electrical generating plants which would emit heated effluents into the lake. Only substantial further research will furnish the basis Attached hereto as Exhibit A is a summary of my research experience from 1946 to the present. Attached hereto as Exhibit B is a list of my professional experience and honors. Attached hereto as Exhibit C is a list of publi- cations which I have prepared or of which I have partici- pated in the preparation. I hold the following memberships in professional societies AAAS (1959); Corporation Member, Bermuda Biological Station for Research (1956); Int. Soc. Theor. Appl. Limnology (1960); American Institute Fish Res. Biol. (1962); American Soc. Zool. (1949); Amer. Soc. Limnology & Oceanography (1951); Ecol. Soc. Amer. (1958); Amer. Fish. Soc. (1954); Sigma Xi (1949); Fellow, International Academy of Zoology (1960); Amer. Soc. Ichth. and Herp. (1958); N. Y. Acad. Sci. (1966). -2- ------- 1737c for judgment whether thermal changes will have moderate or pronounced effects and whether these will be more or less gradual. Experience with other man-induced environmental changes (deforestation and resultant stream warming, for instance) that affected complex aquatic ecological systems make one cc fident in predicting the. there will be changes, many of them not beneficial. I agree with the statement of David Ehrenfeld in "Biological Conservation/1 Holt, Rinehart and Winston, Inc. 1970 that, "Chances in water temperature affect both the activity and energy requirements of aquatic organisms. Oxygen requirements also change. If the temperature rises, oxygen consumption increases but oxygen solubility in water declines. Many organisms have a narrow range of temperature tolerance. At some point lethal temperature is reached; this varies according to the rate of change of temperature, species of animal or plant and physiological condition of the individual. Since a rise of 10° C. is sufficient to double the rate of many chemical reactions, it can readily be understood why even a small amount of thermal pollution is sufficient to disrupt the organization of aquatic communities. Thermal pollution also damages ecosystems indirectly. Most important, it aggravates the effects of poisons and accelerates deoxygenation processes." One electrical generating plant will have some adverse effect and several of them would exacerbate conditions in a more than additive manner, due to the prevailing hydrographic con- ditions set forth below. Some scientists believe that heated water remains on the surface and quickly loses heat to the atmosphere rather than to the water. However, present knowledge of water-air heat exchange and heat exchange between water masses in the regions of Lake Michigan to be affected is incomplete as there is not available information on all possible weather conditions such as patterns along the shore under which these exchanges would take place. Nevertheless, and especially if there are a dozen electrical generating plants along the shoreline and if the current? flow along this shore a they are indicated to c":>, long term adverse effects of heating the shallow water are likely to occur and eutrophication is likely to be accelerated. Some of the likely changes to be enumerated below are not solely or not even predominantly caused by temperature increases -3- ------- 1737d but a temperature rise contributes to them; others are directly related to temperature rises. Like many biological phenomena they proceed slowly at1 first, soon to increase in geometric proportion and to become ever more difficult if not impossible to reverse. (2) It is my opinion that even the incomplete knowledge about Lake Michigan which we now possess/ coupled with general experience of ecological phenomena permit certain scientific conclusions and opinions, as set forth below, and that make the occurrence of long term deleterious effects of heat loading of Lake Michigan's shore waters highly probable indeed. I am particularly concerned, about the following long range effects, covering two or more decades, of heated effluents from several electrical generating plants being voided into Lake Michigan: (a) An increase in the rate of eutrophication of the shore waters. (b) A worsening of conditions favorable for, if not a Iphreat to, the survival of a very valuable and unique fish fauna. t (c) A change in conditions so as to favor less desirable fish species such as carp and alew-ife. •V Discharges from electrical generating plants will cause Lake Michigan shore wafers to be threatened by increasing eutrophication. The cooling water discharges enter and are restricted to coastal waters, out to but a few miles from the shore. These lake areas also receive a substantial and increasing load of nutrients in the form of nitrogen and phosphorus compounds from domestic effluents and from agricultural runoff and, according to our present knowledge, the water in them does not mix substanti-ally with the water in the lake at large during the fall, winter and spring; during the summer more mixing occurs but even then it is not continuous. Consequently fertilizing effects first and foremost occur in near-shore waters, proceeding faster at higher than at lower temperatures. It is my opinion.; that the shore regions of Lake Michigan contain relatively discrete water masses which do not mix with the waters of Lake Michigan during the year at large. This opinion is hased upon my experience ;. s well as upon a recent report of the Federal Water Pollution Control Administration, Great Lakes Region, phicago, Illinois, entitled "Lake Currents" (Lake Michigan Basin),.November 1967. -4- ------- 1737e "Temperature records taken during the winter of 1961 through the summer of 1964 indicate that the following conditions occur ... The existence of thermoclines and thermal barriers during extended periods of the year greatly reduce mixing of the shallower shore w.'iiers and the waters of the hypolimnion with the main body of the lake. Such conditions promote the build-up of persistent pollutants discharged into isolated waters. Because of the prolonged periods during which such conditions can continue such build-ups can impair the uses of the water adjacent to the discharge points." Id. at p. 233. "Thermal barrier conditions during the fall, winter and spring limit the outward extent of effective mixing volume ... The late spring storms and lake overturn break up the zonation due to the thermal bar and create conditions for effective mixing with the lake proper. However, during the summer when the thermal bar no longer exists, similar build-up occurs. Boundary effects, friction and the Southern gyre are probably responsible for the lateral transfer of water along the shore." Id. at p. 353. "In general the shore currents move northward on both sides of the lake, except for periods during the late fall, winter and early spring.... Average current speeds on the western side of the lake range from 5 to 10 cm/sec, while those on the eastern side range from 12 to 14 cm/sec.... Inshore and offshore currents are quite separate from one another." Id. at p. 179. Indicators of the changes generally subsumed under the term "eutrophication," and even now noticeable along certain portions of the shores of lower Lake Michigan, are the prevalence of algae, plankton and bottom organisms and eventually of fish tolerant of, by virtue of their evolution, and therefore adapted to warm oxygen-poor turbid water instead of those adapted to cool clear oxygen-rich water. The latter conditions were those of the Lake Michigan's geologic history and the organisms that evolved in the Lake, or in lakes like it, are therefore genetically fitted to them rather thin to new man-induced one~. The biology of these fish and organisms do not permit rapid adaptation to man-induced changes. Specific indicators of eutrophication are: blooms of -5- ------- 1737f bluegreen algae, the colonization of suitable substrates by the profusely growing green alga'Cladophora the filaments which have known nuisance value.1 If effluents from electrical generating plants generate stationary warm water masses for variable periods of time it is likely that point heat sources will accelerate localized conditions of chemical and organic pollution and that commercially valuable cold water fishes will disappear and be replaced by carp, suckers, alewifes and the like. Each of these factors singly, but more so in aggregate, decrease the value of shore property as well as certain recreational opportunities. The biological changes are gradual and cannot be properly ascertained by a one, two or even three year study following a local change such as a newly installed heated water discharge like Michigan City Generating Station as overall climatic fluctuations may mask their effects. However, the biological changes gain momentum once they have begun unless the conditions favoring them are reversed. The deterioration of Lakes Erie and Ontario since, the turn of the century provides reliable and relevant analogies to the danger Lake Michigan faces from heated water. The average water temperature of Lake Erie has risen by 2° F. since 1920, due to heat loading, even without massive spot heat inputs such as occur through electrical generating plants, and due to alterations in land use. Such a rise is tantamount to displacing the entire lake to a location 50 miles to the South. Small as the temperature change is, it is considered a contributory factor to the disappearance from Lake Erie of the Lake Herring, formerly the most abundant and valuable species in the Lake. It also favored the growth of undesirable algae in Lake Erie. Such changes in Lake Michigan as are presently being observed suggest that a comparable deterioration process may be already under way in Lake Michigan. The Great Lakes, but especially Lakes Michigan, Huron and Superior are the home of a unique, c^Trnercially valuable species complex of fishes, i.e., the trout and salmon, related whitefishes and the lake trout. The numerically most abundant and commercially and recreationally most valuable among them spawn in in-shore or near-shore waters. Experiments and observations at the Great Lakes Fishery Laboratory rf the Department of Inte: ior have shown them to b 2 very sensitive to increases in water temperature, especially during their larval and juvenile periods. Their eggs are deposited on the bottom and their larvae must rise to the surface to gulp air for initiating the filling of their swimbladders. Without this one gulp they can never adjust their buoyancy. At that time -6- ------- 1737g they are but an inch or so in length and even if they sensed deleterious surface temperature, they are instinctively driven to the top where they will not be able to avoid warm water than could kill them. Such kills might be sporadic but could increase in frequency as patches of heated water multiply with severcT. instead of one or two electrical generating plants voiding heated water. The kills might also not be noticed due to the small size and semitransparent nature of the fish larvae. Given such conditions, the effects of the kills would become apparent through a gradual irreversible reduction in the number of adult fish and eventually likely lead to the complete disappearance from Lake Michigan of a yet unpredictable number of their species. It is ironic, in this context, that millions of dollars were and are spent to save these same species from the deprada- tions of the sea lamprey and to rehabilitate them to their former abundance when the danger to them may now be shifted to thermal loading of the Lake from electrical generating plants. The main difference between the two dangers is that lamprey control necessitated costly research before it could be implemented while the method of heat abatement of cooling waters is well within technological research today. The Pacific Salmon, recently introduced into Lake Michigan is in far less direct danger from thermal change than the species native to the Lake, inasmuch as the numbers of the former will be replenished by artificial propagation. Only where spawning streams or shore areas near them become heated may direct temperature effects threaten some of their numbers. While zones of heated water near the shore may not harm the salmon directly, they adversely affect the fishes' recreational potential. State of Michigan biologists believe that warm water near the shore such as prevailed due to climatic conditions in 1968 and 1969 kept the fish away from the shore and therefore out of the reach of the sport fishermen's craft. Heat loading of shore waters could well make these conditions that are adverse to recreational salmon fishing a much more permanent occurrence. Some salmon which have established spawning runs in Lake Michigan streams will enter the shore waters near them on an instinct driven journey to their spawning grounds. It has been the experience of Michigan fishermen that they are far less likely to strike the fisherman's lure in warm than in cold water. Alewives and other undesirable fish species will be favored through lake temperature increases. Alewives are shore spawning warm water fishes which have entered the Great Lakes -7- ------- 1737h inadvertently, through a man-made channel. In Lake Michigan they live at the lower edge of their temperature range and are very vulnerable to such cooling as occurs occasionally. If warm water becomes available to them they seek it out, entering into existing heated effluents in great numbers. A warming of shore waters is likely tc favor them as are large streams of warm water from electrical generating plants likely to attract them. They are, however, also delicate fish, prone to mass mortalities. Temperature conditions favoring their numbers could well be accompanied by far greater die-offs than have been experienced until now. Clean-up operations of millions of alewives are indeed costly to society. Over a twenty-year period their cost may well reach a significant portion of that involved in installing, initially, cooling devices for the effluents of electrical generating plants. If ancillary losses in the tourist industry were to be included, the total loss may well equal or exceed the costs of installing cooling devices. In 1967 such total direct and indirect losses due to alewife die-off was estimated at 50 million dollars on the State of Michigan shoreline alone. I am aware that there well could be possible beneficial consequences of heated electrical generating plant effluents, especially in the first few years of a plant's operation, before the deleterious effects mentioned here would have time to build up. Pishing may improve in or near the effluent cones due to the attraction by the warm water of certain shore fishes such as perch, bass, pike and bluegill. These same water areas may, incidentally, also afford ice free fishing lagoons in the winter. V7ater might become warmer in certain places and make them more attractive for swimming, and in the same places the swimming season might be prolonged, at least before the build-up of algae detracts from water contact sports. These beneficial consequences, given continued eutrophication influences from other sources will almost certainly be replaced over the years with eutrophication, disappearance of native fishes and alewife nuisance. Any assumed beneficial effects would represent a poor interest indeed on a continuously devaluating large environmental capital. Cooling devices for the effluents snould be installed on all present and future electrical generating plants discharging heated water into Lake Michigan to prevent them from contributing to the devaluation of this capital. Later alleviation of thermal loading through subsequent modification of existing plants could well be more costly not only to the power industry, but, by virtue of the nature and time course of the changes indicated, it would also put an ever increasing economic burden on society at large. -8- ------- 17371 Research Experience Sensory physiology, especially cheuical and temperature senses of fishes: 1968-' pilot study of effects of thermal pollution on behavior of bullheads. 1957-1958: Chemical senses in communication and social behavior of fishes. 1957: Electro-olfactograms of tuna (unpublished) Cheraosensory orientation of tuna (unpublished) 1963-1966: Research with chemical and mechanical senses of fishes in relation to behavior. 1961-1963: Research with time-coordinated behavior and learning of fishes (see Biographical sketch and Publications) 1961: Sabbatical Leave, study of fish physiology and behavior v?ith Prof. Sven Dijkgraff and G, P. Baerends of Universities of Utrecht and Groeningen, Holland, respectively. Holder of OEEC Senior Visiting Scientist Stipend. 1953-1957: Research on temperature and tactile senses of fishes, Resoarch and Behavior of Reef Fishes. 1946-1953: Graduate Studies, Madison, Wisconsin, under Professor A.D. Hasler on ecology and physiology of fishes, teaching assignment at then Iowa State Teachers College and student research supervision (University of Iowa graduate students) and ov?n research on limnology and ecology at Iowa Lakeside Laboratory. EXHIBIT A ------- 1737J professional Experience and Honors Re-introduced instruction and research in Limnology, Iowa Lakeside Laboratory, 1950-1953. Director, Bermuda Government Fisheries Research Program, part-time, 1954-1958. Fisheries Advisor, Government of Cambodia, on leave of absence from University with AID, 1953-59. Senior Visiting Fellow in Science, O.E.E.C., at University of Utrecht and Groningen, Holland, study of comparative physiology and behavior, 1961. Behavior and ecology of reef fishes, senior investigator (NSF), 1955-57. Bermuda government - fisheries research program, program director (government of Bermuda), 1955-56. Temperature oensc of fishes, senior investigator (Horace H. Rackham School of Graduate Studies), 1956-50. Investigations of sensory structures in skin of fishes, senior investigator (Horace H. Rackhatn School of Graduate Studies), 1958-62. Time-coordinated behavior of fishes, senior investigator (NSF) 1962-63. Extra-enteral food uptake by fishes, senior investigator (Michigan Memorial-phoenix Project). Time sense of fishes, senior investigator (NSF) 1961-62. Coloration of Reef Fishes (Horace H. Rackham School of Graduate Studies) 1965. Skin senses of fishes, principal investigator (PHS Grant No. NB- 04687-01-05) (1953-1958). Chemical Senses of Fishes, principal investigator (NIII, INDB Grant 04687-06-09) 1968-1971. Research and Fact finding on World Status of Aquaculture for National Council on Marine Resources and Engineering Development, 1967. Participation National Academy of Sciences organized International workshops: Oceanography and Fisheries Manila, 1967, Food, Djakarta, 1968. Consultant to Econ. Comra. Asia and Fa^ taut, U.N. Bangkok; also to Asst. Adminiscrator for Far East U.S. AID/ Department of State, Washington, D.C. and short terra State and Federal Assignments dealing with physiology of aquatic organisms in relation to water quality control. Fellow American Association for the Advancement of Science (1963) President and Co-founder: Michigan Asoociation for Conservation Ecologists (1964) Member Pacific Science Board, U.S. National Academy of Sciences (1957) Distinguished Faculty Achievement Award, The University of Michigan 1957, EXHIBIT B ------- 1737k BIBLIOGRAPHY - PROFESSOR JOHN E. BARDACH A biological survey of Lake Opinlcon. Curran, H.V/., J.E. Bardach, R. Bowman, and H. Lawler. Queen's University Biol. Sta. Rep., Kingston, Opt., 48 p. 1947. A preopercular tag for perch. Bardach, J.E., and E.D LeCren.. Copeia, 1948 (3): 222-£24 Daily migrations of perch in Lake hendota, V/isconsln. Hasler, A.D., and J.E. Bardach. "jour V.'ildl. hgt. Vol.13, No 1: 40-51, Lake Hendota Perch Teach School. Bardach, J.E. V/isconsin Conserv. Bull., July 1949, pp. 11-12. Do fish have a color vision? Bardach, J.E. Bios. 21(4): 273-275, 1950. hicrophotography without a camera. Bardach, J.E. Sci. News, Iowa Acad. Sci. 18(3): 7, 1950. Changes in the yellow perch population of Lake hendota, V/isconsin, 1916-1948. Bardach, J.E. Ecol . 1951, 32(4): 719-728. Preliminary report on the distribution of bottom organisms in West Lake Okojoji, Iowa. Bardach, J.E., J. Morrill, and F . Gambony , 9 p . , 1951 . A demonstration of the effects of water density. Bardach, J.E. Turtox News, 31(11): 208, 1953. Harvest and products. Lagler, K.F., and J.E. Bardach (in) Fish and fishing in recreation and commerce. Ann Arbor, Univ. Mich. Extension Service 14 p., 1954. Coastal streams. Lagler, K.F., and J.E. Bardach. (In) Fish and fishing in recreation and commerce. Ann Arbor, Univ. hicn. Extension Service, 14 p., 1954. Continental shelf and banks. Lagler, K.F., and J.E. Bardach. (In) Fish and fishing in recreation and commerce. Ann Arbor, Univ. hich. Extension Service, 8 p., 1954. Conservation. Lagler, K.F., and J.E. Bardach. (In) Fish and fishing in recreation and commerce. Ann Arbor, Univ. hich. Extension Serv., 25 p., 1954. EXHIBIT C - page 1 ------- 1737-1 2. The high seas. Lagler, K.F., and J.E. Bardach. (In) Fish and fishing in recreation and commerce. Ann Arbor , Univ. Mich. Extension Serv., 10 p.,. 1954. Plankton Crustacea from the Thelon v;atershed. Bardach, J.E. Can. Piel-i Nat., 68 (2): 4? -52, 1J54 . Effects of the wind on water movements in Lake West Okojoji, Iowa. Bardach, J.E. Proc. Iowa Acad . Sci., 6l: 450-4 57, 1954. (Review of) The western end of Lake Erie and its ecology. by D.H. Langlois), Bardach, J.E. Sci. Mon. 80 (l): 59- (Review of) Etude experimental du determinisme de la regeneration des nageoires chez les poissons teleosteens. (by J. Buser-Lahaye) . Bardach, J.E. Progr. Fish. -Cult. 16 (4): 188-191, Certain biological effects of theraocline shifts. Bardach, J.E. Hydrobiologia, 7 (4): 309-324, 1955- The opercular bone of the yellow perch, Perca_ flavescens, as a tool for age and growth studies. Bardach, J.E. Copeia, 1955 (2): 107-109- (Review of) Fischkrankenheiten (by W. Schaeperclaus) . Bardach, J.E. Copeia, 1955 (2) 155- Bermuda Fisheries Research Program, Progress Report # 1, Sutcliffe, V/.B., Jr., and J.E. Bardach, Bermuda Govt . Publ., Hamilton, Bermuda, 14 p., mimeo, 1955. Bermuda Fisheries Research Program, Progress Report #2. Bardachj J .E . , and L.S. Mow bray . Bermuda Govt. Publ., Hamilton, Bermuda, 94 p., 1955- (Review of) Margins of the Sea (by M. Burton). Bardach, J.E. Sci. Mon., 80 (6): 383-384, 1955- The sensitivity of the goldfish (Carassius auratus L.) to point heat stimulation. Bardach, J.E. Amer. Nat. 90 (854): 3^9-317, 1956. (Review of) World Sea Fisheries (by R. Morgan). -dach, J.E. Science, 124 (3231): 1085-1086, 1956. Field and laboratory observations on the growth of some Bermuda reef fishes. Bardach, J.E., and D.W Menzel . Proc. 9th Gulf Caribb. Fish Inst., (1956), pp. 106-112. EXHIBIT C - page 2 ------- 1737m Bermuda Saga. Bardach, J.E. (In Michigan Rorecter by Staff and students of the School of Natural Resources). Univ. Mich. pp. 71-73, 1956. " The senses of fishes. Bardach, J.E. Bermuda Fish. Quarterly, 1(2): 6, 1956. Marine Fisheries and Fish Culture in the Caribbean. Bardach, J.E. Proc. Gulf and Carlb. Fish. Inst., pp.; 132-137, 1957- (Review of) The Galathea deep sea expedition 1950-1952, (by A.F. Bruun et al.) . Bardach, J.E. Sci. Mow. 84 (6): 322- 323, 1957. ;. • Behavior, sexual dichromatism, and species oT parrot fishes. Winn, H.E., and J. E.'- Bardach. Science, 125 (3253): 885- 886, 1957- The temperature sensitivity of some American freshwater fishes Bardach, J.E., andR.G. BJorklund. Aiaer. Nalt.. 91 (859): 233- 251, 1957- ;. Bermuda Fisheries Research Program, Final Report. Bardach, J.E., with L. Smith and D.W. Henzel. 59 p., 1958. Bermuda affair. Bardach, J.E. (in Michigan Forester by staff and students of the School of Natural Resources). Univ. Mich. pp. 7^-75, 1953. The production of Exopthalmos by Androgens in two species of teleost fish. Matty, A.J., D. Menzel and J^E. Bardach. J. Endoc., 1958, 17, 31-4-318. On the movements of certain Bermuda reef fishes. Bardach, J.E. Ecol. 39 (1):139-146, 1958. The role of the senses in the feeding of the nocturnal reef predators Gymnothorax raorij^a and G_, vlcinus.". Bardach, J.E., H.E. Winn, ancTZTW. Menzel. Copeia, 1959 f2) =133-139. The summer standing crop of fish on a shallow Bermuda reef. Bardach, J.E. Limn, and Ocean. Vol. IV., No. 1: 77-85, 1959- Different4al food selection by mo^ay eels and a possible of the mucous envelope of parrot fishes in reduction of predation. Winn, H.E., and J.E. Bardach. Ecol. Vol. 40, (2): 296-298, 1959- Report on fisheries in Cambodia. Bardach, J.E. Ag. Div. USOM Cambodia, 58 p., miraeo., 1959. EXHIBIT C - page 3 ------- 1737n Etude sur la peche au Carabodce . Bardach, J E. 1959, Serv. Eaux et Forets , Phnom Penh, Cambodia, 80 p. tairaeo. (Review of) The Open Sea: Its' Natural History (Sir Alister Hardy). Bardach, J.E. Scl. 130(3384): 12^7, 1959- Some acpucts of the comparative Liology of parrot fishes at Bortr.uda. Winn, H.E., and J.E. Bardach. Zool . 45(1), I960, 29-34. On the transport of calcareous fragments by reef fishes. Bardach, J.E, Science 133(3446): 98-99, On touch receptors in fishes with special reference to the mo ray eels ( Gymnot hor ax yicinuG and G. morin^a) . Eardach, J.E., and L.A. Lo3v;snthai . Copeia, ~l"96l, (T) , ^2 The sensory function of modified fins of some marine fishes. Bardach, J.E., and J. Case. Am. Zool. 2(^4): 76, 1962. Time -coordinated pref ceding activity in fish. Davis, R.E., and J.E. Bardach. An. Behav. 13(1): 154-162, 1965. Sensory capabilities of the modified fins of squirrel hake (Urophycis chusg) and searobins ( Pr3.onptu_n carollnus and L- gvo-i.ans) . Bardach, J.E. and J.Case. Copeia 2, 19^-206,1965, Detergents: Effects on the chemical senses of the fish Ictalurua natalis (le Sueur) . Eardach, J.E., M. Fujiya and A. Holl. Science, 1^8 (3577): 1605-1607, 1965. A comparison betv.'een the external taste sense of marine and freshv/ater fishes. Fujiya, M., and J.E. Bardach. Bull. Jap. Soc. Fish., 32(1): ^5-56, 1966. Tolerance to temperature extremes: Animals. Part IV: Fishes. Bardach, J.E., J.J. Bernstein, J.S. Hart and J.R. Brett. Environmental Biology-, Biological Handbooks compiled ar/1 edited by P.L. Altiaan and D.S. Dittmer, Federation of American Societies for Experimental Biology, Bsthesda,Md. , 1966, pp. 73-80. The chemical senses and food intake in the lov.'er vertebrates. Bardach, J.E. Symp . on Mutr , and the Chem. Senses, Cornell Univ., 1^66. Johns Hopkins University Press, Baltimore, '*d., 1967, pp. 19 Investigations of external cheraoreceptors of fishes. Bardach, J.E., M. Fujiya and A. Holl. Proc . 2nd Intern. Symp. on Olf action and Taste, Pergamon Press, N.Y., 1967, pp. 6^7-655. EXHIBIT C - page k ------- 1737o 5. A new laboratory method for tracking aquatic animals. Bardach, J.E,, G. Johnson and J.ll. Todd. Med. Biol. Illustr., 1957, XVII (2): 103-111. Orientation by taote in fish of the genus Ictalur_u_s_. Bardach, J.E., J.H. Todd and R. Crickner. Science, 155(3757): 1276- 1278, 1967 There Is Poetry in Science. Bardach, J.E., and Alice Bloch. Mich. Quart. Rev. VI(2), April, 1967, 107-108. Chemical communication in social behavior of a fish, the yellow bullhead (Ic. talurus nata1 is). Todd, J.H., J. Atema and J.E. Bardach. Science 158(3S01): 672-673, 1967. Bardach, J. and J, Todd, Chemical Cormmnication in Fishes, jLn_ Advances in Chetnoreception, Appleton Century Crofts, Mew York, in Press Bardach, J.E., Taste in Fishes, in_ Handb. of Sensory Physiology, Jul. Springer Verl. Berlin, Heidelberg, Nex York. L. Beidler ed. in preparation Bardach, J., and J. Todd. Chemische Verstaendigung bei Fischen. UMSCHAU in Wissenschaft imd Tcchnik, Frankfurt a.M., in press. Bardach, J.E., G. H. Johnson, and J.H. Todd. Orientation by Bulk Messenger Sensors in Aquatic Vertebrates. Presented at Second Conference on Planetology and Space Mission Planning. Ann. New York. Acad. Sci., in press. BOOKS ICHTHYOLOGY, K.F. Lagler, J.E. Bardach and R.R. Miller, John Wiley and Sons Inc. 545 pp., 1962. DOWNSTREAM, A Natural History of the River. John Bardach, Harper ant5 Row, N.Y., 278 pp., 1964. HARVEST OF THE SEA, A Scientist Looks at the Oceans - Their Past, Promises and Prospects. John Bardach, Harper and Row, N.Y., 301 pp. 1968. EXHIBIT C - page 5 ------- 1733 T. E. Dustin same validity as a demand that you prove a war yet unfought will kill people. I challenge them to look for themselves at Lake Michigan and tell us that pollution does not kill. Why should the burden of positive proof rest on our shoulders? It is because we have always carried that burden that Lake Michigan is in its deteriorating condition now. It is time those who would use our waters for septic tanks and stewpots prove their actions will be harmless. They cannot make that case; and it will take more than one hired biologist to make it for them. Is it not time — is there not already enough in our abominable environmental history on Lake Michigan — to at last stand firm and say "enough"? Let us turn back the destruction of Lake Michigan before the fact. Once it is a fait accompli, it becomes just another mistake of the past that we must live with indefinitely, if we will be able to live with it at all. Both the Federal and State Governments should by now have seen enough of the fait accompli here not to want any more of it. We recognize that every special group of polluters ------- 1739 T. E. Dustin does its own thing when appearing before these conferences* The steel mills gave you their routine, and the chemical companies, the refineries, the harbor interest, the Corps of Engineers, and now the utilities, each in turn, as their own environmentally irresponsible status quo comes under test. But just look at Lake Michigan and where it is going. It seems evident — and the Izaak Walton League has been a participant in all of these matters — that unless we s-ee and understand Lake Michigan in a larger per- spective, we will be permanently committed to these cat-and- dog squabbles as each new kind of defecation in the lake comes to light. And as long as we are committed to unlimited growth, unlimited production, unlimited consumption, unlimited population, unlimited power, and unlimited profits and material things of all kind, there will be little hope that our greatest efforts can save this lake or anything else that cannot be priced in dollars. It seems the utilities are committed to just such a course. They will come before you with the statement that power capacity must double every 10 years to meet the "demand." It is a vicious circle. There is something fundamentally defective in our way of doing things in the environment. We have always operated our industrial systems open-endedly, scratching from ------- 1740 T. E* Dustin the earth what we could use, and indiscriminately spewing out what was not profitable to convert. We are long past the point that this stone age attitude should have changed. But it must change, and we must all be part of that change. We will have to learn how to create closed systems, includ- ing retention and conversion of waste heat. We recognize Lake Michigan and its general environment as a unit, not separable nor dissectable as a pie, whose parts are doled out to the most ravenous appetites. It is our position the whole of it is'weakened when one part is assaulted. It is a total resource of incalculable value to all of the people in its watershed and far beyond that. If we justify its impairment at one location, then it is diffi- cult to defend at other places. Above all, the Lake Michigan environmental unit should be a public trust, and no one should have the right to impair it; everyone should have the responsibility to restore and preserve it. The cost of failure to accept and act upon this principle will be infinitely greater than the alternatives; and we will be committed to an endless series of futile conferences mainly because we have not defined and made clear that the legitimate uses of Lake Michigan simply exclude using it as a dump for waste heat, chemicals, ------- 17U T. E. Dustin harbor dredgings, and all of the other spewtum of our society. No well-considered Lake Michigan policy could possibly include such uses. Instead of adopting a general Lake Michigan policy, we are continuing to be confused by smokescreen rationale which create the aura of acceptability for further destruction of this lake. In recognition of this perpetual problem, the Indiana Division of the Izaak Walton League has adopted a 10-point proposed policy for Lake Michigan. We do not pretend that it is the last word or that it is ultimate in quality. But it is a start. Most important, it treats Lake Michigan as an environmental unit; and we believe the lake must eventually be seen in that light, and not as a carcass from which chunks can be torn off at will by any interest that wants a piece — such as the utilities now propose, and the steel mills before them. Proposed Policy Position 1) Prohibitions of any more landfills or altera- tions of the natural shorelines, coupled with a total evaluation of the social, economic and ecological qualities of Lake Michigan. 2) Acquisition of an environmental easement along all undeveloped portions of Lake Michigan shoreline, pending results of the total evaluation, at which time decisions should be made as to what portions of the easement should ------- 1742 T. E. Dustin become permanent, and what should be expanded in the public interest and for environmental protection. 3) Establishment of total effluent standards for all discharges to Lake Michigan including the 1 degree Fahrenheit above ambient proposed by the Department of the Interior,, 4) A strict constructionist establishment and interpretation of a nan degradation policy for both water and air discharges in the lake context. 5) A no-discharge policy for all commercial and industrial shipping, including on-board surveillance and enforcement by trained interstate or Coast Guard agents, together with complete environmental control systems and design for all such vessels using Lake Michigan. 6) Prohibition of any dumping dredged materials from harbors, ship canals, industrial wastes or slags, and similar materials into any waters of Lake Michigan or its drainage basin. 7) Special Federal and State appropriations earmarked for sewage treatment systems in the Lake Michigan Basin, planned for maximum cost effectiveness along lines proposed in 1969 by the U. S. General Accounting Office. &) A total prohibition of all persistent pesticides in the Lake Michigan Basin. ------- 1743 T* E. Dustin 9) A general "inland development policy" which would prevent further visual, physical or ecological intrusion on Lake Michigan. 10) A firm policy with respect to all Lake Michigan ports which would require nonpolluting handling of all shipboard wastes and residues, and environmentally designed and operated fueling, servicing and cargo trans- ferring procedures. Until we are all ready to proceed with a compre- hensive policy at both the Federal and four-State levels, and until we are ready to enforce it, we see little hope of saving the Lake Michigan environmental unit. As long as there are holes and vagueness in our position, they will be exploited. On the other hand, if a policy can be firmly established, the kind of brush fire we are fighting today will be diminished if not extinguished. The utilities will, as they should, build away from these shorelines and include all environmental factors within integrated and closed systemso They are perfectly able to do this, or would be able to do it, when the answer to doing it in and on the lake is simply a flat "no," In closing, in the record is a letter of September 16 by Senator Vance Hartke of Indiana, which was submitted ------- 1744 T. E. Dustin in the context of the Michigan City hearing on the NIPSGO application,, We wish that to become a part of the record as it is especially germane, and I will turn in to you a copy of the statement prepared by the student Alpha Chapter of the Izaak Walton League of Fort Wayne, which is the first student chapter of the Izaak Walton League. We will submit that for the record. MR. STEIN: We will be glad to receive that information for the record. (The documents above referred to follow in their entirety.) ------- ,\|sf. fc, •. - ,.,-; , ><'..:,<•'.;:,;.'•$"<•• l'£olQtt«l William Stewart ecHMMrrrce ON COMMON* WASHINGTON, D.C. 20510 .September Army Corps' of Engineers" Imrk Street \.\ •.;. • ' hicago, i'Dear Colonel Stewart: • Indications from a great many Indiana residents, especially - northwest region of the state, provide evidence of the interest 7* I felt would be shown at the Michigan City hearing which J requested that you hold, regarding an application by the Northern Indiana Public 5 Company to construct a flume and to discharge heated water : Lake Michigan, r i» me interest of not biasing the hearing, J have withheld my until its conclusion and now desire to have the following included ftn the record of the proceedings,' , • . I oppose the granting of this permit and urge the Corps of ISagitteers to encourage the applicant to consider inland sites for con- struction of any; increased generating capacity that may be needed, ^> opposition to. granting of the permit is based upon the following: I,) While there are conflicting views on the effect of » it seems clear that introduction of heat to the Water of Lake can have nothing but a deteriorating effect. Studies which > minimize the effect of thermal pollution appear superficial* tittle to'consider long-term adverse effects, and fail,Id take into. '/.^ th.e"'pro life ration of thermal sources which are already ,costtr,i« f to the degradation of the lake, 2,} The construction of a huge power plant and,a .schaffe staclc'immediately adjacent to^the edge,of •?„ P\|<\|itroposeclf will create a major visual'intrusion National Lalceshore on the west and tower ecreational harbors and facilities lying. imrn.edfintct.y, ------- i^CJolonel Stewart • ' -2- ' September 1&,;>19?Q "- '-'3») State-of-the-art control of sulphur oxide discharges " . '"/•-,; .utility plants is highly unsatisfactory, and, indeed,' such controls- '.' ' - for existing power plants along Lake Michigan seem virtually non- V';existent,'; Control of particulate emission is almost equally unsatis- - ; .'' •^.factory; complaints have been lodged by many interests along the ;•" "X&ke Michigan shore, indicating unacceptable flyash fallout ami great ; 'i;eo8t"wt removing it and restoring finishes to such objects as homes , '- r;tod pleasure boats. There is no acceptable assurance that an additional ' y"power plant at the proposed location will reduce this costly form of :;f pollution, . . , . :'l;- !;";„ " '4») Construction of the plant would be accompanied by huge ,-::>eoal and combustion products storage areas, inevitably creating an :'fyesore, destroying the beauty of the shore areas and quite probably ' \ • .adding to existing pollution problems of both air and water, as well as /Increasing local noise background, -si ' .. , '; ' 5,) Considerable erosion lias-taken place along the Lake Michigan '"shoreline, most notably in the Beverly Shores area, and this appears to' ;/:t»e traceable to landfills at Michigan City, which interfere with the normal .."littoral flows along the shore and to the considerable discharge- of hundreds fj.of thousands of gallons of cooling water per minute from the existing flume. ",f'-!'" , 6» ) Jn spite of plans to prevent or minimize-chemical pollution /aspects from power plants, nutrients and heat appear to be contributing to accelerated growth of algae and to the continued degradation of water "quality which is occurring in Lake Michigan. For decades. Colonel .Stewart our society has been at Russian roulette with our water resources, Almost universally in the past, we have given ourselves the^benefit of the •''doubt in deciding whether to use our shorelines and great bodies and -''streams of water as recepticles for wastes and other unwanted by-products ,jof production processes. :f'v- ' . /. ''- The results of this policy have ruined much of our rivers and ''streams, has polluted our Great LaKes to a point approaching uselessness . .for recreation, commercial and sport fisheries, and for many oilier ^legitimate needs which are clearly in the public interest. r While we have enacted far-reaching legislation, which if fully • ;implemented should begin to reverse- the destruction of our waters, •'Including Lake Michigan, the fact is that this body of water is now in , ; :• worse condition than it was five years ago. In. my opinion, this is . - traceable to the fact that new abatement facilities are slow in coming, ------- Stewart , - 3 - September 16, 1970 not planned for maximum effectiveness, niul are offset by new sources of pollution, which arc being permitted. This is intolerable. Even, now the areaa of Lake Michigan that arc still usable for millions of bathers and other water recreationists are maintained . - that way only through heavy use of chlorine and other disinfectants, •tich $S are used at the Indiana Dunes State Park by the Department of .Natural Resources, ...' •.• . It is not at all alarmist to anticipate that the next significant increase in environmental pollution could well rodurc thesc-waters below the quality of safety and aesthetic acceptability. ' "•' ' -,: to the present situation I have also become aware of the Distressing fact that the company has already constructed major parts jof ,a discha rge flume required by the proposed new plant. Apparently, ,1t$u.9 has been done in anticipation of routine approval of the permit application, lam sure the Corps of Engineers is sincere in its intent '.fcO give full consideration to the provisions of the National Environmental '^Policy Act of 1970, and is in no way a party to any pre-liearinn conrlu- : r informal understandings. : ' , Let me observe that throughout much of our environmental it has been the burden of )ho>;e concerned with pollution to conclusively that a proponed aeiKity will be harmful to environment. I believi: this priiu'iple ha ,s outlived its unefulixess, Jtf it ever had any. It should be the burden of those interests which 'proposed the- activity to demonstrate conclusively that no harm will result from it. L > £- The evidence and data available with respect to the type of activity proposed by the Northern Indiana Public Company leads me to the conclusion that the company cannot mn°he that case, and that very great damage will in fact be caused to all of the environmental qualities cited'.in your notice of the September 10th lu-aring, jf this plant is per- mitted to be built at the proposed location. ';t ". " . Therefore, the permit application should be rejected, and the company should be encouraged to locale inland. ,Sueh a facility should encompass within its site; all systems needed for an* pollution control; ------- ;;.., . r> - •;% '•> - - - - • -1748 i- ' « % ' '••"", - " .r „ > Colonel Stewart _ _. -_4 - , September 16, 3970 Cooling pottds or other techniques', to prevent thermal pollution of ''" waters';" carefully 'planned fuel storage areas; d a "detailed plari'for non- polluting disposal of combustion residues. ' '''.-•'• '' ^ ' '"• "-.' '• /Sincerely, ;'. ---> - •• ' .'-•„. Vance Hartke juj:- 1" "'"* ; * ., -f.-•","; United States Senator i. ' •• ?» t ------- 1749 Lake Michigan Enforcement Confernece Workshop c/o The Sherman House 100 West Randolph Street Chicago, 11 Iinois Attention: Mr. Murray Stein, Chairman (Federal Water Quality Administration) We are an organization of college students who are formally associated with the Izzak Walton League of Americans. Some of us arranged and organized, and all of us participated in the Earth Day seminars presented at the Fort Wayne Regional Campus of Indiana-Purdue Universities last April. The seminars were conducted by various University faculty members, and by members of the Fort Wayne community, including Mayor Harold Zeis and state and federal officials. They were we 11-attended, from 9:00 a.m. to 10:00 p.m., by students from local high schools, and from the several colleges and universities in the city, as well as by other interested persons from the Fort Wayne area. As you may know, regional universities such as ours, are largely attended by people who'are working to pay all or most of their own way through school. Some are married, with families, some are veterans; virtually all are concerned with information and education, before demonstration. In an effort to prevent our concern for the environment from ending with Earth Day, this group met to find ways of continuing our interest, and of taking an active part in changing unfavorable conditions. In the end, it was decided to affiliate with the Izzak Walton League (as Its first campus chapter) becuase we believe our efforts can carry further through cooperation with a respected organization whose resources of various kinds far exceed those a smalI group can muster. While our commitments prevent us from attending the conference, we would like our views to be known and heard. I We heartily commend the three Interior Department agencies for the responsible and forthright statements issued in their report "Physical and Ecological Effects of Waste Heat on Lake Michigan." It seems unnecessary for us to point out what many at the conference have undoubtedly discussed in detail: the incalculable resource—economic, recreational, biological, climatological, aesthetic, spiritual—which lakes represent. Many avenues of investigation suggest that there is no evidence showing the effects to be deleterious to disastrous, and extremely difficult (if not impossible) to counteract. The conclusion is inescapable that preventive medicine is imperative, not only in terms of effectiveness, but also because corrective measures are unquestionably even more costly. ------- (2) 1750 We therefore support the view that recommends no increase in temperature of the waters of Lake Micigan. It We also strongly support the search, by government and industry, for better ways of dealing with all industrial and metropolitan wastes, including the thermal waste discussed in the report "Feasibility of Alterna- tive Means of Cooling for Thermal Power Plants Near Lake Michigan." We encourage federal agencies to support actively those methods which promise the least damage, in any way, to the environment. While it is to be anticipated that objections to such proposals will be raised on the basis of costs, let it be noted that cost considerations do not, in the end, harm a company or industry as much as they harm the consumer. It is he who ultimately pays. Ironically, this is true whether it be in terms of higher costs for services, or in terms of a devaluated earth. We, as present and future residents of the Fort Wayne area a community which depends primari ly for power on the Indiana and Michigan Electric Company—wish the Conference to know that we are not only willing to pay more for power, but insist that we must, in order to bear our rightful share of the responsibility for preventing further deterioration of Lake Michigan And, we strongly recommend that effective controls be instituted by industry and the government for the prevention of yet another pollutant being introduced into this lake. Ill We recognize that most of the ill effects of an industrialized society were not realized or even imagined only a few decades ago. Many practices which were acceptable in a sparsely-populated world have become intolerable in a crowded one. We do not blame the past. It is one of the characteristics of mankind to be more gifted at hindsight than at foresight. We do blame the present for remaining, in such large measure, insenstive or callous to the dangers of our present situation. We recommend that those in authority, in whatever sector of the nation's activity, work for a speedy discontinuance of all current practices contributing to the eutrophication of Lake Michigan, and that all possible measures to be taken to reverse the process. We heartily support the ten-point policy position of the Indiana Division, Izzak Walton League (enclosed) ------- (3, 1751 Reclaiming and maintaining a healthy world is going to be expensive. It must inevitably cause changes in our present patterns of living. But it is no longer a debatable Issue: the only alternative to making changes is planet-wide disaster. We accept the price. We urge you to do so, too. Alpha Chapter Izzak Walton League Indiana-Purdue Regional University Fort Wayne, Indiana 46807 2101 Coliseum Blvd. East. ------- 1752 (I) Prohibitions of any more landfills or alterations of the natural shorelines, coupled with a total evaluation of the social, economic and ecological qualities of Lake Michigan; (2) Acquisition of an environmental easement along all undeveloped portions of Lake Michigan shoreline, pending results of the total evaluation, at which time decisions should be made as to what portions of the easement should become perma- nent, and what should be expanded in the public interest and for environmental p rotect i on; (3) Establishment of t<->tal effluents standards for ALL discharges to Lake Michigan including the 1 °F above ambient proposed by the Department of the Interior; (4) A strict construct?onist establishment and interpretation of a non- degredation policy for both water and air discharges in the lake context; (5) A no-discharge policy for all commercial and industrial shipping, including on-board surveillance and enforcement by trained interstate or Coast Guard agents, together with complete environmental control systems and design for all such vessels using Lake Michigan; (6) Prohibition of any dumping dredged materials from harbors, ship canals, industrial wastes or slags, and similar materials into any waters of Lake Michigan or its drainage basin; (7) Special Federal and State appropriations earmarked for sewage treatment systems in the Lake Michigan basin, planned for maximum cost effectiveness along lines proposed in 1969 by the U.S. General Accounting Office. (8) A total prohibition of all persistent pesticides in the Lake Michigan basin; (9) A general "inland development policy" which would prevent further visual, physical or ecological intrusion on Lake Michigan; (10) A firm policy with respect to all Lake Michigan ports which would require non-polluting handling of all shipboard wastes and residues, and environmentally designed and operated fueling, servicing and cargo transferring procedures. ------- 1753 To E. Dustin MR, STEIN: Any comments or questions? If not, thank, you again, MR, DOWD: Mr, Dustin, I am Joseph Dowd. 1 am counsel for Indiana and Michigan Electric Company, In your statement, you refer only to the work of Dr, Ayers, Are you aware of the testimony or the substance of the testimony that has been presented here this week by Doctors Pritchard, Lee, Dr, Robertson, Dr, Raney, and Dr. Pipes? MR, DUSTIN: I would say that Dr, Ayers, according to the press release, seems to be the only one willing to be quoted. At least he is the only one quoted in the Fort Wayne press as far as we could see. Are you aware of the testimony of Dr» Bardach? MR. DOWD: Yes. MR. DUSTIN: We hoped that he would be here to handle this thing. I would like to make a comment. I think it is inappropriate, sir, that we should be willing to gamble the life of Lake Michigan on the say-so of the few men that you retained to provide these responses. There are certainly essential facts associated with thermal pollu- tion. I think that cannot be denied. Reduced contents of oxygen, for example; stimulation of algal growth. ------- 1754 T. E. Dustin These matters are not of bathtub origin, as Dr. Ayers would like us to believe. There is a great deal of testimony also to indicate that Dr. Ayers is wrong in the idea that most of the heat is dissipated to the atmosphere. It is, in fact, mixed with the cooler water. The Department of Interior people have suggested that possibility. Do you have anything else? MR. DOWD: Would it be correct to say that you are not aware of the testimony of the scientific' witnesses presented by Commonwealth Edison during the week? MR. DUSTIN: We are familiar with some of the depositions that have been filed in the Commonwealth Edison matter, however not in the direct context of this hearing. However, I have read Dr. Ayers1 complete testi- mony with respect .to the Donald C. Cook plant at Bridgman which is essentially the testimony that NIPSCO is relying upon at the Michigan City plant. Dr. Ayers and his associates, as far as we know, failed to deal with the cumulative effects of thermal pollution in this area, nor with the views of other biologists that the inshore waters are biologically essential for the life and health of Lake Michigan and its source waters that would be most severely affected by ------- 1755 T. E. Dustin thermal pollution, not only from the $0 percent of the thermal pollution for which your particular industry is responsible but from all other sources, too. There are many sources of thermal pollution here in Lake Michigan and, of course, none but a few particular plants in Indiana are so involved. MR. DOWD: Thank you, Mr. Dustin. MR, DUSTIN: You are more than welcome. MR. STEIN: Anything else? MR, FETTEROLF: Yes. I would like to ask Mr. Dustin a question. In your testimony, sir, you referred twice to problems with dissolved oxygen and algae in relation to heated discharges. Could you elaborate on that a little bit? MR, DUSTIN: Yes. I believe that Dr. Donald Mount of the Federal Water Quality Lab at Duluth has indicated a very substantial shift from healthy diatom food cells toward the green and the blue-green algae as temperature shifts as little as 4 or 5 degrees upward. I have forgotten the exact range, but something like from &2 to $6 degrees, or something like that. It is a very strange shift in the distribution of the different types of algae that would be found in water. It is a simple ------- 1756 T. E. Dustin question of physics. I don't think — if you would like me to get into this, I am not a physicist guy, you under- stand — that warm water simply will not dissolve as much oxygen as cold water. I don't think that is subject to controversy. MR. FETTEROLF: But you don't have any evidence that this is observed in lakes that have received heated discharges, have you? MR. DUSTIN: We, of course, have to rely to some extent on biological experts for whom we have respect and who have no reason to be influenced by other sources. Some of these matters have been discussed for me by Dr. William Eberly of Manchester College, who is one of this country's leading limnologists, and I am sure that if you wish I can obtain from him a written statement. He has done some of his postgraduate work at Uppsala University in Sweden, which to my understanding is the outstanding limnology institute of the world. If you would like me to, I am sure we can provide this for the record. MR. FETTEROLF: I am sure the conferees would be delighted to see it. MR. DUSTIN: In that case, we shall provide it. MRo STEIN: Mr. Petersen. MR. PETERSEN: My name is 0. K. Petersen. I am ------- 1757 T. E. Dustin an attorney for Consumers Power Company and I have one or two short questions. It was my understanding that Dr. Bardach may be here today to testify. MR. DUSTIN: We hope so. MR. PETERSEN: Is it merely your hope or do you have reason to believe that he will be here? MR. DUSTIN: No, I have no information that he will be here. MR. STEIN: He is listed as one of the people who want to speak. MR. PETERSEN: Thank you. You spoke of the Department of Interior — I take it you are speaking of this report — the so-called "white paper" — when you talked of the Department of Interior report. MR. DUSTIN: The gentleman was referring to Interior's "white paper" on Lake Michigan, and I was countering with the discussion of a "white paper" produced by NIPSCO which is far less meaningful than this one. MR. PETERSEN: Do your sources agree entirely with the material set forth in this "white paper" as written? MR, DUSTIN: Well, I — let me put it this way: ------- 17 53 T. E. Dustin We have only had that document for about 2 or 3 weeks, give or take a little. We haven't had the opportunity to review this with the entirety of the Academy of Science. But if that is another desire of the conference, I am sure we can provide an analysis. We happen to have in Indiana a professional resource chapter. Credentials for membership in that chapter are Ph.D. in one or more of the life sciences. We have forty members in that chapter. We would be pleased to present an analysis of the Department of Interior's recommendations. MR. PETERSEN: I am merely trying to ascertain your positions, not what you are wanting to do in the future, the basis for your precept. MR. DUSTIN: If the record is open for 30 days I am sure we can do that. MR. PETERSEN: The basis for your precept is, in part, this "white paper" as written, as I understand it. MR. DUSTIN: Yes, sir. MR. PETERSEN: And the material as to heat and the inshore zone and the retention of heat therein and in the waters of Lake Michigan is part of your theory. MR. DUSTIN: Yes, and I wouldn't want to quote Dr. Bardach. I think we will let him speak for himself ------- 1759 T. E. Dustin on it. MR. PETERSEN: Thank you. I have no further questions at this time. MR. STEIN: Are there any other questions? If noti thank you, Mr. Dustin. MR. DUSTIN: Thank you. MR. STEIN: Let me announce the schedule. The way it looks, it is going to be a long, long day. We have to give up this room at 6:00 o'clock, I understand, for a dinner scheduled here. The only breaks we are going to take will be dictated by Mrs. Hall. We may work right through. The conferees may eat lunch at their desks. I realize it is very important for us to get this public testimony. I also know, as I have in the past, in making these pleas or suggestions that you summarize what you are going to say, that it is very difficult for people who are not professionals to summarize, and they feel that they have to read exactly what is in their paper, but I ask you all to cooperate so we can get through at a reasonable hour. Again, I want to emphasize everyone is going to be heard, and we are going to give everyone an opportunity to present his views. May we have Mrs. J. F. Voita who has a statement ------- 1760 Mrs. J. F. Voita of Senator Ralph Smith. STATEMENT OF MRS, J. F0 VOITA, OAK PARK, ILLINOIS MRS. VOITA: I would like to speak for myself because I am teriffically interested in Lake Michigan, but the speech that was just made, of which I only heard a part, gives probably all of my feelings and I hope that a great deal of consideration will be given to it. I think that the fact that all of these wonderful organi- zations are working toward saving Lake Michigan is proof of how important it is. I know that Senator Percy is doing a tremendous job also. It seems to me that it is very foolish on the part of power companies to talk about the cost of doing it some other way, the right way. When you think of what the cost will be to save or to do somthing about Lake Michigan after we have ruined it, there is no com- parison as far as I am concerned. I wrote a letter to four people from Illinois. One of them was Senator Smith. And I was very much sur- prised and pleased this morning before I came to have a call from Washington, D. C., saying that he was very sorry ------- 1761 Eileen L. Johnston that he could not be present but he wanted this statement read. This is it: "I am a co-sponsor of President Nixon's legislation to prevent pollution of the Great Lakes. A clean Lake Michigan is an important factor in the maintenance of a healthy, vital economic climate in the State of Illinois. This goal can be accomplish ^d by strict enforcement of anti-pollution regulations. We must have complete adequate safeguards to control pollution and other detrimental ecological effects of our Great Lakes." Senator Ralph Smith. MR. STEIN: Thank you. Are there any comments or questions? If not, thank you very much, Mrs. Voita. May we have Eileen L. Johnston? STATEMENT OF EILEEN L. JOHNSTON, WILMETTE, ILLINOIS MS. JOHNSTON: My name is Eileen L. Johnston and my home is in Wilmette, Illinois. Mr, Stein and conferees, thank you for the privilege of speaking before you. The other day, Mr. Vaughn, engineer of water purification, city of Chicago, said that he was looking ------- 1762 Eileen L» Johnston forward to my presentation. At that point I didn't know whether I was going to say anything, but I thought if he wanted me to, I would do so, so here I am. It is going to be a sad day in Chicago when Mr. Vaughn retires. He has been a dedicated man. And, Mr. Stein, speaking of retiring, I think it would be very nice if you and the conferees could send a little message to Mr. Blucher Poole telling him how much we are going to miss him at this table. MR. STEIN: I miss him already, MRS. JOHNSTON: I do, too. I miss that Hoosier humor and twang. MR. STEIN: You have to recognize that no one misses him more than I do. I have worked with Mr. Poole for the past 25 years. MRS. JOHNSTON: I realize that. Well, I believe that I am one of the hysterical people that Dr. Raney was referring to the other day. I have been on the environmental beat for sometime now and aim thoroughly convinced that man had better take some drastic actions to restore his environment. May I have the privilege of introducing to the Illinois people — Mr. Stein,"may I have the privilege of introducing to the Illinois people, who may not ------- 1763 Eileen L. Johnston realize that Mr. Currie is the chairman of our new Pollution Control Board, sitting immediately to my right? MR. CURRIE: Thank you. MIS. JOHNSTON: In 196£ I made a statement before this conference and stated: "We must restore all of Lake Michigan to pure water including its tributaries. This wonderful lake is actually one big well for the use of the people of four States and it should be treated as such. Who would throw sewage, chemicals, oil, heat, pesticides down the well and expect to survive? "No individual, Federal installation, State installation, municipality, or industry has the right to put anything into our source of water — the lake. Lake Michigan is not the four-State dump for municipal and industrial wastes, pesticides, thermal pollution, boat wastes. Let's clean up this big well, then keep it that way. We are making progress with legislation. With proper enforcement and continued research we should be able to do the job. "The public needs education. We need a new value put on our most valuable resource throughout the Nation. It is going to cost us money for pure water. Let's face it and go to work." An article by Harlan Draeger in the Chicago ------- 1764 Eileen L. Johnston Daily News of August 3» 1970, quoting Mr. Mayo, Mr. Dumelle, and Mr. Miller shows clearly that we are not making progress in the lake cleanup despite efforts of industry. Are we wise to even consider putting more heat into the lake? Mr. Stein, are you able at this time to give us an approximate date for a reconvening of the Calumet Enforcement Conference? It is long overdue, Mr. Stein? MR. STEIN: Yes, Mrs. Johnston. I note you have attended these things and know how they work and, again, you know I am the Chairman of the conference and the representative of the Secretary. The Secretary of the Interior directs the reconvening and the calling of these conferences. Very often he asks me to call them in my delegated authority, but I do think that we will be in touch with the other States and make a recommendation to the Secretary of the Interior on that» I have no statement now on the reconvening of the conference. We have two things to consider: 1) We have special problems such as this thermal problem; and 2) all of these States have busy programs, and part of the counter-program is that we just have to keep the conferences down so they can do their work. Just prepar- ing for these conferences takes a tremendous amount of staff work on the part of the State agencies and everyone ------- 1765 Eileen L. Johnston else. We try to hold them as frequently as we think they will do the most good, but we will take that up with the States, and I think we can give you a judgment on that after I have checked with the people back at the ranch in Washington, and we will do so. MRS. JOHNSTON: I urge other citizens to do so because the last time this was — this was in August of 1969 and things are not very good down in that part of the lake. It was pointed out by this study fco Mr. Dumelle and Mr. Mayo brought it out. My position has not changed one bit from 196$, so you see I do endorse the Department of the Interior position of September 19700 It was a teriffic meeting and I think, Mr. Stein, it might be very worthwhile to have the highlights of that meeting published so that people can obtain it. I have toured the Ann Arbor laboratory and I have observed experiments going on over there, talked with the research men, and heard them speak at confer- ences on research. Mr. Frangos, I have a question for you. Last spring I toured the Jones Island Treatment Plant in Milwaukee, and the superintendent told me they would be ------- 1766 Eileen L, Johnston chlorinating the effluent by the end of the year. Now, this is October. Do you know what progress has been made? In view of the big discussion that took place at Milwaukee, I feel it should be brought up at this time. MR. FRANGOS: Well, the superintendent has been telling me — and we didn't understand that as a commitment legally to our agency, Mrs. Johnston — but they are proceeding along the timetable that we have established in the State of Wisconsin0 They are not chlorinating as of this date nor will they be chlorinating this fall. Their schedule is for next fall. MRS. JOHNSTON: The superintendent should not have told me that they were going to be chlorinating by the end of the year if that is the case. I urge a speedup of the phosphate deadline in sewage treatment effluent. We have the technology. In fact it is being applied in Milwaukee. Both Mr. Vaughn's and Mr. Dumelle's papers bring out the urgency of immediate action. We must keep in mind we are talking about a very sick lake full of lead, mercury, oil, radioactive wastes, arsenic, pesticides, nitrates, phosphates, heat, and we just don't know the whole story. The ill effects of any one of the pollutants might be so harmful, but ------- 176? Eileen L. Johnston the synergistic effect may be so ominous, I respect Commonwealth Edison for their study plan and for the caliber of the research men who testified for them. Certainly no man has studied Lake Michigan more than Dr. John Ayers, and I have always had great respect for D:f. Ayers, They do have problems that are difficult but that can be solved. This, of course, applies to the other power companies around the lake. The public will, I am sure, be willing to carry its fair share of the cost of alternate methods to once-through cooling when it is made fully aware of the alternative. I realize the outcome of this conference will be based on the judgment of extremely competent men. I have all of the faith in the world in you conferees. I just hope you will remember the small voice of the citizens in your deliberations, and there is one other thing I would like to mention, please, Mr, Stein. A lot has been said about the heat input from other industries other than power, and when we toured U. S, Steel down in Gary — remember, Mr. Stein — in, I think, it was 1968 — that brand new facility — I was really shocked and amazed when I asked the man the temperature of the effluent and it was 11 degrees warmer than the input. MR. STEIN: Thank you. Are there any questions? ------- 1768 Eileen L. Johnston You know, Mrs<> Johnston, I was surprised it was that low considering what they ran that water through, MRS. JOHNSTON: Really? MR. STEIN: Sure. You saw the heat of that steel. MRS. JOHNSTON: Oh, yes. MR. STEIN: And what they subjected it to. MS. JOHNSTON: But when you think of all of the industries down at that end of the lake, and Mr. Morton or Mr. Schneider at the Lake Erie Conference, wasn't there some discussion in the auditorium on the future industry building down there for awhile? MR. STEIN: Well, I didn't hear that. Again — and you know you raise a question here and a lot of people have talked about this — let me make one thing clear: I don't think that people either in the State water pollution control agencies or the Federal water pollution control agencies have any authority over land utilization and I am not sure you people would want us to have thato The land utilization has traditionally been a local responsi- bility. Usually the States control it, certainly not the Federal Government, except when you are dealing with the Federal lands, of course, but with non-Federal lands we don't. ------- 1769 Fo Pierson The point is, however, once a decision is made by the local people of land utilization, we do have the powers to assure that the environment is protected, and this must be borne in mind * I think when people talk to us about putting a moratorium on sites or on uses, I am not sure they recognize 1) the limits of their authority or 2) the implications of that kind of request, to put the Federal Government in that type of business. I am not sure you would like to live under that sort of Government in this country, MRS. JOHNSTON: Thank you. MR. STEIN: Thank you. Frank Pierson, STATEMENT OF FRANK PIERSON, SPOKESMAN, CAMPAIGN AGAINST POLLUTION, CHICAGO, ILLINOIS MR. PIERSON: My name is Frank Pierson, I am representing the Campaign Against Pollution here not so much as a technician, but as a concerned citizen, conveyor of peoples' sentiments, and so on. We just turned in a copy of our formal technical testimony and I won't trouble you with it here. I am here ------- 1770 F. Pierson to stress a single point and to ask some extremely simple questions• The problem of thermal pollution has been discussed throughout Chicago and the suburbs. The people of Chicago and the suburbs, the thousands of us who constitute the campaign against pollution and other sympathisers have come to the following conclusions which we feel is the only human conclusion: There must be no discharges of heat into the lake by a power company. We won't tolerate those dis- charges. And when I say this, I am talking about some very worked up, very adamant people. We pledge ourselves to be unrelenting in the fight against heat discharges of any magnitude by the power companies. We insist that these companies must employ closed cooling systems and that people won't be fooled by phony demonstration projects designed to conceal the fact that those projects propose a thermal pollution threat. So we ask you gentlemen for a favorable answer and we hope that it will come soon. The longer you wait, the more certain we become that you are dickering behind our backs with big corporations, and we are positive that you have the interest of big money and not the people at heart. That concludes what I would like to say. ------- 1771 F. Pierson I would like to ask Chairman Stein a question, and that is when he expects this body will make a decision concerning the matters that are being discussed today. MR. STEIN: Well, a lot of people have contributed many attributes to me which I don't have, and I appreciate being given the wonderful clairvoyance, but I can't predict that. We have a group of five conferees, all independent thinkers. We have had some very complicated information presented before us. We are not completed yet, I think if you want to wait until the wee hours of this morning or tomorrow,,! will be able to give you a better judgment when this is complete and I have consulted with the other conferees. MR. PIERSON: Well, may I ask this: Can you say that you will have a decision by the end of October? MR. STEIN: Any decision that we have will depend on actions of many people other than myself. I can't speak for them. I will try to get a decision as rapidly as I can. From my personal point of view, I would hope that the conferees would be able to come up with a determination within a couple of weeks.., I haven't spoken to them and I have no notion of what they want to do. This is, again — and you are asking the kind of question that people ask ------- 1772 F. Pierson about timetables in enforcement cases and when things are going to be done. But this depends on the determination of third, fourth, fifth parties, and one person doesn't handle all of the strings and is not able to make all of these judgmentso I think my function here is to hold everyone's nose to the grindstone to be sure that there are no dilatory tactics used and we arrive at the decision as rapidly as is humanly possible. MR. PIERSON: Could I tell .my people, then, that we could expect a decision — at least a recommendation — from this body within, say, 2 weeks? MR. STEIN: You can tell your people that but please don't tell them I said it. MR. PIERSON: Let me ask one more question: Will this body be meeting with industry before a decision is made other than in this hearing here? MR. STEIN: I don't think the body will meet with industry. Let me make another thing clear: As a public official, and I guess maybe the others, I have an open door in my office, and whether you or a citizen group, industry, or anyone wants to come up and see me, they are always welcome. I don't know that anyone wants to come up, but I don't feel as an official we can close the door to anyone, I think it ±e fairly clear on ------- 1773 F. Pierson our record that when we meet in a body with people who have an interest in pollution control, we do this in a public manner <, I have said this again and again. We are a public agency doing the public business in a public manner. J£ you think that the implication is there are going to be any private meetings, large meetings that no one knows about, the answer is no. MR, PIERSON: Would you do us this favor then? If and when some of the power companies would like to get together with you, would you invite us to those occasions so that we can present the citizens' viewpoint? MR. STEIN: Well, again, we don't operate, in a sense, that way, and I have talked about this many, many times. If you want to meet with me, I am not sure I will invite the power companies or anyone of that kind, I think, an essence of our society — and 1 know your group has been here before and I have put this out before — an essence of our society is a right of privacy. Privacy doesn't mean secrecy, and we respect that right of privacy of every citizen as a basic constitutional right. And if I want to have a private meeting with my wife or my children,, I don't think that anyone has a right to ask to come in^. I think if any one of the group here wants to come into my office or anyone else's office or ------- 1774 F. Pierson just meet on a personal or other basis, we will have that meeting. I will assure you one thing, I am sure the other people here do this. Nothing I do officially is governed by confidentiality or secrecy. Every public operation we have will be fully disclosed. MR. PIERSON: I would like to say that I think this is a public issue and not a private one of the sort you referred to, and I think that the people should be represented at even the small gatherings where decisions might, in fact, be made without our knowing it. I presume that this wouldn't be a situation in which you are trying to conceal some sort of negotiation. MR. STElN: No decision is going to be made without your knowing it or anyone's knowing it. But, by the same token, in the ordinary conduct of any public business I may have between, oh, I don't know maybe 10 or 15 people in the course of a day coming into my office on special pollution problems, a lot of them spend considerable time and expense in coming to Washington to see a public official. Before they could get past that phalanx of secretaries in my outside office, if I had to tell each one of them that before I could see them, I would have to notify someone else who might have a ------- 1775 A. Pancoe remote interest in what they were concerned with so they all could go to the meeting, I think we would have a sorry kettle of fish. We just don't do business this way, and I think you have to recognize we are operating within our society. Sir, I have got one more thing to say: If you don't have confidence in your public officials and if you don't think that we are going to represent the public interest in all our dealings with whoever we deal with in the best way, public or private, then it is up to the people to get rid of us. But we have to have that mutual faith and confidence if we are going to do business. MR. PIERSON: We think you represent us but we would just like to help you out a little bit. MR0 STEIN: We appreciate it. Thank you. May we have Arthur Pancoe? STATEMENT OF ARTHUR PANCOE, SAVE - CAMPAIGN AGAINST POLLUTION, GLENCOE, ILLINOIS MR. PANCOE: I want to thank you gentlemen for the opportunity to testify„ My name is Arthur Pancoe, a resident of Glencoe, Illinois. I am here as a scientific ------- 1776 A. Pancoe director of SAVE and also Campaign Against Pollution, I have a graduate degree from Northwestern, and Master's from Northwestern University, and I expect to discuss this problem from a slightly different point of view. The use of Lake Michigan for thermal discharge from nuclear plants constitutes only a temporary home for the heat. When considering the possible damage from this discharge and realizing that the heat will in turn be dis- persed into the atmosphere in a relatively short time, the question arises: Why not emit the heat to the atmosphere originally via cooling towers? Taking into account seasonal, and shorter range temperature variations, the heat will remain in the lake approximately 10 days on the average, (Ref, 1) It seems ludicrous to take a chance with the quality of the lake under such circumstances. The total consequences of depositing large amounts of heat in the lake cannot now be determined accurately. The probabilities indicate that if damage does occur, it will not be apparent until years or even decades in the future. And should danger signs occur from the heat, could the plants in existence even be reoriented? The St, Louis-based Committee for Environmental Information in March 1970 estimated that "In the year 2000 ------- 1777 A. Pancoe if power consumption continues to increase and there is no corresponding increase in overall efficiency powerplants of all kinds will dispose of roughly enough waste heat to raise by 20 degrees the total volume of water which runs over the surface of the entire United States." The committee had more dire conclusions with regard to carbon dioxide and radiation contamination that will result from such plants. But these problems are not pertinent to the subject being considered. There are some calculable parameters that can be of use in judging whether a risk can occur in certain areas. It can be roughly determined that the heat input to the lake from all plants by 1990 would be less than 1 percent of that supplied by the sun on a clear early summer day. (Ref. 2) This figure on a superficial basis appears to make the entire question of thermal pollution moot0 However, if we are sagacious about this figure and if additional aspects of man-created heat are taken into account, our complacency will soon disappear. First, unlike the sun, the plants will supply heat to the lake continuously, with no interruptions by either darkness, cloud cover, haze, cold days, or cold seasons of the year. Also the heat will be injected entirely into the inshore portion of the lake at depths ------- 1773 A. Pancoe of less than 10 meters and into an area representing less than 8 percent of the lake's surface. Under these more concentrated conditions the input in the area affected will represent approximately 10 percent of the solar generation again on a clear summer day. (Ref. 3} It is now important to discuss a process by which this heat in the shore areas will be concentrated, perhaps dangerously, in the spring of the year. During this time a phenomenon occurs which is not unusual in lakes but particularly prevalent at times in Lake Michigan. This is a condition in which a thermal bar of water (i.e., water at its maximum density 4 degrees centigrade) is established offshore forming a barrier which allows little horizontal mixing between inshore and the much larger offshore volume of water. This condition can last days or even weeks.- The heat which is already concentrated in the inshore area will be trapped and will spread out in a thermal plume traveling great distances along the shore. As spring proceeds and the bar moves farther offshore, usually sometime in June, the thermal mixing of the lake will return to normal. However, with regard to possible biological harm, uhis intense inshore concentration of heat occurs at precisely the most sensitive time of the year. (Ref. 4) ------- 1779 A. Pancoe J. J. Resia of the Department of Biological Sciences, Northwestern University, formulated a detailed description of the danger to the fish population from this phenomenon, (Ref. 5) I have attached herewith a detail of his statement. Another problem that bears consideration is possible fish kills resulting from upwellings about thermal plumes. Such kills have already been documented with regard to fossil plants. (Consumers Power, Port Sheldon, August 29, 1968) As discussed by Resia, fish population will be attracted to the areas of heated dis- charge . It is well established that the greatest danger to a fish population about a plume exists from temperature drops occurring from a sudden upwelling of cold bottom water< Therefore, the critical upper limit of discharge is governed by this factor and not the upper lethal temperature of a given species. The maximum acclimation temperatures for the game fish in Lake Michigan make it doubtful if any major heat discharge does not involve a risk. (Ref. 5) These allowable acclimation temperatures are well, below proposed discharge temperatures of the plants„ But, more startling the recommended maximum discharge temperatures are below natural maximum monthly surface temperatures. ------- 1780 A. Pancoe (Ref. 6) Thus, safety to the fish population, from even the proposed strong 1-degree limitation above ambient now being considered, is negated. More important than ambient standards is whether any major heat discharges should be allowed. As described earlier, large amounts of heat are continually added in the spring of the year to a rather limited volume of water. Even though this is accomplished by diluting the heat in large volumes of water, the increase in lake temperature inshore will be precisely the same as if the heat were added at a more severe temperature originally. At this point, I wish to digress. It is my con- tention that the various standards being suggested for dis- charge into the lake all provide precisely the same safety to the lake: none at all. I want to strongly emphasize this point if no other point in my statement. The public, in my opinion, is being misled, and I certainly do not think, in the case of this board, purposely, by the 1-degree stan- dard into believing the lake is protected. I do not think the public has been fully cognizant of the fact that the main free ride is given by the lake itselfo There is roughly a 15- to 25-degree temperature change between the water at the point of intake and the outfall point during 10 months of the year. I want to strongly emphasize this ------- 1781 A. Pancoe point, I think the 1-degree, again — not intentially by this board — is a coverup. If I were the power company, I could live within this 1-degree temperature standard very easily and accomplish the exact same damage, if there be damage to the lake. As I pointed out earlier, I do not think that it is even fair to put the power companies to the expense of going through various contortions to live within this standard. The question is: Will the heat harm the lake? Now, I want to make a little statement here about scientists, and this will cover all sides of the question. MR. STEIN: Mr. Pancoe, when we put you on, you indicated you would take 10 minutes. Are you going to adhere to that? MR. PANCOE: I am going to end with the statement on this one point, because I think it is the only point I have to add to the discussion. I don't think any scientist either for or against this heat discharge can honestly say that it either will or will not harm the lake. Einstein in his later years said that his present theories of relativity are more than likely nearer to a correct prediction than the former Newtonian laws, but that his laws will then be improved upon as time goes by by other scientists. ------- A, Pancoe Thus, when any scientist says that he unequivo- cally can state that there will be no damage to lakes from heated discharges, I think this man is possibly dishonest. I likewise feel that anyone who says that heated discharges will definitely harm the lake is equally dishonest. With this in mind, I think that the real question here is: We do not know. And with this, I want to close by stating that I don't think that the heat should go into the lake. It can go just as easily under less stringent standards as under the previous 5-degree standards. I don't think the harm comes from the temperature the water is put in, but from the cumulative effect and the total number of B.t.u.'s put into the lake will be precisely the same in either case. Thank you. MR. STEIN-: Did I understand you, Mr. Pancoe? Your proposal is that power companies or industrial plants not be permitted to put any heated water into the lake. Is that correct? MR. PANGOE: That is my proposal. Either the power companies should be allowed to put the heat in or not allowed to put it in, and I think I could show them if no one else could how to put ------- 1733 A, Pancoe the heat in under the 1-degree standard. MR. STEIN: Are there any other comments or questions? If not, thank you very much, Mr. Pancoe. MR. PANCOE: Thank you. (Mr. Pancoes presentation follows in its entirety.) ------- r / I i ^ I X [ j I j \^ SOCIETY AGAINST VIOLENCE _ ^ ^v ^ NORTH SHORE AFFILIATE TO THE "" ------- 1785 SOCIETY AGAINST VIOLENCE TO THE ENVIRONMENT BOX 84 GLENCOE, ILLINOIS 60022 %&§&?? PAGE 2 During this time a phenomenon occurs which is not unusual in lakes but particularly prevalent at times in Lake Michigan. This is a condition in which a thermal bar of water, (i. e. water at its maximum density 4°C.) is established offshore forming a barrier which allows little horizontal mixing between inshore and the much larger offshore volume of water. This condition can last days or even weeks. The heat which is already concentrated in the in- shore area will be trapped and will spread out in a thermal plume traveling great distances along the shore. As spring proceeds and the bar moves further offshore, usually some time in June, the thermal mixing of the lake will return to normal. However, with regard to possible biological harm, this intense inshore concentra- tion of heat occurs at precisely the most sensitive time of the year. (ref. 4) J. J. Resia of the Department of Biological Sciences North- western University, formulated a detailed description of the danger to the fish population from this phenomenon, (ref. 5) Another problem that bears consideration is possible fish kills resulting from upwellings about thermal plumes. Such kills have already been documented with regard to fossil plants. (Consummers Power Port Sheldon, Aug. 29, 1968). As discussed by Resia, fish population will be attracted to the areas of heated discharge. It is well established that the greatest danger to a fish population about a plume exists from temperature drops occuring from a sudden upwelling of cold bottom water. Therefore the critical upper limit of discharge is governed by this factor and not the upper lethal temperature of a given species. The maximum acclimation temperatures for the game fish in Lake Michigan make it doubtful if any major heat discharge does not involve a risk. (ref. 5) These allowable acclimation temperatures are well below proposed discharge temperatures of the plants. But, more startling the recommended maximum discharge temperatures are below natural maximum monthly surface temperatures, (ref. 6) Thus, safety to the fish population, from even the proposed strong 1° limitation above ambient now being considered, is negated. More important than ambient standards, is whether any major heat discharges should be allowed. As discribed earlier, large amounts of heat are continually added in the spring of the year to a rather limited volume of water. Even though this is accomplished by diluting the hept in large volumes of water, the increase in lake temperature inshore will be precisely the same as if the heat were added at a more severe temperature originally. Another field of concern is the effect on alge growth, (blue- green) resulting from removing large volumes of nutrient, enriched water from the hypolimuion (the cold bottom layer), warming the water, returning it to epilimnion (the warmer top layer), and thus ------- 1786 SOCIETY AGAINST VIOLENCE TO THE ENVIRONMENT BOX 84 GLENCOE, ILLINOIS 60022 '<& PAGE 3 increasing the growing season in the surface waters. Additional secondary effects possibilities are depletion of oxygen in the bottom waters in summer, changes in species composition, numerical relationships in lake plants, and animal populations, (ref. 7) Clarence A. Carlson of Cornell in a paper entitled "Ecological Impact of Nuclear - fueled Power Plants" states many other con- siderations not mentioned. a) Due to inefficiency of nuclear plants 60% more waste height is released to cooling water per K. W. than fossil - fueled plant causing great extremes of conditions via vie fossil plants. b) Temperature is important to aquatic organisms as a lethal, directive, and controlling factor. c) Increase in temperature will increase the rate of metabolism and oxygen consumption in aquatic organisms while con- currently decreasing the oxygen - dissoling capacity of the water. d) Increased temperature generally stimulates growth of taste and odor producing organisms. e) formation of sludge gas f) multiplication of saprophytic bacteria and fungi g) consumption of oxygen by putrefactive processes h) warming of water likely to increase suseptibility of fish to certain disease organisms and metabolic poisons. He also states that less than 5% of the 1900 fish species found in U. S. have been studied with respect to temperature response. The Fishery Resource Management paper "Some Adverse Effects of Thermal Pollution of Aquatic Ecosystems" suggests other dangers from thermal discharge, (ref. 8) Since means of disposing of the heat directly into the atmosphere. are available why take any risk with the lake? Arthur Pancoe Scientific Director of SAVE References 1,2,3, - C. H. Mortimer, Director, Center for Great Lakes Studies Zion, 111. May 2, 1970 4,5,6, - See attached 7 - Alfred W. Eippen, July 3, 1970, American Society for Advancement of Science 8 - See attached ------- Table 3. Recommended seasonal maximum temperatures for spasming and' depths at vhich spawning has occur'red in Lake Michigan Specie Season Depth (ft. 1 T^mp^rj^u£e_(^F)_ Lake Trout .Lake Herring Lake White Pish Yellow Perch Channel Catfish Coho Salmon Oct. - April Nov. - April Nov. - April April - May Jan. - March May - June Fall 10 Streams I/ Keller, M., 19^9« Personal communication. £/ Kpelz, 1929. 3/ Wells, L. , 19o9- Personal coEraunication. J/ Wells, 1968. 5/ Embody, 193!. 6/ Unpublished data, BCF, Ann Arbor, Michigan. 7/ Price, 19^0. o/ Unpublished data, 1IWQL, Duluth, Minnesota. 2/ Sneed, K. Personal communication. ------- Ref. 5 SOCIETY AGAINST VIOLENCE TO THE ENVIRONMENT BOX 84 GLENCOE, ILLINOIS 60022 1733 "One thing which definitely is not needed in the current debates over effects of waste heat from nuclear power plants on Lake Michigan is another biologist who takes the position of an advocate. I therefore must preface my following remarks with a.brief bit of philosophy. With few significant exceptions, predictions of resultant harm to the Lake's biota are honestly debatable. When specialists in pertinent fields disagree, the issues become quite clouded and confusing to the public. The clouds part a bit, though, if the layman keeps two things in mind. First, the empirical, inductive method to which modern science is wedded never "proves" or disproves" anything. No matter how dogmatically some scientific "truths" often are taught, it must be remembered that at the philosophical foundation of scientific method is a rule which says that the most an investigator can hope to accomplish by his experimental results and interpre- tations is to cause one hypothesis or another to seem more or less likely to be true. Hence, competent scientists, honestly attempting to be objective, can and often do disagree.. This brings us to the second point. The current environmental quality crusades in general and the nuclear power plant controver- sies in particular have seen too many scientists showing too little regard for objectivity. Abuses of this nature seem to come from both sides of almost every confrontation. It can be maddening for a scientist to try to refute a less idealistic oponent's "absolute certainties" with wishy-washy "it appears thats" and "the data suggest thats. " Nevertheless, scientists and engineers who my- opically pander either to their employers' vested interests on the one hand or to crowd response on the other do service to no one and, I fear, are going to learn that in the long run, their credibility and that of their profession is as fragile as it is valuable. Granted the above, I would like to describe a problem which I feel has not yet been given any real attention by those about to decide what can and can not be done with waste heat in Lake Michigan. In the temperate latitudes in which we live, organisms are forced to adjust their life cycles to the rigors of changing seasons. Mother Nature has been very fussy about compliance, and those species which failed to synchronize became evolutionary drop-outs. One well-known environmental cue that is widely used by plants and animals as a season-indicator is photoperiod, the changing length of the day. Thus, many birds,"for exampie, are "told when tUeir gonads should ripen, when they should mate, and when they should fatten up and migrate by the lengthening or shortening day- light hours. For terrestrial organisms, as well as for those which are found in rivers and streams (lotic environments), photoperiod ------- 1789 SOCIETY AGAINST VIOLENCE TO THE ENVIRONMENT BOX 84 c5Cffl PAGE 2 GLENCOE, ILLINOIS 60022 is a cue far more trustworthy than temperature. For the biota of lakes and ponds (lentic environments), however, seasonal temper- ature changes usually are pretty consistent (especially in large lakes), and it is well-known that for many lentic species (notably, fishes), water temperature plays the principal role in seasonal synchronization. Since the effects of thermal discharges, present and proposed, on the overall temperatures of Lake Michigan can be considered insignificant (which, possibly, is why Commonwealth Edison spokesmen have mentioned them so often), and since the plumes of heated water will be small in relation to total Lake area, it is not immediately evident that a significant proportion of any popu- lation in the Lake could be affected adversely. There is more to the story, however. In the first place, the littoral (nearshore) areas of any large body of water are by far Ihe most biologically important. In these littoral areas, Nature provides light and nutrients in relative abundance, and productivity is high. Since populations always produce more offspring than the environment can support, and since the principal limiting factor in the survival of offspring of most aquatic animals is food availability, natural selection has "taught" the great majority of species to reproduce in littoral waters. Thus, these near- shore areas, into which the nuclear plant effluents are to be directed, see a lot more biological traffic than comparable off- shore areas. Included in this relatively congested situation are those fishes which are spawning, those which have been spawned, and those predators desirous of eating spawner or spawnee. We understand, then, that biomass is relatively large in the general vicinity of the proposed heated effluents, but the story goes further. Most animals have preferred temperatures. This means that their activity is less at one temperature than at any other. In fishes, for example, an individual's preferred tempera- ture depends on such factors as species, previous thermal history, age, physiological state, time of day and year, and many other things, known and unknown, but it may be generalized that if a group of similar fish are placed in a thermal gradient, they will tend to congregate at their preferz'ed ternperature in a sore of "gapers' block" effect. I have heard the advocates of "thermal enrichment" speak enthusiastically of fishing "hot spots" produced by power plant discharges. Such phenomena are produced when ambient water temperatures are below the preferred temperature of fish in the general vicinity of a heated plume. When the fish congregate at their preferred temperature in the gradient caused by the plume, a fisherman's bonanza results. But there may be a catch to this. I have already discussed why fishes tend to be in the general vicinity of the thermal plumes, and how they can tend to move to positions in the plumes where temperatures are above ambient. Such situations already exist ------- 1790 SOCIETY AGAINST VIOLENCE ENVIRONMENT BOX 84 GLENCOE, ILLINOIS 60022 •'AtVv * V* * "t-V ^LW' TO THE Jt^-V&fV'* %^' CLxLJ LJ W PAGE 3 on small scale in Lake Michigan. But if to these considerations we add the proposals for a growing number of large discharges from nuclear plants, we must conclude that greater percentages of the Lake's fish populations would be spending greater amounts of time at temperatures above ambient. Besides having other, more well-known, physiological effects, water temperature (as mentioned previously) is the principal seasonal timer for many species of fish. In effect, progressive changes in the ambient temperature of the Lake "tell" a fish when to begin and complete gonadal development, when to feed,when to migrate, and when to spawn. Thus, each species of fish is influenced to perform some or all of these activities at a time of the year most advantageous for survival of the population. It must be noted that the physical characteristics of the season are not the only reasons why timing is important. Spawning, for ex- ample, must be performed simultaneously by the greatest possible proportion of the population, for maximum efficiency, and the lar- vae must latch in synchrony with the often ephemeral availability of important food species (which also are influencpd by tempera- ture). Add to all of these considerations the complex, seasonally- variable food-web interactions in the Lake, and one begins to understand the validity of questions raised about fishes spending time in the proposed "hot spots" rather than in waters of ambient temperatures. The temperature a fish "likes" bears no necessary resemblance to the temperature that is good for survival of its population. I have heard attempts by some to defend calefaction on the grounds that elevated temperatures have no adverse effects on certain aquatic animals from arctic or tropical latitudes. I have also heard it mentioned that in certain fish culture practices, people spend money to heat ponds to increase yield. In answer to the latter, it should be noted that such people also have to feed the fish in those cultures. Cultures are not ecosystems. AricTTn~ answer to both, we need only keep in mind that we are concerned with temperate latitude fishes trying to stay alive and obtain food in a tempeKate latitude lake. Finally, I wish that discussions of ecological effects of waste heat could rise above naive considerations of what is lethal to adult fishes. There's more than one way to skin a population, and knocking out reproduction sounds to me as though it might be fairly effective. " J. J. Resia Department of Biological Sciences Northwestern University ------- 1791 Table 2. Lethal temperatures for some Lake Michigan fishes. STDCCICS Acclimation Temperature ' (° Channel Catfish- Lake Herring— V Lake Trout-' Coho Salmon- Yellow Perch Gizzard Shad— 77 68 59 •50 77 68 50 36 68 59 73 68 59 50 111 77 Summer^-/ 77 Winter^ 59 50 lil 77 F) Lethal Temperature (fFj feL . 92 91 86 82 78 79 75 61 73 73 (69)' 77 77 76 75 73 90 86 82 77 70 93 Lover Ii3 111 32 32 Ii8 39 37 33 (3) (3^0 (32) Mi lio 38 35 32 liO 32 32 32 50 37 Hart, 1952 2/ Unpublished .Datas BCF, Ann Arbor, Michigan 3j Parenthesis denotes estimates from short term tests. Huntsman.and Sparks, 192^. jl/ Brett, 1952 5/ Hart, 19^7 ------- 1792 Table 1. Recommended month lymaxi mum surface temperatures for heateS discharges into Cake~Michi£an. Lake Michigan— ... Recommended Monthly Maximum Period Surface-Temperature (° F)— - Surface Temperature s 'Maximum Dec. Jan. Feb. March April May June July August Sept . Oct. iiov. 50 te 37 37 M 53 65 71 7^ 72 65 5* Minimum 33 32 37 32 32 36 te ^ 50^ 50^/ 50 V2 55 50 50 50 50 55 70 85 85 85 85 70 I/ Surface te:nperatues are the 3T readings recorded at 0.0 feet. 2/ Excluding Green Bay. Surface temperature range in Green Bay in ~ June, 1963 vas 15-9 - 25.0° C and in July, 1963 2>i.3 - 17-7° C. 3_/ Fron stations less than 5 miles froa shore and avay frora river mouths contained.in: Lake Michigan Basin Office, BT Data, 1962 end 1963 .and for vinter r.onths from Noble and Michaelis, 19^8. "Winter temperature data from Federal Water Pollution Control Administration, (Great Lakes - Illinois River Basin Project) Buoy Stations." ^J Personal connunication, Mr. John Carr, EC?1, /Jin Arbor, Michigan. ------- 1793 Cons, hhl November 6, 1969 Fishery .Resource Management SOME ADVERSE EFFECTS OF THERMAL POLLUTION ON AQUATIC ECOSYSTEMS I. Through habitat changes A. Aquatic_plants 1. Overstimulation of plant growths present. 2. Shift to less desirable plant forms. Eg, from diatoms or greens to blue-greens. B. Reduction -_of water body' s capacity to decompose organic wastes 1-. Increased decay -1 overutilization of dissolved oxygen in local area, hence lowered decomposition capacity downstream. 2. Stratification isolates organic matter in anaerobic bottom waters. C. Increase stratification period 1. Degraded conditions for fish in hypolimnion ( protracted 0? depletion, food consumption, etc) 2. Longer growing season in epilimnion. II. Throuf;h_gffects on aquatic organisms themselves Perspective: Temperature responses have been studied in less than yl° of the approximately 1,900 specie? of North American fishes. To date virtually all of these have been studies of mshort-term temperature effects. 1. Thermal shock (sudden) a) Through condenser cooling cycle b) Into or out of plume of heated water 2. Heat death (gradual) 3. Death in early life stages o) Before hatching b) Directly after hatching c) Deformity -' abbreviated life span (continued on p. 2) ------- 179^ B. Death thru indirect ecological effects of elevated temperatures 1. Accelerated metabolism + lowered 0? carrying capacity of haemoglobin = Greater need for 0 in env't. But higher temp -* lower 0? in water. Results: a) Extreme cases: Asphyxia b) Less extreme: Weakening. This, plus more direct effects of higher temp.; can produce: (1) Lowered resistance to toxic substances (copper, cvanid0% insecticides, detergents, etc.) (2) Lowered resistance to fungus or disease, plus more rapid proliferation of many pathogens. (3) Decreased ability to forage, escape predators, etc. 2. Disruption of food supply through changes in hatching dates and/or growth rates. a) Heavy mortality of food organisms hatched too early in spring. (Example: mayflies hatched in March unlikely to survive or reproduce.) b) Food organisms of suitable size no longer available when needed by predators (Example: Small walleyes heavily dependent on larval perch.) c) Larvae induced to move into areas not rich in plankton. 3. Interference with spawning activities of adults. a) Block migration. b) Fhysiol. trigger fails at too rapid rise. c) Trigger missing if temp, never reduced? C. Changes in species composition, through: 1. Competitive replacement by spp. more temperature tolerant Example: ?2F. optimum for Igmth bass, not for trout 2. Competitive replacement by creating conditions more favorable to growth and/or reproduction of other spp. •Examples: longer growing season + higher temp, might caucc alewives to reach spawning si'/.e at Age II instead of III. Longer growing season can provide opportunities for more spawning in one season (certain spp.) A. W. E. ------- 1795 Mrs. L. Botts MR. STEIN: Mrs. Lee Botts. STATEMENT OF MRS. LEE BOTTS, OPEN LANDS PROJECT, CHICAGO, ILLINOIS MRS. BOTTS: Mr. Chairman, conferees. I am Mrs. Lee Botts representing the Open Lands Project, a private nonprofit conservation organization with offices at 53 West Jackson here in Chicago. My chief responsibility on the project staff is to serve as executive secretary for the Lake Michigan Federation that has been organized as a clearinghouse for conservation and civic groups in the four States that border Lake Michigan. For this conference, as for the Illinois Pollution Control Board hearings last week, I have been authorized by the Project Board of Directors to urge that the Department of Interior be supported in its effort to protect Lake Michigan from possible thermal pollution. This position was necessarily taken without consideration of the lengthy and sometimes detailed and factual presen- tations made here this week in opposition to the Interior recommendation. Yet after hearing most of the testimony given this week and studying most of what I did not hear in written form, I must still conclude that a strict thermal ------- 1796 Mrs. L. Botts standard is the only means now available to assure prevention of damage from thermal pollution. It is a danger I and some scientists who have not been retained as consultants to utility companies still consider the likely consequence of use of Lake Michigan waters for once-through cooling in the quantities required by nuclear plants and the large fossil fuel plants now contemplated on its shores. This conclusion has been reached not so much because of the strength of the Interior reports issued in defense of its proposal as because of the weakness of the alternatives offered by those who have demonstrated historically that their chief aim is to produce electricity as cheaply as possible regardless of the cost in natural resources. Those of you who attended the Milwaukee meeting of this enforcement conference last March will remember my complaint then that the Federal Water Quality Administration was a paper tiger in the way it confronted, that is, failed to confront the need for a thermal standard. I am in sympathy with the power companies who have been allowed to proceed with the building of their very expensive plants without the guidance of a definitive standard applicable to the whole lake and who are now confronted with the tiger that is somewhat erratically but nevertheless charging ------- 1797 Mrs. L. Botts at lasto Even so, I am glad the tiger is here. I am even more in sympathy with the public that is still being con- fronted with the need for a decision without conclusive scientific evidence and with conflicting and contradictory assertions about the issues from scientists and other technical consultants whose appearance here is financed by vested interests seeking a standard that will impose as little restriction as possible on their activities. In speaking here I have three purposes: One is to point out some of the contradictions and unresolved issues that have been raised in the previous days of this conference, and the second is to make available some pertinent expert knowledge from independent sources in the public interest. Finally, following these independent presentations I wish to make a proposal for an alternative means of achieving protection of the lake from thermal pollution which, if accepted by the power companies, might indeed make it possible to have our power and keep our lake safe, too. 1. The first question I would like to raise is whether there is any contradiction in arguing that the power companies only wish to produce electricity as cheaply as possible in terms of direct costs for the benefit of a public that is presumed to consider electricity ------- 1793 Mrs. L. Botts paramount in maintenance of "the good life," and then denying that public's right to question this purpose by terming it hysterical. Surely neither Dr. Edward Raney, in his professed regard for human ecology (undefined), nor Mr. Brandt of Consumers Power Company, in his labeling of an unconvinced public as hysterical, would deny that it is the public, one way or another, that will ultimately pay the cost of whatever decision is made by this conference. I submit that the first duty of this conference, the Department of Interior and the power companies is to carry oat the public's desire„ As a member of the public, I applaud the Department of Interior for acknowledging that I would prefer to pay a bit more for my electricity each month to make certain that my lake remains free of thermal pollution. I trust that those who would use the lake to produce power would not deny that it is my lake and my neighbor's lake and that of my fellow citizens in Illinois, Indiana, Michigan, and Wisconsin rather than the property of corporate interests whether they produce power, steel or paper pulp. This brings me to my next question. 2. All the discussion by scientists representing utility interests this week has concerned demonstrating that no damage would be done to the lake in terms of its present condition, as if that condition were satisfactory for all ------- 1799 Mrs. L. Botts purposes, except for a few complaints that thermal dis- charges were receiving unfair attention when other sources of pollution are more culpable. I would point out that the members of the public who are most concerned with avoiding all possibility of thermal pollution are for the most part the same persons who would seek to correct the damage being done by other means, such as overloading with sewage, chemi- cal wastes and so forth. Further, I would point out that our concern with the condition of the lake has been generated not by our fellow, if you will, hysterical citizens but by your fellow scientists and technical experts. Here in this very conference we have heard a report from Jacob Dumelle suggesting that the quantity of phosphates in the lake has been greatly underestimated. Repeatedly in public hearings and on other occasions ever since the Stoermer-Yang report on "Plankton Diatom Assemblages in Lake Michigan" was released last spring, I have cited their conclusions in explaining my own fears about the future of the lake. As I said before the Illinois Board last week, Stoermer and Yang state that the changes that have already occurred in the population of planktonic plants and animals indicates that the decisions made in the next 10 years or less will determine whether the life now in Lake Michigan will become more like the present life in Lake Erie. ------- 1SOO Mrs. L. Botts I have never heard this conclusion refuted. Indeed I have never heard any part of the Stoermer-Yang study disputed, unlike the controversies that have raged around some of the scientific reports made by consultants to the power companies. Not only lay members of the public but other scientists, some of whom fortunately have undertaken to interpret the situation for the public, are worried. I would like to read briefly from an article prepared by Dr. William Beecher, director of the Chicago Academy of Sciences and member of the Open Lands Board, for the new publication "Illinois Environment." The title is "An Ecologist Looks at Water," and he says: "I saw Lake Erie the year before it died. With Dr. Paul Ehrlich and Dr. Joseph Gamin, both then on my staff, I visited Middle Island to collect for an experiment on miteborne diseases a quantity of the watersnakes that live on that limestone island .».. At Middle Island more than once we saw the big snakes swimming in from the open lake with mud-puppies in their mouths, the amphibians known to comparative anatomy students as Necturus. It was a minor part of the food chain. I relate this because the following year the snakes were not there. The mud-puppies had died off, mayflies had ceased to hatch and the whole food-chain of western Lake Erie had collapsed. The end had come with ------- 1301 Mrs. L. Botts stunning suddenness — and all we had noted was an unusually large amount of algae along the shores and in the small bays! "Of course it could happen to Lake Michigan! The clear, cold waters, teeming with splendid fish, noted by Marquette and Joliet, are already clouded by the algal slime that betrays a last-ditch attempt of the ecosystem to replenish the oxygen used up by bacteria in combatting pollution. ... "Lake Michigan has two basins, separated by a high ridge that runs between Milwaukee, Wisconsin, and Grand Haven, Michigan. The longshore currents come down the west shore past Chicago and then tend to swirl around in the toe of the lake, trapped by the ridge. Sediments produced and deposited by industry in this lower or southern lake basin tend to accumulate on the bottom, perhaps to be periodically brought into the surface waters in the spring and fall overturns of the lake, due to warming and cooling of the top layers. In the fall of 1964 this may have happened. I announced that Lake Michigan had become a Killer lake when several of us found 10,000 gulls and 2,500 loons dead on the Illinois, Indiana, and Michigan shores. The cause of the deaths of these very tough birds was never determined but the mayflies have ceased to hatch out of Lake Michigan, and last year there was a die-off of inud-puppiec, some picked up on Oak Street beach0 The warning flags are uo and I remember how ------- 1302 Mrs. L. Botts quickly Lake Erie turned the corner! But Lake Erie is part of a broad river of lakes and can be cleaned up by flow- through once pollution stops. Lake Michigan is a cul-de-sac and the canal would be ineffective in saving its life if it turns for the worse.1* It is unfortuante for the utilities, but the fact remains that they seek to use a lake that already needs restoration in large areas, which brings me to my third point o 3. Repeatedly testimony has been given this week that damage to water quality by existing thermal plumes cannot be demonstrated, with the Waukegan plume most frequently cited. My question has to do with the fact that this discussion has been in terms of the present condition of the lake in that area where relatively little life as evidenced by fish or other biological signs can be found, apparently either inside the plume or outside it. No one has attempted to assess the possible past role of heat in relation, say, to the input from the North Shore Sanitary District in bringing the lake to its present state there. When I have asked whether anyone has compared the present ecological state to a previous one, I have been told there is no baseline data available from, say, 25 or 45 years ago or longer. All I know is that formerly there was ------- 1303 Mrs. L. Botts a much greater commercial fishery out of Waukegan Harbor than now and that this past summer almost all of the beaches in the area were closed to the public as unsafe. It is con- tradictory to say that the future effects of heat will be studied without attempting to assess its possible past role, My fourth point also has to do with difficulties of field studies. 4. I have heard many references this week to the difficulty of making judgments based on laboratory findings without field experiences to confirm them. I have also heard this week Dr. Donald Pritchard's descriptions of possible diffusion systems based on calculations derived from mathematical modeling and the assertion that Dr. Pritchard has proved that with a properly designed diffusion system based on results of his calculations only a small fraction of the lake's area will be affected by thermal discharges from the nuclear plants. Is it not contradictory to reject some laboratory findings of potential thermal pollution and accept Dr. Pritchard's mathematical proofs of protection for most of the lake with his mathematically-tested diffusion system? And, considering the public ownership of the lake already discussed above, who will have the authority to impound even the very small areas Dr. Pritchard says will be needed, ------- Mrs. L. Botts 99 acres at Zion possibly, provided his calculations are substantiated in application? Finally, when and how will actual field tests be made of the system he proposes, to determine whether, in fact, it is mechanically feasible and the required engineering is achievable in Lake Michigan where it would be needed? In short, is it not contradictory to reject some laboratory predictions and accept others? I have another quarrel with Dr. Pritchard, which constitutes my next point. 5. Dr. Pritchard asserts that the money required to build cooling towers would be better spent for, for example, sewage treatment plants. Is he suggesting to Commonwealth Edison that the money this company would have to spend at Zibn to avoid discharge of heat be made available to the North Shore Sanitary District already mentioned? Certainly the need is there, and if this kind of tradeoff — a term I learned in studying power production issues — is possible, then I believe the public might find it worth considering. Unfortunately, our past experience leads to believe that the money Commonwealth Edison saves by not building cooling towers will be put to use by the company for its own purposes unless, as already has happened in Illinois, some public body like the Illinois Commerce Commission directs otherwise. I am among those who regrets ------- ISO 5 Mrs. L. Botts that we do not have a public body with the power to give such directives in the present case, and remain convinced that a strict thermal standard is the only means available to protect the lake. Still another question has been raised by Dr. Pritchard's presentation. 6. If Dr. Pritchard's recommendation for a discharge system proves reliable, then how will the public be assured that the best possible system will be used on all nuclear plants discharging into the lake? I am submit- ting to you with this statement an updated fact sheet on the existing and proposed Lake Michigan nuclear plants on which the variations in discharge systems is apparent. The only instance in which a design of a discharge structure has been substantially changed to my knowledge is at the Donald C0 Cook plant near Bridgman, Michigan, where the point of discharge was moved from 150 feet offshore to 1,200 feet. There the change resulted from public protest to the Corps of Engineers about possible erosion damage, not from the company's concern with Lake Michigan. Indeed, it is the Corps of Engineers that grants permits to build discharge structures, and under its new policy of implementation of the National Policy Act, presumably applications for any new plants would be ------- 1306 Mrs. L. Botts submitted to the Department of Interior and FWQA for review. But what about these five plants where the discharge structures are already under construction or are already completed? Under what authority will they be required to make changes? The Corps of Engineers has observers here, but is not participating. Are we to assume that the power companies will voluntarily initiate needed action? I became interested in the methods of discharge myself when I observed about a year ago that at the Point Beach plant in Wisconsin the cooling water would be dis- charged at the shore on the surface, in accordance with the theory that Dr. John Ayers espouses about the means for achieving most rapid dispersal of the heat into the water. Yet I knew that at Zion the discharge would be diffused 700 feet offshore under water in accordance with the theory now advanced by Dr. Pritchard. When I asked the represen- tative from the Wisconsin Power and Electric Company about the difference, especially since the plants are both on the same side of the lake although 200 miles or so apart, and had been built by the same company, Sargent-Lundy, he talked for 10 minutes and then said, "I guess I haven't answered your question, and I have to say we don't know, that we are proceeding according to our best judgment.11 Well, I will have to say that I think it is ------- Mrs. L. Botts contradictory to reject the right of the Department of Interior to proceed according to its best judgment and still retain the right to proceed in that fashion as the prerogative of power companies. This discussion of the possible need for change in plant design brings me to the next point. 7. Is it not contradictory to assert the impossibility and the economic hardship involved in changing plant design during construction but before the plant is being operated, and yet to assert that it will be feasible and the power companies are willing to suffer the financial loss involved in adding cooling facilities later, provided, of course, it becomes necessary owing to proved damage to the lake? This leads me to yet another question. 8. How and by whom will the damage be determined? By consultants to the power companies? I am afraid that will be unacceptable to those concerned about the possi- bility of damage. By the State agencies? But we are already confronted with the difficulty of separating the interests of at least some State agencies and the power companies. By the Federal Water Quality Administration? I suppose the outcome of this conference will indicate whether and the extent to which the paper tiger has indeed changed its stripes. This question of authority to make assessments ------- 1303 Mrs. L. Botts brings me to point number nine. 9. We have heard this week of Dr. Edward Raney's conclusion that with judicious placement, a large number of nuclear plants could be operated on the shores of the lake without danger, yet Dr. Raney did not tell us his criteria for judging the sites nor who would do the judging for future sites much less who will review the existing sites. That brings us back to the question of whether the power com- panies will agree to change existing sites if they prove unwise, and I am afraid the answer is obvious. One specific criterion has been mentioned this week and that is that thermal discharge plumes should not overlap. In one existing case on the lake it has always been a matter of concern to the conservationists that the relationships of the Point Beach and Kewaunee plants only 5 miles apart on the same bay have not been assessed. Who will determine now whether their plumes will overlap and assure us that something will be done about it if they do? The question of assurance brings me to point number ten. 10. Mr. Kopper of the Indiana and Michigan Power Company spoke of his company's assurance that no injury will befall Lake Michigan and of their efforts not to intrude on the environment through use of paint of a particular color and proper design of the building. ------- 1809 Mrs. L. Botts Unfortunately for the public's peace of mind, this is the company that installed a coffer dam that started an erosion process the company's own geological consultant, Dr. Jack Hough of the University of Michigan, said in an open hearing would extend 20 miles down the shoreline unless stopped. Still more unfortunately for those particular members of the public whose property was directly affected, they had to resort to a lawsuit to secure replenishment of sand on their beaches. I believe one of those property owners is present today and I will leave it to him to tell you whether he thinks sand-colored paint and low-lying buildings provide adequate environmental protection at the Donald C. Cook site. 11. My last point in this series concerns a most fundamental assertion that has been made repeatedly by various spokesmen this week, and that is the statement that the addition of heat from the nuclear plants might prove, or some say would prove, beneficial to the lake. Exactly what is meant by beneficial has not been clearly defined. If it means that there will be even less trout and salmon and more carp, I question how many members of the public will agree, even if they can catch carp all winter near powerplant outfalls. If it means an increase in total biomass, as ------- 1810 Mrs. L. Botts asserted by Dr. Mary McWhinnie before the Illinois Board last week, how does this equate with a denial that the additional heat will accelerate eutrophication, when the first stage of advancing eutrophication is just such an increase in the total quantity of living matter in a body of water? Another suggestion has been made by Dr. Fred Lee that addition of heat to the water might increase its capacity to deal with pollution by increasing the rate of chemical reactions. Apart from the fact that I am confused as to how this increase is going to take place if Dr. Pritchard is correct, shouldn't it be possible to confirm this assertion by the finding of improved water quality near existing outfalls? Yet we are told there is no dis- cernible difference within a plume and outside it. In conclusion of this part of my statement, I believe it must be obvious by now that at least as many if not more questions have been raised for me by this week's workshop as have been answered concerning thermal discharges and Lake Michigan. In view of all the contradictory assertions, is it wonder the public is confused if not hysterical? There is one point on which I find myself in agreement with the power companies and their consultants ------- l&Ll MrSo L. Botts who have appeared this week, as well as Dr. Philip Gustafson of Argonne National Laboratory and others, and that is on the lack of information about existing thermal discharges. It has seemed to me that not only are more facts needed about effects of existing powerplants but that we also need the judgment of independent scientists who are qualified to advise us to their opinion about the probable long-term results of using Lake Michigan for seven or more large nuclear plants. Finally, I believe that for the public to make its decision about its willingness to bear the greater direct costs engenderedby avoiding use of the lake as a heat sink,advice is also needed by independent experts about the cost of using cooling devices relative to the benefits obtained,. Thus I am happy to be able to introduce two sources of independent information,, The first is Miss Edith McKee, a consulting geologist, who has interrupted an almost completed study of Traverse Bay to describe here the effects she has observed of operation of the Big Rock Point nuclear plant there. Her background and qualifications will be described by Lowell Gomes, a member of the consulting firm with which Miss McKee is associated. The second is Dr. John Bardach, a distinguished aquatic biologist of the University of Michigan, who has ------- 1S12 Mrs. Lo Botts come from Ann Arbor to serve as a consultant to the public. A third person, Dr. John Langura, an economist, who had intended to make a presentation on the costs of cooling devices relative to the means of the companies to provide them, has had to go out of town to attend a funeral. His presentation will be filed with you as soon as he returns. I have been supplied with an abstract of an article by Dr. Beeton from the University of Wisconsin, and copies have been given to the conferees. Dr. Beeton sent this material at our request because of the points that had been raised during this week on whether there was any difference between the inshore and offshore waters of the lake, and I will read a one-paragraph abstract of the same. (See Pp. lSl2a-l&L2f) "Significance to the eutrophication problem of inshore-offshore differences in nutrients and the planktonic diatoms of Lake Michigan. "Many engineering studies dealing with water supply, disposal of sewage, waste heat, and industrial waste have been based upon the assumption that the entire volume of Lake Michigan was available for dispersion and dilution of the pollutants. Recent studies have indicated, however, that inshore waters in most areas of the lake proper have different concentrations of phosphorus, nitrogen, and ------- SUBMISSION OF PAPER AMERICAN SOCIETY OF LIMNOLOGY AND OCEANOGRAPHY, INC. 33rd Annual Meeting University of Rliode Island August 26 - 29, 1970 NAME Beeton Ruth Holland First Initial Last CO-AUTHORS (If appropriate) A. M. Beeton ORGANIZATION Center for Great Lakes Studies, University of Wisconsin-Milwaukee ADDRESS Milwaukee. Wisconsin 53201 TITLE OF PAPER: Significance to the eutrophication problem of inshore-offshore differences in nutrients and the planktonic diatoms of Lake Michigan. ^^^ i ABSTRACT (Approximately 200 Informative words. Use attached sheet if necessary)! Many engineering studies dealing with water supply, disposal of sewage, waste heat, and industrial waste have been based upon the assumption that the entire volume of Lake Michigan was available for dispersion and dilution of the pollutants- Recent studies have indicated, however, that inshore waters in most aeas of the lake proper have different concentrations of phosphorus, nitrogen and Silica from offshore areas. These inshore and offshore differences in the distribution and con- centration of nutrients are reflected in the distribution and abundance of planktonic diatoms and in the species composition of the Melosiras. The present study was undertaken to further document inshore and offshore differences. Samples were obtained by car ferry on a transect which ran across Lake Michigan and Green Bay from Frankfort, Michigan, to Menominee, Wisconsin. The new data substantiated earlier findings, and indicated in addition that there were differences between inshore and offshore waters in Green Bay. »ge3ted Division; Environmental Enrichment Deteriorating Environment Natural Environments Other DEADLINE: May 15, 1970 MAIL TO: Projection Requirements; Vl/4" x 4" Overhead Viewer Dr. I. E. Wallen Office of Environmental Science Smithsonian Institution Washington, D.C. 20560 ------- OFF MILWAUKEE OFF LUDINGTON I8l2b 27 May, 1970 415 Fragiloria crotonensis Tabellaria flocculoso Stephanodiscus hantzschii MAP MILWAUKEE Pig. 1. Example of inshore-offshore differences in distribution of three species of diatoms in Lake Michigan. Inshore samples were taken 3 miles off Ludington and Milwaukee, offshore sampling locations were greater than 10 miles from shore (from paper by R. Holland Beeton and A.M. Beeton, presented at 33rd annual meeting of the American Society of Limnology & Oceanography, Kingston, R.I., Aug. 1970) ------- OFF MILWAUKEE OFF LUDINGTON 8001 I8l2c STATIONS ,-ig. 2. inshore-offshore differences in concentrations of silica, total Phosphorus and non- I^S3ffiSSf±'^^ of Limnology and Oceanography, Kingston, R.I.-, Aug. ------- Made in United Stales of America nU'! tioiu LIMNUI.O(;V ANp OcicANCXMiAi'i Vol. 13, No. 3, July 1068 pp. 5S5-557 CORRELATION OF MELOSIRA SPECIES WITH TROPHIC CONDITIONS IN LAKE MICHIGANI Certain species of the diatom genus Melosira have been associated with differ- ent trophic conditions, that is, the degree of available nutrient supply. Hustedt (1945) has called Melosira granulata (Ehr.) Ralfs the planktonic diatom most charac- teristic of eutrophic waters in Europe. Melosira granulata and, to a less marked extent, Melosira ambigua (Grun.) O. Mtil- ler characterize strongly eutrophic bodies of water in Britain (Lund 1962fl). Melosira bintlerana Kiitz. has become one of the predominant diatom species in western Lake Erie in the past 30 years (Hohn 1968), while the waters of Lake Erie have under- gone accelerated eutrophication during the same time (Beeton, in press). Melosira islandica O. Muller is the dominant diatom in Great Slave Lake, which is considered oligotrophic (Rawson 1956; Lund 1962b). The distribution of these species in certain regions of Lake Michigan appears also to be correlated with trophic conditions. METHOD A Van Dorn sampler was used to collect 219 samples at 2, 5, and 10 m from five regions in Lake Michigan and southern Green Bay (Holland, in prep.). The di- atoms were cleaned with nitric acid. After most of the acid had boiled off, the mix- ture was diluted and passed through a 0.45-/i membrane filter. Diatoms were ex- amined at 970 X under phase contrast from a portion of dried filter made transparent with immersion oil. Each complete valve was counted as one-half diatom frustule, DISTRIBUTION OF MELOSIRA SPECIES The species association in southern Green Bay was markedly different from ^^Contribution No. ijjfr Center for Great Lakes Studies, University of \Vfscnnsin-Mi1waiikeo. those of the regions sampled in Lake Mich- igan itself (Fig. 1). The flora of Green Bay was characterized by species that have been associated with eutrophic conditions: large numbers of M. granulata and sec- ondarily, M. ambigua and M. binderana. Although M. Islandica occurred only occa- sionally in the waters of Green Bay, this species was the dominant form in Lake Michigan near the western shore and in the open lake areas. It was a codominant with M. ambigua near the eastern shore. Melosira granulata and M. binderana were seldom found in the lake. COLLATERAL DATA Collateral data from the five sampling areas provide a comparison of relative trophic differences. Average diatom con- centrations were higher in Green Bay than in the lake (Table 1). Diatoms were more abundant in the ncarshore areas of the lake than in the offshore areas, but numbers were about one-third greater at inshore Michigan than at inshore Wisconsin. Total and partlculate phosphorus were considerably higher in Green Bay than in the lake, while average nitrate-N levels in the bay were almost three times lower (Table 1), and at times were not detect- able (Allen 1966). Presumably most of the nitrogen was tied up in the plankton and little remained as nitrate. Beeton (in press) has established that southern Green Bay is a eutrophic area. Average values for total and particulate phosphorus near the Michi- gan shore were much lower than those in Green Bay, but were higher than those of the other areas of the lake. Nitrate-N lev- els in waters of inshore Michigan were higher than those in Green Bay hut lower than nitrate-N levels in other areas of the lake. ------- 656 NOTES AND COMMENT ' » Melnsira ambigun ——— Mnlor.irg (underarm —-.— Melosira granulate ___ MelOEira islandico Fio, 1. Sampling location* and abundance of predominant species of Melosira (frustulea/ml) in wnithern Green Bay and Lake Michigan, April into November 1065. TABUI 1, Avtnge poneentratiant of phoiphartu, nitrate, and total diatom, April into November 1085, and oaU volume and total btomau (tn parentheses) of predominant speciet of Meloiira at ((me of peak abundance in touthern Green Bay and Lake Michigan, (Value* of phosphorus and nitrate in pvb from Allen J00fl; diatamt in fniittiles/ml; cell volume in n's total species biomasi in n'/ml. A = absent or uncommon) Tcrta] P Dtemlved P Particuthta P Nitrote-N Dlatomi Af, fwibigittf MI fc ------- I8l2f NOTES AND COMMENT 557 TROPHIC SIGNIFICANCE The distribution of species of Melosira appears to reflect trophic levels: eutrophic conditions in Green Bay, oligotrophic con- ditions in offshore waters and waters near the Wisconsin shore of Lake Michigan, and intermediate conditions near the Mich- igan shore. The size of the standing crop of Melosira in the different areas (Fig. 1) supports the above conclusions. Eutrophication generally favors the development of large numbers of cells as well as the occurrence of large forms or colonies (Findenegg 1965). Although M. islandica at times had a greater cell volume than the forms which have been associated with eutrophy, the greater combined numbers of the latter in Green Bay produced a significantly greater total biomass there (Table 1). Thus, the total biomass of Melosira was greatest in Green Bay, least along the western shore and in the open lake, and intermediate near the eastern shore. Nalewajko (1966) reported a similar phenomenon of differences in diatom spe- cies among regions in Lake Ontario. Melo- sira islandica was a predominant species of the central lake, while Stephanodiscus tennis predominated in coastal areas, sug- gesting differences in trophic levels be- tween inshore and offshore waters. RUTH E. HOLLAND" Center for Great Lake Studies, University of Wisconsin-Milwaukee, Mihvaukee 53201. REFERENCES ALLEN, H. E. 1066. Variations in phosphorus and nitrate in Lake Michigan and Green Bay, 1063. Paper, Oth Conf. Great Lakes Res., Chicago, 111., March 1066. BEETON, A. M. In Press. Changes in the envi- ronment and biota of the Great Lakes. Proc. Intern. Symp. Eutrophication, Natl, Acad. Sci. FINDKNECG, I. 1065. Relationship between standing crop and primary productivity. Mem. 1st. Idrobiol, 181 fiuppl, 271-089. HOHN, M. H. 1068, Majpr changes in the plankton diatom flora of the Bass Island region of western Lake Erie, 1038-1065, Paper, llth Conf. Great Lakes Res., Mil* waukee, Wise., 18-20 April 1068. HUSTEDT, F. 1045. Pie Diatomeenflora nord- deutscher Seen mit besonderer Berticksicht- igung des holsteinischen Seengebiets. Arch, Hydrobiol., 41« 302-414. LUND, J. W. G. 1062o. Phytoplankton from somo lakes in northern Saskatchewan and from Great Slave Lake. Can. J. Botany, 401 1400-1514. . 1062b. The periodicity of Meloiira (•- landica O. Mull, in Great Slave Lake. J, Fisheries Reg. Board Can., 19i 801-504. NALEWAJKO, C. 1066. Composition of phyto- plankton in surface waters of Lake Ontario, J. Fisheries Res. Board Can.. 231 1715-1705. RAWSON, D. S. 1056. Algal indicators of trophic lake types. Limnol. Oceanog., li 18-25, "Mrs. Alfred M. Bee ton. ------- 1313 Mrs. L. Botts silica from offshore areas. These inshore and offshore differences in the distribution and concentration of nutrients are reflected in the distribution and abundance of planktonic diatoms and in the species composition of the Melosiras. The present study was undertaken to further document inshore and offshore differences. Samples were obtained by car ferry on a transect which ran across Lake Michigan and Green Bay from Frankfort, Michigan, to Menominee, Wisconsin. The new data substantiated earlier findings, and indicated in addition that there were differences between inshore and offshore waters in Green Bay." We are grateful to Dr. Beeton for making this information available to the public interest. Now, I would like to introduce Dr. Gomes, who will introduce Miss McKee, who has slides and materials relative to her findings in Little Traverse Bay. Then, with your permission, I would like to read into the record Dr. Bardach's recommendation, a statement he made regarding the potential for heat input to Lake Michigan and Dr. Bardach himself is present to answer questions about his statement. Mr. Gomes. ------- 1814 L. Gomes STATEMENT OF LOWELL GOMES, SENIOR ASSOCIATE, THEODORE S. LEVITON & ASSOCIATES, CHICAGO, ILLINOIS MR. .GOMES: .1 am Lowell Gomes. I am a Senior Associate with the firm of Theodore S. Leviton & Associates, at 203 South LaSalle Street, Chicago. One of my projects has been to coordinate our firm's various research efforts concerning Lake Michigan and the other Great Lakes, and I am here to present my firm's general viewpoint on the thermal standard question. Miss Edith McKee, our Chief Geologist, will present the specific findings to date, following my presentation. We are in favor of a responsibly moderate approach to this problem. We realize that the importance of keeping the lake as an unspoiled natural resource must be balanced with the necessity of increased power generation by non- fossil fuel means, both to ensure adequate power and to reduce air pollution. We maintain that, because of the exigencies of the situation, we must take a very practical approach: one that utilizes to the fullest any existing hard information on the lake from whatever source obtainable. It would be nice if we had great amounts of scientifically exact data ------- 1815 L. Gomes stretching back decades, covering all parameters measuring lake quality. We don't have this data, at least for the most part. But this does not mean that no information exists; rather it indicates that we must look more deeply and more broadly than we have. Our research shows that it is grossly misleading to speak of the lake as a whole; it is only slightly less deceiving to divide the lake up into "the open lake" and "the inshore lake." We maintain that the ecological and environmental effects of discharging heated water at any particular site can be accurately assessed only by complete study of the site in question. It is dangerous to attach unmerited significance to results of isolated laboratory study or to conclude with any degree of finality from one or two studies of existing thermal intrusions that such interference is not dangerous to the Iake0 Models and laboratory studies eliminate many variables that exist in nature; studies conducted at other sites are bound to involve variances which may make the conclusions inapplicable to other sites. Cross-disciplinary efforts are necessary to help eliminate the effects of insufficient data and of conclusions based on studies which exclude important parameters. We have attempted to do this by taking a hard geological look ------- 1316 L. Gomes at the whole lake in general, and at Little Traverse Bay in particular. There has been considerable testimony on biological, biochemical and meteorological aspects of the thermal problem, but very little has been mentioned of the geological impact, a gap we will attempt to plug. Beyond this, we have interviewed responsible long-time residents of the Little Traverse Bay area and have questioned them con- cerning changes they have noticed. While a beach-side resident may not be a qualified biologist, he certainly is competent to observe when the water washing up on his land was clean, when he first noticed significant algae growth, or when he no longer was able to see the bottom. With no conclusive historical scientific data in this area, we cannot ignore this sort of observation without violating our responsibilities to preserve the lake as a natural resource. Our research on the lake generally, and on Little Traverse Bay in particular, enables us to reach some tentative conclusions which lead to the following recom- mendations: 1. That 1-year studies of any heated discharges are not sufficient to detect significant trends, even locally, that will predict long-term effects on the quality ------- 1&L7 L. Gomes of the lake. 2. That it is not prudent to assume that we can permit heated discharges to approach the projected 19^0 levels, without risk of serious effects. 3. That the number of powerplants allowed to use lake water for once-through cooling must be severely limited until long-term studies are completed on existing plants• 4, That long-term or perhaps perpetual studies are needed at each site to monitor and determine effects of thermal discharge on the ecology and the environment. These studies should be made by governmental and other agencies as well as by the power companies. 5. That such studies should be cross-disciplinary and that they should be of a scope and depth which will allow the gathering of data from all available sources. 6. That more extensive work in several scientific disciplines, including lake geology, should be incorporated into site location studies and planning. 7» That any harmful effects of thermal discharges may be significantly lessened by consideration of geological factors. This would be primarily of use before site con- struction. 30 That a 1-, 3-» or 5-degree temperature ------- L» Gomes standard would not necessarily be sufficient to protect the lakei as well as presenting enforcement problems. 9o That the standards pertinent now are necessarily qualitative rather than quantitative; thus the laws promul- gating these standards should be framed to implement this idea of quality-oriented standards. The measured effects must be legally interpreted in each case. 10. That if new powerplants are allowed to come onstream, they may do so only with the written and legally enforceable understanding that they may be required to alter or terminate their usage of lake water for once-through cooling if sufficient harmful effects are detected. The specific research on the lake in general and Little Traverse Bay in particular will be presented by Edith M. McKee, Certified Professional Geologist, and the Chief Geologist with Leviton & Associates. Miss McKee has an unique, varied and in-depth knowledge of Lake Michigan gained over 27 years of professional and personal experience with the lake that gives her a valuable overview of scientific knowledge tempered with great personal involvement, A back- ground brief is attached to the outline of her presentation. I would add here that her presentation is printed only in outline form due to the shortage of time available to formulate this information; Miss McKee only returned from ------- 1819 E. M. McKee her research at Little Traverse Bay this Tuesday. Although the Little Traverse Bay study is not finished, several new factors will be presented from the study that previously have not been adequately considered. Miss McKee. STATEMENT OF EDITH M0 McKEE, CHIEF GEOLOGIST, THEODORE S. LEVITON & ASSOCIATES, CHICAGO, ILLINOIS MISS McKEE: I am Edith M. McKee. I am a geologist with 27 years of diversified professional experience with the U0S.G.S. and industry in inshore and offshore, surface and subsurface exploration and development programs in the United States and foreign areas. Since 195$, I have worked as a consulting geologist, currently acting as chief geologist for Leviton & Associates of Chicago. The Illinois Geological Society has certified me as a qualified professional geologist. The American Institute of Professional Geologists has awarded me the title of certified professional geologist, based on detailed examination of academic training, specialized training, geological experience, and ethical conduct. My area of special interest is the integrated ------- 1820 E. M. McKee mapping of surface and subsurface geological structures, tectonics, stratigraphy, georaorphology, and paleogeomorphology as they relate to mineral accumulations and land use. Water is a mineral and an erosional depositional force and within the geological area of concern. The Chicago area has been my family base for several generations. Since the 1890's, family vacations have been spent in Bay View, Michigan, located on Little Traverse Bay at the far northern end of Lake Michigan. Petoskey, on this large map at the head of the room, is located on Little Traverse Bay. Bay View is one mile east — a short walk. While not a member of the 1890 vacationers, I have had a long established interest in the entire lake. Since 1932, however, I have been intimately familiar with the waters of Little Traverse Bay as a distance swimmer, boater, fisherman, and summer resident. Since 1938, I have known the Little Traverse Bay shores, basin, and waters as a trained geologist. Except for the summers of 1947» when I was working for Shell Oil in Texas, and 1950, 1952, and 1953» when I was working for Aramco in Saudi Arabia, I have been able to visit Little Traverse Bay for at least short periods each year since 1932. Since 1967, I have been engaged in an ongoing program to map in detail the bottom terrain and associated ------- 1821 E. M. McKee geology of the Great Lakes. Lake Michigan was the first lake study. This summer has been spent studying Little Traverse Bay and the north basin of Lake Michigan. Indeed I was called off the U.S. lake survey's research vessel, Shenahen, this week to attend this meeting and will have to complete the survey late this month as the snow falls out there along with the temperatures. Water quality — last Saturday I was out, we got two stations and had to come back in. We were standing on our ears. Sleet was coming down at the same time. Water quality, currents, ecological and geological data obtained since June 1970 are relevant to the thermal pollution concerns of this meeting. In fact, I feel a little bit of an outsider having visited and worked with the site of the only nuclear plant operating on Lake Michigan0 The only place in Lake Michigan where the effects of the thermal plume from a nuclear powerplant can be studied is Little Traverse Bay at the far north end of the lake. The Big Rock nuclear plant is located northeast of Charlevoix on Big Rock Point which makes an abrupt eastward trend of the shoreline to form the southern shore of Little Traverse Bay. This bay extends eastward for 14 miles. ------- 1322 E. M. McKee East-flowing surface currents carry the thermal plume from the Big Rock nuclear plant along the south shore toward the head of the bay. There has been an unfortunate attitude that Little Traverse Bay is too small and the water is too cold to afford critical data concerning lake circulation and water quality. This is not a valid assumption. Both Little Traverse Bay and the south basin of Lake Michigan are partially enclosed basins with consider- able-topographic relief and similar geologic formations. Both have well established currents throughout the water column going at different directions. Both are scheduled to receive slightly more than one and a half million gallons of heated water for each square mile of surface water every day from nuclear powerplants. Little Traverse Bay has been receiving this heat input since 1963> and negative changes in the water quality appear to be accelerating since 1964* Now, to get down to the presentation of the geological materials developed since 196? and including the work done this summer, we will start the slides here and I will quickly talk, trying to go as fast as possible here. When I took these pictures to Earth Day programs ------- 1323 E. M. McKee at a number of high schools in this area, the question was always asked: How many years ago did you take a picture like that? The water at the north end of the lake is still blue on a bright summer day. Inshore it is cloudy. There is algae beginning to come in, but you can still see the beautiful picture. If you would please run these through — apparently this isn't working — if you would please run these though at a steady rate of about a second per — this is the offshore picture. Now, this series of maps is called paleogeo- morphic. It shows the entire development of the Great Lakes region. This is part of the 196? study that covers 600 million years of development of the Great Lakes area. Each one of the maps in this series extends from north of Lake Superior to south of Tennessee; from Iowa to the eastern seaboard, New Jersey. How do we put these together? We still have today in the world active volcanoes pouring out lavas. This is a picture of a lava field in the Belgian Congo. This is a recent crater in the Philippine Islands. We can go to places — geologists can — and know what happened even that long ago0 ------- E. M. McKee The waters came and the waters went. For most of this time, this part of the new continent has been covered by a shallow warm salt sea. This is in the Persian Gulf where we have sand spits built up. The same thing we can find in the subsurface now in this area. Gradually the Michigan Basin, of which most of the lakes except Superior are evolved, was surrounded by the coral. As they go through, you can see there is a change in the water — I mean the sea and land relationships. Gradually the seas drained off. We had enormous rapid chemical erosion, physical erosion, because there were no plants on the land surface. We have the same thing today in the desert areas in the middle east. This series is taken over in SaudJ Arabia, but it is the same type of terrain which I can map in the subsurface, and all of these have importance on the whole economic program, the whole use of this region. After about 300 million years of this rapid erosion, we had developed a circular pattern with the center of the Michigan Basin about Saginaw. The hard rocks stood up as ridges around the edge; the soft rocks had been eroded. It was at this time that the major basins ------- E, M. McKee for the Great Lakes came into existence. It is this type of topography, subaerially eroded, that we are finding in all of the Great Lakes. In many places, it is covered by modern sediments, post glacial sediments. I believe Dr. Collinson talked about that sometime at this meeting. It was on top of that topography that the glaciers came down. It did not scour the basin. We will now go on up to the lake again. It is always fun to get offshore. In order to know the lake basin, in order to know the amount of water in the lake basin, you have to know in detail the shape of that basin. There is onshore geology; there is offshore geology. Now, this is a picture of the bottom of Lake Michigan, which has been developed through this on-going study done in cooperation with Dr. J. L. Hough at the University of Michigan. The Mid-Lake High is a 200-foot barrier rising from the bottom dividing the north basin from the south basino The area of the south basin is very much restricted. It goes down to better than 500 feet on the south end but nonetheless it is comparatively small. The Mid-Lake High has a 200-foot vertical cliff on the north side. The darker colors indicate the deeper waters. As you can see, the deepest hole goes up southwest ------- E. M. McKee of Frankfort. This is an enlarged portion of the Mid-Lake High which in the Chicago area is particularly important because this is the big barrier that controls the curents within the south end of the lake and, even as we will see later, controls the surface currents. And this is up at Bay View. The cliff here is Traverse limestone. It is exactly the same geological formation. It looks exactly the same — because we had a submarine and went down and looked at it — as the western cliffs of the Mid-Lake High off Milwaukee. It reacts in the same way. This is called a fence diagram. It was con- structed from the oil well records in Michigan; the water well records in Wisconsin. We had dredged the samples0 We knew bedrock outcrops in the bottom of the lake. This is the first time that we have been able to project accurate — well, with reasonable accuracy — the geology beneath the lake basin. This is of importance because of the input of ground water at some of the contacts that we will see later. This is a bedrock geology superimposed on the topography of the lake. We will be interested in the yellow-green, at the moment, which is the Traverse forma- tion, and the blue-green outside of this. Little Traverse ------- 132? E. M. McKee is up at the extreme end, just above the legend. It is at about a third across the bay that we have this contact between the yellow-green — the Detroit River — and the blue-green. It is along this contact that we have a series of artesian wells input of water 39 to 41 degrees instigat- ing and carrying out year-round west-flowing bottom currents, We have the same juxtaposition of geological formations off of Milwaukee. We have the Detroit River formation recognized onshore. We have the Traverse forma- tion in the Mid-L^ke high. It has not yet been determined if there is ground water input along that to increase the current flow or not0 Back up in the north country again. This is the head of the bay in the sag between these two geological formations. The sand has moved in — dune sand* It is very permeable. Any building back there where they have had septic tanks, the drainage has been directly into the bay. That is now controlled. At the far southeast corner of the bay for many years there was a cannery, and I remember that distinctly because, as a swimmer, I would head over towards Harbor Point which was 3-and-a-half miles away, and as I would be swimming along, I would know where the currents were; I would know where I would suddenly be swimming in 70-degree ------- E. M. McKee water and suddenly down to 40-degree — you know that» There is no doubt when you hit it. This is a picture of Harbor Springs, one of the best natural harbors on the lake. It has been developed along this geological contact between the Traverse and the Detroit River. There are springs in this harbor. It has deep enough water to take — well — some of the largest boats that come in. This is one of the big cement boats that took shelter in there this summer. Right off Harbor Point, the currents flow eastward into the bay so strongly that they keep the point cut sharply, but there is a bottom current that flows so strongly to the west that it takes out the fishing nets. All of the weather in Little Traverse Bay comes from the west. There are a few days when it will come from the east, but that is most unusual. You will remember that Big Rock Point is located approximately 14 miles west of where this pier is. The plume from Big Rock is held quite close to the shore and moves along at a good rate. When we get a storm such as this was a few weeks ago, it stirs up the bottom, but it also tears up the algal growth that has come in. When I knew the bay as, say, just a swimmer, until ------- E. M. McKee the early sixties, there was no algal growth on the rocks. There was no algal growth on the bottom. Now, when waves come over on the dock, there is so much vegetation,algae that has been torn up that the dock itself is green. You can rake up the piles of algae. Just a few years ago, as I say, about 1962, the waters were clear, such as this. You could see down 50 feet very easily. This summer, only twice have I been able to see the bottom off the Bay View dock. If we had the lights off I think you could see that there, is enough algae contained within the shore waves this summer so that it looks like a vegetable soup. This growth of algae has been noted by people familiar with the area, one of them being — I don't quote everybody that I talked with up there, but I will quote Edison Tanner, who is a real estate salesman up thereo He lives directly on the bay about 2 miles west of here toward Petoskey and toward the nuclear plant. He moved there in 1962. At that time, there was no growth on the bottom. In 1969 — MR. FETTEROLF: Excuse me a moment. Where were these photographs taken? MISS McKEE: Little Traverse Bay. MR. FETTEROLF: Where? ------- 1330 E. M. McKee MISS McKEEs At Bay View, Michigan. The dock I have been showing is the dock at Bay View, Michigan, which incidentally — MR. FETTEROLF: Which is downcurrent from Petoskey? MISS McKEE: That is right. It is east of Petoskey 1 mile. And, incidentally, the dock which is shown on the current U. S. Lake Survey charts went out with a magnificent form in 1927. The current dock at Bay View was built in 1934-1935 and I am not sure if this indicates that — the Lake Survey and Corps of Engineers have not been in there since — but if you try to dock at the old dock, you are going to have to go about 20 feet down. MR. STEIN: May I reiterate that I have at least 37 more speakers listed, and we want to hear every- one. So I ask you and everyone who speaks to recognize time is limited and to give consideration to those people who are waiting to follow you. MISS McKEE: I will try to go as quickly as possible. This summer, I have been gathering information — I have seen the water quality — as I am a geologist, I am not a biologist — but this summer, the University of Michigan ship, Inland Seas, has been based at Harbor Springs. ------- 1831 E. M. McKee They have had a full series of biological tests they have been making off Nine Mile Point, which is a few miles east of the Big Rock plant. Also the Corps of Engineers Lake Survey research vessel Shenahan has been based at Mackinaw City making a 2-week run around the north end of the lake, making water quality studies. They also have a station off Big Rock and possibly Nine Mile, and it is this ship which is coming into Little Traverse to make my own surveys there. I have pinpointed where the very cold bottom waters come in through the bay. It climbs naturally out towards the big lake in a westward flowing current naturally. There are compensatory east-flowing mid-depth and surface currents which take the warmth from Big Rock directly along the shore. Fishermen again. I will quickly go through a lot of these. There was, for the first time that has been recorded,actual scientific work going on in the bay this summer. This, going in with the currents and showing how they follow the bottom topography, ties in with the study of Lake Superior I did last summer. Here again is the bottom topography,, This is ------- 1332 E. M. McKee why six geological provinces were noted. Now, this is taken from a drift bottle study made at Marquette University, and the currents which were indicated here followed the topography, the bottom topography very much indeed, very closely. I won't go into how these things are made, but they are very well documented. We will now come down to the currents in the entire Lake Michigan area. These are the currents without topography. As you will see, there is a division about Milwaukee. These are the bottom currents. These currents have been adopted directly from government reports. We will now put the same current patterns over the bottom topography. It is easy to see how the Mad-Lake high, the 200-foot barrier, influenced the very bottom currents, the mid-depth currents, and even the surface currents. They are all put together here and they all tend to have a general pattern. We have our air pollution, and fading away into the sunset, as any good travelogue does, at the moment. But this is accurate scientific work available in Little Traverse Bay, in other areas. It can be docu- mented — the changes that have occurred since 1963 — whon the Big Rock plant went into operation. Thank you. ------- 1333 E. M. McKee MR. STEIN: Thank you, Miss McKee. MR. CURRIE: May I ask a question, Mr. Chairman? MR. STEIN: Well, I don't know. Mrs. Botts, do you want to handle this? Do you want questions now or after you complete your presentation? MRS. BOTTS: Mr. Stein, I have spoken to Dr. Bardach, and he is willing to let the public officials — you told us were waiting to speak — speak now. He would be glad to do that, and then he would go ahead with his presentation. As to whether Miss McKee answer questions now or later, it makes no difference to us. I will leave that to youo MR. STEIN: We will take the questions from Miss McKee. MR. CURRIE: Miss McKee, have you found any evidence of harm caused by heat inputs in Little Traverse Bay? MISS McKEE: There has been decided erosion of water quality in Little Traverse Bay. The visibility has dropped to nil. Most of the summer — only twice this summer have I been able to see the bottom clearly from the Bay View dock, and it would be only about 12 feet down. ------- 1334 E. M. McKee This has been remarked upon by boaters, by fishermen, by long-time residents. There has been one thing about the distinctive qualities of the Big Rock plant put into a chart, I believe prepared by Open Lands — if I am not in error — that the Big Rock had the coldest waters of the lake. This summer I have kept temperature records of Little Traverse Bay June, July, and August, and from July they have been consistently and even up to nine points higher than the temperatures reported here at Chicago. For the first time, this summer the waters got up to 75. As I say, usually up there if the water hits 6$ it was good swimming. At 70, it felt too warm; and this year, it was over 70 for the entire month of August. Whether this is due to the plume or not, it hasn't been coordinated in with the biological and water quality studies. But there are indications that there has been definite and acceler- ating degradation of the water. MR. CURRIE: I think my problem is, as you recognize, one of causation* There are many areas of the lake in which considerable degradation has occurred, and a number of different paranefcers of water quality have changed, and I wonder if there is any way that we can move along toward identifying which of the changes is responsible ------- 1335 E. M. McKee or which group of changes is responsible for the changes we see. Do you know, for example, that nutrient content of the water is unchanged and the only change has been heat and therefore there is a causal relationship between heat and degradation? MISS McKEE: The input of sewage effluent has been cut. In 196 5» the Bay View summer resort, by order of the government, stopped its own sewage plant and switched into the treatment plant in Petoskey. There have been several other resorts which have done the same thing so that the sewage input has been cut. There has been a comparatively stable population. There are no farms and no, say, kept lawns or parks along the lake that would add to the fertilizer input. The streams are comparatively shallow which go into the lake because of the pitch and slope of the geological formations which are responsible for the bay being where it is. The color of Bear Creek which comes in at Petoskey is a deep brown; that is tannic acid from the cedar swamps, but even that is a very short rate. The only major change that we have been able to recognize since the early sixties in the way of downgrading the water is the heat input. MR» CURRIE: And you say that phosphate and other ------- 1836 E. M. McKee nutrient inputs to the bay have been decreasing. Is it also true that phosphate concentrations in the bay itself have been decreasing? I take it that as long as you keep putting any new nutrients in there is a possibility that concentrations will continue to increase even though the rate of input has decreased. MISS McKEE: That I do not know. I have been working with the geology. I am leaving the water quality up to the Lake Survey people whose job it is. MR. CURRIE: Do you know whether the water quality problems are worse within the plume from the Big Rock plant than elsewhere in the bay? MISS McKEE: Unfortunately you caught me with my plume down! That is part of the work which has to be done when I get back up there. As a matter of fact, I was scheduled to be mapping on Tuesday, instead of coming down here. MR. CURRIE: Does the study that you are under- taking have biologists factored into it? MISS McKEE: I am told it can.tie in with the biological studies done this summer by the University of Michigan, and they had the Inland Seas based at Harbor Springs from May through August. MR0 CURRIE: Thank you very much. I think that ------- E. M. McKee this kind of study which you are undertaking is exactly what we need to help us with this kind of very difficult decision, MISS McKEE: Well, that is one of the big points that we make —that we have to have cross-discipline studies. You can't have it just from the biological, just from the geological, just from industry, just from city point of view, MR. FETTEROLF: Miss McKee, I too have been very fortunate in having had a great deal of experience in Little Traverse Bay. We had a summer home at Wequetonsing prior to World War II, and it was my intrigue with the water at that time that led me to become a biologist. Now, I would like to ask you if you have traced the heat input from the Big Rock plant along the shoreline of Lake Michigan? MISS McKEE: I have taken some temperature readings, but not as complete as it will be after I have had the Shenahan in, which is equipped with electronic equipment of all sorts including the electronic thermo- graph. MR. FETTEROLF: What is the draft of that boat, ma'am? MIG3 McKEE: The Shenahan, I think, is 4 feet. MR. FETTEROLF: I hope you'will be able to get ------- E. M. McKee into shore close enough to measure plume. We have done extensive work in that area both prior to the construction of the plant and after in relation to radiation monitoring, and we have mapped the plume on many occasions. We do not find sensible heat beyond a mile from the plant along the very inshore areas. We do note Cladophora and green algae growing on the rocks occasionally in the area of the plume, but we relate this more to the fact that the plant has an on-site water treatment facility than to the addition of heat. As far as collecting Cladophora for radiation sampling in the area of Big Rock, we find it extremely difficult and we are forced to go to the spits of land on which the gulls perch and fertilize the lake, and that is the only place we find Cladophora. Now, I agree entirely that the clarity of the water in Little Traverse Bay has decreased tremendously over the years0 I believe that we would relate this to the discharge of treated sewage from Petoskey and from Harbor Springso Both of these wastewater treatment plants are under order from the Water Resources Commission to cut their phosphate loadings in accordance with this inter- state conference's decree. MISS McKEE: Good. I know both Petoskey and ------- E. M. McKee Harbor Springs are in the throes of putting in new sewer systems to take care of all of the communities, summer and winter, on both sides of the lake. But this is the type of input where the geologists and the biologists and the physical chemists, physicians, etc. should get together and discuss it. MR. FETTEROLF: I think you would find that long- term temperature records for the bay would be available from the water intakes of the communities around the bay. MISS McKEE: Good. You are the first one who has known that. I have been asking this summer at every com- munity and nobody has known of any records that have been kept. MR. STEIN: Are there any further questions of Miss McKee? Thank you, Miss McKee. I knew you were my kind of biologist-- the kind that would be possibly caught with their plume down! I knew that when I read your bibliog- raphy. Anyone who has written an article entitled, "Are All these Dry Holes Necessary" is great! At this time, we would like to hear from Congressman Mikva, ------- Hon. A. J. Mikva STATEMENT OF THE HONORABLE ABNER J. MIKVA, U. S. HOUSE OF REPRESENTATIVES WASHINGTON, D. C. MR. MIKVA: Mr. Chairman, members of the panel, I would like to strongly urge you to follow the Department of Interior recommendation that "... no significant dis- charge of waste heat into Lake Michigan should be permitted." The great lake is not and should never be considered an industrial dumping ground. If there is any single issue before this four- State enforcement conference, it is not whether industry must pay more or less for stopping its pollution but whether, in the future, the lake itself will be used primarily for the profit and exploitation of industry or whether it will remain a great natural resource of the people. The people who live along its shores will quickly tell you that Lake Michigan is their lake. They swim in it, boat in it, sun bathe on its shores, fish in it, drink its water,, At least they used to be able to do all those things. Its presence has given their residential neighbor- hoods a distinctive quality. If the temperature of the ------- 1341-1843 Hon. A. J0 Mikva lake rises and the death of the lake accelerates and the salmon leave and the lake trout go away and the beaches become clogged with dead alewives and algae and the bacteria count in the drinking water rise, then the quality of life for the people along its shores will change. A Chicago on the bank of a dead lake is a different Chicago, and probably a dead Chicago. Our Government must begin to care about the quality of life of its individual citizens as much as it cares about the prosperity of its corporate giants. This conference is a good place for that caring to begin. Experts have been produced by both sides arguing for or against the damaging effects of heated discharge water on the life of the lake. No definite answers have been found. Commonwealth Edison has argued that heated wastewater will damage plant and marine life but the damage will be minimal. Environmentalists, on the other hand, have argued that heated water discharge from nuclear powerplants will do irreparable injury. Dr. Wesley 0. Pipes, professor of civil engineer- ing and biological sciences at Northwestern University, has informed me that he believes it would be impossible to find any group of scientists qualified to carry out a study of thermal pollution who would also be completely objective ------- Hon. A. J. Mikva about the interpretation of the data due to the present public concern and polarization about water pollution. Last weekend a biologist testifying before the Illinois Pollution Control Board argued that more data on thermal pollution would be needed before "realistic and meaningful limits" could be set on heated water discharges. When expert confusion abounds in such situations involving the public good and the quality of life, then government agencies should err, if err they must, on the side of the people, and place on polluters the burden of proving beyond any doubt that their discharges will cause no injury. Indeed the watchword ought to be: not in the lake unless you can prove beyooa a reasonable doubt that it will not adversely affect the lake. I am not an expert on the technical aspects of thermal pollution. I represent the interests of the people in my congressional district along the shore of Lake Michigan. Last winter a number of my constituents brought to my attention Commonwealth Edison's questionable use of the Pipes and Beer study of thermal discharge from the utility's Waukegan powerplant. I understand that the study is being referred to in the present controversey. The study, conducted by Wesley 0. Pipes and Mr. Lawrence P» Beer, has been labeled by the power company as a preliminary ------- 1345 Hon. A. J. Mikva environmental investigation which proved that the Zion Station discharge would have no detrimental effect on the lake, and I suggest that it proved no such thing. According to Professor Pipes, his study states simply that, "... there is no indication of any deleterious environmental effects due to the Waukegan Station discharge ...." The Waukegan Station, however, is hardly comparable to the Zion Station in both size and power production. In a letter to me, Professor Pipes disagreed with Commonwealth Edison's use of his study and assured me that it "... does not provide scientific assurances that no harm will be done to Lake Michigan by discharge from Zion Station." It was, he added, ",.. an extremely short term study." It is my understanding that the data for the study was gathered on J days in April 1968. The man who supervised the gill net catches for the study, Mr. Bruce Munch, Director, Northeast District, Division of Fisheries, Illinois Department of Conservative, has informed me that he believes that any conclusions drawn from the study's gill net catches would h;..•/? very little ecological significance. I understand from conversations with Mr. Munch that the fi:;h caught in the gill netting were simply attracted to the location by the warm water and ------- Hon. A. J. Mikva that there was no way to determine how long they had been in the heated water or whether it was harmful to them or not. To a layman like myself, Professor Pipes' and Mr. Munchs reservations about the conclusions drawn from the study by the power company make its current use as a backstopping outrageous. I was sorry to learn that Commonwealth Edison is still referring to it to buttress their argument that the Zion Station discharge will, not be harmful. The argument is not true. The formula that we are dealing with here is very simple. If there is any possibility that heated water dis- charge will damage the lake then the discharge of heated water must be restricted. Feasible and economically reasonable alternatives such as cooling ponds and towers exist to do so. Unless these alternatives are used, not only will we accelerate the eutrophication of the lake, but we will open the flood gate for the accelerated industrial and commercial exploitation of the lake as wello A basic policy decision on the use of the lake must be made. Gentlemen, in making that decision, I hope you will keep in mind that in the long run no one will really profit from a dead lake, not even Commonwealth Edison or its power customers. ------- Hon. A. J, Mikva Mr. Chairman, I said I make myself feel as though "I saw this picture before.1 I am sure this discussion about whether the steel companies should dump their wastes into the lake was like the discussion you hear from some of the new mothers at the present time — that just because there is no proof as yet that birth control pills will not do any harm, this is not assurance that they will not do any harm. Maybe at the time that U. S. and some of the steel giants built their plants there wasn't any proof. But we have proof now, and it is to the sorrow of all of the people on the lake that there wasn't some far-sighted public officials at that time who said, "Not in the lake unless you can prove it won't do any harm." Thank you for your time. (Applause) I would be glad to answer any questions but I suspect I will be caught with more down that the previous speaker! But go ahead. MR. STEIN: Are there any questions of Congress- man Mikva? I guess not. You have been very persuasive. MR. MIKVA: I hope so. MR. STEIN: Thank you very much. May we hear from Attorney General William Scott? ------- W. J. Scott STATEMENT OF WILLIAM J. SCOTT, ATTORNEY GENERAL, STATE OF ILLINOIS, SPRINGFIELD, ILLINOIS MR. SCOTT: Mr. Chairman, gentlemen. For the most part of this past week, you have been listening to the hired spokesmen of the polluters, the great corpora- tions, the electric companies, the municipalities and others who are using Lake Michigan as a free sewer. As an attorney general of the State of Illinois, I am here to seek equal time for the people who are the victims of the polluters —the 30 million citizens of the four States that you people represent who are depend- ing on you and have entrusted you with the responsibility of preserving their environment. Now, during the previous days of testimony, we have heard scientists and representatives tell us in effect that they don't know what is going to happen when they pour billions of gallons of heated water into Lake Michigan. They have said, in effect, give us 4 or 5 years of lenient standards so that we can determine what will happen. They have asked you people who are entrusted with preserving Lake Michigan for the millions of unborn ------- 1S49 W. J. Scott generations to give them 4 or 5 years of using Lake Michigan as a test tube. They further said that if some- thing goes wrong they will pay for it. They have said, in effect, that if something goes wrong we will pay for it; go out and buy a new lake. They have said, in effect, that it is scientifically feasible to recirculate. but it is going to cost millions of dollars^. Qf course, they have added to it, on top of it,"We have already gone ahead and located some of our plants in places where it may be physically impossible to build cooling towers or to recirculate. Now, I submit to you that on one side we have private corporations that have been granted a monopoly to sell electricity in a given area. On the other side, we have citizens of your States who have entrusted you with preserving their environment. And the main question before this conference is: Where is the burden of proof going to be? Is the burden of proof going to be on the people that want to use the lake as a free sewer, or is the burden of proof going to be on the citizens that you represent? I submit to you that the answer is fairly obvious —that if we are going to do our job of repre- senting our constituents that we have to insist on the strictest possible standards; that we have to say. wherever ------- IS 50 W. J. Scott scientifically feasible, that we use the high scientific knowledge available to preserve the environment; that we have to say,wherever there is a question of doubt, the doubt has to be resolved in the benefit of the people that are going to depend on Lake Michigan for their drinking supply, for their recreation,and perhaps for their very health and lives. So the real question that you have to determine is: Where does the burden of proof fall? Because nobody can tell you what is going to happen when they start recirculating the lake through dozens and perhaps as many as a hundred atomic reactors. Nobody has been able to tell us that. They refer to examples. Congressman Mikva mentioned the thermal pollution from the plant at Waukegan. I submit to you that last summer the public health official for Lake County, Illinois, where the Waukegan plant is located, ordered the closing of every beach in Lake County. Now, we don't know what the cause of that was. We don't know specifically where the major causes were. But we do know that the pollution came from the municipal sewerage; it came from U. S. Steel; it came from Commonwealth Edison; and it came from Abbott Laboratories. The combined factors resulted in the loss of those beaches to the people of that county. ------- W. J. Scott I think that it is very clear that you people have the responsibility of insisting on the highest standards possible . I am hearily in accord with the Federal report which says that there should not be any significant discharge into Lake Michigan. In fact, I think that wherever it is scientifically feasible, the word "significant discharge " should be interpreted to mean none whatsoever. It is going to cost money; we realise that. But nobody can put a price tag on an aesthetic Lake Michigan. Our tourism, our boating industries, our fishing industries, our recreational industries are all dependent on that Iake0 But more than that, the lives of the 30 million people in the four States that have designated you and that pay your salaries to protect their environment are depending on you to set standards that will do that. I am here to urge you that wherever scientifically feasible, you insist that the water be recirculated rather than just utilized as a free sewer. Thank you. (Applause) MR. STEIN: Thank you. Thank you very much for your presentation. May we go back to Mrs. Botts? MRS. BOTTS: I would like to say that a statement has been mailed to me. The postal service didn't cooperate ------- 1352 Mrs. L. Botts in getting it here in time. I will have to submit it into the record later. Dr. Frank Hooper, a biologist at the University of Michigan, will give you his predictions about the possible effects of heat on the future of Lake Michigan, (The statement of Dr. Frank F. Hooper follows in its entirety.) ------- 1853 Statement of Frank F. Hooper Professor of Fisheries and Zoology Regarding thermal inputs into Lake Michigan My name is Frank F. Hooper; I am a professor in the School of Natural Resources, The University of Michigan. I teach a course in aquatic ecology. My specialty is water quality and lirnclcgy and my graduate students and I have r.ade substantial research contributions in this area. Formerly I was employed by the State of Michigan as an aquatic biologist* In this capacity on several occasions I served as a consultant for the Michigan V/ater Resources Commission regarding pollution problems in the State of Michigan. I have ser\red as an aquatic ecologist for the Atorrdc Energy Commission a&d in this position I have advised tueia on vratcr quality and liinnological matters (additional credential.? are attached). I do not favor further licensing of power plants requiring cooling water on Lake Michigan until the appropriate regulatory agency has set limits for the annual and seasonal thermal inputs into this lake. Such limits must be set with the reasonable ex- pectation that they will protect existing fish stocks and in- vertebrates and that they will preserve existing aesthetic features of this resource. Limits, standards or criteria used in regulating heat as well as any other pollutant must be set on the basis of the concentration ------- 1854 -2- the pollutant ultimately makes in the receiving water and not upon the concentration of the substance or condition (i.e. tempera- ture) in the effluent discharge. Only in this way is it possible for agencies to regulate or protect a resource. There is an abun- dance of evidence in the history of water pollution control on major river systems which substantiates this principle for regulation and administration of water use. In the case of heated effluents entering a largo lake such as Lake Michigan, limits set upon the temperatures in individual plumes should not be used as a control over thermal effects upon biological systems. Since 2 or more adjacent plumes may merge and form an in- shore water mass that retains its identity for considerable periods of time and have serious biological effects, it is essential that limits be set upon total heat input into inshore waters. Inshore water masses heated by the thermal discharges in the spring may have serious biological effects upon fish spawning, re- production of invertebrates and upon the growth rate of plankton. Integration of all of these changes in the system uay ultimately completely alter food chains so that an entirely different community of animals and plants is produced. With large thermal discharges algal blooms in the spring and early summer might be anticipated. Environmental perturbations of this sort bring about decreases in diversity of the flora and fauna ------- 1855 -3- and lead to high densities of a few species and create nuisances as far as recreational uses are concerned. I would envision that during the spring and early summer months many of the recreational facilities along the shoreline would be jeopardized by the inputs from a number of nuclear installations or other sources of hot water. Thermal limits should be established for specific sections of Lake Michigan since the shoreline varies widely in its biological characteristics and upon its capacity for production o"~ various species of plants and invertebrates. Standards set in this manner would then allow thermal inputs up to a prescribed maximum at which time further cooling water discharges must be brought to ambient lake temperature. Regulated in this way, it should be possible to avoid adverse ecological changes. With relatively little effort and using only existing data it should be possible to arrive at useful estimates of thermal liwits which should be set for various sections of Lake Michigan shoreline. Although all of the desirable data are not at hand (and may never be) given the best available expertise the regulatory agency can at the present time arrive at safe and conservative approximations for ther- mal loading. Such limits or standards must be subject to revision as additional data are provided. However, at this stage it is im- portant that resource standards be established since such action will ------- 1856 -4- clearly define the principle upon which future decisions can be expected. The map of projected or proposed nuclear power plants generat- ing on Lake Michigan shoreline is exceedingly impressive. The anticipated power needs for Michigan and adjacent states can only lead one to believe that many major installations will be constructed in the future. Thus it is essential to establish appropriate regu- latory criteria at this time. ------- 13^37 Frank F. Hooper, Professor of Fisheries and Zoology. University of California, 1939. A.B. University of Minnesota, 1948. Ph.D. University of Chicago, 1942-43 (meteorology). Oak Ridge Institute of Nuclear Studies, 1957. Teaching Assistant Zoology, University of Minnesota, 1940-42, 1946-48. Air Force Weather Officer, Alaska, 1942-46. Instructor, University of Michigan, 1948-52. Biologist, Institute for Fisheries Research, 1952-1962; 1964-65. Aquatic Ecologist, Division of Biology § Medicine, U.S. Atomic Energy Commission, 1962-63, 1966. Biologist in Charge, Institute for Fisheries Research, 1965-66. Professor of Fisheries, School of Natural Resources and Professor of Zoology, College of Literature, Science and the Arts, 1966- Present. Treasurer of American Microscopical Society, 1953-56. Executive Committee, American Society of Limnology § Oceanography, 1957-1960. President, American "Society of Limnology and Oceanography, 1966. Associate Editor of Journal of Wildlife Management, 1959-1961, Associate Editor of Transactions of the American Fisheries Society, 1964-1968. Associate Editor of Ecology, 1970-present. ------- 1358 September 24, 1069 Publications by Frank F. H Hooper, Frank F. 1947. Plankton collections fzoa the Yukon and Mackenzie River systeas. Trans. Ar,er. Hicr. Soc., LXVX(l): 74-84. _ ___ 1948. Th3 effect ox debris root (z-otenone) upon plankton and bottom fauns organisms of a small Minnesota lake. Proc. Minnascta Acad. Sci., 16: 29-32. ___ 1949. Age analysis of a population o£ the gsaeiurid fish Sshi lbegjgs^_ so 1 lis_ (Herasia). Copsia, April 15(1): 34-3S. 1951. Litaaologieal features of a Minnesota seepage lake. The AffiSTiesn MidXassd Naturalist, 46(2): 462-481. _ 1952. Ravie;-,'. Lisnolegy by Paul S. Kolch, second edition. McGra* Hill Book Co.. New York, 538 p., SO tigs. Ccpeia. 4: 285. _ 1DS3. Revise. Fisjidsg-sp.taSs of Linaolcgy by Frans Ruttner, edition,) 19S2;" English translation by D.G. Fycy and F.E.J. ' Fry. Univ. cf 'TGi-sato Pirsss, Toi.-oaso, 19SS: XI * 242 p., 51 figs., Copsis., No. S: 195-196. ________ r __ ____, Robsz.^ C. Ball. sii-J Hcwasd A. Tanner. 1S53. An ~" iw the artificial ci3?£ul£.tioa of a small Michigan lalie, Trsas. Asaar. Fish. Soc., 82(1952): 222-241. ^^^.^ _____ » sj?.d AJ.fired i>S. Elliott. 1&53. Rsisase of inorganic phosphorus flrova extracts of laJ;s jsad by protosos. Trans. Aassy. ^"ic^. Soc., LXXIS(S): 276-281. ____ 1954. Liirnolsgical features of Weber Lal;es Chsbcy^an Ctnisty, Michigan . Psp. Mich. Acad. Sci.s XXXIX (1953): 223-240. Lagisr, Karl F., and Fra?& F. Koc-p&r. 1SS4. Fish production In inland waters. Univ. of Michigan E;:ten?.ion Service., Teieccarss Syllabus, srit ,1S Fis'n an.d Fishing is Recv^sticn £ad Cc^sssree } 6 p. Hccpsi4 P.P., K:d A. Be Ccck, Jr. 19£50 Chsr.fic-rl control of subniorgad water weeds with scrlito ivi'ssnite. Midi. Dapt. Cons., Fish Div. Penphlet No. 16, M&i-ch, 6 p. Hoops? , F.F. 1SSS. Eradication o£ fish by ehssiieal treatssnt. Mich. Dspt. Ccns., Fish Div. Per^hlet Ho. 19, Decsn-bc-T, 6 p. Koopar, Frsjik F. 1356. SDKS cho^lca.1 and r.o:-.phopot2'3.c charactsristics of scitthsra Miehigar. IE!;SS. Pap,, Mich'. Acad. S^i., XLi'(19SS): 109-130. /jidsi'son, Richs.i'd 0., ar.tl Fran'c ?e Hac-por. 19S6. Saasonal abv-v^dajics and production of Httical bott<::3 fir^ia in a scathorn Michigm lake. Trnns. Asis?. Mic~. Soc.s LXXXV(3>: 2SD-2TO. ------- 1859 Ball, R.C., and F.F. liocpe?. 19S6. Edited translation by Michael Ovchyanyk of "Byiisiriies of the total benthie bicsass in ths p?cfundsl of Lake Bsloie" by E,V. Borutsky, Proc. Kossiao Linrso- logical Station of the KydroMSteoyalcgical Service of U.S.S.R. 22(1939): 1S6-213. Repre&jcs-d by Mich. Dopt, Cons., 26 p. plus illustrations. Hocpsr, Frank F. 1357. Vegetation control problems in wildlife habitats- fish. Proc. 13th North Centi'sl Wse-d Control Conference: 24-25. Hoopa?, F.F., end A.3. Ccck, Jr. IS57. Chasici-l ccnti'ol of sub«-3rged w&tey ws&ds with scdiua c?s&nit:@. Mich. Dipt. Cons., Fish Div. Psnphlet Ho. 16 (Revision of 1935 publicytic3i)9 July,, 6 p., 1 fig. , Frcssk F., aid Alfred R. Gssssda. 1337. The use of Toxsphcri* as £ fish poisoa. H'ans. tass.% Fish. Soc., -S5(195S): 1CG-190. ?, F.F. 1958. Eradication of algss v/ith ch'Smcals. Mich. Dept. Corss., Fish Div. Paaphlet No. 25 s Fobruniy, 5 p., 1 fig. Kospsrp Fs-ssi!< F. 1SS8. Review. Giaids to fisliss of K&w K by Willis® J. Koster. Asasv. Inst. Biol. Sci. Bull. 8:29. Bsatty, Lse D, „ and Fran!? F.^Moopsi-. 1958. Bsnthie associatic^s of Sugar loaf Laks, Pap. Mich. Asai. Sci., .XLIII: 89-106, , K.G., snd Frank F. Hoops?. 195S. Tosr-phsse (Chlorinated Csoplieaa) as a saSective fish poises. Prog. Fish-Cult. , 20: - ISO. sr, Frenk F. 1959. Review. A treatise of (en) liruioSogy, by G. Evelyn Kutchinson.- J. Wildl. Mgrat., 2S: 1958. Popalatioa ccatrol by chemicals snd seis i'e^iiltir. p^oblstns. Tysins. 2nd Saieinar on Bioltgici^.i Frcbloas i>3 i'/at&r Poliuticn, U.S, Public Sfeelth Son'., R&by^t A. Teft. Scsiitc-^-y Enginesring Cesi 1959. Use of the nowoy organic insectici ------- I860 Knight, Mlsn, Robert C. Ball, r.rsd Frrtnk ?. Hooper. 1952. Scss eat ira^es of wis-asy production vatc-s in Michigan ponds. Midi. Acad. Sci., XLVII(19S1): 2J9-233. Schalske, C7.ai5.-e L. , Frcnk F. Koopsr, and E.J. flaercl. 19-52. R3St3oas3s c£ f- snsri lake to chslatec* is.£ili- yit^ri Tr-^-Af &«-• n-s^'ri Cf-f ^t'iffi- t •«»'?,? 7% £,^ltAOj». ii-'-^i^^'a ------- 1861 -4- Sohacki, Leonard P., Robert C. Ball and Frank F. Hooper. 1969. Some ecological changes in ponds from sodium arsenite and copper sulfate. Michigan Academician (Papers of the Michigan Academy of Science Arts and Letters), 1:149-162. Bahr, Thomas G., Robert C. Ball and Frank F. Hooper. 1969. Arsenic 74 Metabolism in an aquatic ecosystem. Michigan Academician (Papers of the Michigan Academy of Science Arts and Letters), 1:163-174. Hooper, F. F. 1969. Eutrophication Indices and their relation to other Indices of Ecosystem change . In Eutrophication: Causes, consequences and corrections. Proceedings of a Symposium, Nat. Acad. of Sciences, Washington 1969. ------- 1862 J0 E. Bardach MRS. BOTTS: At this time, I would like to introduce Dr. John Bardach who, as I mentioned before, is a distinguished aquatic ecologist, who has consented to appear as a consultant to the public. Dr. Bardach. STATEMENT OF JOHN E. BARDACH, PROFESSOR OF NATURAL RESOURCES, UNIVERSITY OF MICHIGAN, ANN ARBOR, MICHIGAN DR. BARDACH: Mr. Stein, conferees, ladies and gentlemen. I am John Bardach, and I am a professor of natural resources at a reasonably well known educational institution. My credentials are attached to the statement which the conferees have in their hands. I would like to add that I came here paying for my part of the jet emissions that are added to the skies over Lake Michigan and that I am extremely concerned from a long-range point of view over what is happening. (See Pp, 1737i-17?7o) I would like to preface my remarks by saying that on my flight today I paid for insurance for a rather unlikely contingency, namely that my airplane would drop down. We are concerned here with what insurance we should ------- 1363 J. E. Bardach pay for another contingency, a contingency that in my scientific opinion is far more likely to occur, namely the galloping eutrophication of Lake Michigan if heat is permitted to be discharged in an unabated fashion as is now planned over the next 20 or 30 years or so. I think the key word here is "eutrophication," because from it follow all other consequences. It has been though not completely but reasonably well established that during crucial periods of the year — that is in the spring and in the fall — the shore waters of Lake Michigan form a rather discrete entity. Now, why are those crucial periods? The spring is a crucial period because in it unfold the succession of algal species. If the heat regime is altered upwards, we will have undesirable algae early and we will have different successions of algae, as has been demonstrated in some cases in smaller lakes and as is apparent now even in some shore regions of Lake Michigan. Let me add that it is not a question of heat being the main or the only culprit. We all know this. It is a complex situation in which effluents may hold the limiting factors for eutrophication, but in which heat unquestionably — if these factors are present — speeds the biological processes. ------- 136. J. E. Bardach The other crucial period is in the fall where there is an equally discrete segregation of water in the shore regions. In the fall, a rather unique set of fishes, the whitefishes, come to spawn, and they come to spawn in the shore areas. They spawn only if the water temperature goes down at a certain rate. We do not know what this rate is, but we do know that the water temperature has to become lowered at a certain rate and reach a certain lower tempera- ture for these fishes to spawn at all. Now, it is quite possible that regionally or for that matter locally these conditions will be so altered that the spawning of whitefishes will be inhibited. Recently we have introduced salmon into Lake Michigan. They are doing very well. It is possible regionally, again, locally that the temperature changes, if permitted to occur in an unabated fashion, will affect some of the biological characteristics of the salmon. I will give you an example. The conversion efficiency, that is the efficiency with which the salmon converts food into its flesh, declines from 32 to 22 percent as the temperature goes up from 56 to 6? degrees Fahrenheit. There are many other such influences that are temperature- conditioned or temperature-influenced. I am not telling you anything new if I say that there are very many of them we do not know. ------- 1365 J. E. Bardach I was in Switzerland this spring, where I grew up, and in the last 30 years a very beautiful lake, Lake Zurich, in which I used to swim as a boy, has undergone irreversible changes. It is now a rather nasty soup. When I talked to some of my friends in Switzerland they said, "What are you going to do with your Great Lakes? We understand that some changes have already occurred." — And I think that the Stoermer-Yang diatom studies indicate this. — "Are you going to stop what we didn't stop?" I said, "I don't know. I hope we will." Let me stress: The effects of eutrophication, including the partial effects of heat, are cumulative and not lineal. They start slowly, accelerate, and accelerate very fast once they have started to do so. In fact, a before-and-after study done at a plant site several years after the plant has started putting heat into the lake may tell you nothing or so little that you can't make any predictions from it. Natural variations may mask these effects, but it is not difficult to assess that the contribution to the heat load of the lake from a large number of plants in the southern end would have a cumulative effect that works in a synergistic fashion with the enrich- ment. There is nothing naturally good or bad about either a trout, a salmon or a whitefish as opposed to a perch, ------- 1366 J. E. Bardach carp, sucker, or alewife lake. These are sociocultural values but I think that we have stated them. Lake Michigan is a unique environment. There isn't another one in the world. And we said that we would rather have a lake trout, whitefish, and salmon lake. If we do not want to wake up — not "we," but perhaps your children and some of the young people in the audience — if we do not want to wake up in the year 2020 reading in the newspaper that there was a severe carp die-off in the shore waters of southern Lake Michigan because of nocturnal oxygen depletion, if we are to keep a unique natural environ- ment as little changed as possible, we must as a society, as one of the many things we do, take measures to hold to an absolute minimum the heat discharges to the shore waters of Lake Michigan. Whatever the technical means by which we do this, these are open to discussion, but there is no question about the fact that unabated discharge of heat into Lake Michigan will have the effects predicated on analogies by many biologists. In fact, even if we do abate heat discharges, we may not have much of a chance. It may already be too late. Eutrophication is like a disease. It has an incubation period. It starts rather slowly and then it becomes ------- IB67 J. E. Bardach galloping. But if we don't try now to do something about this one factor which we are here to consider and discuss, we do throw away much of our chance to keep Lake Michigan as it is now or perhaps even improved. Thank you, (Applause) MR. STEIN: Thank you, Dr. Bardach. Are there any questions? MR. CURRIE: les, Mr. Chairman. MR, STEIN: Yes. MR. CURRIE: Did I gather, Dr. Bardach, that one of the things you said was that whatever adverse effects heat discharges may have on the biology of Lake Michigan are likely not to be reversible? We had statements from several industry witnesses the other day that if there were chances in the biology of Lake Michigan due to heat discharges they were likely to be reversible. I take it you disagree, DR. BARDACH: No, I didn't say any such thing. I did not say they were irreversible. They are? in fact, reversible or very likely to be so. But what is the ti.ie frame? We are now in 1970. By 2000, I understand, the heat load should be from various sources and not only the power companies, about 10 times what it is now. At the same time it seems doubtful to me that by then we will have cleaned up all our effluents. ------- 1363 J. E. Bardach The changes of exit ro phi cat ion are reversible, but I think Lake Michigan is a case where these changes are likely to go slowly because of the sinking effects of the lake. MR. CURRIE: And this is true of whatever part of eutrophication is caused by heat as well as whatever part of it is caused by too much nutrient, in your opinion? MR. BARDACH: I would think so. MR. STEIN: I think this is a very important point and I want to see if I understand it. If I understand what you are saying, you are saying that perhaps the total effect of eutrophication can be reversible in a very long-range time frame. I think that is what we know generally about eutrophication. But I think what Mr. Currie was referring to is that, even in the short range, if we had heat in the lake and that proved to be harmful, this is just transitory. By removing that heat, the effect of that heat would be dissipated maybe in a season or two, and we wouldn't have to wait for this long-time recovery in order to reverse eutrophication. We know how long that is, having tried to reverse eutrophication in other bodies of water. DR. BARDACH: Well, these are hypothetical situations, Mr. Stein. Let us assume that we go along as ------- 1369 J. E. Bardach we are going now, and in 19#5 we say, "Okay, enough. Tomorrow no more heat into Lake Michigan." Are you asking me how fast the reversal of eutrophication would be? MR. STEIN: What I am saying — I am trying to split this into two questions. I believe I have read enough of the literature, been in enough conferences, par- ticipated in enough meetings and discussions to know how difficult it is to reverse eutrophication. I think that the point that Mr. Currie raised is a closer one here. That is, if we stop heat say by 1975 if there proves to be damage, by stopping that heat we will not have accelerated eutrophication on our hands because of that heat. We will not have to wait for that slow process of reversal if it ever is to come. But once we stop the heat, the effects of that heat or any damage it may have caused will immediately disappear. The heat wouldn't have caused any damage at all, except in the sense that it is going to have a transitory impact on the lake. DR. BARDACH: Well, I am going to make a guess. That is all I can do. It would still take a number of years. I don't know how many. But if you could pinpoint the effects; if you could abstract the effects of heat and take the effects of heat singly, and nobody can do this ------- 1870 J. E, Bardach now — it would still take a number of years — and I don 't know how many — before the aftermath of these effects or the conditions to which these effects have given rise would disappear. MR. STEIN: Thank you. Are there any other comments? MR. FETTEROLF: Dr. Bardaeh, I think you are basing your premise on if a large segment of the shore waters of Lake Michigan were warm. Now, if you had a plume from a single plant and for some 3 or k miles down shore from there you had increases in algal growth possibly due to added heat, and then you ceased that input of heat, would the reversal then take several years or a short time? DR. BARDACH: It would take a shorter time; probably not several years. But — well, let me day again: My concern is for the year 2000 and the year 2050. MR. STEIN: Are there any other comments or ques- tions? MR. CURRIE: Yes, Mr. Chairman. MR. STEIN: Yes, Mr. Currie. MR. CURRIE: I think I might be helped a little along this road, Dr. Bardach, if you could give us a more precise indication of the way in which heat increases ------- 1371 J, E. Bardach eutrophication. We have heard from several people on this subject, and I have been trying to get it straight and I am not sure I have it. I think we have been told so far that heat inputs will not increase the total mass of algae present at any given time in the lake. Would that square with your opinion? DR. BARDACH: Well, again, you see, you are trying to divide something that is hard to divide. But let me say this: Assuming that you have all signs of algal growth early during the year because of changed heat characteristics of the inshore waters, you would have for that particular alga a longer time to multiply than you would otherwise have. So you would, at this point, increase the total amount of algae that are present as opposed to the amount of algae that would have been present had no heat been discharged. MR. CURRIE: Yes, I think that is an important point, and that helps me a good deal. Is that change one that would be irreversible? I would think that the next year, if the temperature of the lake were reduced, that then you would not duplicate that condition, is that right? DR. BARDACH: Locally — well, if you talk now about one plant and you stopped completely heat discharge ------- J. E. Bardach from that plant, the next year you would, of course, not duplicate that condition, but that does not mean that in that particular year you would have no algae at all. MR. CURRIE: Dr. Bardach, have you conducted studies on the effect of heat on eutrophication in Lake Michigan or in comparable waters? DR. BARDACH: I have not conducted studies on heat effects on eutrophication in Lake Michigan, but I have done some studies on comparable waters. The unfortunate thing is that there are no comparable waters, and there are no even slightly comparable waters on which such studies have been conducted. All such studies have been conducted on smaller bodies of water. The only analogy we have — and there again they are unfortunately rather incomplete cause-and-effect — for what they are worth — data on Lake Erie and Lake Ontario, And Lake Erie and Lake Ontario have deteriorated. In Lake Erie, the change in average lake tempera- tures since — I think it was — around the 1920's by only 2 degrees Fahrenheit is suspected — you see, you are sort of extrapolating backwards — is suspected to have caused the demise of the lake herring and related fishes which were living at that time at the extreme range of their temperature tolerance, and that this gradual warming has ------- J. E. Bardach been tantamount to displacing Lake Erie 50 miles to the South. Unfortunately the studies of heat effects on eutrophication and the studies specifically of heat on fishes and other aquatic organisms are relatively scarce. There are some — for instance, I would like to know — the statement has been made that young fishes of this peculiar and specific species complex that we have in Lake Michigan may be particularly vulnerable during the early part of their lives to heat loading. Now, there are lots of things we don't know about them. For instance, we don't know whether all of them or only some of them have to come to the surface to gulp air to fill their swim lungs„ If we knew this we might be able to make a somewhat better prediction, given hypothetical situations, of surface temperatures. Let me add one other thing: I am not concerned about fish kills as such. Well, no, it would be wrong to say I am not concerned; of course, I am. But I am not as concerned about the 5»000 fishes that die because some powerplant shut off its effluents and the fishes were sub- jected to a cold shock, say, or the reverse. I am much more concerned about the very slow and gradual effects. I have done or my students and I have done some studies ------- 1374 J. E. Bardach on the effects of raising the temperature in the fishes' environment close to its lethal temperature. We have looked at what does this do to the animal's behavior? We have studied the most heat-tolerant fishes — fishes that one day may abound in Lake Michigan, And we have found that as you get past the comfort zone of these fishes, their behavior becomes quite different; they become very much more aggressive to one another; they cover much larger distances in search for food and comfort. They may, in fact, be very much disturbed in their reproductive behavior. Now, that is something that will have effects that go over 4, 5, 6, 7 years or longer, and eventually their numbers in the lake or a body of water are reduced, None died, or nobody died earlier than they should have. But he or she was adversely influenced. MR, STEIN: Are there any other questions from the panel or — Mr. Petersen. MR. PETERSEN: Thank you, Mr. Chairman. Dr. Bardach, as I understand what you have said, you are concerned principally with the effects of heat over the long range. Dr0 Bardach, would that be properly interpreted to mean that it would not appear that the effects of any ------- 1375 Jo E. Bardach one plant would be noticed in Lake Michigan? DR. BARDACH: In answering this, let me say that I have great sympathy with the power industry in one respect: They have been subjected to a lack of guidelines from public quarters, quite understandably so. Now, one plant may or may not have a local effect. That is all I can say. MR. PETERSEN: You wouldn't expect one plant to have by itself an effect on all of Lake Michigan in the manner in which you have described,in what you have had to say today? DR. BARDACH: I think it only fair to say no. MR. PETERSEN: Do you theorize that the presently existing plants are having that effect? DR. BARDACH: They unquestionably contribute to eutrophication; to what degree, I am not prepared to say0 Let me be quite frank with you. It may be that this effect is so small that it is very hard, if not impossible, to detect. MR. PETERSEN: In this regard, you are relying, as I understand, on the idea of a separate and unmixing body of — what was it? — shore waters? DR. BARDACH: Yes. MR. PETERSEN: What do you mean by shore water? ------- 1376 J. E. Bardach DR, BARDACH: I mean water to a depth of about 10 meters, which during certain parts of the year, as set forth in several publications — one of them "The Lake Currents in the Lake Michigan Basin," by the Federal Water Pollution Control Administration Great Lakes Region, November 196?, and again in this publication, "Physical and Ecological Effects of Waste Heat," as pointed out there, because of specific thermal effects on the water, there is a thermal barrier that prevents the mixing during certain parts of the year. I am not sure to what extent the duration of these separations has really been determined accurately. But let it suffice to say that they are part of the year, and I think they are not part of the year, the spring and the fall, where these thermal barriers exist, that would separate out about 10 percent of the lake water from the rest of the lake. MR. PETERSEN: Does this thermal barrier keep the mixing of the lake totally or is it merely a partial bar to mixing? DR. BARDACH: During the time it exists? MR. PETERSEN: I presume — you said it is not a continuous phenomenon. DR. BARDACH: No, when the bar is removed, there is mixing with — well, in the summer, there is mixing ------- J. E. Bardach with the epilimnion, and if the bar does not exist, during turnover times, then there is mixing in the entire lake. MR. PETERSEN: My question was: Does the bar prevent mixing between the inshore and the offshore part of the lake totally or is it only a partial bar to mixing during the time that it exists? DR. BARDACH: From what I know about the matter, it does prevent effective mixing. MR. PETERSEN: Now, doctor, have you performed any studies in relation to the thermal bar in Lake Michigan? DR. BARDACH: I said from what I know. MR. PETERSEN: Are you familiar with the study which Dr. Pritchard described when he was here, wherein he noted not less nr^ing but greater mixing over the thermal bar were difficult studies? DR. BARDACH: I wasn't here when Dr. Pritchard presented his testimony. MR. PETERSEN: You were not aware of that? DR. BARDACH: I was not aware of that. MR. PETERSEN: Could that in any way have any change ? DR. BARDACH: Yes, certainly,, If this were found, if this were ascertained, certainly,, MR. PETERSEN: As I understand it, you have done ------- J. E. Bardach no studies within any existing thermal plumes. DR. BARDACH: I have done tank studies with thermal plumes, again on the behavior of fishes. MR. PETERSEN: What kind of studies? DR. BARDACH: Tank. MR. PETERSEN; Ah! But not within — DR. BARDACH: No, I have not studied thermal plumes within Lake Michigan. MR. PETERSEN: All right. You have no reason to believe that fish will swim into the thermal plumes and remain there to the point that they are killed or hurt? DR. BARDACH: Sometimes yes; sometimes no. MR» PETERSEN: Sometimes you believe they will swim in and be killed? DR. BARDACH: Sometimes I believe they may well be, if not killed, so affected that they do not recover or are susceptible to other either disease or environmental factors that may befall them after they have had either a heat or cold shock. MR. PETERSEN: Ah! From shock, you are speaking? DR. BARDACH: Yes. Well, I think you have to separate. There are unquestionably instances where it may happen that the fish are actually killed, not immediately but within — you see, a fish doesn't die like this — ------- J. E. Bardach (Dr. Bardach snapped his fingers) — it is affected and it may be a few hours later that it gives up the ghost. But in other cases it may get a heat or a cold shock and may die even 2 or 3 weeks later, and it is very difficult to say that this was it. Certainly in the lake I can only make this study under highly controlled condi- tions. MRo PETERSEN: It is my understanding that you reached this present theory at least 2 months ago. DR. BARDACH: Which present theory? MR. PETERSEN: The present theory which you have. DR. BARDACH: I have many theories. MR. PETERSEN: The theory of damage to Lake Michigan from thermal effects that you have enumerated to this audience today,, DR0 BARDACH: No, I wouldn't say this, Mr. Petersen. I wouldn't say this. I have been concerned about the effects of eutrophication on Lake Michigan for quite awhile. When I helped Consumers Power Company to design the before-and-after study for their Palisades plant, I stated in the document that I presented to Consumers Power Company that I am very concerned with possible eutro- phication effects — synergistic eutrophication effects of effluents and heat. ------- J. E. Bardach MR, PETERSEN: In this regard, doctor, has Consumers Power Company asked you for the scientific basis of your conclusions? DR, BARDACH: Consumers Power Company has, at this time, accepted my suggestions to conduct a study. Consumers Power is to be congratulated for having initiated and being in the process of conducting this study,, Later — that was several years ago — as I have continued this, I have become more concerned, and my concern has reached somewhat greater proportions than it had when I designed or helped to design this study for Consumers Power Company. Consumers Power has asked me, at this point, to be good enough and tell them what kind of study they should conduct — well, how can I put it? — to foretell with as much confidence as possible the effects of the Palisades plant. I am in the process of thinking about how this might be done. MR. PETERSEN: And has the fact that you have performed work for Consumers Power Company prevented you from speaking your mind today or any other day in Indiana or elsewhere? DR. BARDACH: It has not. MR. PETERSEN: Thank you, Dr. Bardach. MR. STEIN: Any other comments or questions? ------- J. E. Bardach Dr. Bardach, will you wait? MR. HIPKE: My name is Jack Hipke, Wisconsin Power and Light Company. First question: You say that eutrophication is discrete in the spring and fall in small lakes. V/here does this heat come from? DR. BARDACH: Eutrophication can occur without additional heat sources, and does occur without additional heat sources, and I have never slid that the heat that will be put into Lake Michigan causes eutrophication. MR. HIPKE: Okay. Question number two: Are the fish that you have mentioned in your study in the conversion of food able to make a choice in temperature? DR. BARDACH: Are they able to make a choice in temperature in the experimental situation? MR. HIPKE: Correct. DR. BARDACH: No, they are not, because such a study would be impossible to perform. MR. HIPKE: Isn't it possible, then, that fish in actual surroundings could make a temperature choice and thereTors there won't be a depletion in the weight of the "ish due to the conversion of food? DR. BARDACH: It is certainly possible. But let us assume that the salmon has no particular desire to ------- 1832 J. E. Bardach go to some particular place. If he does so, and if, in fact, it could consciously ascertain that his conversion is adversely affected, it is likely that he would choose, but the fish doesn't know whether he is in — what his conversion efficiency is. MR. HIPKE: Question number three: You mentioned oxygen depletion in the year 2020, I believe. DR. BARDACH: Yes. MR. HIPKE: Was this in reference to the area of the plume? DR. BARDACH: No, it had no particular reference. This was a very hypothetical situation, in reference to almost anyplace in southern Lake Michigan. And let me add: It may well be that you have this contingency even if you have no waste heat. MR. HIPKE: Okay. Thank you, doctor. MR. STEIN: Are there any other comments or questions? MR. COMEY: I am David D. Comey, representing Campaign Against Environmental Violence. Dr. Bardach, you mentioned that certain fish have to go up to the surface in order to fill their air bladders very early in their Iife0 Could you describe a little bit more what that mechanism is and what it would ------- J. E. Bardach moan if on further knowledge it turns out that many species have to accomplish this function? DR. BARDACH: Yes. Fish use their air bladders or gas bladders to assume weight or density equal to that of the water. That makes it easier for them to remain at a particular depth level. They have to expend less muscular energy to do so0 There are essentially two kinds of fishes: Fishes that have a duct to the esophagus from their gas bladders, and those fishes that have not. In either case, much of the exchange of gas in the swim bladder — that takes place through special tissues that secrete gases from the blood. But to begin with, when the fish first hatches, very many species, in order to stimulate that tissue to perform, hsve to take one small gulp of air, and that small gulp of air, of course, has to be taken at the sur- face. Now, there are, again, hypothetical situationso Let us assume that a small hatch of these fishes came to the surface. They are small fishes, not very well able to move and swim along, and they are carried by surface currents into ex n area of very much higher temperature — say 5 or 6 degrees higher than the one in which they were immediately before. As they cannot navigate very well at that stage, ------- 1334 J, E. Bardach they might be trapped there, and thus either die or be so affected that they don't survive the next few weeks. It is indeed likely that those places are rather small, if they exist at all. But if I look at the perimeter of southern Lake Michigan and the powerplants that are planned there or may undergo modification to make them somewhat larger, I think that these areas may become somewhat more extensive and may depress the survival success of these species. We do not know to what extent, but the possi- bility certainly exists. MR. COMEY: Mr. Petersen, counsel for Consumers Power Company, asked you a question about a study concern- ing some dye-testing currents. Are you familiar with another study done by Gabriel Csanady at the University of Waterloo several years ago indicating that dyes run through the condenser of a nuclear powerplant on Lake Huron tended to hug the shore for many miles and not disperse? Are you familiar with that study? DR. BARDACH: No, I am not. MR. COMEY: Well, let me go to another question then0 You are familiar with the food chains of salmonids in Lake Michigan and other cold water lakes? DR. BARDACH: Yes. MR. COMEY: Would you say that benthic organisms ------- J. E. Bardach that would be entrained at a condenser intake located approximately 3»000 to 4»000 feet from shore would survive a 100 percent Delta T in the condenser of 25 to 28 to 30 degrees Fahrenheit? DR. BARDACH: I doubt it. MR. COMEY: Do you think Mysis Relicta, for example, would survive such a thermal shock? DR. BARDACH: Mysis Relicta happens to be a very cold-loving crustaceon, and I am not aware of any tempera- ture tolerance or thermal shock studies that have been done on Mysis Relicta. It would be my guess that they would be very seriously affected. MR. COMEY: Is the zone in which most of these intake pipes are located which are out there in order to get at least 25 feet or 35 feet of depth for the Corps of Engineering navigational purposes — are they located in a zone of high biological production from benthic organisms and other elements in the fish food chain? Is that a zone of greater productivity than the immediate inshore zone? DR0 BARDACH: By and large, yes. But I think you would have to really look at each particular plant intake before you could make any general pronouncements. MR. COMEY: One last question and that is: Are fish attracted to a warm—water discharge? ------- 1386 J. E. Bardach DR. BARDACH: Oh, yes. MR. COMEY: Do they have a tendency to prefer water that is, say, just a few degrees below the level at which they tend to exhibit the characteristics that you have earlier described? In other words, are they like butterflies in the sense that they go towards light when perhaps if they knew better they shouldn't? DR. BARDACH: Well, some fishes do. I would suspect that some of the fishes we are most concerned with might not. Some studies have been done at Lake Me'.ndota where there is a very, very strong discharge of heated water, and bluegills, carp, yellow bass, apparently were attracted to the outflow, and they were attracted to the outflow in part because in the outflow zone there happened to be more food at certain times of the year. Let me say here that I am convinced — and I said so in a number of statements that I have made — that there are beneficial effects on fishes. You have got to make your choice. What is it you want to fish for? Let me please add one more thing. There is a possibility in heat abatement to turn heat into a rather beneficial contingency„ It would be possible, ladies and gentlemen, with 100 cubic feet per second of equithermal waters — that is water that has the year-round a temperature ------- 1887 J. E. Bardach about 1? to 1$ degrees centigrade — to raise in an intensive fashion a million pound of trout. So there are possibilities here. MR. COMEY: Do you know of any present powerplant that plans to use that — DR. BARDACH: I do know of several powerplants that use heat, One is the Long Island Heat and Power, which uses it for oyster-growing. J> nd there are several powerplants — many in Russia — that do this. Experiments have been conducted with growing fish in heated effluents in Hindustan, in Scotland, where it was possible to speed the rate of growth of perch and sole to maturation and legal size to 1 year as opposed to 3 years in the Irish Sea. MR. COMEY: Yes, I believe the New York Depart- ment of Conservation plans such a fish hatchery at the Bell Station on Lake Cayuga, but the Bell Station did not materialize. DR. BARDACH: Well, there is a problem here, Mr. Comey, and that is that the amounts of heated water are so great that only a part of it could adequately be accommodated in an economically sound enterprise. MR. COMEY: Thank you very much. MR. THOKE: My name is H. Thoke. I am a representative of the State of Wisconsin Southeast Chapter ------- J. Eo Bardach of Trout Unlimited. This question is related to a question from the representative from Wisconsin Electric Power Company regarding choice of the fish going to a warmer or a colder area of a plume. What effect would a heated plume have on the migrating instinct of the trout and salmon that are presently in the lake? Would it deter them for accomplish- ing the migrating instinct to go up the stream to spawn? DR. BARDACH: You are asking me a very difficult question. Under certain conditions, it is possible that it might. It depends at what stage of their migration they encounter this heated water. MR. THOKE: Obviously the thing I am trying to point out here is that there is another approach to, I think, the direction the question was directed, and I will just leave it there. DR, BARDACH: Yes. Well, I think that one thing, gentlemen, if you may permit me to say so — one thing that these questions brought out is that there is a heck of a lot we don't know. MR0 STEIN: Go ahead. MR. PETERSEN: 0. K. Petersen again. You were asked a question about benthic organisms entrained in water coming through a plant. Do you envision ------- J. E. Bardach many benthic organisms being entrained in water moving at one-half of a foot per second? DR. BARDACH: I couldn't answer that question, Mr. Petersen. Mo PETERSEN: Would you expect benthic organisms so entrained and if hurt, damaged, or killed, to signifi- cantly affect the benthic population in the area of a steam electric generating plant? DR. BARDACH: It would depend — well, probably it would not have, but let me add one other thing. It may be that if there is a benthic organism so entrained, and if it is spewed out again and it is half dead, it may still be eaten by a fish. But I don't think that these are really — well, these are questions directed at me as a physiologist and I can only hedge because, as you notice, we just haven't got the data, and I can give you best guesses. But let me repeat: The concern is one about synergistic overall long-range effects. MR. PETERSEN: And, doctor, you haven't yet replied to Consumer Power Company's request for the back- ground on your theories, have you? DR. BARDACH: Would you like me to tell you here what I wrote to Mr. Brandt? MR. PETERSEN: I have seen the letter which you ------- 1390 J. E. Bardach wrote to Mr. Brandt. DR. BARDAGH: Well, I am trying to do so as fast as I possibly can , Mr. Petersen, it may well be — it may well be that I have to throw up my hands, not that I cannot help you, but that I cannot help you to satisfy you. It may well be — (Applause) — it may well be that we have to mount these studies in a somewhat different way. MR. STEIN: Thank you. Are there any other comments or questions? Well, thank you very much, Dr. Bardach. Mrs. Botts, are you ready to conclude? MRS. BOTTS: Very sorry our presentation has taken so long, and I am aware that there are people waiting, My conclusion will be quite brief. It should be obvious that the expert witnesses you have just heard have not appeared here in support of a particular point of view. I myself believe that is why their participation in this procedure is all the more important,and I wish to express the gratitude of the Lake Michigan Federation and the Open Lands Project to them. Earlier I stated that I would conclude by making a proposal for an alterrv: tive of protecting the lake to adoption of the Department of Interior proposal to prohibit discharge of heat into Lake Michigan. Before discussing ------- Mrs. L. Botts it, I would like to make clear that in the absence of any other alternative, the Open Lands Project will continue to support the Department of Interior recommendation. My proposal is to establish a new means of siting powerplants, based on public participation through review by hearings in the early stages of the process, and with enforcement powers lodged with an interstate agency estab- lished for the purpose. Policy for the agency would be determined by an advisory commission representing various sectors of the public, the power industry, and State and local governments. The first step toward establishment of this new system would be development of criteria to serve as guide- lines for the following processes: 1. The location of powerplants. 2. The operation of powerplants. 3. Means of evaluating environmental effects of operation of powerplants. 4. Definition of conditions under which power- plant operations would be suspended temporarily and/or permanently. A good start toward development of criteria may have been made in this enforcement conference, where thanks to the brashness of the Fish and Wildlife Service, the ------- 1392 Mrs. L. Botts issues are at last out on the table. Perhaps the process could be carried further by a roundtable conference in which the scientists would be free to challenge each other and members of the public free to challenge them. I am certain the Lake Michigan Federation advisory council would welcome an opportunity to join with Common- wealth Edison, other power companies, and the staffs of the various Interior agencies in planning and carrying out such a conference. When it met, I do not think there would be any disagreement that the first task would be to define the research needed and to set a timetable for its accomplish- ment. Parallel with establishment of criteria, the States around the lake would have to enact their own legis- lation in support of the interstate siting commission, and approval of Congress would have to be obtained. Obviously, this is a very cursory discussion of a complex process, but it is offered here to demonstrate that conservationists object to the way powerplants have been sited in the past, not to their being sited at all. I believe this conference has demonstrated the urgency of arriving at a decision on the question of whether the existing nuclear plants should be permitted to operate as ------- 1393 Mrs. L. Botts constructed. Because of the time that would be required to carry out my proposal, even if adopted, I see no alternative except interim acceptance of a prohibition against dis- charge of heat into the lake, and soon, in the interests of power as well as the lake. If at this point the power industry continues to refuse to accept the public desire for prevention of thermal pollution, then it should be recognized that responsibility for any future of failure of power supplies rests with the industry that refuses to fulfill its function rather than to change the way it carries that function out. Thank you. MR. STEIN: Thank you, Mrs. Botts. (Applause) Mrs. Botts, you suggest a procedure where we have a forum for scientists to confront each other, and to be questioned by the public. I have been here for a week and I think that is what has been happening. This is a rhetorical question you don't have to answer. Also I wonder, Mrs. Botts, if you have ever checked — because this is one of my fields of specialty — on how long it has taken us in the past from the idea of a reception to get an interstate agency established in any field in water. MRS. BOTTS: I am aware of that. ------- 1894 EXISTING AND PROPOSED NUCLE-AR POWER PLANTS QN LAKE MICHIGAN FACT SHEET September, 1970 Plant Name, Location Company Capacity, Megawatts Cooling Water, Gallons /Day Intake Discharge Maximum Temperature Elpyat.inn Construction Permit Date Scheduled Ooeration Engineer- Architect Reactor Contractor Unique Environmental Factors Ci- ent Sta.uS Zion 2 units Zion, 111. Common- wealth Edison _,_., 1085 each unit 1 billion each unit 2600 ft. offshore 760 ft. offshore 19.6 degrees December 1968 1972 1973 Sargent- Lundy Westing- house Multiport diffuser discharge, small site Much pub- lic opposi- tion, 2 lawsuits pending Donald Cook 2 units Bridgman, Michigan Indiana & Michigan Power Cg^ 1054 1060 1 billion each unit 2200 ft. offshore 1200 ft. offshore 21 degrees March 1969 1972 American Electric Service Corp. Westing- house Shore erosion problem, Harbor permit soueht Discharge distance increased, 1 lawsuit pending on erosion damage Point Beach 2 units Two Creeks Wisconsin Wisconsin Electric & Wis-jyiich. 497 each imtt 500 millioi each unit 1750 ft. offshore 150 ft. offshore 19.3 degrees July 1967 1970 1971 Bechtel Corp. Westing- house Five miles from Kewaunee Interven- tion filed to oppose operating license Palisades 1 unit South Haven Michigan Consumers Power Co. 700 700 million 3500 ft. offshore Canal to. Lake 28 degrees March 1967 Spring, 1970 Bechtel Corp. Combustion Engineering Highest discharge temperature on lake Intervention hearing underway since June Kewaunee 1 unit Kewaunee Wisconsin Wisconsin Public 527 520 million 1600 ft. offshore 220 ft. offshore 19.2 degrees August 1972 Bailly 1 ,~, 1 unit Burns Harbor. Ind. Indiana Public Service Co. 657 660 million No permit application Big Rock lunit Charlevoix, Michigan Consumers Power Co. 75 70 _jmiUion. . 1600 ft. offshore No permit Canal application > to lake About 20 degrees 20 degrees Announced j 1960 Feb., 1070 I 1976 Pioneer j Service & Sargent- Engineering Lundy Westing- house < Five j miles ! from Two Creeks On schedule ' 1 \| General Electric Inside Nat'l Park, warmest intake water Capacity increased, public oppo- sition befor< constructior 1962 Bechtel Corp. General Electric Smallest nuclear plant on lake, coldest water _ Experi- mental and only operat- ! ing reactor on lake All the nuclear plants now being planned for Lake Michigan are of the pressurized water reactor type and are designed to use once-through cooling techniques, except the Big Rock and Bailly boiling water plants. This fact sheet has been prepared by the Open Lands Project, 53 W. Jackson, Chicago, Illinois 60604. ------- 1395 Hon. R. E. Mann MR. STEIN: Thank you. May we hear now from State Representative Robert E. Mann? STATEMENT OF STATE REPRESENTATIVE ROBERT E. MANN, CHAIRMAN, LAKE MICHIGAN AND AD- JOINING LAND STUDY COMMISSION, CHICAGO, ILLINOIS MR. MANN: Chairman Stein and other conferees. I am appearing before you today as chairman of the Lake Michigan and Adjoining Land Study Commission of the State of Illinois to urge that you adopt the 1-degree Fahrenheit thermal standard recently recommended by the U. S0 Depart- ment of the Interior and that you do everything within your power to see that your respective State water pollu- tion control agencies or State legislatures make this stan- dard enforceable under your State law. The opportunity to adopt a thermal standard which will protect Lake Michigan is a rare if not unique opportunity for this conference. Hopefully no serious irreversible damage has yet occurred in Lake Michigan because of past and present discharges of heat. Action now can protect the lake from the very real prospect of future damage. ------- 1896 Hon, R. E. Mann All too often in the past the attitude of the people who had the power to preserve the lake has been either to wait until damage has occurred before acting or to take action without knowing it would solve expected problems. To date, two Federal-State conferences have been convened to deal with pollution of Lake Michigan. There should never have been any need to call these conferences. If action had been taken in time, the pollution of the lake would never have occurred. Let me be more specific. The first conference which dealt with Lake Michigan was convened in March of 196$. This conference which centered on the Calumet area took two basic steps to abate the pollution which was reported in a United States Public Health Service document published a year earlier. First, it adopted water quality criteria for the lake and surrounding waterways; second, it adopted requirements for improvements in the waste treatment methods of municipalities and industries, setting deadlines for completion of these improvements. On first glance this sounds fine. But the standards specified only how bad we would let lake water become, not how much polluters would be allowed to dump into the lake. And the schedules for waste treatment improvement have often been laxly enforced. ------- 1S97 Hon. R. E. Mann As could have been expected, in August 1969» a preliminary report of a technical committee which had been appointed to "assess ,.. the results obtained by conference actions and determine whether further action by the con- ference would be required by the conferees to achieve satisfactory water quality in the conference area, ..." concluded that in general, water quality in the conference area was still unsatisfactory based on sampling data taken between August 1966 and March 1969. The point is that long ago we knew our lake was deteriorating yet the Federal-State enforcement conferences took a circuitous route to meet the problem, without sig- nificantly bettering the situation. These conferences didn't go to the heart of the problem. They didn't regulate how much junk could go into the lake by adopting effluent standards. As a result of not adopting such standards we are at this late date, according to State of Indiana authorities, subjecting our lake to the following punish- ment in that State alone: 513,36$ pounds of suspended solids per day 115,316 pounds of oil per day 12,&2& pounds of cyanide per month. Let me cite another example of the laxity which I think has pervaded these conferences in the past. In ------- Hon. R. E. Mann April 1964 a report of the United States Public Health Service suggested that although algal growths in the Calumet area were not as dense as in other areas of the lake, this may have been due to the presence of toxic sub- stances which inhibited algal growth despite the high nutrient content of the water in the south end of Lake Michigan. At the first session of the Two-State Conference in 1965» Mr. Hyman Gerstein of the Chicago Water Department stated that one of the most alarming features of the pollution picture was the indication of accelerated Lake Michigan eutrophication. He reported that nutrient levels had increased and that algal growths of nuisance propor- tions had occurred. Yet the conference made no reference in its recommendations to nutrient problems. In fact, by only requiring secondary treatment for municipal sewage, the conference virtually assured that phosphorus, which is perhaps the key nutrient to be controlled in preventing eutrophication, would continue to enter the lake in signi- ficant amounts. Only in 196$, when the Four-State Confer- ence was convened did eutrophication receive significant consideration And that action may have been not only too late but too little. Mr, Jacob Dumelle, formerly with the Federal Water Quality Administration and now a mcnbnr of the Illinois Pollution Control Board, has recently ------- 1899 Hon. R. E. Mann stated that original estimates of Lake Michigan phosphorus input may have been too low. This raises the question of whether the 80 percent removal standard adopted by this conference is sufficient to retard eutrophication of our Iake0 I realize I have strayed from the precise topic of your deliberations today. I felt it was necessary, however, to graphically demonstrate that you as conferees have some amends to make to the citizens of the States you represent. I can suggest no better way than by taking strong action to retard, if not eliminate, the heat loading that is currently plaguing and planned for our lake. The Lake Michigan and Adjoining Land Study Commission has formally recommended the adoption of the proposed 1-degree Fahrenheit standard. This was done after a serious review of the available literature which left no doubt in our minds that deleterious effects were quite likely to result from gross thermal inputs into Lake Michigan, that the technology to avoid this danger was available and that no better method existed to spur development of alternative and nonpolluting sources of power. I am submitting for your consideration a copy of the brief we prepared to support these conclusions. I must add one caution. The 1-degree Fahrenheit ------- 1900 Hon. R. E. Mann standard will be meaningless if powerplants are allowed to be constructed in such a way that tremendous amounts of heat will continue to pour into the lake through dilution by merely increasing the amount of cooling water used in the plant. I trust that such a safeguard will be made part of your recommendationo I want to pause just a moment to say something about the Zion plant. When the Illinois Pollution — when the permit was granted to the Zion plant, it was granted for the purpose of construction only; no commitment was made to Commonwealth Edison that they could operate. Now, when Commonwealth Edison, through its paid mercenary experts, testifies and implies that only one plant will do no damage to Lake Michigan, it is ignoring the realities of Illinois politics. I have been in the Illinois General Assembly for & years. I know from bitter experience how effective and pervasive the special interests of this State are. If you permit Zion to operate without fully putting the burden of showing that no damage, no degradation to the lake will take place, then you will not be able to stop a ring of powerplants around this lake. I hope I don't sound dogmatic on it; I hope I sound bitter, because it is from experience of 8 years on ------- 1901 Hon. R. E. Mann the Illinois General Assembly, and I am saying this pointedly to my constituents. Chairman Currie, I know, has already demonstrated, I think, great expertise in his new role, but I want to share that one piece of experience that I have had as a member of the Illinois General Assembly. I think Commonwealth Edison, I think this con- ference, I think State Representative Bob Mann, I think everybody else concerned with the lake owes accountability to the people of this State. That lake is held in trust for the people of the State of Illinois, and I would hope that one of the resolu- tions which would come out of this conference is that Commonwealth Edison ought to be put on notice that the fact that they have invested millions of dollars into that plant has nothing to do with the welfare of the State of Illinois or with that lake. If they have made a mistake, that is their problem; that is not our problem. (Applause) In closing, let me state a principle that I think should be the guidepost in your deliberations. Our natural resources are a public trust precariously held in your hands in this instance. As our trustee, you must demand that those who propose to tamper with the lake prove beyond any reasonable doubt that no deleterious consequences ------- 1902 R. E. Mann will result from their actions. After the delays of the past, nothing less than this is acceptable. And I would add just one thing, Chairman Stein. I have not meant to go into the gunnysack with regard to past actions. These are over and past. But I think that all of us can learn from the bitter experience from the past and realize that the time is reached where we must now have no — no further degradation of our land. Thank you very much. (Applause) MR. STEIN: Thank you. Are there any comments or questions? Mr. Mann, I would like to ask you one question, if you would wait — MR. MANN: Yes, sir. MR. STEIN: — just for a second. MR. MANN: Yes, sir. MR. STEIN: I would like to get your views on that since you have had experience with this. As I under- stand it — and I have heard this sometimes before in other areas of the country — that you indicate that when these plants were built, and particularly the Zion plant, the construction — the plant was built and now you are faced with operation. Is that correct? MR. MANN: Yes, sir0 ------- 1903 R. E. Mann MR. STEIN: In light of that, what do you think of the proposal that we heard from the power industries that we permit them to discharge heated water into the lake and after a couple of years if you find it is doing damage to take corrective action? MR. MANN: I don't like it because I don't believe it. MR. STEIN: Are there any other comments or questions? If not, thank you very much, Mr. Mann. MR, MANN: Thank you, sir. MR. STEIN: Several of the people have submitted statements for the record, and without objection, I would like to put them in as if read: Charles D. Sigwart, Student Council on Pollution and Environment; Robert A. Butler, President of Rosemary Beech Association; and Dr. C, H. Mortimer, Director, Center for Great Lakes Studies. We try to accommodate everyone, but I think we have come to the point where our reporter just has to have a break, and we are going to have a five-minute recess. (Short recess.) (The statements above referred to follow in their entirety,,) ------- 1904 Statement on Thermal Pollution Oct. 2,1970 Charles D. Sigwart B.S. engineering, MIT 196? currently a PhD candidate Northwestern University, Dept. of Biological Sciences representing! Student Council on Pollution and Environment (SCOPE), an advisory committee to the Dept. of the Interior; and Northwestern Students for a Better Environment (NSBE). The current growth rate in energy production and in energy use per capita will probably continue. Inevitably a large part of the energy is transferred to the environment as waste heat. In view of this trend we must seriously consider the precedents we are setting. We must not view only the effects of single sources of thermal effluents today but must consider the total effects as the thermal load on our lake doubles redoubles with coming decades. Current practice favors applying the thermal load to nearshore waters which are the biologically most productive areas of our lake. If we continue the effect on Lake Michigan will be substantial. At a minimum, even small changes in temperature can cause large shifts in the relative numbers of various species of fish. It is not pertinent to argue relative merits of particular species, but it takes only small changes to disrupt the reproductive cycle of some species or to eliminate their food supply(l)(2). Another serious problem is that the nutrient levels in nearshore waters are approaching the levels found in Lake Erie and increases in temperature will tend to encourage excessive algal growth{3)» These nearshore waters do not freely exchange with the rest of the lake due to the longshore currents and the periodic development of the thermal bar(4). In view of the complexity of the problems we cannot hope for a simple standard which will protect the lake into the forseeable future. Therefore we reccomend thatt A. In granting permits to discharge thermal effluents it should be incumbant upon the applicant to show adequate reason to believe that his discharge vrill not cause ecological damage. B. and that Thermal discharges should not be allowed in nearshore waters.including plumes swept there by currents, which exceed one degree Fahrenheit. C. Larger, temperature differences from ambient might be tolerated provided (A.) is satisfied and it is shown that heated water does not reach nearshore waters. The need to protect the most biologically active waters is pointed up by the various reccomendations of the National Technical Advisory Committee on Water Quality Criteria in 1968 of a 3°F. standard for lakes and a 1.5°F. standard for estuaries in summer(5)* particularly where spawning areas are involved. These reccomendations are made with due consideration that there are technically feasible alternatives to reduce the thermal load on Lake Michigan which are economically feasible(6). (1.) Mackenthun, Ike Practice' of Water Pollution Biology, FWPCA, 1969,p.l9ff (2) Physical & Ecological Effects of Waste Heat on Lake Michigan, Bur. Commercial Fisheries, Great Lakes Fishery Lab, Sept. 1970, p.7-18 (3) ibid. p.78 (1) ibid. p.21-22 (5) National Technical Advisory Committee, Water Quality Criteria. 1968 FWPCA P.33,P.42,p.70 (6) Feasibility of Alternative Means of Cooling for Thermal Power Plants Near Lake Micniffgn" l''WQA August,1 i"9~7"0~ ------- 2 WO t0 Mr. Chairman: -<£, /, - /cy ^ X_ t_£ My name is Robert Butler and as President of the Rosemary Beach Association I am representing that group at this conference. The Rosemary Beach A ssociation is comprised of 33 families who live immediately north of the Donald C. Cook Nuclear Plant in Bridgman, Michigan. We are very much disturbed by the gigantic enterprise that is being developed next door. And in particular, we fear the consequences of thermal pollution since, ac- cording to present plans, millions of gallons of heated water will be dis- charged daily approximately 1100 feet from the shoreline. Prevailing winds in the summer will bring this plume of hot water directly to our beach. A prolific growth of undesirable forms of algae would render our recreational facilities completely unsuitable. Moreover, should the duration of ice form- ation in winter be shortened, our beach would be subjected to devasting erosion from the winter storms. On more general and important terms, we are gravely apprehensive about the future of the lake as a viable natural resource to be enjoyed and admired. What will happen if the power companies are permitted to discharge hot water into the lake and our fears become a reality? A representative from the Michigan Water Resources Commission had a suggestion. At a public hearing before the Army Corps of Engineers in Bridgman, Michigan last year exclaimed: "If you have a case, take it to court. " But it would be A absurd to believe that our group with its most modest financial resources could counter successfully a giant such as the American Electric Power Company. Because of the complexity of the problem, legal action on our ------- part would be enormously expensive. We simply could not afford such an undertaking. Furthermore, we were distressed to hear this advice from an official of a state agency formed ostensibly to protect the public interests. This is why we feel the desperate need for a governmental board comprised of dispassionate experts in ecology; a board empowered to act decisively to protect our natural resources. To permit the power companies to in- crease the rate of eutrophication of Lake Michigan for purely economic reasons would constitute a stark betrayal of public trust. Respectfully submitted, f^ & r<~^ Robert Butler, President Rosemary Beach Association Stevensville, Michigan ------- 190? Lake Michigan Beach Zone V. aters: Vjriatio/is in Temperature Arising from Natural Causes by C. H. Mortimer, Director Center for Great Lakes Studies University of Wisconsin-Milwaukee September 1970 A Contribution to discussion of the Report by the U. S. Department of the Interior, Fish & Wildlife Service (September 1970), "Physical and Ecological Effects of V. aste Heat on Lake Michigan", presented at the Third Session of the Federal-State Enforcement Conference on Pollution of Lake Michigan, 28-29 September 1970, Chicago, Illinois. ------- 1908 Lake Michigan Beach Zone V< aters: Variations in Temperature Arising from Natural Causes Contribution to discussion of the Report by the U.S. Department of the Interior, Fish & Wildlife Service (September 1970), "Physical and ideological Effects of Uaste Heat on Lake Michigan", presented at the 3rd Session of the Federal- State enforcement Conference on Pollution of Lake Michigan, 28-29 September 1970, Chicago, Illinois. by C. H. Mortimer, Director Center for Great Lakes Studies University of U isconsin — Milwaukee Milwaukee, V>isconsin 53201 Introduction Seventeen years ago, on my first visit to this country, I began looking for clues to Lake Michigan water movements in the temperature records of municipal water intakes. Because of the large volume flow, the temperature of the raw water taken into the plant is virtually the same as that at the intake point, typically some 50 ft below the lake surface and some 5000 ft offshore, i.e., just outside the "beach water zone" defined in the above Report. I was astonished at the large and often rapid temperature fluctuations at the intakes in summer, apparently related to motion of the thermocline. I also discovered that, when the thermocline remained for several days near intake depth, wave-like fluctuations were seen (example in Fig. 1). These led to a study of internal waves, which continues today. If the intake temperatures are plotted on a less open time scale than in Fig. 1, and stations on opposite sides of the lake are compared (Fig. 2), large, irregular fluctuations are apparent, and these are often out of phase across the lake. This behaviour indicatps motion of the whole basin, involving an upwelling on one shore (producing low intake temperatures) and a "downwelling" on the other shore (producing high intake temperatures). ------- 1909 One of the principal questions before this Conference concerns "thermal stresses" which may arise in inshore waters of Lake Michigan from the expanding requirements of the power industry and other municipal and industrial users. The purpose of the present note, therefore, is to describe the natural background against which the anticipated "stress" must be examined; and a memorandum was prepared for the Conference before the recent receipt of the above Report. As that Report gives background infor- mation on the annual thermal regime of Lake Michigan, that portion I have therefore omitted. But I find that, presumably because of space restrictions, the Report does not treat the natural variability of temperature in more than a paragraph (p. 11) and in a greatly smoothed annual diagram (Fig. 6, "beach zone water temperatures"). The present shortened note may, therefore, serve a useful purpose in drawing attention to the conspicuous variability during summer and also by making the point that the Chicago water intake (used in the preparation of Rept. Fig. 6) shows much less summer variability than do intakes situated along the middle reaches of the basin. Coastal Upwelling The cause of the major fluctuations in intake temperature—upwelling induced by wind stress combined with the influence of the earth's rotation—is well illustrated by comparison of Figs. 2 and 3. By a fortunate coincidence, the Fig. 3 multi-ship survey was carried out, on 9 August 1955, just after two days of strong wind from the north had brought about massive upwelling along the greater part of the eastern shore. On 7 August there were sharp rises and falls of temperature at intakes on the western and eastern shores, respectively. At Milwaukee and Racine, for example, Fig. 2. shows a rise of 15nF in 12 hours, with an even greater rate of fall in temperature (20°F in 6 hrs) at intakes on the eastern shore. As Fig. 2 is based on 6-hr means, t Ayers et_al. 1958. The Lak~e appears to be particularly sensitive to winds veering from west to north, see mortimer 1963. ------- 1910 the actual temperature changes must nave been more rapid than the figure indicates. The order of magnitude of commonly occurring rates of temperature change can better be assessed in Fig. 4, in which the intake temperatures are plotted, for the months of July and September 1963, as hourly readings, or hourly means derived from thermograph records. The greatest variability and the greatest rates of rise and fall were again found at the eastern intakes: Ludington, iviuskegon, and South haven, where rates of fall of 8°F per hour were not uncommon, while the rates of rise at these intakes were generally less. At the corresponding western intakes—from waukegan northward--the rates of rise and fall were consistently less than on the eastern shore, values of 3QF per hour being typical. The variability at the southern end of the basin--Chic ago and Michigan City--was considerably less than that further north. The general conclusion is that temperature variability in beach zone waters is greatest at stations in the middle reaches of the lake (there are no intakes north of Jttostok) and least at Chicago. In general, the rates of temperature rise and fall are highest on the eastern shore, where also the highest maximum temperatures are attained (and maintained for longer), for example, reaching a 1963 maximum of 75°F at Muskegon and Michigan City. During 1955 (Fig. 2) the temperature maxima were 80° F at iViuskegon and 82°F at benton harbor and iviichigan City, maxima during 1955 at intakes along the western shore were some 8°F lower. There is considerable variation from year to year both in timing and dur^ion of upwelling periods (compare, for example, Figs. 2 and 4); but the high summer variability with rapid temperature changes is a persistent feature representing a randomly-occurring thermal stress to organisms in the beach zone waters. The occurrence of this stress is as unpredictable as I have assembled 20 years of summer records with the kind help of "pen friends" in various municipal filtrations plant. ------- 1911 the occurrence of the wind systems which cause the upwellings. Vvith the sediment disturbance and high turbidity which follow onshore winds on long stretches of Lake Michigan shoreline, and with winter icing and the wide summer temperature range here described, the beach zone waters of Lake iviichigan represent a biologically unfavourable environment and one in which the bottom fauna is generally relatively sparse. The controlling influence of Lake-wide motions on inshore tempera- tures is confirmed by comparison between the intake temperatures illus- trated in Fig. 4 and the cross-Lake temperature distributions illustrated for selected railroad ferry crossings from Milwaukee to Muskegon in Figs. 5, 6, and 7 (from Mortimer 1968). The upwelling and downwelling zones occupy, typically, near-shore strips of order 10 km width. Further offshore the influence of (near-inertial) internal waves is dominant. That the wave pattern is not confined to the cross-Lake section is demonstrated by Fig. 8, which shows not only western upwelling on two sections (compare Milwaukee and fcheboygan intake temperatures for 29 July in Fig. 4), but also (portions of) wave patterns in the N-S longitudinal section. Up to this point, this note has dealt in facts relating to natural variations in Lake Michigan inshore temperatures. In conclusion, I offer a few Comments prompted by a first reading of the report Tae neport makes tae commonly ueld assumption that power generation, now doubling approximately every decade, will continue to do so until the year 2000, i.e., an eight-fold increase over the 1970 figure. The Federal Power Commission, however, has not yet forecast beyond 1990. My own rough estimates up to that date (see Tables in appendix) are not at variance with those in the Report. They indicate that the Lake- wide effects will be small (for example, the only important Lake-wide effect appears to be that, by 1990, the water loss would increase by not ------- 1912 5 more than 2% above natural evaporation, representing also about 2% of the mean Lake discharge), but that the main thermal effects will be concentrated locally. The crucial unanswered question is: "How locally?" As the Report emphasizes, the added heat must pass through near- shore water before complete dissipation in offshore regions; and turbulent diffusion is usually the principal transport mechanism. The rates of turbulent diffusion will largely control the residence time of the added heat in the beach water zone. In appendix Table II this zone is defined as that bounded by the 10 m (33 ft) contour. A guess at a possible mean residence time of 10 days for the heat added to this zone yields an increase of 0.66C above "ambient" averaged over the whole of the zone. The use, if any, of such an estimate is to indicate an order of magnitude only. The residence times and the amounts of heat added will vary greatly between one region of the beach water zone and another. The greatest and most serious unknown is the magnitude and the variability, in space and time, of the eddy diffusion coefficients. That variation is certainly extremely wide; and this makes realistic modelling an almost intractable task. For example, we may visualize two extremes: one, case (a), in which an upwelling movement, of the kind described in this note, removes the whole inshore water mass from many miles of coastline in a few hours (see Fig. 3); and another, case (b), in which diffusion rates are low during a temporary minimum in inshore current activity, or during the early stages of a developing thermal bar.* Case (b) is, of course, the The mechanism of the thermal bar, with a brief account of the his- torical development of the concept, is outlined in the appendix and Fig. 9. V< hile it is likely to be an important factor in thermal loading of the Great Lakes, the thermal bar should not be looked upon as a nearly complete barrier to heat transfer (as the Report appears to suggest on p. 22). V^hile the "bar" temporarily impedes horizontal mixing between the water masses on either side of it, there is continual mass (and heat) transport toward the convergence, and a downward transport of the mixed water mass to deepe4 regions of the lake is maintained (see Fig. 9b). It would be useful to have a rate comparison between the vertical transport in the thermal bar and horizontal transport by turbulence when the bar is not present. ------- 1913 6 critical one for thermal loading; but, with present knowledge, prediction of its frequency or probable duration is highly unreliable. In view of the difficulties outlined above, the Report cautiously assumes the worst case, thereby maximizing the "thermal stress" in the beach water zone. The Report also attempts, again with proper caution, to list all the harmful ecological effects which present knowledge suggests might occur. Some of the suggestions on the list are necessarily specula- tive; but equally speculative advantages of added heat have not been con- sidered (for example, enhancement of the capacity of the Lake for self- purification from the polluting wastes, which today pose a much more serious threat to the Lake's ecological health than do thermal additions). ]Viy principal disappointment with the Report is that while it catalogs what might happen, it has not sought evidence (or recommended research to discover) what in fact has happened to the ecology of the Lake near the cooling water outfalls of existing large power plants. Some of these plants, of size-order comparable to the planned nuclear plants, present us with ready-made full-scale experiments which have been running for years. In view of present uncertainties and ignorance (both physical and biological) this is an opportunity which should not be passed by. A thorough study near such plants could lead most directly to realistic assessment of safe thermal limits, to criteria for siting new power stations well away from biologically sensitive areas, and to a well-informed public value judgment on this issue. Its companion Report, U.S. Dept. of Interior (August 1970), "Feasibility of Alternative Means of Cooling for Thermal Power Plants near Lake Michigan" does not examine the possibility of piping the effluent two miles or more offshore to reduce thermal stress in the beach zone and to achieve better entrainment and dispersal. This possibility may also be worth considering in future for municipal sewage plant and storm water outfalls, which in favourable circumstances might be com- bined with power station outfalls. ------- - 1914 7 The public is already paying heavily, in one way or another, for an astonishing multiplicity of research effort on "thermal pollution". Nevertheless, I would: Recommend that an integrated effort be made to answer, through ade- quately planned and adequately equipped studies carried out on a year- round basis at selected existing Great Lakes power plants, the following questions: "What variations are there in patterns of heat dispersal in the Lake ?" and "What influence have these patterns had on Lake ecology ?" An answer to the first question will involve descriptions of the currents and the turbulent regime under different weather and Lake conditions, based not only on the dispersal of heat, but perhaps also on the dispersal of more conservative (chemical) properties, for example, the chloride input from major rivers, or controlled artificial additions. (For example, Dr. Ayers'studies of dispersal of river water in the Lake indicate, I understand, a comparatively high rate of turbulent dispersal.) An answer to the second question will involve control studies in regions not influenced by thermal addition. If this (applied) research program is adequately conceived to answer the above two questions, then it will also teach us a great deal we need to know about Lake Michigan. C. H. Mortimer 24 ^mber 1970 References Ayers, J.D., D. C. Chandler, G.H. Lauff, C.F. Powers, &E.B.Henson 1958. Currents and water masses of Lake Michigan. Univ. Michigan, Great Lakes Res.Div., Publ No. 3, 169 p. Mortimer, C. H. 1963. Frontiers in physical limnology with particular reference to long waves in rotating basins. Proc. 6th Conf. Great Lakes Res. ,Univ. Michigan, Great Lakes Res.Div., Pub.No. 10:49-45. Mortimer, C. H. 1968. Internal waves and associated currents observed in Lake Michigan during the summer of 1963. Univ. Wisconsin- Milwaukee, Center for Great Lakes Studies, Spec.Rept. No. 1, 144 p. ------- 1915 APPENDIX Tables I and n and Note on the "Thermal Bar" presented at the 2nd Annual Four-State Conference "Power Production and Protection of the Lake", sponsored by the Open Lands Project, at Zion, Illinois, 2 May 1970 (also embodied in a memorandum pre- pared for the Argonne National Laboratory entitled: "Electric Power Stations on Lake Michigan: A Simple Approach to Assess- ment of Physical Effects on the Lake", March 1970). Line 4 (power to be dissipated, 109 BTU's/hr) has been added for compari- son with Table 8, p. 29, of the U.S.Dept. Int. 1970 Report. Lake Michigan: Estimated thermal influence of electric power generation for the years 1970-1990, I. Units Estimated electric power generated lo9 w(e) Assumed overall efficiency Power to be dissipated Power to be dissipated 10s Daily equivalents: (i) Heat (ii) Area and volume of "slab" of cooling water, 1 m thick raised in temperature by 10° C % 109 w(h) BTU's/hr 1013g-cals km2 1012cm3 1970 n i 30 16 54 33 1975 14 33 28 95 58 1980 20 35 37 126 76 1990 50 40 75 255 154 w(e) = watts of generated electric power; w(h) = watts dissipated as heat. 109w(h) = 103 Mw(h) = 2.06 x 1013 g-cal/day = 3.415 x 109 BTU's/hr. 8 ------- Lake Michigan: Estimated thermal influence of electric power generation for the years 1970-1990, II. 1916 Power to be dissipated (cf. Table I) Daily equivalent heat input (i) whole lake surface (5.81 x 1014cma) (ii) inshore strip of depth < 10m Temperature rises, assum- ing 10-day storage: (i) whole lake volume (4.78 x 1013cm3) (ii) inshore strip of depth < 10m (2.3xlOI3cm3) Equivalent evaporation(per year) (i) volume (ii) decrease in whole lake level (iii) percentage of mean out- flow (46 x 103 cfs) (iv) percentage of natural annual evaporation (26 in) Unit 109w(h) g-cal/cm2 g-cal/cm2 °C °C 1014cm3/yr cm/yr % % 1970 1975 1980 1990 16 28 37 75 0.57 1.0 1.3 2.6 7 12.5 16 33 .0007 .0012 .0016 .0032 .14 .25 .33 .66 2.0 3.6 4.7 9.5 0.34 0.62 0.81 1.63 2.3 2.5 * 8% of whole lake surface ^assuming all heat dissipation is through evaporation (590 g-cal/cm3 at 10°C) ------- 1917 The Thermal Bar The thermal bar convergence will probably turn out to be an important fea- ture of the annual temperature cycle and nearshore circulation in all very large temperate lakes. It arises because, in such lakes, the inshore shallow waters cool off more quickly in the early winter and warm up more quickly in spring than do the deeper offshore waters. Thus, in late December and early January in Lake Michigan , inshore waters have cooled below the temperature of maxi - mum density (4C) while the offshore well-mixed deep waters still remain slightly above that temperature. Forel (1895) was the first to observe (in the Lake of Geneva, Switzerland; see his schematic representation in Fig. 9a) that, in the mixing zone between the inshore and offshore water masses, the mixture (at maximum temperature near 4"C) is denser than either of the component water masses; and it consequently sinks. The conversity of the curve relating tem- perature and density of pure water, with a maximum at 4°C, shows why this should be so. The sinking mixed water mass is replaced by surface convergence of more in- shore and offshore water, leading to continued mixing and sinking. This conver- gence mechanism, recognized by Tikhomirov (1963) both in spring and early win- ter in Lake Ladoga (Fig.9b), acts as a temporary thermal barrier to horizontal exchange between nearshore and offshore water masses. The thermal bar is most strongly developed in spring and early summer and forms a sharp division between stratified water with high surface temperatures inshore and unstratified water below 4C in the deep offshore regions. As spring heating continues, the thermal bar moves progressive o!fchore until stratification is established right across the Lake (Fig.9c, after Rodge»s, 1966). A similar sequence of events during spring will probably be found in Lake Michigan, first in the southern half and later in the northern half of the basin; and Fig.9d (Church, 1945) probably represents the aftermath of a thermal bar in the northern half of the Lake. Currents induced by the thermal bar have components parallel to the shore- line and normal to the shoreline (i.e., toward the convergence); and there are also (smaller) descending currents in the convergence (Huang, 1969). ------- References (Thermal Bar) Church, P. E. 1954. The annual temperature cycle of Lake Michigan (n): Spring warming and summer stationary period, 1942. Misc. Rept. No. 18, Inst. Meteorology, Univ. Chicago (Univ.Chicago Press). Forel, F. A. 1895. Lac Ldman. Monographie Limnologique, Vol. 2 (Paris), 651 p. Huang, C. K. 1969. The thermal current structure in Lake Michigan, a theoretical and observational model study. Univ. Michigan, Great Lakes Res. Div., Spec.Rept. No. 43 . Rodgers, G. K. 1966. The thermal bar in Lake Ontario, spring 1965 and winter 1965-66. Proc. 9th Conf. Great Lakes Res., Univ. Michigan, Great Lakes Res.Div., Pub. No. 15: 369-374. Tikhomirov, A. I. 1963. The thermal bar in Lake Ladoga. Bull. (Izvestiya), All-Union Geogr.Soc., 95_: 134-142 (Amer. Geophys. Union Translation, Soviet Hydrol., Collected Papers No. 2). Legend to the following Figure 9. The Thermal Bar: (a) in winter in Lac Leman (Forel, 1895); (b) in spring and winter in Lake Ladoga (Tikhomirov, 1963); (c) formation and development in Lake Ontario (after Rodgers, 1966); (d) aftermath of a thermal bar in June in northern Lake Michigan (Church, 1945). [ Fig. 9b is attributed to Tikhomirov in S. V. Kalesnik's book "Lake Ladoga," Leningrad, 1968.] ------- 1919 -a w c C ?H TO 0) £', O Jj bfl C. C rt 0 o. o o; S §^ "I « 13 til 0) !H I Q) . o 0 o M « QC ------- 1920 i I I i i i i i i i i i i i i LUDINGTON A J s '> ''»?, A • \ -_,/_>U-\^/' 1'.^ DATE OF FiG. 3 CRUISE Fig. 2. Temperatures, °F, at the following municipal water intakes (July to Sep- tember 1965): Two Rivers, Wis.(35); Ludington, Mich. (45); Milwaukee, Wis.(55); Muskegon, Mich. (50); Racine, Wis.(29); Michigan City, Ind. (38). The numbers in brackets indicate the depth of the intake in feet belov; the lake surface. The above graphs represent 6-hr mean temperatures, prepared from thermograph records or from other readings, except for Two Rivers and Ludington, tor which only daily readings were available. ------- SURFACE TEMPERATURE °C SYNOPTIC 3ZI 9 AUGUST 1955 1921 Fig. 3. Lake Michigan surface temperature, °C, S August 1955, based on a multi-ship survey (Ayersj^tjil. 1958). The corresponding temperatures at the coastal water intakes are shown in Fig. 2. ------- 1922 Figure 4. ------- kilometres from Milwaukee breakwater 1923 120 127 Fig. 5. Lake Michigan 1963: Distribution of temperature, °C, in the Milwaukee Muskegon section (selected from a series obtained on railroad ferry crossings, Mortimer 1968), Run. No. 164, 19 July. ------- 20 Kilometres from Milwaukee breakwater 40 . 6O 8O 100 1924 120 127 Fig. 6. Lake Michigan 1963: Distribution of temperature, °C, in the Milwaukee - Muskegon section (selected from a series obtained on railroad ferry crossings, Mortimer 1968), Run. No. 192, 6 August. -3.-TIMEtCS.TJ 1 20 21 -JL-. 22 23 1 ------- 20 kilometres from Milwaukee breakwater 4O . 60 80 too 1925 120 127 Fig. 7. Lake Michigan 1963: Distribution of temperature, °C, in the Milwaukee- Muskegon section (selected from a series obtained on railroad ferry crossings, Mortimer 1968), Run. No. 214, 16 August. -00 , \| 1 L_ LAKE MICHIGAN 1963: TEMPERATURE DISTRIBUTION. 'C, IN THE MlLWAUKEE-MUSKEGON SECTION 1 . . . 1 , , , 1 , _. RLIN NO 2i4 DATE: 16 AUGUST 1 , , , ] " ~: i i ------- 1926 Me Fig. 8. Lake Michigan 1963: Distribution of temperature, °C, along the cruise path of R/V "Cisco" on 29 July, from Milwaukee to mid-Lake, then north for 16 km, then west to Sheboygan. Isometric projection; direction in degrees (true). ------- 1927 The thermal bar. Forel'e concept [«] LAKE ONTARIO SURFACE TEMPERATURE MID-LAKE, N-S TEMPERATURE SECTIONS Surface Temperature i C«nhgro4< Junt 7-9.1942 *t\| 28-30 JUNE, 1965 • -V1 ' -'"' ' fc si" v- / ' MA ,y»} ,,' i ,,/• '•:67 66 Figure 9. The thermal bar. ------- 1923 J. T. Sobota MR. STEIN: Let's reconvene. William Singer. MR. SINGER: I prefer to wait for the conferees. MR. STEIN: You may have to wait a long time. MR0 SINGER: I have waited since 9:00 o'clock. I think it is rude to ask someone to testify when there is no one here to listen. I have waited since 9:00 o'clock. I would rather not testify until the conferees are here to listen. MR. STEIN: Dr. Sobota. STATEMENT OF JOSEPH T. SOBOTA, M.D., PRESIDENT, TEMP, KALAMAZOO, MICHIGAN DR. SOBOTA: Chairman Stein, the Federal Water Quality Administration, the Bureau of Commercial Fisheries, the Bureau of Sports Fisheries and Wildlife, members of the Lake Michigan Enforcement Conference, and ladies and gentle- men of the public. My name is Dr. Joseph T. Sobota. I live at 2312 Glenwood Drive, Kalamasoo, Michigan, and I am speaking on behalf of myself and Mr. Ron McCandlis, $619 Clato Street, also of Kalamazoo. I am Executive Director of TEMP (Thermal Ecology Must be Preserved); Mr. McCandlis is President of the Michigan Steelhead and Salmon Fishermen ------- 1929 J. T. Sobota Association. More importantly, we represent the public in a contested Atomic Energy Commission hearing concerning the Consumer Power Company's Palisades Nuclear Plant in Covert, Michigan. The Michigan Lakes and Streams Association and the National Sierra Club have joined us in this AEC hearing being held in Kalamazoo, Michigan. Mr. McCandlis and myself, as citizens of the State of Michigan, are represented by the Michigan Water Resources Commission with regard to water pollution problems. In 196? this Board gave an order of water use determination to Consumers Power Company allowing them to prospectively operate the Palisades Nuclear Plant, in spite of this plant's planned normal operation of dumping daily into Lake Michigan 561,000,000 gallons of water heated 28-degrees Fahrenheit above normal lake temperature. No reconsideration of this order was made in the intervening years, even though much new substantial evidence of thermal pollution connected with nuclear powerplants has since been developed, some of which you .heard in the earlier parts of this morning. In March 1970, the AEC gave notice in the Federal Register of its intent to license this plant unless parties whose interest would be affected intervened. At this time, the State of Michigan remained without water temperature standards approved by the Department of the Interior, In ------- 1930 J. T. Sobota turn, the Department of Interior had neglected to promulgate regulations of thermal input into the essentially Federal Lake Michigan. This dual vacuum of inactivity by the Department of Interior and the Water Resources Commission in failing to set thermal standards provoked our intervention April 2, 1970. Our petition for a public hearing included the request for implementation of the National Environmental Policy Act (NEPA) as a vehicle for coordination of AEG, Department of Interior, and Water Resources Commission consideration of thermal pollution in Lake Michigan. A determination on thermal pollution in an AEC hearing on nuclear plant licensing would affect not only the Palisades Plant but would serve as a precedent to the many other plants of this variety planned or actually under construction on the shores of the lake. The hearings began in Kalamazoo June 23, 1970, and are still in progress. In these hearings the Atomic Energy Commission staff and the applicant, Consumers Power Company, have by legal maneuvering attempted to avoid the topic of thermal pollution and the effect of the Palisades and similar nuclear powerplants1 total impact on Lake Michigan. Until as recently as September 25, 1970, they have been eminently successful in preventing such discussions. ------- 1931 J. T. Sobota Through the brilliant legal representation of Mr. Myron Cherry, our attorney, the AEG Safety and Licensing Board in session in Kalamazoo referred to the Atomic Safety and Licensing Appeal Board in Washington the following September 3 ruling for judgment: "The ruling that the National Environmental Policy Act ... requires the Staff of the Commission to transmit the application of Consumers Power Company (Palisades Plant) to the several agencies of the Government for comments respecting the environmental considerations enumerated in said Environmental Act. In addition, the ruling requires the Staff to prepare an environmental policy statement based upon the comments submitted by the several agencies of the Government and direct it specifically to the items enumerated in the Environmental Policy Act." In other words, the Safety and Licensing Board in Kalamazoo asked thaf the Consumers Power Company and the AEG staff, under the requirements of the National Environmental Policy Act, consult with all concerned agencies of the government, both State and Federal, regard- ing the ecological impact of the Palisades Nuclear Plant and the other nuclear plants in the lake basin. The Appeal Board in its answer docketed September 25, 1970, Noo 50-255, essentially said that this type of ------- 1932 J. T. Sobota report is not necessary for a one-megawatt license, but is necessary for a full power license. This is the first such implementation of questions outside those of radioactive consideration to be addressed by the AEC. After 4-and-one-half months of tedious, difficult and considerably technical matters, our strategy of using the National Environmental Policy Act as a vehicle of introduction of thermal pollution at an AEC hearing had paid dividends. The opportunity now exists, through the AEC, to circulate the Palisades Nuclear Powerplant license and an environmental report of the ecological impact of this plant for comment to all appropriate Federal agencies which might have expertise in this matter, so that this will be addressed to you gentlemen now at this meeting. We interpret this ruling as opening the door for a significant participation by the Department of Interior in respect to this licensing activity. Since the State of Michigan has no thermal standards and since the Department of Interior, through the agencies represented here (Federal Water Quality Administration, Bureau of Commercial Fisheries and the Bureau of Sports Fisheries and Wildlife) has recommended a one-degree limit of heat input at the point of discharge in its excellent report presented at this meeting, we maintain that the Interior Department has the ------- 1933 Jo T. Sobota only guidelines available for licensing this plant and any other nuclear plant on Lake Michigan's shoreline. The Appeal Board ruling specifically states: "The determination (under NEPA) as to whether an action constitutes a major Federal action significantly affecting the quality of the human environment is one to be made by the agency proposing or authorizing the action; and we find this confirmed in the relevant legislative history. As to the matter of making the determination, we find nothing in NEPA which would preclude agencies from imple- menting this responsibility as they implement others, through the issuance of regulations which treat the categories of agency actions." Since the State of Michigan has no thermal stan- dards for Lake Michigan, and while the Department of Interior has no regulations, the only valid documents or guidelines by the Interior Department are the ones submitted regarding the 1-degree limit for heat input into Lake Michigan at the point of emission. In a matter of weeks, the environmental report of the Consumers Power Company and the Palisades licensing application will be forwarded to you gentlemen representing the Department of Interior and the otate agencies here. On the strength of your report submitted here entitled ------- 1934 J. F. Sobota "Physical and Ecological Effects of Waste Heat on Lake Michigan," the AEG will have no choice but to enter in testimony regarding thermal pollution at the hearing, and to resolve the considerations under which this plant will dispense heat into Lake Michigan. This is the way that the regulations and the guidelines will be implemented in an action that demands decision at this instant. These hearings are being held at this instant. I urge you to immediately request the license and the environmental report from Consumers Power Company, and immediately notify the AEC Hearing Board regarding Docket No. 50-255 of your eminent participation in this hearing on the matter of thermal pollution. It is within your power now, on the basis of the AEC's own ruling, to so participate and effectively promote the conclusions stated so well in the previously cited paper "Physical and Ecological Effects of Waste Heat on Lake Michigan." The Department of Interior must utilize this opportunity to either promulgate a pro- tective thermal standard without a pollution coefficient and actively participate in the current AEC decision-making hearings, the Palisades hearing in Kalamazoo, Michigan, in particular, or the significance of this conference will be nothing more than a fraudulent exercise of public ------- 1935 J. F. Sobota appeasement. The Department of the Interior can now assume, to a great extent, the responsibility abdicated by the Water Resources Commission of the State of Michigan for the past documented 32 months. As far back as January 196$, the distinguished former Secretary of the Interior, Stewart Udall, in a letter to the then Governor Romney of Michigan, stated, "I am at this time excepting (Department of Interior) ... approval of temperature parameters as these apply to the (fish, wildlife, and other aquatic life) water use for all interstate waters covered in the Michigan State's original and supplemental standards submissions, including the waters of the Great Lakes. I believe that further dis- cussions regarding these temperature 'parameters are neces- sary, and I am instructing my people to contact your officials without delay to begin working out such modifi- cations as would afford great protection to this important water resource use. I would greatly appreciate your cooperation in this matter, and I remain confident that our mutual efforts will result in modified temperature parameters which I can approve." This letter was written January 1968. The Michigan Water Resources Commission has still not proposed temperature standards which are acceptable ------- 1936 J. F. Sobota to the Department of the Interior. Is this the type of inaction to be expected from a responsible representative group? The responsibility also has been abdicated by Consumers Power Company management. While they consistently live within the letter of the law, they maintain public and hearing positions which are contradictory. Publicly Consumers Power Company maintains that no thermal pollution will occur with the Palisades Nuclear Powerplant. In the Atomic Energy Commission hearings in Kalamazoo, however, they have legally briefed against hearing in an administrative process their scientific proof and substantial alternate scientific opinion on thermal effects such as the concise paper just submitted by the Interior Department, and remarks by eminent scientists like Dr, Don Pritchard. We may surmise something of the soul of Consumers Power Company management from tactics of the type just cited. Apparently, in the area of thermal pollution where anti- pollution controls are feasible and available and documented, Consumers Power Company management has arbitrarily decided not to provide the power of the Palisades Nuclear Powerplant to the citizens of Michigan, rather than add one of the available and feasible means of cooling the nuclear power- plant water effluent. ------- 1937 J. F. Sobota The organizations I represent have always operated within the established rules of practice of the Atomic Energy Commission, and other legal restraints that we are obligated to work under. Delays of the plant in no way add substance to our organization's aims. Our position as simply stated is additional power supply to Michigan without pollution. We refuse to accept a utility company's promise that any harmful effects to the environment caused by a nuclear powerplant would be taken care of if and when any occur. I would like you to remember the earlier presen- tation of the algae in Little Traverse Bay. That was interesting news to me. I would like to know now what material action will be taken to cure that if, in fact, it is secondary to the Charlevoix big water plant. While maintaining this posture, utility companies neglect to define "harm" and exactly what action they would take if such future -damage occurred. We are not willing to play Russian roulette with Lake Michigan. We have no evidence historically, scientifically, nor can we deduct intuitively, that damage once it occurs to the lake is reversible. Also, in view of this fact, we must be on guard to prevent plants of the Palisades type from gaining a vested interest by mere active operation, enabling them to hide behind grandfather ------- 193^ J. T. Sobota clauses, such as those which exist in the Federal Water Quality Act of 1970. Accommodation to pollution is an abomination which should not be tolerated "by anyone in this room charged with protecting the public interest. This applies as much to power company representatives as to Federal and State representatives. While the power companies must live within the letter of the law, and they do, we charge them to live within an enlightened outlook in an unpolluted world. In summary, the organizations I represent have acted in a novel way to introduce the implementation of thermal standards in an AEG hearing of a license to operate a nuclear powerplant on Lake Michigan. The legal ruling established in this hearing to date now affords the Department of Interior the opportunity to act directly, with guidelines and regulations, in areas such as the State of Michigan, where no thermal standards exist, as an active participant in forming the licensing stipulations which will be in effect for the operation of such plants. We charge them to act in a responsible manner at the Palisades nuclear power hearing now under way in Kalamazoo, Michigan. This action will serve as a precedent to all other nuclear power facilities in the Great Lakes ------- 1939 J. T. Sobota Basin and effectively implement the guidelines which were so well presented by the Department papers released at this conference. Successful participation on the part of the Department of Interior, or better yet, responsible action by the Water Resources Commission of the State of Michigan, would provide the national precedent needed to blunt massive thermal pollution threatened by a rapidly growing nuclear power industry. Thank you very much. (Applause) MR. STEIN: Thank you, Dr. Sobota. Any comments or questions? MR. FETTEROLF: Yes. Dr. Sobota, at the meeting of the Michigan V/ater Resources Commission held on October 27, 1966, the order of determination was adopted relative to Consumers Power Company, Palisades Plant. This was before temperature standards were required, and in the absence of temperature standards I would like to read you Section 6 of that order which states: The company shall not impart heat nor con- tain any substances in sufficient quantity to create con- ditions which are or may become injurious to the oublic health, safety, or welfare, or which ar° or may become injurious to domestic, commercial, industrial, agricul- tural, recreational, or other uses which are being made ------- 1940 J. T. Sobota of such waters, or which are or may become injurious to the value or utility of riparian lands, or which are or may become injurious to livestock, wild animals, birds, fish or aquatic life, or the growth or propagation thereof. In Section D of this order of determination, it states: The company shall make measurements of wastes discharged to Lake Michigan and shall perform such analyses as are necessary to demonstrate that the requirements of this order are being met. Reports of such analyses and measurements shall be available for inspection by authorized employees of the Water Resources Commission, and an annual report thereof shall be submitted to the Commission by the company. With respect to — DR. SOBOTA: May I answer that statement, please? I have read that statement, and I would like to again go back to the text of my remarks and substitute "utility companies" for the Water Resources Commission. While maintaining the posture in that document which is so elegantly stated, the Water Resources Commission and the companies have failed or neglected to find harm in exactly what action they would take if such actual damage occurred. Now, without the possiblity of using measuring sticks for decision-making, and language of that type, I ------- 1941 J. T. Sobota doubt whether, in fact, anything could be said other than a very nice-sounding rhetoric to that statement0 (Applause) MR. STEIN: Any other comments or questions? MR. FRANCOS: Mr. Chairman, do we have copies of that presentation now for the conferees? DR. SOBOTA: I have a certain number of copies available. 1 don't know whether there will be a sufficient number for all of the members of the conference. MR. STEIN: '.tfhy don't you bring up the ones you have ? Mr. Petersen. MR. PETERSEN: Thank you, Mr. Chairman. 0. K. Peterson. Dr. Sobota, I understand you are a medical doctor? DR. SOBOTA: Is that a question? MR. PETERSEN: Is that correct? DR. SOBOTA: Yes, I am a physician. I specialize in pathology* MR. PETERSEN: Are you also a lawyer? DR. SOBOTA: No, I am not. MR. P3TER3EN: Then your comments as to the State of Michigan not having standards in effect as to Lake Michigan are your conclusions as a doctor rather than as ------- 1942 J. T. Sobota a lawyer? DR, SOBOTA: They are my conclusions as a physi- cian, as an interested party in these hearings, as an active participant in the intervention in a nuclear plant, and as a citizen. MR. PETERSEN: Are you aware that such standards were adopted even if they were not approved by the Depart- ment of the Interior — Secretary of the Interior — correction. DR<> SOBOTA: I understand that there were stan- dards that were attempted to be promulgated, but were consistently denied approval by the Department of Interior, yes. MR. PETERSEN: Is it my understanding that if Consumers Power Company should put up cooling towers at the Palisades plant that you would have no more difficulty with the plant, and you would withdraw your opposition to the licensing of that plant? DR. SOBOTA: We would like to discuss that possibility with the Consumers Power Company. MR. PETERSEN: Then, when you say you would like to discuss the possibility, you are not saying that is the standing of your group? DR. SOBOTA: Our standing is that we would like to ------- 1943 J. T. Sobota protect the ecology surrounding that plant, and protect the impact of heat dissipation from multiple nuclear plants on Lake Michigan by whatever feasible means are available for antipollution devices that would be attached to such a set of plants. MR. PETERSEN: When you said here that Consumers Power Company had deprived the people of Michigan of that electricity instead of putting up cooling towers or taking other cooling action, you were not stating your entire case, were you? DR. SOBOTA: What I was stating there is that Consumer Power Company management because of whatever policies might have been the basis of the foundation for designing and implementing the use of that plant had not put on that plant feasible antipollution devices, and because of that particular problem, and because of the void of standards — thermal standards both by the Federal and by the State Government, certain citizen groups adopted a policy of intervention so that these questions would be answered properly before the operation of that plant began. It is a 40-year plant, and the operation of such a plant, in the face of unknown irreversible damage to a lake, and at a time where it may become a precedent- setting plant and license for all of the plants around the ------- 1944 J. T. Sobota Lake Michigan basin was also some of the reasoning for the intervention in that particular plant by conservation groups. MR. PETERSEN: Your theory, then, is to oppose this plant at this stage of operating after it has been built instead of opposing future plants on a construction basis, as you did not oppose this plant when it was being constructed. DR. SOBOTA: We do not oppose this plant, and I think I want to make that very clear. AEG has seen fit not to license this plant until after a hearing of all" of the issues involved in the safety, in the performance evaluation of the plant, and in the other considerations that are made for the licensing of such a plant. It is the AEG, in fact, that has not given you an operating license. MR. PETERSEN: Did you or any of your group oppose the construction license for this plant? DR. SOBOTA: I was not in the State of Michigan at that time. We were not even formed at that time as far as an organisation. But I must say we probably do have a much quicker reaction time especially in view that we understand technology races along and may leave the decisions behind before adequate decisions could be made. And in that ------- 1945 W. S. Singer regard we did act rather decisively and quickly after we had analyzed the data that were available to us and also to the conferees at this conference, and also to the Water Resources Commission of the State of Michigan. MR. PETERSEN: I take it your answer is no. DR. SOBOTA: We did not participate in the con- struction or permit hearing which was rather perfunctory, after reading the transcript, because of the absence of both my personal presence and the absence of organizations concerned with this problem at that time0 (Applause) MR0 PETERSEN: Thank you very much. MR0 STEIN: Thank you. May we have Alderman William Singer? STATEMENT OF WILLIAM S. SINGER, ALDERMAN, 43rd WAHD, CHICAGO, ILLINOIS MR. SINGER: Mr. Chairman and members of tho conference. I am pleased to have the opportunity to appear before this Third S -ssion of the Lake Michigan Enforcement Conference and to testify regarding the proposed standard before you at this time which would provide that "... no significant amounts of waste heat ..." be discharged into Lake Michigan. ------- 1946 W. S. Singer Today you will hear testimony from the public on this proposed standard and it is a fair guess that the testimony will be relatively uniform in favor of your adop- tion of this standard. This is no secret, but it occurs to me that it is fair to go beyond the mere unanimous public support for this proposed standard and probe the reasons for this public support. First, it must be abundantly clear that the people of the States surrounding Lake Michigan fear its ultimate death within this decade. The Lake Erie tragedy and the constant reports of the eutrophication of our lake has justifiably alarmed residents of the four States bordering Lake Michigan. Second, against this background of fear is a total lack of trust and unwillingness to go further with those who have polluted the lake for too many years. Industry now says, "Give us a few plants and some more time." And the public says, "Damn your time" — and rightly so. What basis is there for trust when day after day the pollution of the lake continues primarily through the efforts of industry? The simple fact is that industry does not deserve our trust. Third, the public has seen too many examples of "Try now, pay later." Drugs have been placed on the market ------- 1947 W. S. Singer with insufficient testing, with often disastrous results. Pollution of our environment has been caused by any number of devices or products which the public was told would help create "the better life." The public has paid dearly for the better life and, indeed, if the same processes continue, the end of the better life may be around the corner. Fourth, and perhaps most important, the public knows what our science and technology can do if pushed far enough. I would add here that the intent of this statement is that it knows that the plants can continue their opera- tion without thermal discharge; it knows it because even the industry has said that there are alternative means such as cooling towers, circulation systems. The powerplants on the lake are the path of least resistance, economically speaking, for the industry. The proposals to use lake water and to discharge it at substantially higher degrees are similarly the path of least economic resistance. I understand that one witness has stated that the proposal before you "is economically unrealistic<," Economically unrealistic to whom? To the public? No, it is economically unrealistic, or stated perhaps more accurately, less advantageous to the power industry. But it is quite realistic to the public who will have to pay ------- 1943 W. S. Singer if thermal discharges are found to be harmful to the lake. Gentlemen, no one of us can ever accurately reflect total public sentiment on any issue, but on this proposal there can be little doubt that the public does not want to take any more risks with the future of the lake. They don't trust industry and they know that time is short. It is unacceptable, as one power company spokesman has suggested that it might be, to let the plants go ahead and then we can test to determine if there is damage. But that same spokesman has said that if after a year of study damages did occur, it might take 2 or 3 years to change the processes and eliminate the thermal discharge. That means a period of almost 4 years during which time the thermal discharges would continue unabated. Can we afford any chance like this with Lake Michigan? The public, I believe, says that we cannot, and is asking you to say to industry that there will be no more chances. It is asking you to say no thermal dis- charges. I urge you to adopt such a strict standard at this session of the conference before it is too Iate0 Let me add: It occurs to me that another public reaction might be gleaned from the testimony before you today of the seeming confusion that might result if one were to ask, as you have, who and in what period of time ------- 1949 W. S. Singer will come forth with a standard which will be effective to stop any possible damage to Lake Michigan resulting from thermal discharges? Who? Is it you as a conference? Is it the Department of Interior? Is it each individual State? The public doesn't really know, and I must say I doubt you gentlemen know what the fastest way to achieve that standard is. But you gentlemen, collectively or individually through your own States, have some power, and the decision ought to be to exercise it as fast as possible even if it means adopting a standard and promulgating a standard for your individual States which may only be an interim one, because an interim one will at least give the public assurance that not until there is a clear and demonstrated — it is clear and demonstrated that no harm will result will thermal discharges be permitted. If you want to label it "interim," fine, make this clear, too: It will be interim until the industry has made its case clear. And I suggest that if the public is going to have any confidence in the political process in terms of ending or turning around the process of eutrophication of Lake Michigan, indeed all over this country, if they are going to have that confidence in the political process, then you gentlemen have it within your ------- 1950 W. S. Singer power to do something about it soon. We cannot continue the game of "Whose back is the monkey on?" You can do it individually or collectively — I don't care which — but I urge you to do it. Thank you very much. (Applause) MR. STEIN: Thank you, Alderman Singer. Any comments or questions? If not, may we have Mrs. Louise Erickson? While she is coming up, I have several telegrams which I would like to put in the record as if read, and the statement of the Elk River Drainage Basin Council, submitted by Mr. Ted F0 Miller, Chairman, and Mrs. James Janis, Secretary, and one more telegram I would like to read: "It is my understanding that the FWQA will be concluding an enforcement conference today concerning the pollution problems of Lake Michigan and that the major problem on the agenda will be that of thermal pollution from powerplants. "Whereas the scientific evidence regarding this problem is admittedly inconclusive, it is my hope that it will be regarded as sufficient to permit agreement on a specific thermal standard for all plants on the lake. Any such standard will necessarily be an imperfect approximation ------- 1951 Hon. P. A. Hart of what is needed. Yet it would appear nonetheless to be an improvement over the current system in which different plants are held to different standards of beunt (sic.) depending on which State's shoreline is involved. "As for what the new standard should be, as you well know, I lack the scientific competence to so much as hazard an intelligent guess. As a lawyer, however, I can advise that difficult questions of fact are often best resolved by reliance on the issue of burden of proof. With the question of thermal pollution, it would appear that the burden as to safety must lie on those who would introduce potentially dangerous elements into the environment. Unless that burden is sustained we may risk intolerable dangers to a resource we all hold dear. "I wish you every success in your efforts. Sincerely yours, Philip A. Hart, Chairman, Subcommittee on Energy Natural Resources and the Environment." I would like to place that telegram in the record, (Applause) I guess, knowing Senator Hart — I suspect I will be before the committee to explain whether it is successful or not successful in the future. (The telegrams and statement referred to pre- viously follow.) ------- 1952 Telegrams (The following telegram was received from F. M. Baumgartner, President, CNRA.) "The Citizens Natural Resources Association of Wisconsin strongly support Secretary Hickel's standard of one-degree increase in water temperature from atomic powerplants." (The following telegram was received from E. K0 Born, President, Sheboygan Chapter, Izaak Walton League of America.) "The Sheboygan Chapter of the Izaak Walton League of America and the Sheboygan Chapter members serving as officers and directors of the state league heartily endorse that the water temperature increased by nuclear powerplant located on Lake Michigan be held to one degree. The state league is represented by 2000 members and the Sheboygan Chapter by 215 members." (The following telegram was received from Mrs. Betty Priebe, Waukesha, Wisconsin.) "Favor stand against water pollution. Am owner of bonds in Consumers Power. Environment most important." (The following telegram was received from the Staff of Virginia's Beauty Salon, Eleanore Grace, Manager, Milwaukee, Wisconsin.) "We urge your continued effort to set standards ------- 1953 Telegrams for Lake Michigan at the tolerable limit of one percent thermal addition above water temperature, according to Secretary of the Interior V/alter Hickel's statement. We the general public may not be vocal but you have our full support. Happy New Year, dear Mr. Stein, to you and yours0" (The following telegram was received from Keith A. Ziolek, Park Ridge, Illinois.) "Adopt strictest standard under consideration. Save the lake." (The statement presented by the Elk River Drainage Basin Council follows in its entirety as if read.) ------- 1954. ELK RIVER DRAINAGE BASIN COUNCIL TO PROTECT THE WATER AND LAND RESOURCES OF OVER BOO SQUARE MILES COMPRISING THE ELK RIVER WATERSHED STATEMENT TO THE FEDERAL ON POLLUTION OP LAKE MICHIGAN AW ImS TRIBUTARY BASIN - THIRD SESSION. October 2, 1970, Chicago, Illinois Thank you for this opportunity to be heard relative to the preservation of Lake Michigan in general, and to .ermal pollution in the Basin in particular. The Elk River Drainage Basin Council operates in northern lower Michigan between Traverse City and Charle- voix and represents 30 municipalities and almost that many groups and organizations. Organized under Michigan ct 200 in December, 1969, the sole purpose of the Council is to work towarde the preservation of the natural resources the over $00 square miles within the Elk River Drainage asin. The Basin outlet is at Elk Rapids, flowing into ihe East arm of Grand Traverse Bay. This part of the country Is still beautiful. But, even our clean waters now show increasing traces of algae, detergent foam, oil slick, muddy waters and the usual debris of litter which follow man's activities. Tourism provides the main economic base for the area - hunting, fishing, skiing, boating, etc. Agriculture is a mainstay with cherries being the special product. Because of its natural attractiveness, many "downstaters" and out-of-staters are anxious to visit A COUNCIL OF MUNICIPALITIES AND ORGANIZATIONS IN ANTRIM. CHARLEVOIX, GRAND TRAVERSE, AND KALKASKA COUNTIES. ESTABLISHED UNDER MICHIGAN PUBLIC ACT 2OO. ------- 2m 1955 and live in this area. However, preventitive measures must be taken to protect those resources which are attr acting the Increasing numbers of part-time and full-time residents. Because of this Increasing population and the great potential for this increase, our Council is concerned about the future supply of power for homes and industries. Our power currently is supplied by several utilities - Consumers Power Company and Cherryland Rural Electric to name only two. New or enlarged power plants in the Basin could cause conflict in several ways, ranging from the aesthetics to the thermal discharge which has been an inherent part of any power Installation to date. Our waters are generally cold wateir streams and lalces which support an ecology of cold water fish and plants. Any type of mixing zones permitting heated effluent would alter the ecology of the involved area and permit the speed-up of deterioration of the waters because of the higher temperatures. Our Council has not formally been Involved in a detailed s tudy of temperature standards, types of preferable cooling systems or construc- tion techniques. It Is felt, however, that the entire community would support strict enforcement of the highest standards for control and avoidance of thermal discharge. We would hope to have the opportunity to review and comment on any proposal for power plant construction within this Watershed. We urge a Lake Michigan Basin adoption of the 1 degree ma xlmum discharge temperature of heated effluent as recommended by the Federal Water Quality Administration. We are apprehensive of the ability to measure the temperature of mixing zones at all times of the year and so would encourage the measurement of the effluent at the point of discharge. Strict enforcement of the strictest standards will be the only way ------- 1956 in which cold water recreational uses can be preserved and true conservation attempts can be successful. Thank you. ELK RIVER DRAINAGE BASIN COUNCIL Ted F. Miller, Chairman Elk Rapids, Michigan 49629 June Janis, Secretary Route 1 Williamsburg, Michigan ^9690 ------- 1957 Mrs, L. Erickson MR. STEIN: Mrs. Erickson. STATEMENT OF MRS. LOUISE ERICKSON, CHAIRMAN, RACINE COMMITTEE FOR THE NATURAL ENVIRONMENT, RACINE, WISCONSIN MRS. ERICKSON: I am Mrs. Louise Erickson from Racine, Wisconsin. I am speaking for the Racine Committee for the Natural Environment. By an analysis of the ecosystems of Lake Michigan, by studying the huge numbers of carp, alewives, smelt, and other fresh fish, it is apparent to most of us that Lake Michigan is already a lake which is ecologically very ill. Therefore, the Racine Committee for the Natural Environment maintains that thermal pollution of Lake Michigan should not be allowed, and toward this end supports the proposed standard of one degree temperature rise. I should like to make some further comments. First, I am going to make some comments in regard to Green Bay. As you saw Green Bay on the map — the geological maps which were shown earlier — you could see that Green Bay is essentially a very shallow bay, particularly in its south end. I have been in the area of Green Bay all my life ------- 19 53 Mrs. L. Erickson in summers. We have a cottage on Washington Island and I have been in this area every summer since I was 3 years old. On the peninsula, there is a beautiful park called Peninsula Park, and there is'a tower here, and I can remember as a girl that looking off that tower over Green Bay the water was blue as blue could be, and now when you look at the water, it is very brown. The fishermen who used to fish in Green Bay cannot fish there anymore. They can't catch fish in Sturgeon Bay. You can't catch fish off the west side of the peninsula. In order to get good eating fish most of the time they need to go off the end of the peninsula. Green Bay itself must be too polluted, too disturbed for proper fishingo The algae have become thick in Ellison Bay. I swam there this summer. The rocks are just absolutely covered with green. I heard a fisherman speak 3 or 4 years ago at a water quality hearing on Sturgeon Bay. He said they used to cast their nets out at Sturgeon Bay but they can't do it now and sometimes when they put their nets in the water, the fish would be caught alive and a tide would come over and the fish would die before morning in the nets. ------- 1959 Mrs. L. Erickson The algae are beginning to come to Washington Island where our cottage is. I can remember some 20 years ago that one could see the bottom in 30 feet of water. Well, you can't do that anymore; it is getting cloudy. They are beginning to get many carp there on this island which is quite a ways out in the middle of the lake, in the bay. Now, none of this, I presume, is directly attributable to the power companies nor their thermal load that they may place on the lake. But I should like to make a special plea that Green Bay is almost dead at its south end, that it receives a huge load of pollution from the Fox River every day. A statement was made at a Green Bay conference on the lake that the amount of pollution going into Green Bay was equal in biological oxygen demand as if a city of a million people were putting its pollution into Green Bay every day with no treatment. So you can see that the south end of Green Bay is a great problem area* So, therefore, I would like to. make a plea that Green Bay be considered as a special instance of — a special part of Lake Michigan, and that due to its high priority as a problem area that plants be not allowed to be sited on Green Bay and contribute to the thermal ------- I960 Mrs. L. Erickson pollution of this particular area until all of the sources of pollution can be cleaned up. In regard to siting, I would like to make another statement: I, too, bewail the fact that the Kewaunee plant and the. Point Beach plant were allowed to be placed so close to each other. One of these is a double plant, and they all three are fairly large, and so this is, in effect, locating three plants within just a few miles of each other. Now, the thermal effects of this can be rather disastrous. I think this was a very great mistake in siting of plant location. Then, I want to make another plea in regard to siting of a nuclear plant or plants0 There is actually no reason why these plants should be allowed to be sited immediately adjacent to recreational areas. I personally have long enjoyed the Point Beach Park. But when I go there now and have to see these ugly towers in the plant that is already there, I feel that there is a certain amount of visual pollution of the beautiful Point Beach Park. The Point Beach Park is also near to the Point Beach Forest in Wisconsin and isn't a very good help for that area. ------- 1961 Mrs. L. Erickson The Cook Plant over in Michigan is right in the middle of the beautiful Grand Marais area which is being attempted to be preserved as a natural area. The Indiana Dunes are also having trouble becuase they have a fossil fuel plant that is sort of a problem for that lakeshore. Wouldn't it be possible to have our electric plants placed somewhere that is not adjacent immediately to some beautiful area that we have preserved for the people to use as a recreational site? (Applause) I would like to say that it seems apparent to me in reading some of the testimony and in hearing some of the statements at this meeting — I have not been here the whole time — that it is not only the power companies in Illinois that have a monopoly on not caring so much about the envir- onment but I would like to point out that our Wisconsin power companies do not seem to do this either. Then, in closing, I would like to say that I am very much concerned about Lake Michigan as a whole, and I feel that we may be approaching the point of no return. I can remember when scores of fishing boats could go out in the lake and could reap the fish from the lake, and now the catch of whitefish and trout in — Lake Michigan trout, and so forth, is almost miniscule. I think we may be reaching this point of no return, ------- 1962 R. McCandlis We may be reaching the point that Dr, Bardach mentioned for the lakes in Switzerland, or for Lake Geneva in Switzerland, when he spoke of the increasing rate of eutrophication. We don't know but what Lake Michigan may be on the beginning of this steep climb toward complete eutrophicationo So I think we should be very careful and want to preserve our lake immediately before it is too late. So let us say — borrowing a phrase of Dr, Bardach — let us not contribute to the "galloping eutrophication" of Lake Michigan. (Applause) MR. STEIN: Thank you, Mrs. Erickson. Any comments or questions? If not, thank you very much. Ron McCandlis. As I understood it, Mr. McCandlis, you said your statement will be 2 or 3 minutes. STATEMENT OF RON McCANDLIS, PRESIDENT PRO-TEM, MICHIGAN STEELHEAD AND SALMON FISHERMENS ASSOCIATION, KALAMAZOO, MICHIGAN MR. McCANDLIS: Ron McCandlis., I live at 5619 Clato Street, Kalamazoo, Michigan. I am President of the Michigan Steelhead and Salmon Fishermens Association. ------- 1963 R. McCandlis I wanted to take a minute to enlighten you gentlemen here at this table a little bit about how directly temperature affects fishing in Lake Michigan, or the Groat Lakes as a whole, or actually fish around the world, as we are learning. I have here in my hands a typical type of thermometer we use. This is an example of an electronic thermometer which I utilize in my research sport fishing on the Great Lakes for over 35 tackle companies. I do this as an avocation. This is a Vexilar-Z'pnar thermometer.* V/e can measure temperatures from curfr,ce to depths as great -\s 100 feet. You may question how important this is. V/ell, I can give you a good example. V/hen we can reach 54-degrcG temperature water, we can catch fish on nearly any lure readily. I was about to point out this particular tie clasp the second gentleman is wearing. If a hook were attached to that tie clasp, it would catch salmon in Lake Michigan in 54-degree water. Ao you move away from 54-degree water, each degree becomes important for the coho salmon. With lake trout, we are talking about 50-dogree, in contrast to salmon, and we have learned to find the exact Trade naiue ------- 1964 R. McCandlis temperature and we look for a temperature within one degree when we are fishing. Now, this has been verified time and time again0 If you want documentation of some of this, I do have records of my 1,500 documented hour's of fishing on Lake Michigan. A good example is over the past 6 weeks we have had fishing in Lake Michigan as one has never seen before,, Three weeks ago in 10 hours I boated with a single rod and reel over 700 pounds of salmon, 5^ fish, because the water temperature of 54 degrees could be attained exactly with great ease with the lure. Earlier it was alluded to in the question of Dr. Bardach what happens in the thermal bar, in mixing across the thermal bar. Fish, especially salmon and lake trout, stay shoreward of the thermal bar. They will not cross the thermal bar in the spring and in the fall. A number of times I have experienced finding the thermal bar with my electronic thermometers. Fishing back and forth across the thermal bar and, as I suggested, to the inside of the thermal bar, I get a fish maybe on every rod, maybe sometimes on just one or two rods. When one crosses to the outside of the thermal bar, no fish appear on the electronic finder, where you can actually identify the species "beneath the boat. You can note there are no fish ------- 1965 R. McCandlis on the outside of the thermal bar; within the inside of the thermal bar there are fish. Also it was asked of Dr. Bardach and some other people here, or there was a suggestion or possibly an inference, that fish can escape heated water. This is not always true. The best example that I can think of is in 1968, when the salmon were returning to their home streams and the urge of spawning due to reproductive hor- mones in the system of the fish was driving the fish instinctively home to its river. It could not find any water temperature less than 64 degrees. It was impossible during that time to catch fish, and this has been documented, The other example I would make on the — MR. STEIN: How much longer will it take you to complete your 2 minutes? MR. McCANDLIS: I will complete it with that. I merely wish to point out that the temperature i~ vu-y specific; within one degree, we can catch fish. And if you question how many people utilise this, I would like to end my comments in pointing out that on Labor Day of 1967, there were 39,000 fishermen fishing between the ports of Ludington and Manistee on Lake Michigan. Give it some thought. (Applause) MR. STEIN: Thank youc Are there any comments ------- 1966 D. Schindler or questions? Mr. McCandlis, thank you very much. Again, I would say, we are here to hear you out, but the question is that some of you have waited a long time. The shorter everyone is in his presentation the nicer people who are waiting are going to think he is. Dana Schindler. STATEMENT OF DANA SCHINDLER, MANISTEE COUNTY ANTI-POLLUTION ORGANIZATION, MANISTEE, MICHIGAN MISS SCHINDLER: Gentlemen of the panel and representatives of the conference, I am representing the Manistee County Anti-Pollution Organization, Manistee, Michigan. This is a small organization, but we bring this chloride problem to your attention because of its urgency for all members of the Lake Michigan watershed area. MR. STEIN: Miss Schindler, how long will your presentation take? MISS SCHINDLER: It will take from 15 to 20 minutes, sir. MR. STEIN: Miss Schindler, I am afraid we have ------- 1967 D. Schindler a problem here if we are dealing with thermal problems as well as chlorine problems. Now, you can speak on this, but I am afraid we are going to have to give priority to thermal problems. Now, if you can't summarize your statement, I am going to have to ask you to step down and we will have people on thermal problems come first. MISS SCHINDLER: The letter of invitation did not — MR. STEIN: I understand that. I am just talk- ing about when you get on. Can you summarize this or do you want to wait until later? MISS SCHINDLER: I will go on. MR. STEIN: Can you summarize your statement? MISS SCHINDLER: It is immoral for Michigan industries to pollute water that the people of Illinois, Wisconsin, Indiana, and Michigan are going to have to try to drink. MR. STEIN: Miss Schindler, I take it you are not going to summarize. MISS SCHINDLER: I will summarize. MR. STEIN: Thank you. MISS SCHINDLER: I hope that most of you have had the opportunity to review this presentation0 Your ------- 1963 D. Schindler future drinking water is at stake. Our organization took water samples and had them analyzed. Through investigation, we found that our drinking water was being contaminated with chlorides. For example, the chloride testing of Lake Michigan, 20 feet northwest of the Packaging Corporation of America's pipeline in Lake Michigan registered 220 parts per million. Michigan's State-Federal standard is 50 p.p.m. This is compared to the Indiana and Illinois State-Federal standard of 10 p.p.m. Within the text of our attached report given at a Natural Resources Commission meeting in June, titled, "The Unpolluted Truth About the Water Pollution Problem in Manistee," we outlined every problem we were able to find in our area concerning the ground and surface water contamina- tion. Nothing stated therein has been refuted by the Michigan Natural Resources Commission or their subsidiary agencies. In our attempt to stop the chloride pollution of the ground and surface waters of our area which includes Lake Michigan, we drafted a letter to Ralph Purdy of the Michigan Water Resources Commission on June 30, 1970, a copy of which is attached — June 13, excuse me. (See Pp. 1994-1996) In this letter, our engineering data outlined three feasible methods to discontinue chloride discharge completely within 30 days, the simplest and most economical ------- 1969 D. Schindler being to return the brine back to the now inoperative wells, thus returning the salt to the Sylvania level from whence it came. This would eliminate ground and surface water contamination• The MWRC will not issue the cease and desist request which was included in the above letter saying that conclusive evidence of injury does not exist. If conclusive evidence does not exist, one would wonder, then, the mean- ing and the purpose of the water standards. Why have them when if they are violated it is not evidence enough? On July 30, the MWRC issued a letter to all salt- and brine-producing industries. We attach a copy of this letter and ask you to note especially the target date of December 1, 1971, for the "elimination of concentrated chloride discharge." (See Pp. 1999-2000) We have since spoken to the MWRC and have inquired as to what disposition will be made of the lower concentrations of chlorides entering Manistee Lake and River and Lake Michigan both legally and illegally. The MWRC advised that they will probably have to establish a program, but to our knowledge there is no program planned except to ask these industries to voluntarily discontinue concentrated chloride discharge by December 1, 1971. May I repeat that our engineering data has shown that this can be economically accomplished in 30 days. We were not satisfied with this target date and ------- 1970 D. Schindler our next step was to draft a second letter to Ralph Purdy again giving engineering data on how the major chloride producer could alter his process in a minor way to greatly reduce chloride discharge. To date, Mr. Purdy has not seen fit to reply to this letter dated August 2S, 1970. Turning specifically to Lake Michigan, the Packaging Corporation of America is creating a reverse estuarine by dumping 1 million pounds of chlorides per day into Lake Michigan which they purchase from Standard Lime and Refractories. This figure was confirmed by Norman Billings, Assistant Executive Secretary of MWRC, in a letter of May, 11, (P. 2017) the point being that Section (k) of the Corps of Engineers 1956 permit for this pipeline allows a maximum of 5»000 pounds of solids to be discharged daily. We are talking about a discharge of a million pounds. Therefore, it is MACAPO's opinion that the terms of the permit are being grossly violated by this chloride addition. Incidentally, these chlorides are added to increase the specific gravity of Packaging's 10.5 million gallons of paper mill waste dumped daily into Lake Michigan. These chlorides are supposed to make the very dark brown effluent sink and, therefore, disappear. The industry does this with the blessing of the MWRC. You might arrive at some indication of the strength of the effluent which PGA is attempted to sink by considering the fact that in June 1950, paper mill waste ------- 1971 D. Schindler from this above-mentioned industry, in combination with weather conditions caused a fish kill in Manistee Lake believed to have been the largest fish kill in the history of Michigan. The 1956 order of determination did require improved waste treatment facilities but nevertheless please note particularly that a September 1963 letter from Mr. Purdy speaks of the improved condition of Manistee Lake, explaining that portions of the Packaging Corporation effluent had been diverted to the Big Manistee River and to Lake Michigan, as these bodies of water, he states, "... have ... the capacity to dilute the salt and assimilate the oxygen-demanding effluent." (See P. 2022) Since this letter of 1963, our Nation has become aware that our oceans and Great Lakes do not have this sempiternal capacity, that our earth and water and air are limited in what they can supply without care, and that we are drawing close to that limit. We hope that our Water Resources Commission would act according to this knowledge, even if it would mean reversing previous orders. And yet when the Packaging Corporation of America completes their $6.5 million secondary waste treatment plant in December 1972, we have been informed by Donald Voigts, their Environmental Director, that the brown color of their mill effluents will remain and that the chlorides cannot be discontinued; that they are "necessary to sink the color." (Out of sight, out of mind.') ------- 1972 D. Schindler We are not saying that Packaging Corporation is not doing something about their pollution. Six and a half million dollars means they are doing something. But we are wondering if the priorities are correct. Just a minute more. We are gravely concerned about the continued addition of chlorides to Lake Michigan as this is a freshwater lake, and adding a million pounds of chloride daily is bound to have ecological consequences unnatural to freshwater. I asked Donald Voights what he thought a million pounds of chlorides entering Lake Michigan daily would do and what effect this would have, and he shook his head and said, "Nasty." Ecological consequences are of utmost importance especially when ground water contamination of the Manistee area and no doubt dryness and various misuses in other areas will force the Lake Michigan watershed area to rely on Lake Michigan for drinking water. Our concern is multiplied threefold as a result of MWRG's Regional Engineer, Robert Courchaine's statement to MACAPO's secretary, that the MWRC may consider exempting the Packaging Corporation from the concentrated chloride dumping termination date of December 1, 1971> "as it might ------- 1973 D. Schindler work a hardship on theme" The temperature as it leaves the factory is 90 degrees. Charter boat fishermen have said it is 4 degrees higher than the surrounding waters. MACAPO has no desire to shut down any industry. The industries are only doing what the MWRC has allowed them to doo The economically feasible, technological methods are available to stop this willful pollution, but it is our opinion that the MWRC has placed the people of Wisconsin, Indiana, Illinois, and Michigan, second to the special interests of industry. MR. STEIN: Is that the conclusion? MISS SCHINDLER: It would seem a most reluctant attitude — One can only conclude that if this — just a minute, please. The scope of this deterioration is not by any means a local problem. Those of us who have taken part in this Four-State Lake Michigan Conference can readily see that this vast volume of high parts per million of chloride can saturate the total volume of Lake Michigan. One can only conclude that if this continues and no cease and desist is rigidly enforced, the whole of Lake Michigan will approach and surpass the high chloride ------- 1974 D. Schindler standards set by Illinois and Indiana. In conclusion, it is a sad state of affairs when the attitude of our State agencies is that of the old cliche; Speech is Silver, but Silence is Golden. But this is an era when something must be said; more importantly, something must be done. I thank you for this opportunity to speak, and we hope with your help that all pollutants of Lake Michigan will cease and desist. (Applause) MR. STEIN: Thank you, Miss Schindler. Are there any comments or questions? MR. FETTEROLF: Yes. I do not feel that a total response to this is called for at a conference on thermal pollution. But very briefly, I would like to say that in response to the letters sent out by the Michigan Water Resources Commission in August of 1970 asking the salt companies to enter into a voluntary agreement to virtually eliminate their brine discharges by December 1971 have been responded to, and the companies are investigating various techniques and will submit their plans as soon as they are prepared. Now, once the plans are submitted, then we feel that these voluntary programs will then be incorporated into an enforceable stipulation by the Commission. For ------- 1975 D. Schindler various reasons it is impossible for them to go ahead immediately. The areas are simply not available for them to dispose of their brines, but, Miss Schindler, there is one area in which your organization could be of a great help to the industry in that area: the Packaging Corporation of America is proceeding with plans for secondary treatment and disposal of their wastes. They are having a very difficult time in having any of the townships agree that they want this treatment facility on that land. If you could perhaps work with the local officials up there to aid Packaging Corporation to find a suitable site which could be properly zoned, this could certainly expedite the matter. MISS SCHINDLER: The people don't want the Packaging Corporation clime because it creates a horrible odor and it kills the trees. It is brown, untreated effluent, and no township is willing to accept this. And in response to our statement about finding ways to return chlorides, or eliminate the chloride pollution, I am wondering why Mr. Purdy will not respond to our letters and what is wrong with the five or si;c methods we have suggested for eliminating chlorides? And it does seem that there is no more ------- 1976 D. Schindler technological method than simply returning the salt back into the wells from which it came — the inoperative wells. This would eliminate ground and surface water contamination without any problem at all, and our own engineering data has shown that this can be accomplished in 30 days. We have received no word from the MWRC as to why this plan is no good; if it is no good. MR. FETTEROLF: I would be pleased to take this up when we get back in Michigan, but in the interest of time — if that is your attitude, I would be glad to go into a detailed explanation of this. MR. STEIN: Are there any more questions or comments? MR. CURRIE: Yes, Mr. Chairman. I find this testimony profoundly disturbing, and what I find disturbing about it is the possibility that any such things as- described in the testimony may be happening to Lake Michigan. I think this conference once again should be urged to reconvene at an early date in order to consider such problems as chloride accumulations and chloride inputs to the Iake0 I recognize that this is primarily a thermal pollution workshop. I think we have to get back together very soon and consider all our other problems ------- 1977 D. Schindler of Lake Michigan, and I would urge the conference to recon- vene soon in order to determine whether or not there has been compliance with the deadlines set down by the confer- ence itself in the past and, if not, to cause legal action to be instituted wherever necessary to assure that compliance takes place; and finally to reconsider the adequacy of the standards themselves. Again, I would like to note the comparison that Miss Schindler drew between the Illinois standard of 10 p.p,m, of chlorides for as long in the future as 19$0, a standard which I criticized yesterday as too lenient, and the Michigan standard of 50 p.p.m. (Applause) MR. STEIN: Mr. Currie, I have always said the four States up here had some of the best water pollution control programs in the country0 I spent a good part of the fifties and perhaps some of the early sixties down in the southwest dealing with oil well brines and salt pollu- tion on a massive scale. I thought we had that licked. I thought we had the remedial facilities down there with reinjection. We have cleaned up tremendous oil fields where we had brine problems, and I surely hope the States can do this here without any assist from us again because we hate to slip backn (Miss Schindler's report follows in its entirety) ------- 1978 THE CHLORIDE CONTAMINATION of Lake Michigan at MANISTEE, MICHIGAN Presented by Miss Dana Schindler representing the MANISTEE COUNTY ANTIPOLLUTION ORGANIZATION (MACAPO) of MANISTEE, MICHIGAN PRESENTED TO THE FOUR STATE LAKE MICHIGAN ENFORCEMENT CONFERENCE September 23 - October 2, 1970 at the SHERMAN HOUSE Chicago, Illinois ------- 1979 Representatives of the conference: It is immoral for Michigan industries to pollute water Chat the people of Illinois, Wisconsin, Indiana and Michigan are going to have to try to drink. I hope that you have all had the opportunity to review this presentation. Your future drinking water is at stake. When MACAPO was founded April 29, 1970, we decided to tackle the worst pollution problem our area had; water pollution. We didn't know what to look for. As one of our members put it: You can see it, You can smell it, It's NOT water; It's something else? So we took water samples and had them analyzed. A copy of the analysis is attached. Through investigation, we found that our drinking water was being contaminated with chlorides. These chlorides come from salt producing industries of our town; namely Morton Salt, Morton Chemical, Hardy Salt and Standard Lime & Refractories. Within the text of our report, "The Unpolluted Truth About the Water Pollution Problem in Manistee," we outlined every problem we were able to find in our area concerning the ground and surface water contamination. Nothing stated therein has been refuted by the Michigan Water Resources Commission or their subsidiary agencies. A copy of the report is attached. In our attempt to stop this chloride pollution of our ground cind surface waters, which includes Lake Michigan, we drafted a letter to Ralph Purdy on June 13, 1970, copy of which is attached. In this letter our engineering data outlined 3 feasible methods to discontinue chloride discharge completely within 30 days. The MWRC will not issue the cease and desist request, which was included in the above letter, saying that conclusive evidence of injury does not exist. Copies of their letters to us of June 18 and July 30 are attached. In early June we also learned that the MWRC had just completed a 2-year study of the Manistee area to determine what was responsible for the chloride contamination and what feasible methods could correct this. On July 24, 1970, after much pressure on the MWRC from our group, Ken Childs, Geologist for the MWRC presented his study in Lansing. His findings, opinions, and recommendations are as outlined in our news release dated July 25, which is attached. ------- 1980 His study confirmed everything our previous reports had already brought to public attention and then some. Also attached is MACAPO'S presentation to the MWRC on The MWRC then, on July 30, 1970 issued a letter to all salt and brine producing industries. We attach a copy of this letter and ask you to note especially the target date of December 1, 1971 for the "elimination of concentrated chloride discharge." We have since spoken to the MWRC and have inquired as to what disposition will be made of the lower concentrations of chlorides entering Manistee Lake and the Manistee River, both legally and illegally. The MWRC advise that they'll probably have to establish a program to take care of that. So to our knowledge, the MWRC has no program plan except to ask those industries to voluntarily discontinue concentrated chloride discharge by December 1, 1971. By figuring the daily chloride discharge to Manistee Lake and Lake Michigan, these industries now have the green light to pollute YOUR drinking water with over 1 (ONE) BILLION more pounds of chlorides before they legally must stop. We were not satisfied with this target date and our next stop was to draft a second letter to Ralph Purdy, again giving engineering data on how the major chloride producer could alter his process in a minor way to greatly reduce chloride discharge. To date, Mr. Purdy hasn't seen fit to reply to the letter dated August 28, 1970, which we also attach for your perusal. Also attached is a copy of our letter to Governor Milliken dated September 1 , 1970. We have been in contact with the Corps of Engineers, our United States attorney and the Federal Water Quality Administration, urgently requesting their intervention on behalf of the people of the United States. We have been advised that a federal investigation of the Manistee area waters is scheduled by FWQA, although we have no specific date when this will take place. We have furnished evidence to the Corps of Engineers and requested an investigation of the waters surrounding Maniotee so they may furnish our United States Attorney with proof of violations of the 1399 Rivers and Harbors Act. To date, we have received no confirmation if or when the Corps of Engineers will investigate. The United States Attorney will not act until the Corps of Engineers furnish the evidence. The Packaging Corporsion of America is creating a reverse estuarine by dumping 1 (ONE) million pounds of chlorides per day into Lake Michigan which they purchase from Standard Lime & Refractories. This figure was confirmed in Norman Billings' letter of May 11, 1970, which is attached. In 1956, the Corps of Engineers issued a permit to the Packaging Corporation for their present 24 inch pipeline to Lake Michigan. Section ------- 1981 of the permit allows a MAXIMUM of 5,000 pounds of solids to be discharged daily through this pipe. Therefore, it is MACAPO's opinion that the terms of the permit are being grossly violated by this chloride addition. Incidentally, these chlorides are added to increase the specific gravity of Packaging's 10-1/2 million gallons of paper mill waste dumped daily into Lake Michigan, which is supposed to make it sink and "disappear." This industry does this with the blessings of the MWRC. In Manistee Lake in June of 1950 the paper mill waste from this above-mentioned industry, in combination with weather conditions caused a fish kill believed to have been the largest in the history of Michigan1 Please note that a September 1963 letter from Mr. Purdy speaks of the improved condition of Manistee Lake, explaining that portions of the Packaging Corporation effluent had been diverted to the Big Manistee River and to Lake Michigan which he states, "have the capacity to dilute the salt and assimilate the oxygen demanding effluent." Since 1963 our Nation has become aware that our oceans and Great Lakes do not have this sempiternal capacity. And yet when the Packaging Corporation completes its $6-1/2 million secondary waste treatment plant in December 1972, we have been informed by Donald Voights, their Technical Director, that the brown color of their effluent will remain and the CHLORIDE CANNOT BE DISCONTINUED; that they are necessary to ...SINK THE COLOR: We are gravely concerned about the continued addition of chlorides to Lake Michigan as this is a freshwater lake, and adding 1,000,000 Ibs. of chloride daily is bound to have ecologi- cal consequences unnatural to freshwater. Ecological conse- quences are of utmost importance, especially when ground-water contamination in the Manistee area and no doubt dryness and various misuses in other areas will force the Lake Michigan watershed area to rely on Lake Michigan for drinking water. Our concern is multiplied as a result of MWRC Regional Engineer Robert Courchaine's statement to MACAPO's secretary - that the MWRC may consider exempting the Packaging Corporation from the concentrated chloride dumping termination date of December 1, 1971,"if it might work a hardship on them." MACAPO has no desire to shut down any industry. The industries are only doing what the MWRC has allowed them to do. The economically feasible, technological methods are available to stop this willful pollution, but it is our opinion that the Michigan Water Resources Commission has placed the people of Wisconsin, Indiana, Illinois and Michigan second to the special interests of industry. Please refer to the news clipping which is attached as ------- 1982 -1983 one further example of the ever complacent attitude of the MWRC In regard to the pollution problems of Manistee. Even after an exhaustive 2-year study by their State geologist, pointing out the extreme adverse chloride and paper mill waste deterioration which plagues the surface and ground waters of our area, members of the MWRC now take to the public podium to reinsure the main chloride polluters that any small gesture in reducing the chloride parts per million, whether by adding a volume of water or other devious means to perpetuate this facade upon the public can now stand reassured that the courts will take no action in public or private suit for cease and desist of chloride contamination as specified by MACAPO and highly recommended by their state geologist as a first step in the restoration of the waters of our area. We of MACAPO feel that this is just another gesture by the MWRC to gloss over the major problem of our area, by usurping the final verdict of the courts of our land in favor of the continuation of this most immediate deteriorating pol- lution problem of our area. The scope of this deterioration is not by any means a local problem,as any of the States bordering Lake Michigan who have taken part in the Four State Lake Michigan conference and are concerned over the chloride parts per million can readily see that this vast volume of high parts per million chloride can saturate the total volume of Lake Michigan. One can only conclude that if this continues and no cease and desist is rigidly enforced, the whole of Lake Michigan will approach and surpass the high chloride standards set by Illinois and Indiana. It would seem a most reluctant attitude on the part of the MWRC to ignore the major problem by inserting other pollution problems of the area, rather than attacking those which have been exhaustively researched for final and conclusive analysis as to their ultimate solutions and corrections; such as the chloride problem rather than the sewage problem which is a universal problem throughout the United States and the world, and it is a handy pawn to cast into the foray of pollution problems so as to create a diversion while the major stigma of our area runs rampant, unabated by any such firm cease and desist of chloride pollution. It is a sad state of affairs when the attitude of our State agencies are that of the old chliche..."Speech is silver, but silence is golden." But this is an era when something MUST be said and something MUST be done. We thank you for this opportunity to speak and not be silent. We hope that something will be done in the immediate future. ------- r. D. W'K'ttS^lPr '-1! •^•'^ ^ \\' I L I.I AM S & WO K KS I . "4 o I - N F I. R S - 0 U KVCYO R S . — P L A • N NER-S 250 MICHIGAN ST KEF. r. M C GRAND RAPIDS. MICHIC.ATJ -I'lOm TELEPHONE 459-4.-OI May 22 1970 E-75650 Mrs. Carol Magnus 103 Sibben Manistee, Michigan 49660 Dear Mrs. Magnus: Subject: Lab analysis for Manistee County Anti Pollution Organization Enclosed please find our lab report covering the water samples you brought to our office concerning subject project. Also included are two sheets of "Water Standards" published by the U. S. Public Health Service and State Water Pollution Control-Board, Sacramento, California. The cost for this analysis will be between $70 and $90 for which a billing will be issued shortly. Sincerely yours, WILLIAMS & WORKS - . U.' •- v '- '-• •(<>• •- • - '-'•' F% Winchester 1ml Enclosures DlRFCTORS T C 'WILLIAMS t 1. THOMPSON, G. H STADT, K. W ANDERSON, M. M. CHAMBERS. F. E SPICER. K l f'LloIT. J A MtrtDZINiKl. Z R. MILLER, L. VAMIK HORS1. A. O. HU5IVCDI ------- 19S5 Client : j,t>ri.-<- ' U-L v/V LABORATORY DLl'ARTMHNT Water - Waste Water - Soils _ Project No. Date: •?* Chemist: 2) A) ' /)g SAMPLE 1 £ .57 /£_ ,» * •5s 3 ------- THB UlTPCLLUySJO ^:710Ii ABOU'? 2K.3 Esor^rt of tho XIijT^ CO-^T'/ ^^21 i-OJ.-LUVIO:! JCU.C— '.:;'-T.y:j ^ CC.'IIISSIW ------- LA - /.'-"I"/ 5/M'f" n CT c ~ '-> '•'. c/ i- C.V.'.' ------- 1988 a-ci S'5-4•-. The folloificg repsi-rfc is h® "^sult. ef rsmy h^urs ef ie^'-r'jsg, questioning, and i^.l-c;:? wslt-itigo Ssiia ef oiiis data vas c KAO/JPO has epeat a g-osl. dsal of moasy having wa'ier samples 6 "The Galas-Ida Isvsls indioa^sd la this' report s-.ra part ©f thes rc-2 J-J-5 uie Jraep ta ciind that taas® tost easiplea vars tekea^ca a -Saturday an-i £iitiley and nst during ths ^^icaal full pT-ofiuc^loa wsoka Wr-Jill stars eur'presaata'siou at Lake' Kic-higarx aad vsrk-.ouyteay' vjs ifce Ji^nlstea ehiar^nej. arid Into ^fenisc^as L?Jcs"3. Ear 195?8 tha Paeki%'].r-3 CJo^pivratlca ©f litasloaj, ?il©r .Gity plant;, vss is^it-a an Order of D9terju.luvtisa.by the Ml obi 323 Weter -Eescs arses Cs:assn .to ccii Jlr.i«t aad maintain a 5'? ineh pinallna frriu tla-air J?ll«r City,plant ts t© )tarjl:?t of "e7apcrater'-riadfinsaie frsn cbenical .rscovory ec.;l rri^'ral black sulfits .Liquorss pulplu^ aarl blacchins irest« 3^5 sulfita 3«a.i»ciie^!iQal and -.r?.'ifls 'Dsoem^'sr 19&3> the Wt'fe^r ?ssc ureas Csjasio dlaausas'tSstQd "that tia". K-,3 vid ss irabls sdcr* sjid vc-l-azs 5.n. Laic's il3.clil,ssji3 &3 a result c ta«.« P3l.disc'saz-g'?!, v^ys dc."'<:-lm<5ntal to asa£ 33lns icads csf the !afc®e P'QA f'io ;^«iiu-st^a tv take serra^tive a?stdsno. 2ha compea-y prapessd t7 :E'S Kjirsai 8illir,gsa l.rfctev to izs ef May 118 19700' Trtis 30 inch pipe!3.a« Is supposed tc bo eU^Qked aoauallyo aj>'f riling to. KXRO staff eus'ifisers Geerge HdclS;, this outfall hej nst bsij sjhac'ked fer 2»>2^ ycar":->0 «yc Llddle statofi at sur iteefeiag Kay 23tf ,19?J tiif.' Its is satisfied In hla tzyjwlsfiga «.f whet tJis outfall co si it soes no r-eaBcn ta eaoipl-^ this n^w t.oeau.ss a PCU. ssca il .plant ie ta be in operation DaGsabe? Ij, 1972£ ------- 1989 ivs en E3.ll sr;ill s^splala af c-fivir end water diseol&ra^lc Irs ." s.vfear bffiafe fisfc.er.r5 a' advise thai; tinder osrtsdn eeu.clItioJiS 8 .this •".-". s f ^crat^ojj Rictecfs ffpii ib.3 otsifall as far smth as PTaa:fe.ri(, ^(VcLgaao I'he sharper tea's fisherasoa alas ad/isa that, they hare seen and Sf:"i le-yad papor refiise fr^a this area ©f feh© cutfall on.' asay aceaaianso H,«5 hf.ve also taicsn vatar teap era tares at this out-fall asot adrlaa that tsti^i 3 io afecsut a A dagroe- Mglxer sempsra^arg at the Csutfall than in tl.c i;i[a£ent watar area^o It. 2s eur conte-Zitioa that'ths reereati-^aaX use of this araa '«Tf IH-JIS Michigan has bean sovc-rcaly iiapair-sd by th'ls outfallo A ehlorids If -7-5 1 of 220 rag/?. Tras tsflsil s.''s this I©satl3a0 At cur Q«stlng M.iy 28, Geergd Liddls ifs^ asked if he was aware e£ 1ao l'i-ct. that a numbsr cf pEiirats residejxees tmd the U0 S0 Coast Gtiai 2, snstisn on ths end ©f Fifth Avenut vor@ pviunlng raw sawage d:,«s";l~ iato ths Kaaistss 5iT8rc He said tha* he was awara of this f u«1 3 Shsra -is a fircie ths Kanistea Plating boapsiiy-., vhlch-.-ls located ©n tii 3 I-Isaisfesa &-srsrc Aei-crdlias to the ,!-!ie!ilgai3. Daparfeia^at of Has.* t"a A3,r Pellutisa Surysj^ ©f 19648 this company usas the fellowlag Kydrcehloric Suifuric Aold Gi^zgo Lf.ddls was asicsd at v.ur ngatins May 289 "What d© th'«y ^g. wltl thoir vasts chealeals?" Mr0 Liddle than ajslsed v.ga "De yfeu know i" 'hay e^ tc tha lefca or ti the eaaitasy syEtem?" He tfi®n said "?a: b-ii33 we tsusht t& loci into thls0" This platlag CQiapanya being .ta.i tin the .nsrth side of tha ehaimel is in aa area of t©wa vh«re 9 If not alls, ©f the ssTrags is diaaped raw into the eh anno !„ i oi-23 llttla diffsT^eneo T.-hat vho plating e@mpj>ny does with their : «3:aty it still es.uld ge'5 to the ehaanslo Ihis eempaay eould ba "9lfiiia0 cur •Jfsr^y is that they haven °t been «hseksd0 In <5he lianistee Eivar there are a group of aduotor pipes located fcha Memorial Exldge0 Th5,s Is tha disc,ha^3 pcint for 387oOOO 3 ».f ohlo rid ea par day^ 1'we of' ths iadustrlas using these pipes ara S2iai ------- J.990 { 5';,, a "te^il Mass sells to-la -c 2QA to sink i;;s pollv,taats IE. Ls!:a. Michigan,,-) .Echigpa Tcol Ocijoif.'-'AOag a diirisica -:f Manistee Irsn Works is l'»«?«".$ id ©a Kaaistes Lak&j, .;t ths asouth of cap Mania-fees.Rivaiv This e/jsne;^ Is aoms^aa'fe of aa taku&vn, quantity with our greu?0 Thsy ar^ b3£'..aaias "to> landfill part of the lalso and vs suspeot th&t ssae ssrt- of f-isshargej, perhaps cII8 Is cennectsd with this operation but as yat 10 tannet say for osrtain« Michigan Ch>3cii©al is located on the east shsrs of Maaietea LaSe0 ha3 issued an Oyde-r of Defcerainatlaa for their discharge' iat3 Laka0 Ths eheaic?.! they -.prsdU'Se 5,3 l)TO"a.ine0 -The.state tia tlislr disoaar-gs is "iasignifloanto* Hs-^vers, the state alsa tli&- Ihoy d© nst phyBic^liy sample thesa pljjgs asmually0 We hars had rsp? r-is that this filsehas^s pipss.dees Q2aAt br4E.ss sometiass in largs q.acj .titles, but ve have not, .as yet iaade- a psaitivs chssko Haydy Salt is located on-the west sh^ra of Msjaiste© Lake and ire bal. s?a this company to be a chief offender es 6s chloride TTia. Sss.e of Michigan hs,s na Order of "Detenainatiab. fer th^ir c,ra water tests analysed by a private la'ssratezy show this area ,slaai3taa-Lalc:ep plus waste p&nds aheira cu fefe 5a addition to its 30 :lnoh pipeline into lake Michigan,, «hlXe -the ;rlds leiral shsxild be leas in this areaB our tests ohov 50 ?..* es \ndlcated on our Taap0 ihelr dlsehexgs pipes into Kwiigta contain @n©iu;;h solid materials P© as to have fosaad «, Iftstfii ft ,«aulle eati©a0 This fill eztends^ at least 25 yar-.U iota tho ------- 1991 ta,te.'~ • ::.:> vb, ycxincUr^s" -^ this 25" yaztl p»iat9 s 5,15s - ri': t a agr^-adc. In a^-I.-y.pi', -islv Si-; £ 'i.v'ry " rssicraSj, i-axv ri^'.'lgS _ ttf that arounet 1952 -fas State ef Mic>tijga,a g&vs PC4' 15 por oea-s of the flev af tlie "Llttla Mtnlstaa SiTsy.rs tfc'e sr pradu^tion ©f papciro Tv^ vsa at -Is^-st 1,000 erlea. is il 3 rr &r t;f Vsils'a 33 '§3-3 -to b.j'u 'fast or 3© at^va th^- wit r ;. "k^a '2b9 fill r>at-;-:lil is . " * > Iv i,.a ^6 consist Esst.1/ v.r wssd fits?? ^cd Q3.k id,th as^lltr f..-s -ia' e* £,3=-vuile vn:ri,e0 Th« f'.ll py?seatl7 e-rtsnds i«j tha. «dg« of ». «;--.! « ss? ai.- fhia fill S3 fcelT^ u'.:uapsd dlrsetliy late -fs.tEr<> . -;»ra «?•= sir £.1: rriuu-il'j.,.; tiriu^h "shH; ^'irsho feTe e-^nt^n-l that th« fill i--^. --,•" ,1 17' ii <::' ih? /ill ar-3 lei;,.- th "ardlaiar/ 'ai^h 'n,fsr kis- 1 :;• j«:9 tbs ij-jdea haa nr-? 7>3t B-^guji %h-* aur-Ts,/ »n4 lit; L'- .U landfill as taar ^.-'s-anisAtlea rs-iu^BtsA la '3ar latter t®. .,, ¥15' k- r <* "/--v f 1CJ7'(> -i ~« »' -- s.i'3 t v-3'v.,liji%3 sariy va^i.^ Siqusra frotn -,'OA s f)' ; a XyH,r>"0 1'htJi^ is rJ?e<:;a to b«H«ve a.il fe vet a rigid Laapgeti-sia schsd^le has i. vt l^rOp ar:u.tar wall ser .)' );v-ic Tiis mitsr ffR3 a tl^sJc eslcr -ac. h ,1! -,f.i 1h 5aat of their r.las% art? t • uc.iit ;'sr Tb- wall v^ax bsd j---,ei -^' -~r .&st, c,. P' WE* j ' •;.; disturbed bj a 6, r^lias' "4,0 incrs-aae djv:i1n9.-;e inta ih W; s TT net -pa^ltlTa this was tho cauae8 b^.A ths "^i e- m 1 si'°,en0 ------- 1992 1 £4.ia/.pira.B3 th-;.?. o zmh POA fros uhss.e 1 . discharged to Lake Michigan sad to Korion Intoraatleaal £ x-en '.e It sTgafeually enters Manistae Laks or ths M&als-tee Jlivaro hsrs t?3$td othar pipes eomSsg • farom Sfcaadard Lime with ona tssfe l^.sJ'O ppm of hsxana extS'aotablss (dll)0 Standard. Lime h33 alsa fill d ;>a:ct of the laS:ec pips souit la 58 to dates with 4 pipes arssently disc@ygr®4 In t » l-lanistes Blve3P0 The^'3 are ©nly the pipes that are' ab©Ta vat©rc T^3 < f those pipes ay® leaiuig ell lat-a Msalstea Lake0 W Mr0 ; Udle that ws ars will Jag to furnish a beat end personally hij •© iihos® two oil pipes 9 ©f "Whleh ha is not aware0 When-ws >Ir, MadlR if lie was going to shut down ths 38 Illegal pipes that hs dlia-t Jacw a^^ufe he rsp23.edu "N«p I caa8t shut tlism dawn until I tai&v vhit li eomlng out ©f them0 w 'this Is In spite of ^he faet that the ce.ip. al«s haTe eonstrueted illagal disehargg pipes » and that thsy n® 0. dsr ©f D®te2tt.lQatl©n tc esver their disehsygSo A3 you G0a.S3S from th-s absTe,, we da ha-re a various pr@blea0 Ouif : air has bsen landfilled by Ind-astxlal 2fubblslis polluted by talsy fj^ra raw elty esirage "t.e high pateuey ehemicils and ehl©rld§p0 Ons ( f -Jiho VfilO bl©l©gists9 Michael Nswton admitted th-at ttueh ©f the bottia is dead and the rest af it is bslow aysragjo Thielc sludgs and seit! l:^s fa^m these Industrial psroesssea have e©it;ed the bottom of ttt-j ra^po For exaapl89 off tha Hardy dlsobaxges, 'she daoth s©uad«r go js fixm 42 feet to 18 feet t© 38 feetp ijadlcatias a substantial b® 5',t a buildup Wa do not willingly sat th$ penflah in Msaistss I>a\;a b'?5tt so of their bad tasta.0 ------- 1993 u AT. & gr»wp8 va ara susQied and disgusted by th« "roadblocks threrea. c We ar® disgusted by svasira- end by departments vhleh naie up thai? «r>fh. rubles tfhioh are "net S2i>f.i£j.e£lly.witten Into the lawa end by Siate afflciala vlio tali its. tli at if,perts aad answers we ask about are Maone Qf your, bus in«S30" tfii r:a,cji at tlis Infer-anea ^hc-fe we ers not into3.--igi3at enough to raad aad e-yalUvV e' stats repoxrss<, Si-nee tais papsr wss ';rrittens •we hava fcnoxd ssm»""or th.s extent ©f em" ehlsrida problem te l!anist^a« The city has had t»» water- w®ll3 t'ss-- art tea salty to us$<, We have found that thora Is, an extenaiT.e c'il- arlt'Q report that Is a&t yet"completsd0 Once ehlo rides se^p into 6ir d^'niclag watafg >«•« -Kill be 3,E t rouble 0- -Wo-h-^va found that sur li^ shifts cwuld puap thsir ehlcrldss bacfe dc'tm .Into the brine valla tfia: « <:.hny csaa fr&s0 Th-uy could stop this chloride pellutloa within a v ry short tlm®0 Th« tlr.3 Is n©v t« fore© ths^i to do thisc This wil', a;-uae thea a©ms expanse and they won't gat 'fehe revenue fr©m this wis- 3 Vi'iJis as th$y do nsifc But vs nust stp tnls ehlc-rld® pollutiss o? * u ^ drinking vats^p en® of ©ur nsest nesessar/ resouress0 - ON -w-Km ¥.' cant and that the Psople of tho State of Michigan and ©ur dia'al; hCJog natural i^oscTirosa hs.Ta been plased s seend to th® spsoial lit r^: ts" ef inauat-iyo We' hsrely roque0t a cemplete investigstlen af t"ie Mi Mgaa Hatar Basouces GoEasission9 as the M,U000C0 will pr-9?@a«, fe^ Jb-3 aaylieat possible Eorasnto T..6 time is now to put priorities in proper perspeetiveo W« M7S-"1 p--,t an end t© this prae-tioe of State ponaissiveaeps t©was4 industry c Wj hays Iaw30 Since you fully enforce them whers the prlrat -alS ',*•'. is eonesrae^j, thsn we D£MAJJD y@u squally anfsres th«a iid '.at-.yo ------- 1994 Ti^ CuUMTf Aiv'Tl POLLLi'i'lOW (MACU'O) Box 282 I-ianictee, jiichi^an 49"»0 June 13, 1970 • \T'\ f"\ v ,, ., Kr. Hal ph. ,/. I\irdy, Executive Secretary v •' , ' ' Uater j\esoui-ces Co^.assion / I / ,.^ \ Stevens T. Ilacon BAilding- ! v •'' { Michigan Dear Kr. j^urdy: Wo, the ircmbeas of i-iAC^'O, request tha/i, the Water Aesources Commission, give most urgent consicseratiou to a Cease ana Desist Order of Determination for chloriae tatposal. by all industries in i-,ardstee Comity. The time period for the uease and. itesist oruer shoulc. be liberal, thus beariii,, .TO hardship on any incuLtiy aiu <;Q ru^ .-/-3t tne c^nf-JLO'^ration 01 a JO uay Li-ue period, et^cctive July 3'J of this year, v/nich is norc than rraple to coTi^ly with the above oraerx- in our opinion. [.'he Cease and Desi&t orcier should be explicit in the elimination of chlorides beinc disposed in the following areas: 1. Laice Kichigan 2. I-ianictoe Las.e 3. ' £i£ Kaiaetee fiiver 4. Little kixnistee llivcr 5. Any lana area of hanistee County where seepage or process of osuosis vill allov; cnloricies to ccntasiriate adjoining waters and/or properties above the iiylvania level. To cay that the ?.bo\e Ccare and Denict orcer IE not practical or i'easible because of the reco!O..cnc1-:ci J'J d:\. co:n;>lif:r.ce period, XP to oelittle the .\n^-enuity 01 free enterprise aua tiiaL old iiuJste laiov; h;» in. ^et'vinj a jo'^j c;.;, . il'Li 'o liio i. .(in. trif n ol I • ni •. te-: cr<- v -.'!ii_ tr_':th- r in dic;-^-inj 01' crJ.oricPS into the surrounding waters of this coiuity and Lruce i'dcrd^an, ic s^eiiis onl> equitaoie that they shouLa WJI-K jointly in the coifipliaaice witu the Cease ana Jebisi oruer ana acco.-^lich B?t.'.a f'jup in tht- ctbuve pe.aocl o:' ^J a/.ys. ii' i.l;tio 1;; a J-'.c.; OL i • ].:.•: lion Ox t'u. c iu i.vu-...-,:^, It- t. u>j t- c t'-.e J.^ ' >r n^_ T v.rh to the problem as the simplest solution wit hi very well be the cheapest unc. uost practical. Therefore, tlie folJov/inr plans are subiuitled for solutions to accompliening the Cea^a nii'J iX:::i£t oi-oc-r vii; in the ti-;^ p( lioa allowed. 1. l.ort'.in &ilt mid ClciMct-l, ataii«.''.ra LLno and ;efrBctoricc, ana Karuy oalt arc tU* irtjor chloriue dia^orcrr. to the aiiovc liieutiuac-u v.aton;, tuiu luuroiore, should wor.. jointly in the solution of t:iis probli m« ------- 1995 pace 2 iiaJph \i. lloray A. Horton iiilt cc Chejaical, have in their possession, abandoned salt wells below the Sylvania level capable of receiving waste chloriae ana chemical solutions. B. Standard iiime has in their possession cnemical brine wells that are pUFipin^. on a marginal oasis. These marginal wells could be tbe recipient of tail brines wnich v->ula erhance the static level ol the fiela .within the near vicinity in the Sylvania level. C. La; dy ,^alt has a variety of wells, .some of which are not conducive to the production of quality proaucts ana could be used for receiving excess chlorides and/or chemicals. 'Kierefore, each of the above industries has, witnin its own industrial complex, some facility by vmich the aauition 01 a pump and length oi pipe cun retum the excess chloriaen end waste ohloric.es to the strata from whence they came ana meet the pO day cojspl.iaace period. Tnus the cost annually would be the Dumping of these proaucts ana by-proaucts to tho strata arid tne luss of a slight s~mount of money from the profit column of their annual statements since tnece cliloriues •will not be sola for the purpose of hiding other industries contaminants. 2. Providing imagination is lactcin£; for the §bove program by which each industry v;ouJa have to proviae has own pipe and pump, the following method is suggested. A. de jointly owned I." pipeline v;nich presently icstoons i:?.l v.cll, \'T.Th S-4, o-^, :>-o or S-2, v'nich air; all close to 3-1, as a stanaoy well for alt '•".•'4 "'.to Li?f-o~r'} ;ii.-n.-^-.e-,j tv'ur- allowii\. tl e ijf« oi one ot the above mentionea veils as an alternate wnile pieventative maintenance is Deing per- foii'H;u on .j-1 to iai''Utain its £,ooa receptive properties, ihus by selecting I>1 cir.d or,o ol t'.c raoi • :'^n"v i ^r.eti r. "r.j"i.i-1i pjoauoiu^ veils ar a aitposal systea, the area vuula be ensured of continuous and complete oisposal of < c; •- i .id i: : '•: t. !ovi..t'.'. nn !„••.; .'•'•... If thu abovt; t\;o mentioned rnetaods are of such iiagiiitude as to ruaKe tne loss of profits ccc;a thcpe icotnous impractical, the followir)u, metiiod will ensure each oi the above- or the three jointly ol a profit iroa the sale of taeue cnloridcs. ------- 1996 page 5 Ealph U. J-'urdy A. 'Hie production of calcium chloriae is within tiie financial justification of tha aoove three mentioned industries, due to the high quality of ciiloriae brines wiiich aie now wastea as a contaminant of various waters, it is comaion knowledge that standard iiime o. Refractories has considered, the construction oi' such a calcium chloride facility on a profit malting basis. Ihereiore, we can only conclude that industry can and will craiply v/ith"..a Cease and Desist order, if issued, as each has within its own industrial complex, er jointly, a sy.stea for fiisposing ol these chlorides on a no profit or profit basis, a.o the three can jointly choose. Because oi the multitude of contaminants entering the watws of our area, we select but one lor the Cease and Desist oruer as a lirst step in the elimination of the many contaicina/its that must oe stopped irom entering our waters, although this is or4y one, our members feel it is tne easiest to elirairiate, through and by the above mentioned r.ethods. A copy of your Cease and JJesist order iu regard to all chloride Orders of Determination iseuea to these three companies will be greatly appreciated. Our Senators sod Representatives are most anxious to see the total elimination 6f thcoe contauiiu-iiitc and we feel that this s/nall step vriJ.1 be a bi{; move in the ri^ht direction for the eventual'cessation of all pollutants to thete waters. Respectfully subniitteo., (Mrs.) Carole K:-,^.UUS, Secretary reprefcunting the cc: Governor Milliken ben. itocert uriifin Sen. t'hilip Hart Hep. Guy Vanc.orjnet xiep. Deiuiis Cawthorne oc-n. Orour B'^vrta ben. JacK 'x'oepp iialpli Nacknllan Dale ur;-ii'i;r ------- 1997 STATE OF MICHIGAN NATURAL RESOURCES COMMISSION _,.—, WATER RESOURCES COMMISSION AUGUST SCHOLLE 't&^-ii JOHN E. VOGT Chairman t —/J Chairman CARt T. JOHNSON ' ' STANLEY'QUACKEN3USH . .. .,.-.-.. WILLIAM G. MILLIKEN, Governor Vice Chairman t. fn.* LAI I ALA ROBERT c. MCLAUGHLIN DEPARTMENT OF NATURAL RESOURCES HARRY H. WHITELEY STEVENS T. MASON BUILDING, LANSING, MICHIGAN 48926 J\|M OILMORe RALPH A. MAC MULLAN, Director GEORGE F. IIDDLE JOHN H. KITCHEl, M.D. June 18, 1970 Mrs. Carole Magnus, Secretary Manistee County Anti-Pollution Organization Box 282 Manistee, Michigan U9660 Dear Mrs. Magnus: This will acknowledge and thank you for your letter of June 13 relative to the problem of water pollution in Manistee Lake, the Big and Little Manistee Rivers and Lake Michigan. The aggressive interest of your group in the enhancement of the quality ~o_f. these waters is sincerely appreciated and will unquestionably be. of considerable help to the Water Resources Commission in 'its program to place and keep them in the condition they must have. Your letter will be presented to the Commission at its June 25-26 meeting. I would point out that the law vests its specified pollution control authority in the Commission—not the Commission staff. I shall, however, report that the matter is the subject of ongoing, intensive investigation by the staff with intended very early submittal of its findings to the Commission. Your group's support will be especially needed by the Commission in the estab- lishment of unlawful pollution. 1 believe you are acquainted with the law's defini- tion of unlawful pollution (see Sec. 6(a), attached) and I would emphasize the fundamental need to show that a given waste disposal is or may become injurious to any of the values cited therein. You will appreciate that the Commission cannot rest its case upon presumption that a discharge must be pollutional. Neither statutory law, constitutional law nor common law will recognize a presumption that is not based upon fact, and neither your group nor the Commission would gain anything from an action" that is not legally founded. I accordingly encourage you very strongly to look beyond identification of the various discharges, important though that is, and be preparing yourselves to provide the Commission with testimony on how the discharges are causing or may cause injury. We of staff will be reporting to the Commission on the nature and volume of the dis- charges and will look to the Department fisheries authorities to evaluate their ef- fects upon fish life. Such information, however, cannot substitute for testimony by the people who are affected. '.1!C;!!.G'AVJ TMI f (~ CHfAT I I ""' I / «"" /., / ------- 199$ Mrs. Carole Magnus 2 June 18, 1970 In my capacity as a Deputy Director of the Department of Natural Resources, I am also concerned about the question of the possibility of fills which may be illegal under Act 291, of P. A. 1965, as amended. Mr. George Taack has discussed with me your recent letter concerning fills, and we have underway a full survey of the Manistee Lake 'area to determine what action may be warranted. The survey will be completed within 30 days . Again, we appreciate your support and shall look forward to its meaningful continuation. Very truly yours, WATER RESOURCES COMMISSION Ralph W. Purdy XJ Executive Secretary NB:bs Encl. ------- 1999 NATURAL RESOURCES COMMISSION E. M LAITALA Chairman CARL T. JOHNSON ROBERT c. MCLAUGHLIN AUGUST SCHO1LE HARRY H. WHITELEY STATE OF MICHIGAN WILLIAM G. MILLIKEN, Governor DEPARTMENT OF NATURAL RESOURCES STEVENS T. MASON BUILDING, LANSING, MICHIGAN 48926 RALPH A. MACMULLAN, Diredr July 30, 1970 WATER RESOURCES COMMISSION JOHN E VOGT ' Chairman STANLEY QUACKEN3USH GERALD E. EDDY JOHN P. WOODFOSD JIM GILMORE GEORGE F. LIDDLE JOHN H. KITCHEL, M D. Mrs. Carole Magnus Box 282 Manistee, Michigan 49660 Dear Mrs. Magnus: Thank )you for your kind letters of July 27. It was good to meet you also. I do rtot sense that the Commission members' intend to await final publication of Mr. Childs1 report before initiating formal action against the waste disposers, but, indeed, that their purpose in hearing the summary presentation was so that they could get on with the job. I further sensed the members' conclusion, as summarized by Mr. Vogt, that such matters as the housekeeping, which appears to underlie a good bit of the problem, were to be pursued promptly and staff will proceed with consultations along that line with officials of the companies in- volved, looking to such voluntary improvements as can be effectuated, even while the formal instruments are being developed. As stated at the meeting, Mr. Chi^Lds1 report is in draft stage, and it will take some time, probably a few weeks, before it finally clears the Central! Dupli- cating office of the State and can be mailed out. You will have a copy just as soon as it is ready. May I attempt in this letter to respond also to the questions you asked in your July 24 statement. I shall have trouble in doing so to your satisfaction, I'm afraid, because they involve, in part, matters of common law and constitutional law in which neither I nor any of our staff are really authoritative. 1. The Orders which this Commission is authorized by law to issue must be aimed at the prevention of unlawful pollution, which as you understand, are set forth in Section 6 of Act 245 (P.A. 1929). While I believe that injury to the ground waters (or, technically, public health and welfare) seems well established, the -total prohibition of chloride discharge to surface waters would be extremely difficult and probably impossible to defend as being necessary to prevent injury. A "Cease and Desist" order does not appear to be prospective, but Final Orders of Determination, or Stipulations leading to Final Orders if necessary, certainly are prospective. I cannot now estimate the detailed requirements of those instru- ments and can only say that they will be whatever the Commission deems necessary to prevent unlawful pollution. 2. To insure against unlawful discharges, the Cormiission will undoubtedly submission by the industries of detailed sampling reports. Commission ------- 2000 Mrs. Carole Magnus 2 July 30, 1970 staff will keep the arfected industries under surveillance, both by sampling and by inspection of operations. 3. The Commission has, in the past, pursued-penalty proceedings only in case of flagrant or continuing violation. Should such situations develop at Manistee or anywhere else, we expect that it will take aggressive- action. 1. Requirements for pressure testing of pipelines may well be contained in the Order or Stipulation. Staff have not developed their detailed recommendations for testing and reporting. r5. Michigan's chloride standards for intra-state waters are 75 ppm at domestic water supply intakes. Numerical limits have not been set for the protection of other values', but are stated in general terms. Jor the Great Lakes, 50 ppm is the maximum for domestic water supply, computed as a monthly average, and 10 ppm is set as the desirable level where existing conditions are less than 10. One hundred twenty five ppm is the monthly maximum for industrial use protection. Our chloride standards for Great Lakes waters have been approved by the Secretary of the Interior. I am sorry that I do not know what the Great Lakes chloride standards are for the other Lake Michigan states, but in any case, I should be unable to say why they differ from Michigan's if they do. While we are glad to respond to specific questions as best we can, we~are rnost especially interested in-conveying the sense of the Commission's position and pro- gram on water pollution' control. Perhaps your observation of the Commission's pro- ceedings has given your group some reassurance in that respect. In our earlier correspondence we have emphasized the element of injury prevention as the Commis- sion's statutory designated duty and objective. The Commission cannot be arbitrary nor act peremptorily. If proceedings seem unduly protracted, I must state that the Commission acts on matters as rapidly as staff can place them before it. You saw at the July meeting virtually all of our administrative staff, and only a few of them can be assigned to the exacting task of translating the assembled informa- tion into specific action requirements. I believe that you can expect expeditious pursual of a corrective program on the Manistee area problems. We shall look forward to your continuing support. Very truly yours, WATER RESOURCES COMMISSION n NB:bs Norman Billings S Acting Executive Secretary ------- (M.-C-110) 2001 POP. NS'iS RELEASE -JULY 25, 1970 S^ Hescures^ Ocir^iiae.lcn Elating :la Lining,, July 24, Sen Chillds logist ft-r the WSC, prase:.?-; ~d L~-5-c surf-ose and ground water study of -ihe ^.Jiaista* area., 'This sa.-.ci:/ tfd: 5..-1 sc-Jia 50 square miles is. ?ad ar^un-i I-:3,~ISX.3co 't-IXo Chiles n&ae s. brief sumaary cf the history of tlip salt* brine and pap?r Indus-cries,: His sudy brought to light- industrial practices in the degradation of surface and ground waters = Mr0 Guilds study revealed that the Packaging Corporation of iaerica pump part of their papar aiill waste through a 30 inch pipeline into lake Michigan. This discharge contains approximately 8-10 million gallons a day of papar mill traste, p3,us aacthar 1~1-\| tiillicn pounds of. cliloriclss? wiiiGh are used to siulr the effluaato The Pao5:agi«s Corpr ration also pump waste to ponds in" Secbien 1? in Stroaaeh., ccnsistiag of bet we an I5~60 nillion gallons par month or a tctal of a minimiia aiaouzit of -ys- Billicn- gallcns of oiitraatsd vaste, which infiltrates into ths ground water, causing watar degrada'cioric M Kr0 Ohilds study revealed that tl"e salt companies;, Morton & Hardy pump the majority cf their industrial waste bir-iaes into Manistea Lafca and that they also have an industrial practice of baclc flushing their salt v.rells0 Both of these contribute to the de-gradation of ths ground and surface waters „ The brine Indtis tries. Standard Licie and Morten Cb.saical5 discharge industrial waste either to Maaistae Lake or ths Maaist.ee Ghanael eductcre, further conti-ifcuting to ground and surface water degradation'o Hr0 Ghilds stated that all c:C the brine arid salt -industries -"are guilty of m.an.y general practirss cf hcusekaspirig in refersaoe to -operations at we-11 sites and plant si'tes resulting in ground water degradation0 " Tvro other 'cypss of degradation of ground watar of minor significance ware reported by !'irc Cihilds: - 10 Poor septic- tanlr isolation and . 20 Ice er,d cust centre! nhlon pcAise aa inorasse in chloride levels in the shallow via lls close to the rat'.xn arteries » Mr0 Child s concluded: "Shis &r?e. shctrs evidsnce of ground and surface water degradation from industrial cperating practices past and preaento" "In the oi^Ser cf their importance: 10 Ob.loride using indxis tries 20 Paper mill industry 3o Ice and dust .control 40 Ssptic tanks "It is 'believed that if these reer>mr.endation3 are1 useable, you could virtually eliminate all present vas^age of chlorides to surface and ground waters of Manistse0" !„ Es'cura. profiucticn t-mstc-s J;o brine formations and salt galleries0 20 Terminate back flushing pDr's.ctie&s of salt eompanieSo 3c Review and improve upsi general pvaotices that are presently resulting in vast age E,rouc.d plaat" and well sites. 40 Terminate the use of fb.s paper indastry lagoons ia Section 17 In Stronaoh because additional Kaste, assuming the premise that they are providing recharge to the lake, will only provide mere waste that will eventually reach the Iake0 ------- 2002 SlA^u O," MICHIGAN WILLIAM G MiL'JKtN, Governor DE?Ai< f/.'..: A i G.- .''/-.. ^.\.AL R STEVENS T. MASON r.UilDING. LANSING, MICHIGAN 4.3926 . RAIPM A fAAC A\UUAS, Director August 28, 1-970 JOHN E VOOi STANLEY O:jAryi.r.2U'-,H Vice Ch''"- •^rrC-Z <--J' / ttifl S* — Very truly yours, ' " L/C+J /c er.c. RJC/N2/sb ~cc: G. E. Eddy WATER RESOURCES COMMISSIOl lf ' ^ "'~C'J r . ,-rost G. Liddlo, Or. ;C. Chi Ids R. Courchaine -. Norman Billings Assistant Executive Secretary ------- 2003 Statement of the MAHISTBB OOGHTY AST I POI-I-USIOH OIK-MI&AIIGII (MACIT'O) prsseatad bj".l-l:-:.-'j0 GsrcoXs -^.gnus 0 rcsa:v:!l:ig the by P-- ^,-,. -, '• --r\ <-.. .j J. .U--V ... S.- ..tl - 4.' i> l fci—^.O «. ------- 2£ cr r~z Gc^=a.c^uaz: . 2004 It 3.3 our position v'.iat ti'.s ^e'jsnse of unnatural amotmt-s of ohlo.T2.fie in ou? g:?xjnd sad. ans^ac:.; raters pose a. grava throat to supplies in the Mauls tee araae 2he State of !4leaisar. fel'- t!is pro-blea of chlorides in th-3 Maaistea araa serous enough to uei-.&il Kr0 JIt-ii Guilds to spend the last two years compiling data, to identify the 'source of tha problem. The Federal Water Quality Administration considers the chloride problem In tlie Kanistee area of sufficient magnitude' to seliedul^ a detailed survey this susuaer ------- 2005 page 2 . However, no Order of rstarainction was issued to Kaaistea (Hardj Salt) for their discharge of arises- to surface waters por our discussion With l-!y. ,Geo2g3 Jiiddls at our meeting Hay 28, 197'Q« On® would logically as^ ^7/ha^ doas Kaaistee (Harfy) Ss.lt 4c "Jith thair waste chlorides?* if tho Stats of 1'liohi.^an. h-?.s rafutsd --;h© statomont by the Federal ESS? that 7012 EGD of ua.3te br-iuc3 are ratujsied..-to deep wallso We know for a -fact -that Eardy Salt has .for sons tias fcesa, chisapiag vast fconaasje of waste olilor5.G3 blouSs 3Ui'i;o their ssSi pit frea 'sr thsy ass ^"asl^sd back int-o '-fer-Istse LpJ:a0^ In a letter frsia Mre Fiafieldj: ' Vice President of Pvodtjc-tieii ct Hardy Salt to 2i© datsfi July 2a 1970& our orgs'.nlzetlca was assaurod thtvfe aa alteraate method had basn adopted Ijy Ee.^dj's ar,cl taat no mors will enter Maaistea Ls^e f?osi this In Mr0 Gerald Sd-5/s let tar of Hcvsm'^sr 20? 19'63 to I-!a-0 H h.a states tliat Staadard Mae aad Octant IB ssrlcusly consifisslns return of Sriaes to xrsllsB' Quality Ac en the One furthar point of sris-anis concajra to us aa€ the Federal' Water a ministration is the ulti^al'o offset these chlorides iTill have a? quality cf laics Michigant ~ 3?aa-Ste4t-e»PedQral as ia -Lake Fdohigan is 50 rug/1« H^trever, our- ofa water -s tsSea ia the vleia'lty of t>.e outfall end analyzed 'by a private shotr a ehlorids Isvel of 220 s-g/l in May of 19?0? In-MTo- Ralph Pardy's let. tar tc 1-iTe H0 YmE Butle? of Septemfcsr 22» 1964 Mrc Purdy quotss ths Paclca^in^ Corporation of Assrlea-as follotsss W2he effluent to?2ch5^is tj,s shuro WES quits dilate, tiestias oalj • 144 ppa chlorides vrhareas the. Lrina-Cflueat misture •will 7M - 12H ppfflo !1 weaild seamingly -30 a gross fS2.at2.oa of Stater-Faderal staadards .a possible violation of the jpecornl Water Quality Ast of 19_65« With all of these faots before you and realising that by . the Miehig&u • Water Sssouro-as Ooiraaissicn Htxst nsie the ultimate to stop further ohlorids contsaaination of surfaos aad ground waters,, orgsjiisatlca demands ausvers to the follo^rixig questions 0 The dats ishea the Gsaso aad Bssist order" on all chlcride disposal as outlined iu our letter of Jims 13 w5-ll ba issued? What Kathode t-hs MlfEO will enplby to ensure that no illegal chloride disposal -fill ooo-ur? What schedule of financial penalties will fce edoptsa and rigidly enforced for any end all illegal cr aooldeatal dumping? What schednla of regular State aad industrial pipslino aad wsll inspaction ^.21 b? aSoptud to ctiE^re that corrosion c^ age of pips ^rlli not pesait 3.sal:as3 er.d subsequent coat asaiaatioa ? ------- 2006 page 3 Efcy diQ t'ae State 'of Kieliisia find it nsoessasy to as'tabiish a EiazajoKsx e3.1ot-7abl v .elilo:ri'i3 le^ so la-aol hlgaor tb,a;i t^ie otlisr -felires Gcafsrses in tatj F State LaS:© Michiga:-, tlAO^PO -"i,!! ai-jpr^eiate rsseivlns your to these questicas s.'i t-las eiiiiesi possible tiia90" OJhsnk you ------- DI:L>ARV"L;N'T CT ii;;,.,;.::, :;^CAV;C:;, AND V.-ELFARE 2007 PUBLIC ;].:/.,/;;! SERVICE • Division or ..'.iter £«.vl >y and Pollution Control v (, ' GTArr REPORT MANISTl'C RIVER ( M1C.i 10AU) tmd LAKE MICHIGAN The City of Manistee discharges treated domestic waste effluent in the Manistee River System with a population equivalent (P.E.), measured in terms of biochemical oxygen demand, of 1915, one mile above the mouth of the Big Manistec River. Other domestic waste discharges are of.relatively minor importance. Industrial'waste.discharges arc significant. Paper and food produces plants located near the rr.cutr. of the river system have a waste discharge of almost IS.,000 P.E. .T/.-cSureo in terms of biochemical oxygen-demand. Chemical and salt'discharges from industries in this area also contribute to pollution of the river system. A total of 3.12 million, gallons per day (MGD) of organic wastes and 0.71 MGD of chemical and brine wastes are discharged to the Big and Little Manistee Rivers by industry. An additional 7.12 MGD of brine wastes are discharged into deep wells by two of the industries. Water quality, studies have been made at the mouths of 'the Manistee •and Li'ttle Manistee Rivers, on Manistee Lake, and on' Lake Michigan in the vicinity of the mouth of the Manistee R-iver during-the month of August, 1953. These preliminary survey results show that the total solids conteht in the Little Manistee River is 180 parts per million (ppm). This indicates that the industrial waste discharges to this stream do not affect it significantly. The Big Manistee River is affected by the industrial waste discharges, as indicated by the total solids content range of 300-500 ppm. Ninety percent of the total solids in the Big Manistee River are dissolved solids, largely of industrial origin. The effect of industrial waste discharges is further -indicated by the presence of chlorides ranging from-37-266 ppm, in the Big Manistee River. Compared with the 5 ppm chlorides in the Little Manistee River, the increase seeir.3 significant. The Public Health Service Drinking Water Standards have a recommended limit for chlorides of 250 ppm in a water supply Before treatment. One of the two sampling stations on Lake Manistee ($20) shows a wide variation in water quality, depending on the depth of the sample, although the number of samples taken precludes any extensive interpreta- tion. Similarly, the connecting channel from Lake Manistee to Lake Michigan has significant variations, depending on the depth of the sample, based on the one sampling period. The condition at- the 10 meter depth in particular reflects conditions inimiceU. to.good fish and benthic life development. ------- 2008 -2- In order to determine the overall effect of the Manistee Piv-r System on Lake Michigan ,--9« sampling stations-were, established in the iirjTiediate vicinity of the river's mouth. Samples taken from various depths show an area of questionable wate£ quality southward along the shore of Lake Michigan from the harbor mouth. At three sampling stations located inshore off the. harbor or.trance, some variation 'from normal lake water quality is reported. >.or::.al lako water quality is reported at Station 2^, located approximately 2.5 r.ile: south of the harbor and 0.5 mile from the shore. An increased organic load was discharged to LeTke Manistee and the channel from the -Packaging Corporation of America at Filer City for a period this past summer, due to a. breakdown in the plant. All the discharges from the variouc, industries and municipalities in the Manistee area are under the jurisdiction of the Michigan "./at-sr Resources Commission. ------- 2009 STATE OF MICHIGAN WATER RESOURCES COMMISSION MKMAtl t.MIATECH, laming. Ominnflli GEORGE W. ROMNEY, GOVERNOR FRANK J.MUEY GEIAID t eOOY, V«» O«lin««l ^C^JT /J^" [^. - . \f4' STAFF \1 , IORINGF.OEMING XJHNCMAOOt ..^. ~ , ,- NORMAN WLliNGS CEOROf F. UDOU,Mwkge« LANSING 13, MICHIGAN WHN I. DESMOND October 7, 1963 Mr. H. Schindler, Jr. Executive Vice President & General Manager White Star Trucking, Inc. 1750 Southfield Lincoln Park, Michigan Pear Mr. Schindler: We recjret the delay in answering your letter of September 6, regarding Manistee area water problems. An investigation including sampling at times when you experienced difficulties at your Lake Michigan property this past summer would have been most valuable in identifying the offending substances and we certainly wish we had been called at the time you noticed the unsatisfactory conditions reported in your letter. A report on studies made to determine the feasibility of disposal of the Company's waste with brine was received from the Company a few days ago and we have not had an opportunity to review the report in detail. The admixture of brine would be to increase the waste's specific gravity and keep it from moving to the water surface or the shallows. Tests of this principle using hauled brine have been very successful. A meeting between the Water Resources Commission staff and Company people is to be arranged to discuss the report and other phases of the waste disposal problem sometime during the week of October 21. The brine which would be used in such a project would be a portion of that which is presently disposed of to the Manistee channel through a pipeline and eductor system built jointly by Great Lakes Chemical Corporation, Standard Lime and Cement Company and Morton Salt Company in \S6\. This disposal method for the spent brines was adopted by the Companies to reduce the dis- charge of chlorides to Manistee Lake and is being done under Orders of the Water Resources Commission with restrictions on the discharges. These Orders also require the routine filing of reports. The Companies have maintained compliance with the terms of the Orders. Discharge through the disposal system averages about one and one-third milliongallons per day of brines containing about 10 per cent chloride. No reaction would be expected to occur between the inert waste ------- 2010 iir. H. Schindler, Jr. October 7, 1963 Page 2 brines and the Packaging Corporation wastes which contain small amounts of wood sugars, tannins, lignins and cellulose. The Manistee Salt Company discharges approximately six and three-quarters of a million gallons per day of waste containing about 0.08 per cent chloride into Manistee Lake. The effects of these discharges and those of Packaging Corporation on Manistee Lake have been evaluated and have not been determined to create conditions of unlawful pollution. Enclosed is a copy of Act 2^5, P. A. of 1929, as amended by Act 117, P. A. 1949 which you requested. We realize that not everyone is in accord with the statutory definition of unlawful pollution; however, as you realize, we must work within the scope and authority of the present statute. While we have been unable to demonstrate unlawful pollution of Lake Michigan waters at Manistee we realize that it is not possible for our surveillance to be on a sufficiently frequent and regular basis to provide assurance that we have observed the lake conditions under all situations of weather, and of variations in waste flow and water quality. We feel some confidence that the forthcoming meeting will result in early and substantial improvements. If it does not, the matter will be scheduled for attention by our Commission. Very truly yours, Norman Bill ings f Assistant Executive Secretary RJC:bmc cc—R. J. Courchaine Enc. f J ,333.355 ' J I IS ------- M i c~ 1 1 i o A N tint i rt _ f\IOV 25 if * " ' •: I'AKTM T.NT OJ' CONST. If VAT1ON November 20, 1963 OEKAI.n E EODY l nr« IOH Mr. H. Schindler, Jr. Executive Vice President and General Manager White Star Trucking, Inc. 1750 Southfield Lincoln Park, Michigan Dear Mr. Schindler: I delayed an earlier reply "to your letter of 'October 25 because I wished to discuss aspects of the Manistee River situation with members o.f my own staff as well as with members of the staff of the Water Re- sources. Commission. As you probably know, as Director of Conservation I am a member of that body. The Packaging Corporation of America is under orders of the Commission to remove freely settleable and floating solids, to maintain -specified oxygen levels, and not to impart objectionable odor, color, or turbidity sufficient to interfere with the development of public water supplies or with other industrial enterprise or other lawful occupation including recreational uses as to injure fish or aquatic life. The Commission is well aware of the problems that exist in the Manistee area and have been pressing the company for additional corrective measures. I believe that a recent meeting has been held with top-level officials of the company, but I have not been advised as to the outcome. Inasmuch as I am sending a copy of this reply to Mr. Oeming, Executive Secretary of the Commiooion, perhaps he can write an additional letter to you concerning that mooting. ------- 2012 Mr. H. Schindler, Jr. - - page 2 November 20, 1963 As you may know, the chlorides in Manistee Lake have been greatly reduced due to Water Resources Commission orders and despite some comments originating from the Public Health Service that it produces "conditions inimical to good fish and benthoni'c life. There have been no instances of actual injury reported. Also I am advised that the Standard Lime and Cement Company is seriously ' considering underground disposal of some of their waste brine that goes into the Manistee Lake outlet. Sincerely, Gerald E. Eddy Director GEE:ch cc L. F. Oeming ------- 2013 STATE O? MICHIGAN Qpn r> „ WATER RESOURCES COMMISSION ^ iyb4 ICGAL cowm COMMISSION tEGAL COUNoEl u „,.., ... , GEORGE W. ROMNEY, GOVERNOR • H RONK, Chorrmpn or JOHN C MACKIt ^ZX~ GERALD E EDDY, Vke - Cho.rmon For RALPH A. MAC MULLAN D STAFF OFFICES 5,01. H..IA Co™,,,.o..r 200 M.ll Slr.el IORING f. OEMING GEORGE s MCINTYRE ta_ 373 3i«o b«^~. ?««.., D™aor =1 AB-ral.,™ - - - NORMAN BILLINGS JIM GiLMORE, JR, Kalomaroo STATIONS ~£Ki^ OiiW, Hy Muur.ol M«i.g.m.« Or.,p. LANSING, MICHIGAN 46913 GEORGE F. UDDLE, Mu.Ugon "A""" w- IYNN F. BALDWIN, Eoior, Rapidi September 22. igo^t JOHN L DESMOND 0,.»»..^ CUo.». ' °" Mr. H. William Butler Mr. H. Schindler, Jr. Clark, Klein, Winter, Parsons & Prewitt Execut i ve .Vi ce President Counselors at Law White Star -Trucking 2850 Penobscot Building 1750 Southfield Detroit, Michigan 48226 Lincoln Park, Michigan Gentlemen : We have recently received a report from the Packaging Corporation of America, Filer City, regarding their observations of conditions along the Lake Michigan shoreline and the operation of the new waste brine addition to their wastes discharged th/ough the Company's Lake Michigan pipeline since this system was put in operation on August 15. Following are their comments: 1. "During periods of calm, or light winds from any direction up to 4 MPH, we can find no trace of the effluent either on the beach or in the form of a streak visible from shore or from an airplane.. Formerly these conditions would generally form a puddle of effluent which would touch shore at some point. No odor is apparent under the above conditions. 2. When there is a appreciable wind, above about 10 MPH from the quadrants of South to West or West to North, there is a visible streak out in the lake downwind from the spargers. The streak becomes apparent about 500 to 600 feet downwind and is apparently caused by wave motion bringing up the effluent from the bottom strata. The streak is generally less dark than formerly due to better diffusion and in S or SW winds is almost always completely dispersed before it hits the Manistee breakwater. So far it has never touched the shore. Odors on shore are generally less pronounced and are much less frequent than prior to the brine addition. ------- 2014 - 15 Mr. H. William Butler and Mr. H. Schindler, Jr. September 22, 1964 Page 2 3. An East wind (approx. 7 MPH) on one occasion was found to bring the effluent into shore along our property but had no tendency to move it North or South to the other property owners' shoreline. The eff.uent touching the shore was quite dilute, testing only \kk ppm" chlorides whereas the brine-effluent mixture' will run 7 M to 12 M ppm." If you have had an opportunity to observe conditions since August 15 we would appreciate your comments and knowing whether you confirm or concur in the observations of the Company. Very truTy yours, Ralph W. Purdy Chief Eng-ineer RJCrbmc CC--C. Harvey ------- 2016 - 17 MANISTEE COUNTY ANT1 POLLUTION ORGANIZATION (MA CAPO) Box 282 Manistee, Michigan 496GO September 1, 1970 William G. Milliken Governor Executive Office Lansing, Michigan 48926 Dear Governor Milliken: Please find enclosed copy of our letter to Mr. Ralph Purely of the Water Resources Commission. Our organization is of the opinion that the State of I'ichigan can no longer allow the -industries in th» .Manistee area to set their own standards regarding -air and wuto'r quality. The V/at«?r Resources. Commission has sot a tentative target date of Dececiber 1, 1071 for the elimination of concentrated chloride disposal to the surface waters in the Manistee area. We feel that this date is much too far in the future, and only a tentative date at that. There is roughly 1 ,900,000pounds of chlorides entering the surface •waters in the Manistee area every day. That means that until Dec- ember 1, 1971 these chlorid« polluting industries will be legally allowed to dump over ONE BILLION pounds of chloride contaminants into someone else's drinking water. We forwarded a copy of our June 1.1, 1970 Cease and Desist request on chloride disposal to you. itACAPO outlined three possible raethods that would eliminate chloride disposal to surface waters. The V/ater Resources Commission has chosen to ignore our suggestions, which would' have eliminated chloride disposal to surface waters with- in 30 days. It is immoral enough for Manistee industries" to pollute someone else's drinking water, but to continue to pollute when economic and exprdicious methods are available to correct this pollution is >> heinous act. Very truly yours, Mrs. Carole Magnus , Secretary MAC l.PO ------- 2018 DEPARTMENT OF THE ARMY p.-:j . /; ^{i * * ' • J • NOTE.—It is to be understood that this instrument does not give any property rights either in real estate or mate- rial, or any exclusive privileges; and that it does not authorise any Injury to private property or invasion of private "rights, or any infringement of Federal, State, or local laws or regulations, nor does it obviate thenecessity of obtaining State assent to the work authorized. IT MERELY EXPRESSES THE ASSCNT OF THE FEDERAL GOVERNMENT so FAR AS CON- CERNS THE PUBLIC EtGHrs OF NAVIGATION. (See Cu.inm.in.gs v. Chicago, 1SS U. S., 410.) PERM1 ije^g QJ. iv0 si^trist Ergtessr Detroit. Distrsc-bj corps of Engineers. Detroit 2o* irlchl-it NOV 2 o 1-Jv ;_ , 19 Filer Citj, 5.iical£.iri Sij'ss Referring to written request dated 10 Ar^itr/i TL?5^ I have to inform you that, upon the feccmaeiidation of the Chief of Engineers, and under the provisions of Section 10 of the. Act of Congress approved March- 3^ 1899, entitled "An act making appropriations for the construction, repair, and preservation of certain public v/orks on rivers and harbors, and for other pur- poses," you are hereby authorised by the Secretary of the Army. to ccssrbrust a 2h ir^":i vs^te cni^faia extending 1,100 fecb l^cv^ird vrith di (Here de-icriba tin* piopoied structare or woik.) e'i Vr.o cater crj * « ^fi -i ••»'• f- "^cn in A-^"-^ --—««--—,^,-vii (Here to be narr.ed tht* river, ha:bor, or waterway concerned.) at ran'_r>tcsj "!ichir:?.r.j apprc^i-Titrly !> r.ilc3 scuih frcra cntrcr.03- to E?.r'>cr.-- (Hera to fce named tlio neaie-^t Trell-kno^n locality—preferably a to.vn or clry—and the dMtarce in miles and teTitha froi^i somo dt.finito l^'r.t in tho earae, stating -.\hother abo.u or bi_lo\v or £ivini; dnection by points oE cemyajs.) in accordance with the plans shov;n on the drawing attached hereto "" (Or dr.v.'.i.i^d ; g'vy £1-: aui..ker or ot'-ijr ucunlte idf i.iiflc^t'ca m.ar! 5.) subject to the following conditions: ------- 2019 (a) Thai the work shall be subject to the supervision anJ approval of the District Engineer, Corps of Engineers, in charge ,of the locality, who may temporarily suspend the work at any time, if in his judgment the interests of navi- gation so jrequire. (6) That any material dredged in the prosecution of the work herein authorize'd shall be removed evenly and no large refuse piles, ridges across the bed of the waterway, or deep holes that may have a tendency to cause injury to navigable channels or to the banks of the waterway shall be left. If any pipe, wire, or cable hereby authorized is l?.id in a trench; the formation of permanent ridges across the bed of the waterway shall be avoided and the back filling shall be so done as not to increase the cost of future dredging for navigation. Any material to be deposited or dumped under this authorization, cither in the waterway or on ahort! above Hi^h-wattr mark, shall bo deposited or dumped nt the locality shown on the drawing hereto attached, and, if no prescribed thereon, within or behind a goad ond substantial bulkhead or bulkheads, such or, will prevent escape of the material in the waterway. If the mate- rial i3 to be deposited in the harbor of New York, or in its adjacent or tributary waters, or in Long Island Sound, & permit therefor must be previously obtained from the Supervisor of New York Harbor, New York City. (e) That there shall be no unreasonable interference with navigation by the work herein authorized. (d) That if inspections or any other operations by the United States are necessary in the interest of navigation, all expenses connected therewith shall be borne by the permittee. (e) That no attempt shall be made by the permittee or the owner to forbid the full and free use by the public of all navigable waters at or adjacent to the work or structure. (/) That if future operations by the United States require an alteration in the position of the structure or vrork herein authorized, or if, in the opinion of the Secretary of the Army, it shall cause unreasonable obstruction to the fres navigation of said water, the owner will be required upon due notice from the Secretary of the Arrny, to remove or alter the structural work or obstructions caused thereby without expense to the United States, so as to render naviga- tion reasonably free, easy, and unobstructed; and if, upon the expiration or revocation of this permit, the structure, fill, excavation, or other modification of the watercoursu hereby authorized shall not be completed, the owners sT.3',1, without cxpehso to the United States, and to such extent and in such time and manner as the Secretary of the Army may require.lremove all or any portion of the uncompleted structure or fill and restore to its former condition the navi- gable capacity of the watercourse. No claim shall be made against the United States on account of any such removal or alteration i (0) That the United States shall in no case be liable for any damage or injury to the structure or work herein authorized which may be caused by or result from future opeiations undertaken by the Government for the conserva- tion or improvement of navigation, or for other purposes, and no claim or right to compensation shall accrue from any such damage. (ft.) -That if the display of lights and signals on any work hereby aothorized is not otherwise provided for by Izrr, such lights and signals as may be prescribed by the U. S. Coast Guard, shall be installed and maintained by and at the expense of the owner. (»') That the permittee shall notify the said district engineer at what time the work will ba commouccJ, and a~ •far in advance of the time of commencement as the said district engineer may specify, and shall also notify him promptly, in writing, of the commencement of work, suspension of work, if for a period of more than one week, resumption of work, and its completion. fi) That if the structure or work herein authorized is not completed on or before _.!£hirt,-VfciCii;3'b4_ day of ir.'r.V.V.vA??..- _, 19?2_., this permit, if not previously revoked or specifically extended, shall ceasa and be null and void. Seo additional conditions on pa^o anno^od hereto ar£ part hero of e By authority of the Secretary of the Army: PZTErl 0. HYZTn .Colcr.-l., Ccrcj of En District; E-~J.r.ssr 1721 (Civ!!) Tl11' '"™ 3'-pw Firm 00, di'.ed I Apr !3, which n.sy be uccJ until eihijjtod. o. 5 ------- 2020 DEPARTMENT OF THE ARMY PERMIT (k) That, the permittee shall provide adequate facilities to extract freely -settleable solids from the waste water snch that the remaining concentration will not exceed sifty (60) parts per million by weight and the total daily weight of discharged solids will not exceed 5,000 pounds. Should the District Engineer find that either the maximum concentration or daily weight of suspended solids is being exceeded, the permittee agrees to take -whatever action is necessary to reduce' the amount of sclid.s to or below the allowable limits. (l) That, if it is determined necessary to conduct sampling tests of the waste water to check compliance with condition (k), the permittee agrees to permit ready access to necessary portions of its premises by the District Engineer's representatives for this purpose. (m) That, should the District Engineer determine that solids discharged from the outfall sewer are causing an unreasonable obstruction to navigation in the vicinity of the outlet, or un increase in the amount of maintenance dredging in the authorized Federal project at tkuiistoe, Michigan, the permittee agrees, upon notice b" the District Engineer, to either remove and dispose of the deposit at its sole expense, or reimburse the Federal Government for its cost of removal as determined by the District Engineer. (n) That, this permit is revocable by the Secretary of the Army should the permittee -fail to comply with conditions (k), (l), and (m) within a reasonable period as determined by the r>i strict Engineer. ------- 2021 The Manistee News-Advocate June ?, 1950 Hoffmaster Gives Views 021 Manistee Fish Kill LANSING —(UP)— Nature and an industrial plant combin- ed forces to kill millions of fish ranging from shiners to 36-inch trout In Manistee lake, Conser- vation Department Director P. J. Hoffmaster revealed today. Fish specialists have spent two reeks investigating the havoc in he four-mile long lake which has eft dead fish in piles along the horeline. "We believe organic matter lumped into the lake by the Am- •rican Boxboard Company plus na- ural phenomena combined to de- •lete oxygen in the water and suffo- •ta the fish," Hottmastor said. He explained that when there is a jump in temperatures, warm sur- face water sinks to the bottom.' "In the Manistee»lake, it set up thermal currents which dis- turbed masses of organic mat- ter on the lake be^ and pushed them to the surfa'ixV He said. "The organic matter absorbed the oxygen and the fish suffo- cated." Between 600 and 700 rainbow trout between six and 35 inches have died in the fish kill believed to be the largest in the history of the state. Hundreds of dead pike, bluegills. Bunfish, perch, and bass lie alonz the shore while an esti- mated 100,000,000 shiners and 150,- 000 game fish under six inches have died so far. G. B. Bonfield, Grand Rapids, American Boxboard Company exe- cutive, will appear before the Water Resources Commission June 20 to explain the daily dumping of 40,000 pounds of waste matter in the lake. Hoffmaster said the waste dump- ed b? the plant Is roughly compar- able to the waste from a city of 250,0^0 population. ''There's nothing we can do about it nt>w. Even closing the plant down would not help," Hoffmaster said.' "Our worry now Is that the fish kill doesn't haonen azain,"_ ------- >TA'i -;; MICHIGAN .2022 COVM. .,<.. WAT;:;? rrSO^CES COMMISSION A/>r.HSEL f MIATECH Lii-.t, rnj..,., ~t. ol Aan.Ut, „ J/1MF'. S Cil'CVE, IP >,!, i.-ao r.ii,~N~ PAIPM V/ \|U3'.» r''S!Gt/c.c™'' ""-""•'" UN-.tr/, I j, MICHIGAN JOHM :-wr,,-.n September 20, 1963 Mr. Donald G. Jenrings Attorney at Law Board of Commerce Building Man is tec, Michigan Dear Mr Jennings: A copy of your letter of June 7, 19&3 to Senator Hart regarding Manistee Lake pollution was received fn this off ice'on September 3, '963 from H. W. Poston, Regional Program Director of the U. S. Department of-JJealth Education and Wei fare, "Publ i'c Health Service, Water Supply and P_oJLl jrt i on Cont rjl, Reg i on V. We are concerned with your position that pollution exists and is worsening in the Manistee area waters, and would appreciate it very much if you could provide us with further detail on the conditions to which you allude. As you may know, very considerable reductions have been made in the wastes going to Manistee Lake, both with respect to the salt brine and the paper miU wastes. A portion of these wastes have been diverted from Manistee. Lake, to the Big Manistes River and Lake Micnigan which have abundant capncicy to dilute the sali. and to assimilate the oxygen demanding effluent. These diversions were initiated and are proceeding under order and contin- uing surveillance of this Commission, which is the agency charged by state law with the control of pollution. We would be happy to arrange a meeting with you to discuss waste control and water quality in the Manistee area if you so desire. Our files are al'so available for your inspection at any time. Please let us know in what way we can be of any assistance to you. Very truly yours, ' . i •'';;' .> , ' ;-." -v™ ' -'-' ' y . • ' - RJC: !nv: Ral(.h W.'Purdy cc: C. Harvey Chief Engineer R. Courchaine ------- Manistee, Mich., Wednesday, Sept. 23, 1970 2023 World's Fresh Water Salmon Capital P.E. Society Hears Talk on Waste Control Manistee-Ludington chap- ter of the Michigan Society of Professional Engineers had its September meeting last night at Coral Gables-Chippe- wa Hotel in Manistee and heard a talk by George Liddle, district engineer of the Water Resources Commission in this area. Some 20 industry representa- tives from Manistee and Lud- ington joined members and their guests for a social hour and dinner before the meet- ing. . After a brief business meet- ing program chairman Tom Stege introduced Georgs Lid- die who gave an informative talk on existing and pending legislation affecting industries .and municipalities in their con- trol of discharge of wastes to the natural watercourses of the state. Liddle also discussed the latest legislation passed which allows individuals to sue indus- tries or municipalities if they feel aggrieved by air or water pollution. He pointed out that, in most cases, the circuit courts having jurisdication will check with the state's regulatory agencies and if the defendant is complying with agency stipulations, the court will probably rule in favor of the defendant. During an informal question- and-answer period after Liddle's talk, the subject of chlorides in ground waters in the Manistee area was dis- cussed. It was brought out that while high chloride concen- trates exist at some well loca- tions in the area, the chloride concentration in the Manistee city water supply is well below Federal water control stan- dards, way below the taste threshold and, therefore, not toxic or harmful in any way to the users. The pollutants of highest concern to the commission in this area at this time, ac- cording to Liddle, are raw san- itary wastes being dumped into Manistee Lake or Manis- tee River. It was pointed out, however, that the city has com- pleted preliminary engineer- ing and is now vigorously pur- suing the acquisition of feder- al funds for a total program for collection and treatment of sanitary wastes in the Man- istee area. The chapter's next meeting will be in Ludington on Oct. 20, with the program to be an- nounced later. ------- DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE 2023a PUBLIC HEALTH SERVICE Division of Water Supply and Pollution Control STAFF REPORT MANISTEE RIVER (MICHIGAN) and LAKE MICHIGAN The City of Manistee discharges treated domestic waste effluent in the Manistee River System with a population equivalent (P.L.), measured in terms of biochemical, oxygen demand, of 1915, one mile above the mouth of the Big Manistee River. Other domestic waste discharges are of relatively minor importance. Industrial, waste dischargee arc significant. Paper and food products plants located near the rr.ouin of the river system have a waste discharge of almost 15,000 P.E. moacured in terms of biochemical oxygen demand. Chemical and salt discr.arges from industries in this area also contribute to pollution of the river system. A total of 3.12 million gallons per day (MGD) of organic wastes and 0.71 MGD of chemical and brine wastes are discharged to the Big and Little Manistee Rivers by industry. An additional 7.12 MGD of brine wastes are discharged into deep wells by two of the industries. Water quality studies have been made at the mouths of 'the Manistee and Little Manistee Rivers, on Manistee Lake, and on Lake Michigan -in the vicinity of the mouth of the Manistee River during-the month of August, 1963. These preliminary survey results show that the total solids content in the Little Manistee River is 180 parts per million (ppm). This indicates that the industrial waste discharges to this stream do not affect it significantly. The Big Manistee River is affected by the industrial waste discharges, as indicated by the total solids content range of 300-500 ppm. Ninety percent of the total solids in the Big" Manistee River are dissolved solids, largely of industrial origin. The effect of industrial waste discharges is further indicated by the presence of -chlorides ranging from 37-256 ppm, in the Big Manistee River. Compared with the 5 ppm chlorides in the Little Manistee River, the increase seems significant. The Public Health Service Drinking Water Standards have a recommended limit for chlorides of 250 ppm in a water supply before treatment. One of the two sampling stations on Lake Manistee (#20) shows a wide variation in water quality, depending on the depth of the sample, although the number of samoles taken precludes any extensive interpreta- tion. Similarly, the connecting channel from Lake Manistee to Lake Michigan has significant variations, depending on the depth of the sample, based on the one sampling period. The condition at the 10 meter depth in particular reflects conditions inimical to.good fish and benthic life devcJ opment. ------- 2023b -2- In order to determine the overall effect of the Manistee river System on Lake Michigan, 9 sampling stations were, established in the immediate vicinity of the river's mouth. Samples taken from various depths show an area of questionable water quality southward along the shore of Lake Michigan from the harbor mouth. At throe sampling stations located inshore off the harbor entrance, some variation 'from normal lake water quality is reported. i%:or:.: ------- 2023c CO: Rep. Cavtho: COtr.ITY A'.TTI rjL'JJTlW ORGANIZATION Son. Bouws::/. sen. Hart Sen. 3 riff! Box ?32 Cor.. Van do Mnnistec. Michigan A 9660 FWj.A August 23, '1970' Mr. Ralph W. Purdy, Executive Secrotary rfater Hcnourccn Corinlcnio.-i Stevens T. Man on Building Lansing, Michigan 48926 Dnar Mr. Purdy : To date, the Water Resources Gcmml ssion has -been all too reluctant to set standards, thus lettiag industry do its own regulating as wa~ tVif; case In the Orders of Do termination now in existance covering chloride disposal issued in 1958 and 1959. The pollution, of chlorides to Manic- te- Lake and Lake Michigan continue under these Orders of Determination and in accordance uith standards mutually agreed upon, as set by industry. As a first step, the Orders of Determination should be drastically re- vised so that "a minimum amount of chlorides will -be entering Lake Michig and Manistee Lake, This will rive the" major chloride polluters some- thing to really shoot for in their efforts to be good citizens and a working part of the community, By actual test, the la.rge vcluTT.es- of chlorides allowed -tc-..enter-Kanistec.- Lalce and Lake Michigan have at times exceeded even those maximum levols, thus causing an excellerated degradation of the waters .in the immediate area. Thus, it is the intent of MAGAPO to set a more optimum standard and to take a more realistic approach to the problem. We request that the Orders of Determination be revised so that a minimum amount of chlorides will be entering the waters by December of 1971» and these should be issued as a standard. The major chloride polluters are the salt and chemical industries in our area, and our letter of June 13, 1970 gave recommendations which, to date, have been ignored. Mr. Childs surface and groundwater study presented July 2^ and subsequent recommendations coincide with .our recommendations that these chlorides should be returned to the strati from whence they came. Thus, we feel that with such professional opinio and recommendations, our request for a Cease and Desist should be given immediate consideration. As of the month of August, the ¥RC has en- deavored to capitulate with the request of the Cease and Desist by making a step in the direction of asking industry what they can do to cease the discharge of concentrated chloride wastes into Lake Michigan and Manistee Lake. We of MACAPO are dubious of this particular approach to the problem of asking ; industry as to what industry will do in the reduction of chloride pollution to Lake Michigan and Manistee Lake. MACAPO wonders if we are not getting back into the rut of 1958 and 1959 where industry stated then what they could" do. This has led us to the h'igh parts per million that we now experience in our area. We feel- that any ste.p in the reduction of chlorides is a step in the right direction, but we feel that standards should be set by the WRC, rather than by the major chloride polluters. ------- 2023d page 2 tfe realize the economics of such -i r.ove, but once again appeal to the WRC to take a very thorough look'-into the problem and investigate all of the possibilities. We, therefore, suggest that the largest chloride polluter might revise his process in a minor way to reduce the chloride level. Therefore, we once again appeal to the Water Resources Commission as laymen, and offer the possible solution of such an economical step to reduce these chlorides. For example: 1. The production of MgO is through a two "stage reactor, thus into a series of three settling ponds in which the MgO precipitates out and the chlorides are washed from the JIgO, thus giving a pure product to be burned and thus known as Magnesite. It is recommended by "us that a simple change in the process of the three settling ponds could easily facilitate the immediate reduction of large concentrated chloride effluents. By decanting the high chloride effluent coming from the first thickener and then washing in the last two thickeners. 2. The present setup at this pro-ducer of Magnesite is an A3 &. C thickener,system; These three are compiled of the three stage settling and washing systems and we recommend that one large thickener be placed in operation, thus pumping to the "series of smaller thickeners for washing. This material would be pumped by Door-Oliver pumps from the larger thickener and the chloride liquor decanted off and returned to the ground strata from whence it came. I an sure that the WRC, after a quick review of the process at Standard Lisie and Refractories, the Magnesite producer above referred to, might perhaps be able to assist or aid the people with other suggestions in reducing the large concentrated chloride effluents being.transported via the 10 inch pipeline to PGA, thus being added with their effluent and transported to Lake Michigan via the 30 inch pipeline. We would, therefore, appreciate hearing from the. WRC on the following: 1. What' standards the WRC is setting for positive reduction of chlorides for the December 1971 target date? 2. What standards are being imposed on those chloride polluters of Manlstee 'Lake who have no Order of Determination whatsoever for their chloride disposal? 3. We would like to have an assurance'that all concentrated chlorid? effluent will be eliminated in the waste disposal process of PCA to Lake Michigan by December 1971. 4. We would like to be assured that a drastic revision of present Orders of Determinations will be immediately forthcoming to facilitate the ultimate reduction of' concentrated chlorides t'o Lake Michigan- via the lakes, rivers and pipelines in this area by December 1971. ------- 2023e 5. ft'e would like to know the schedule and method for monitoring the present and future effluent 'discharge stations emitting chlorides of any concentration into the waters in the Manistee area during the full 12 months of the year? 6. What monitoring method is the WRC considering for the disposal of salt blocks and salt products now being discharged to -the waters in the Manistee area? After once again hearing Mr. Childs report on August 24 on the. degra- dation of surface and ground waters in the Manistee area, we feel that the problem of chloride contamination is more urgent today than" when we wrote our Cease and Desist request on June 13. Therefore, we implore that a more expedicious and positive approacn be immediately taken to facilitate the maximum reduction of chloride effluents that now contaminate the waters 6f the Manistee area. Very truly yours, (Mrs.) .Carole Magnus^ Secretary MACAPO ------- 2024 R. F. Sturgis MR. STEIN: May we have Raynor Sturgis? STATEMENT OF RAYNOR F. STURGIS, JR0, DIRECTOR, ILLINOIS DEPARTMENT OF GENERAL SERVICES, SPRINGFIELD, ILLINOIS MR. STURGIS: Chairman Stein, conferees, ladies and gentlemen. Thank you very much, Mr. Stein, for inviting me to this meaningful and interesting conference. My name is Raynor Sturgis. I am Director of the Department of General Services for the State of Illinois. I am an engineer by training and have practiced industrial engineering as a consultant in several extractive industries around the country. The Legislature of the State of Illinois this year granted the Department of General Services appropria- tions totaling $2,270,000 to engineer and build pollution abatement facilities where they are needed in institutions operated for the State's taxpayers. With this sura it is expected more than 40 sources of a.i ^ and water pollution will be corrected by the end of next summer. They include powerplant conversions from coal to oil or gas at mental hospitals, correctional institutions, and armories. A sulphur dioxide extraction device is being ------- 2025 R. F. Sturgis engineered for a new coal-burning powerplant at still another State institution. Your deliberations this week treat alternate waste heat disposal methods for nuclear and fossil fuel powerplants. I judge from the testimony that the cooling tower alternative is projected to cost in the vicinity of $300 million. The taxpayers for whom I work in northern Illinois are also the purchasers of electric power. Thus, they would face the Illinois share of this expenditure. Justifying this huge expenditure upon imagined conditions in the year 2000 highlights very well the economic dilemma of pollution abatement. Money needed to improve the air and reduce water pollution around Lake Michigan must be spent to produce results this year and next. The resulting environment should then permit time for the specific research needed to fill in the gaps of information so apparent from differing statements of scientists participating in this workshop this week. This does not mean that using a valuable natural resource as a guinea pig is advocated, or the possibility of irreparable damage is tolerated. This thermal problem is not in this category. Indications have been cited that sport and ------- 2026 R. F. Sturgis commercial fishes may be found in greater numbers in the vicinity of powerplant heat discharges in the fall, winter, and spring to the advantage of people around Lake Michigan. Should not specific research studies be undertaken to determine how these valuable fish should be repelled during the few weeks in the summer when heat conditions might pose a hazard to the greatly improving Lake Michigan whitefish, salmon, and trout fisheries? The cost of this research study would represent a small fraction of a $300 million investment for cooling towers. A successful method of regulating fish movement then could be employed by power companies, only when required a few weeks in July and August, to assure prevent- ing damage to the top of the aquatic life chain most important to human beings in the vicinity of fossil fuel and nuclear powerplant sites around the lake. And since temperature change rather than the presence of heat has been indicated to be significant for aquatic life, is it not possible to design parameters to utilize the lake and still protect fishes? Could this not include relating different amounts of water discharge to their specific temperatures, with outboard motors at one end of the spectrum and powerplants at the other? Gentlemen, I submit to you — and I am not an ------- 202? H. P. Read aquatic scientist or a limnologist, but I wonder if one of your options should be that you consider development of these questions, or answers to these questions before committing a huge expenditure which time could determine might not be required. Thank you very much. MR. STEIN: Thank you, Mr. Sturgis. Any comment or question? If not, thank you very much. MR. STURGIS: Thank you0 FIR. STEIN: Herbert Read. Do you have a copy of your statement? MR. READ: I have only two copies. MR. STEIN: Could you give one to the reporter? I would urge anyone, in view of the long day we are having, if he has a copy of his statement, please come up with two, or get one made so you can give a copy to the reporter because it is going to be very trying if she doesn't havo it. MR. READ: As soon as I get back to the office Xerox machine I will get some more. MR. STEIN: We havo one. ------- 2028 H. P. Read STATEMENT OF HERBERT P0 READ, STATE DIRECTOR, INDIANA DIVISION, IZAAK WALTON LEAGUE OF AMERICA, CHESTERTON, INDIANA MR» READ: My name is Herbert Read. I arn the State Director of the Indiana Division of the Izaak Walton League and I live in Chesterton, Indiana. I will try to summarize this statement. One of the basic points I would like to make is that we who live along the Indiana shoreline of Lake Michigan are particularly concerned over thermal pollution along with the others. This conclusion is due, in part, to a number of factors, some of which I wish to discuss. The dissipating effect of heat, or for that matter any form of viator pollution is slow, due to the sluggish movement of water at the southern end of the lake, I will not elaborate, but the sluggish movement; means this water dissipation of heat or other pollutants do occur very slowly, which is a nrob1om rcr us in Indi'ma0 It is in this lower basin of I/ike L.ichiran, with the sluggishly rotating waters that most; of the electric power generating stations would be located where the heated ------- 2029 Ho P. Read effluent would be deposited. There has been talk about some 25 or 30 sources of such heat flumes. The power industry would like to restrict us to consider only these stations one by one, increment by increment, and prohibit any thought of the total effect by the year 2000 or beyond. We don't do that and we will not accept that increment-by-increment approach. I included in my statement a map of the Indiana shoreline, the purpose of which is to show some additional factors which make our problem more difficult, and that is the existence of landfills jutting out into the lake. The northern Indiana Public Service Company generating stations, and their respective discharge flumes are or would be located so that the heated effluent would be trapped by landfills. The effluent with its heat plus whatever other pollutants are included — and I also dis- cussed a bit of the other pollutants — will extend along the shoreline of several parks including the Indiana Dunes National Lakeshore. While the uninformed swimmer may enjoy the heated water, the subsequent increase of algae, ale- wives, and other pollutants from NIPSCO's discharge pipes will turn the beach into something less than desirableu In the statement itself I describe each of the locations of the generating stations, which I haven't ------- 2030 H. F. Read mentioned or gone into a great deal of detail here because you can understand it better visually than for me to describe it, and in the map I have included a red* area which is the probable destination of any heat flumes, and the problem here, of course, is that these heat flumes, with whatever ill effects they have, will be spread along public bathing beaches, public parks, the Indiana Dunes and National Lakeshore, as well as city and State parks. We had some tests made by the Independant Citizens* Water Pollution Research Associates, Inc., at the Bailly and Michigan city generating stations. At that time we were testing primarily for other forms of pollutants, so we did not go into an extensive heat test. We did make some. We found that the discharge flume was #3 degrees from the Bailly plant, and we could compare this to 66 degrees which was in an area that would be not normally touched by heated discharge — differences of 1? degrees. How, this heated water discharge flume spread along the beach of the Indiana Dunes National Lakeshore. For a mile of the beach it still registered &1 degrees. We didn't go along and make further tests. We will. But I think it is quite obvious that we have special problems, and that is why we want this body to take a hardline stand on it. Solid black area ------- 2031 H. F. Read Mr. Stein, you did say that you did not want discussion of other pollutants, but our experience with other pollutants has a direct bearing on our positions that most of the conservation groups are taking here today, and that is that we have listened to all of the denials of problems by steel companies, chemical companies, oil com- panies They denied that oil would be damaging; they denied that pickling liquor from steel mills would be damaging; and now we are expected to accept the notion that'we would sit by here and let the generating stations build their plants and then maybe sometime in the dim, distant future, if their pollution can be proved, they will do something about it0 You people have not been able to do anything about the pollution that we have — very little. We have not been able to do anything about it, and I don't see if we have not been able to have much progress today how we are going to automatically stop this in the year 1975, which was the year that was mentioned. I think it should be mentioned that the pollu- tants coming out of NIP3CO, including fused mangr.aece- aluminum-titanium-silicon, commonly called clinker or bottom ash; fly ash; iron II and iron III oxides; nickel; chromium; magnesium; cobalt; and zinc — some of these ------- 2032 H. F. Read materials, particularly the zinc, are more suggestive of steel mill processes, and I understand that some inter- connection of piping exists between NIPSCO's Bailly Station and the adjacent Bethlehem Steel Plant. It may be that NIPSCO, as part of its "good neighbor" policy, is allowing Bethlehem to flush some of its untreated wastes of metallic refuse and perhaps also dissolved pollutants and heated water directly into Lake Michigan. This is the reason why we want to get powerplants — particularly NIPSCO — off the lakefront, and it is not just the heat, it is the rest of the stuff that goes along with it. I will end here. Thank you very much. (Applause) MR. STEIN: Thank you very much, Mr. Read. Are there any comments or questions? If not, thank you very much again for your statement. (Mr. Read's statement follows in its entirety.) ------- 2033 To: Third Session, lederal Conference .m Lake Michigan and. its Tributary Basin , Chicago From: Eerbert P. Read, State Director, Indiana Division Izaak ..alton League of America M. R. L>ox 438, Chesterton, Indiana 46304 Date: October 2, 1970 Vie who live along the Indiana shoreline; of Lake Michigan sre particularly concerned over thermal pollution problems nov; being considered. '.This is because the southern tip of uhe lake is where most of the pollutants dumped into the lake end up — and where most of them remain. Our state of Indiana is further notable for being the worst polluter for having the least effective enforcement and totally without any form of leader- ship from any of the local or state governmental units to correct the problem, In short, v;e have a helluva mess on our hand^,, and if the so-called public utilities get their way, we .-light as well start carying the tombstone for the Indiana shoreline of Lake Michigan right now. This conclusion is due, in part, to a number of factors, some of which I wish to discuss. -the dissipating effect of heat, or for that matter any form of water pollution is slow, due to the sluggish movericuib of water at the southern end of the lake, 'ihe littoral drift parallel to the shore moves both east and west, v. ith a net westerly direction. The effect is to hinder northward movement, which when it does occur, upon reaching the underwater ridge near Milwaukee, . usually rotates around to return most of bhe same water to our shore. I think most of us ere la.ailiar with this fact, and there is no need for documentation. It is in thi^ lower casin, with the sluggishly rotating waters that most ol the electric power generating stations v.oald ce located end where the. heated effluent would be deposited. The power industry hired-hand scientists talk unconcernedly atout the little fishes that cavort glee- fully in anc! out of a heat flume which always has suil'ieient cold water around to quickly reduce it all dO'.;n to normal temperatures. Conven- iently ignored is the cumulative effect of 25 or 30 sources of such heat flu-p.es, ringing the sluggish waters, already rich in nutrients, of lov;er Lake Michigan. In common vdth the Atomic Energy Commission, the power co:..pany spokesmen would restrict us to considering the effect only increment by increment, and prohibit any thought of the total effect by the year 2,000 or ..evoncl. This is Because the total carnal-" tive effect, if knovai, could make the aatives r The movement of v;ater along -he Indiana shore is further hindered by the existence of landfills jutting out into the lake. The HIPSCO generating stations , err: cheir respective discharge flun.es, are — or vould be — located so bhat the heated effluent would be trapped by landfills. The effluent '/ith its heat, plut, whatever other pollutants arc included — an.; i will subnit proof of oilier poliutants--v;ill extend along the shoreline of ;.ever&l parks including the Inuiana Dunes Kntional Lnkeshor While the uninformed sv.imiwr may enjoy th= heated -,.ater, the subsequent ------- 2034 3 increase of algae, alewives, and oth-^r pollutents from riPSCO'o cischarge pipes \vill turn the be&ch into a rooting, stinking morass. I have included a map for reference. Consider first the existing coal ffired 603 !."'/ Bailly generating station. The Lethlehem Steel landfill is directly to the west, prohibiting any dissipation of water pollution westward. It ie in fact a pollution pocket, with the heat and other pollutants spreading eastward along the teaches of the Indiana Dunes National Lakebhore, iijnediauely adjacent co the discharge flume. On August 18 and 26, 1970, a ceries of tests of various types of pollutents v.'ere made by the Independent Citizens' Water Pollution Research Associates Inc. at the B&illy and Michigan City generating plants of KIPSCO. On .August 26, the temperature off the bailly otation discharge flume wag 83 i', compared to 66 in the Buffington Tier area, a difference of 17 . The heated water, spreading along the beach of the Indiana Dunes national Lake-shore registered 01° along the first mile of park shoreline. At this rate, it /vould take several additional miles to return to normal lak«j temperatures. To aake matters vjorse, a new nuclear fired 657 II.; capacity station is planned for. this same site for a station total of 1,260 I:./. The additional heat load will create quite a "hot spot" in the National Lakeshore. Simultaneously, hard on the eastern Boundary of the Indiana Dunes Uationr,! Lakecihore is the discharge fluae of KIPoCO's Ilichigaa City station. In addition to the exi3^ing 208 1.1. / units , a 511 IIY; unit (otation total 71^ :'?./) is ceing built, to Le followed by toother of sindlar capacity, some 1,250 iK/, v.lth a discharge of (t>07,000 gpm plus 350,0000gp.!i) 870,000 gpm. The discharge would be, by company figures, 1-s,^- above intake temperature, and some evidence exists that the company figures crc understated, ihc heated c-fflue.no from this otation \vuulu bo directed v;estv;ard onto the beaches of the .fndiane Dunes NaLionnl Lskcshore. Thus both ends of tho main section of the National lakeshore v.-ould be blanketed Ly heated discharged, to ^he point, if expansion continues st the prose jio rate, the flumes «ould join , making continuous along the shore whatever ill effects ei:d problems art aosociated \;ith the discharge But even with the aforementioned sources, the Indiana ^orc- s National Lakeshore and its users may Buffer additional ebaset from KIP&CO. A new statioi1 is planned for Gary, ogain to be located adjacent bo a lend- fill---x.hi ^ one being 'Jni^ed States bteel Co::panys. Tiiu heated effluent, again located in a "pollution pocket," would spread eastward, pact the Gary Ilar^actt.,, lark cccch to the jest ^each unit of tht. Indiana Dunes I-Tational Lektshor^, \<1hic.1-i v;ill be the heaviest use arm. Alter blauUfct- ing thrio beaoh, it will be stopped on the east ^y the Ilid./est ^teel Co. landfill, again polljuin;; a "pocket" of v.ater. but \/e're not through v.'ith tliis uroLlei.i of trapping heated effluent betv.ee'n landfills. At jh. lllinoiL--lncliana state line is ihd Cc;/.ionv.eal bh Ldison titatt. Lii.c Generating Station. A few mileo av'ay the Inland Ctcel Company landfill fon,.s ai'.other "pocket" with the Ma;. aoni anc1 ~»hiting benches in bt:t-..fcen. 'J-hc- chance..-: for cleaning up theje poor, iorli;rn seg.acnts of the paulic real'a ,.uuld bo forever lost ;.ith :.:ore {.. nd i'iore healed ei fluent. ------- 2035 One [i.ore source of Kli'COO'a contribution to heating up Lekt ",'ichigan is ihe. Liitchell Station, near the eastern edge of Gary, end the only station not adjacent to a putlic beach. 1 think, you will now agree that the combinations of Geography, landfills, and MPbGQ's generating ststion locations pose a very serious pollution problem for the Indiana shoreline. But HIPSCO's threat to the well being to Indiana' t> citizens does not end here. For soaie unexplained reason, KIPSCC's discharges into the public waters contain other contaminants, 'ihese include fused mangnnese-alurainuia- titaniu-n.-silicon, (commonly called clinker or botto.a ash); fly ash; iron II and iron III oxideo; nickel; chromium; magnesiuai; cocalt; end zinc. Some of oh&se materials, particularly the zinc, are r.iOre suggestive of steel raill processes. J understand that some intercon- nection of piping exists between NIPSCG's bailly Station end the adjacent ciethlehe.-.i Steel Plant. It may be that KIPSCO, as a part of its "Good Neighbor" policy, it; allowing Bethlehem to flush some of its untreated wastes of n.etallic refuse, an '• perhaps also dissolved pollutant^ and heated water directly into La/te ..lichigan. This is another reason why ve want to get power plants—particularly KIPSCG—off the lakefront. Another factor v.hic!. shapes the response of Indiana conservationists is the anrofor,:;ed, 19th century management attituce towards pollution problems. i;iPSCO's public relations men talk irapressivuly, but we have been on the scene long enough to compare pror.ise with performance. A public utility enjoys a government-protected monopoly, v/ith protective rates which assure stockholders of generou- profits, There is no excuse whatsoever for the resistance we have experienced in Indiana, ariri v.hich is very evident this past -.-eek at these hearings. As expected there are threats of "Brownouts" and "clackouts." If we permit the power lobby to blackmail the public in this fashion, the same tactic can(and .-/ill, be used to excuse other pollution problems in addition to the heated v.ater. Jn fact, virtually any sin cen be rationalized in this Manner. 'J-he fact if-,, of course, that the "blackout" tactic assumes a false alternative—-that the choice is between using Lake Michigan as a "heat sink" or ueing without sufficient generating capacity. 'c are tolcS that until proven otherwise, the heated discharge should be permitted. At sorae future date, after tests conducted t,y, and for, the pollat-ers, if it can be proven to their satisfaction that there is danger, maybe--just raaybe-- iDraetiiing should be done about it. Vihatevcr shortcomings we conserva- tioniots have, we're not dumb enough to accept that ridiculous argument. ite have hearc the sar.iC dei.ial of uanger fror; steel companies and oil companies, and recently I heard a Ph.D. hired by the Agricultural Chemical Industry cloi.i that DOT is not responsible for all those fish kiils and dying birds. In fact, he iuplied, DDT was really good for you and ------- 2036 would cure everything from cancer to corns. Haven't we learned anything from the past? Do Me h?ve to kill off people fcy the thousands before the polluters v/ill adait the danger of their discharges? The matter of enforcement nust fee considered. I am well acquainted the pollution probleaa of Torthv;estern Indiana, and have attended innucieratle public hearings and hoard excuse after excuse. I have tried repeatedly to ottain local and state action to reduce pollution, and I can state fro.n personal experience that the performance of Indiana authorities does not inspire confidence. There can be no more delay. The states would dawdle around v/hile the utilities flood Lake l/.ichigan with more and r.ore heated effluent. Lv.cn if the states^iiltiiaately agree on a policy, 1 have little confidence •ffcat the policy adopted will safeguard i.ake Michigan. There is only one way to go. .The U.S. Department of the Interior must require the states to adopt ':nJ& recommendations as contained in the ------- 2037 ------- 203S Mrs. R. A. Barber MR. STEIN: We have a statement for the record by Mrs. Robert A. Barber who had to leave, and without objec- tion we will enter that as if read. STATEMENT OF MRS. ROBERT A. BARBER, DEERFIELD, ILLINOIS MRS. BARBER: I share the average voter's belief that the lake is a natural resource that can be maintained by sincere efforts at conservation. Those of us who have been interested in the problems created by pollution are pleased that the State of Illinois has given us an accountable group of citizens to set standards for environmental pollution control,, We plead that the Federal Water Pollution Control Agency propose standards to end the use of the lake as a heat sink by utilities, with the present state of scien- tific information and engineering technology. MR. STEIN: We have Seymour Altman, Commissioner of the Highland Park Environmental Control. Commission. Mr. Altman. FROM THE FLOOR: Mr. Altman will be back shortly. MR. STEIN: All right. We will call him again, if he misses his turn, and I am not specifying when. ------- 2039 Mrs. S, Gruen Mrs. Shirley Gruen, Wisconsin Federation of Women's Clubs, has a 3-minute statement. Mrs. Gruen. STATEMENT OF MRS. SHIRLEY GRUEN, WISCONSIN FEDERATION OF WOMEN'S CLUBS GLENDALE, WISCONSIN MRS. GRUEN: I will only take about three minutes of your time. I put down the Federation of Women's Clubs because I got a phone call about this conference. I am a member of the Women's Club and I am a conservation chair- man of the Glendale, Wisconsin Chapter, but I don't really have anything in writing. I would rather — before the 1-degree thermal standard is set, however, I would rather talk as an American citizen. My name is Shirley Gruen, and I live at 214 W. Mt. Royal Road, Glendale, Wisconsin. I am not a geologist, a biologist, an expert on pollution, I am an artist, and I am speaking here as an American citizen to plea for help in saving Lake Michigan from further degradation. I have spent every summer of my life since 1923 — that is the year I was born so you can figure it out, I am 46 years old — at our home on Lake Michigan 3 miles ------- 2040 Mrs. S. Gruen north of Port Washington. Everything said here today about the phenomenal change in the quality of water in Lake Michigan is true. There are now very few clear water days. After every storm, enormous amounts of algae are tossed on the beach. Other people have told of this so I won't go into it. I think I am probably the only one in this room who lives close to the color of the lake. In 1935, before the Port Washington powerplant — and it is run by the Wisconsin Power Electric Company — at that time, it was the wonder of the world. People came from all over to see this technological wonder. Now, I want to tell you that it is not very nice living next to a powerplant,, As the gentleman before me said, it isn't only the pollution in the water, it is the air, it is the coal, it is the coal boats, it is the dredging of the harbor and the Army Corps of Engineers dumping in the lake. It is a relatively constant pollution. Ironically, even at the time this electric powi.r- plant was built in 1935, it was not even in the public interest then» We lived 3 miles away and could not get electricity at a reasonable rate. It was not until 1941, through the REA, that we got electricity, and I tell you we were luckier then than we are now to be without the ------- 2041 Mrs. S. Gruen electricity. I would like to speak here as a private person on the feelings that a private person has —^he powerlessness and the helplessness to right the wrongs of pollution that we feel. Technology and production can be great benefits of man, but it becomes apparent that they are mindless instruments, and if undirected they move with a momentum of their own and destroy everything in their path —the land- scape, the environment, the quality of life» We can't excape it. They begin to dictate how we are to live. The slogan in Wisconsin — I don't know if it still is — I don't listen to that much TV — was: "'Live better elec- trically." Well, I am not living better electrically; I am living worse electrically If it means that I have to go without any electricity in my house for the moment I will do it, because what kind of a life is it to live inside a house \vith every comfort and convenience and not be able to walk outside and enjoy the environment? So that is about all I have to say,, except that as a citizen and as a mother of three children about the ages of some of the children out there, you have to ask yourself as you go through life: "'What is your aim in life? "The environment has been very good to me in my ------- 2042 Mrs. Mo H. Dunlop years on Lake Michigan, and my aim in life is to pay a little rent, and I am going to do everything that I can as a single person in this world to try to save it. Thank you. (Applause) MR. STEIN: Thank you. Are there any comments or questions? If not, Mary Helen Dunlop also has a 3-minute presentation. FROM THE FLOOR: Mr. Chairman, may I ask a question? MR. STEIN: Will you come up, Mrs. Dunlop? I wish the power companies here could distribute some of those electric clocks so people would know when their 3 minutes are up. STATEMENT OF MARY HELEN DUNLOP, EVAN3TON, ILLINOIS MRS. DUNLOP: Mary Helen Dunlop, a private citizen from Evanston, Illinois. I came down here today to listen, and also to make a statement of my own for myself and for other people whom I think are of like mind. When I arrived here, I was told that Mr. George ------- 2043 G. Brown Brown, representing the Committee on Lake Michigan Pollution, had prepared a statement for that committee and was unable to be here. So I will ask permission to forego presenting my own statement in favor of presenting Mr. Brown's statement for the Committee on Lake Michigan Pollution of which I am a member. Is that agreeable, Mr. Stein? MR. STEIN: I take it that is no longer a 3-minute statement. MRS. DUNLOP: I will take longer than that. MRo STEIN: Thank you. Go right ahead. STATEMENT OF GEORGE BROWN, COMMITTEE ON LAKE MICHIGAN POLLUTION, WILMETTE, ILLINOIS (PRESENTED BY MARY HELEN DUNLOP) MRo BROWN: My name is George Brown and I am speaking in behalf of the Committee on Lake Michigan Pollution, Box 5^3, Wilmette, Illinois. The CLMP is a citizens' organization representing members in 10 communities on the north shore. Our main objective is to eliminate and resist present and future pollution threats to Lake Michigan. The committee provides a structure for the individual citizen to contribute to this ------- 2044 G. Brown objective. We have become more convinced over the 4-year life of our group that on important issues relevant to the lake it is important for the public to be heard since reliance on industrial testimony or from political sources is not representative, We have consulted people with expertise within and outside our organization. However, our testimony today will not be primarily technical in nature; that is clearly not our comparative advantage. We do feel, however, that we can make a contribution to the problem of establishing standards,, Our position concerning thermal standards is' as follows: 1. A thermal standard should be stated in a multi- dimensional framework. It is not sufficient to establish standards solely in terms of a single dimension such as some stated increase in temperature level at the point of discharge. Other criteria must be included such as the quantity or pounds of water discharged at a particular temperature increment, the length of time the water is discharged at a given temperature level and amount, the rate of change in temperature level at point of discharge, etc. Reliance on one criteria, although administratively simple, does not reflect strategies which vary the levels of temperature, quantity of water discharge and time period ------- 2045 G. Brown of the discharge. Since combinations of these dimensions have different ecological effects they must be reflected in any standards. Criteria should also be stated in terras of subregions of the lake as well as for the lake as a total system. Failure to state the criteria in a multi- dimensional sense denies the complexity of thermal effects on our environment, 2. A complex monitoring system must be included in the establishment of operative thermal standards. This position is based on the following rationale. The amount and quality of information on the effect of thermal pollution on Lake Michigan is not well understood. We are not in i position at the present time to make predictions with r.ono certainty on the effects of increase in temperature level or B.t.Uo's on the ecological system of Lake Michigan, for the near or distant future. Any standards established now would be somewhat arbitrary. We would accept such a standard as an initiax benchmar.-- if it ic tied to :i lake- wide monitoring system. A monitoring system would provide the me^ns to revise the composite standards. It would nlso provide a moans to orovide inriodi^to ^oedback on ecological changes in the I'.tk^. Although there will be many studios published in the coning years which will attenpr, to show whether ------- 2046 G. Brown thermal effects are significant and their relative magnitude, these studies will not be definitive despite their author's intentions. If a particular study shows no ecologically harmful effects occur at a particular increase in temperature level in a given region that will clearly not be an adequate date base for eliminating thermal standards. A study or even group studies will not reflect the complex interactive effects that occur in the Iake0 It is only with a continuous monitoring and feedback system that the effect of thermal inputs into the lake can be controlled. Information technology is clearly sophisticated enough at the present time to provide the critical link over time between thermal inputs and ecological changes. This link is critical to any decision-making about thermal standards. MR. STEIN: Thank you, Mrs. Dunlop, for Mr. Brown. Any comments or questions? If not, thank you very much. Some people have asked about getting up when their names are called and if they missed their turn. If you go out to eat and you come back and you discover your name was called, I have got a check system here. Just let one of our staff know and we will call you as ------- 2047 Co Mathews soon as possible. In any event, we are going to try not to miss anybody. Mrs. Paul S. Quigg has a statement of about 4 minutes. Mrs. Quigg. She is not here? Mrs. Edgar Wilkinson. Mrs. Wilkinson? Clyde Mathews? According to the information I have, Mr. Mathews, your statement should take about 5 minutes. MR, MATHEWS: That is correct. STATEMENT OF CLYDE MATHEWS, COMMUNITY ACTION TO REVERSE POLLUTION, GARY, INDIANA MR. MATHEWS: Gentlemen, my name is Clyde Mathews. I am from Gary, Indiana, and represent CARP or Community Action to Reverse Pollution. CARP is a group of local ci-tizens organized in opposition to the proposed construction of a 500-megawatt fossil generating plant planned by NIPSCO or Northern Indiana Public Service Company for the western edge of Marquette Park in Gary adjacent to U. S. Steel Gary Works. We are committed to the protection and improvement of our city's air, water, and recreational facilities. ------- 2043 C. Mathews An example of the utter disregard of the public by a "public" utility is found in a position paper issued by the Northern Indiana Public Service Company recently. The paper is entitled "Position Paper on NIPSCO's Electric Facilities and the Environment" and states, "... it (electricity) provides economic and beautification benefits to the Nation which far outweigh the effect power installations might have upon their immediate ecological neighborhoods." As residents of Gary, Indiana, one of the so- called expendable ecological neighborhoods, we take strong issue with this statement and attitude. This statement clearly demonstrates the environmental expediency and irresponsibility which has been characteristic of the power companies in dealing with the communities in which they operate. We, therefore, demand the Federal and State leadership necessary to protect the natural resources essential for those of us who live in this industrial complex and similar ones elsewhere. Recognizing the fact that there is much needed research to provide absolute facts as to the effect of thermal pollution, sufficient evidence has been presented concerning the destructive effects of massive dumping of ------- 2049 C. Mathews waste heat into Lake Michigan to make it mandatory for this conference to act. Both the Federal and State water pollution control agencies must provide stringent interim standards for waste heat discharge. In our local struggle with NIPSCO we find again and again that they have no intention of reducing waste heat unless forced to do so. Municipal governments have the responsibility of protecting the health and well being of their citizens. They must have uniform, unequivocal standards upon which to base their local ** legislation. It is the undeniable responsibility of this conference to provide our cities with these stan- dards . We, therefore, strongly endorse the Interior Department recommendation that "no significant discharge of waste heat into Lake Michigan should be permitted," Thank you. MRo STEIN: Thank you, Mr. Mathews. Any comment or question? (Applause.) Mrs. Miriam G. Dahl. Mrs. Dahl, you also have indicated a 5-minute statement. MRS. DAHL: I took a guess. ------- 2050 Mrs* M. Dahl STATEMENT OF MRS. MIRIAM DAHL, IZAAK WALTON LEAGUE, WISCONSIN STATE DIVISION, MILWAUKEE, WISCONSIN MRS. DAHL: I want to express my appreciation, after having to listen to all that you have this week, that you still are willing to listen to us who are legitimate public, and the general public I am representing today amounts to — I have said 1,500, but it is closer to 2,000 people, so I am sure that all of them will be grateful for your time which you are giving us. Mr. Chairman, and conferees. The Wisconsin State Division of the Izaak Walton League of America representing some 1,500 citizens of the State of Wisconsin reiterates today the firm stand taken initially against the artificial addition of heat to our waters. In deference to the mathematical computations that absolute degrees of return temperatures cannot be equalled (though we think this statement .is subject to question) we accept the allowance of 1 degree above water temperature given in the statement by Secretary of Interior Walter Hickel as tolerable. We know this temperature can be achieved by more than one method. It is fact. ------- 2051 Mrs, M. Dahl We do not subscribe to the proposal by the State of Michigan of a 3 degree tolerance using acres of lake water to cool instead of cooling before returning used water to the lake. This method affects a far greater amount of water at varying upward temperatures than would be indicated in a stated 3 degree tolerance. In a study conducted in Tennessee by James Speakman, tests showed that a 3-degree rise even in the warmer waters has a devastating effect on the hardiest fish natural to that area. Other fish and aquatic life would be affected more quickly. The Columbia River, famous spawning grounds for our best salmon, has been ruined by atomic thermal addi- tions, A 3-degree rise in river temperature in this nitrogen-rich water killed juvenile salmon in just 90 seconds. That is 1-1/2 minutes. Think of the effect such temperatures would have on the coho salmon, trout and other spawn in Lake Michigan. If a 3-degree temperature is possible, a 1-degree is equally possible. Cost has been made a strong point. The actual cost to the consumer will not be that great annually. The alternative to that cost may well result in uncontrollable climactic changes, and no lake, ergo, no water. The alternative to this has to be wise use and sensible ------- 2052 Mrs, M. Dahl administration. In July the National Izaak Walton League of America in convention assembled in Norfolk, Virginia, voted to support Secretary Hickel's 1-degree allowance in thermal addition. Wisconsin State Division supports that decision. And I might say we pioneered the introduction of that into the convention. Conservationists reach a large segment of the "silent majority11 who ask us, "Why is continuance of such malpractice allowed against our environment? How can we stop it?" It is no longer valid to say that economic feasibility demands such action. We are frequently asked to "face reality" by economists and industrialists. We reply that this reality we face is the spendthrift race to overuse, rape, and destroy our true base wealth which economists state is our true wealth together with people. Everything else follows this first premise. When we begin with this reality, we come to a far different set of conclusions with a truly realistic value which includes people, a future, esthetics, and social values to make a whole life. Then money takes its proper place in purchasing the necessities, and not as an end in itself. Life depends on water, air, food, ------- 2053 Mrs. M. Dahl natural resources. Save these. We have heard all the excuses and testimonies to substantiate the inability to meet a 1-degree standard. We say that we can do anything we want to do. We have proved this in outer space and undersea explorations, in creating synthetics (always from natural resources), in medical transplants and other Jules Verne accomplishments. Now, we must attend to our basics. We must make fullest, best use of our rapidly disappearing resources. The "waste-not-want-not1* maxim must replace the wanton disre- gard of single use and discard the rest. We must depend on such government bodies as yours to guide us to firm National standards with full powers of enforcement to protect our remaining resources. We, the conservation groups, and we, the public sector, urge you to set standards of thermal additions to Lake Michigan at 1 degree above temperature. The fragility of Lake Michigan demands this decision. We hope it will become the standard for all waters. Thank you. Respectfully, Miriam G, Dahl, I am Chairman of the State Division, Pollution Abatement Committee of the State of Wisconsin, and have just this year been placed on the National Water Committee for the Izaak Walton League, ------- 205^ Mrs, D. Trump (Applause) MR. STEIN: Thank you, Mrs. Dahl, Any comments or questions? If not, thank you very much. We have Mrs. Paul Kaefer. Harold B. Olin. Mrs. Robert Herlocker. FROM THE FLOOR: She will be back. MR. STEIN: H. R. Thoke. Mrs. Donald Trump. STATEMENT OF MRS. DONALD TRUMP, CHAIRMAN, ENVIRONMENTAL QUALITY, LEAGUE OF WOMEN VOTERS OF INDIANA, VALPARAISO, INDIANA MRS. TRUMP: I will file with you a separate statement. (See P. 2055) This is just from the League of Women Voters of Indiana. I am now speaking for the Lake Michigan Inter- League Group. It represents 75 local Leagues of Women Voters and the State Leagues of Illinois, Indiana, Michigan, and Wisconsin. Each unit has been working for local, State, and regional environmental management programs which are planned to improve the Lake Michigan Ba.sin. Although other ------- 2055 Statenent to The Third Session Federal Conference on Lake I.ichigan and its Tributary Basin Workshop on October 2, 1970 by llrs. Donald Trump, Chairman Environmental Quality for the League of :/oraen Voters of Indiana Our League members' longstanding concern on water quality and its conservation has led them to inquire about the problems created by water thermal changes as well as other problems. We have learned that there can be aquatic changes, synergistic effects of heat with possible toxic substances, and that deep lake water seeisonal temperature stratifications can have deleterious alter- ations, by placing a layer of warm water on it. Plus the value of water for drinking, recreation and industrial use decreases at l}igh temperature. We have also learned about the problems that are presented on cooling water systems, their possible detriment to atmosphere with high construction costs, plus the large areas needed for cooling ponds. Therefore, on equating what the experts report, wucre they agree and disagree, our members are saying it is important that the country and the states move cautiously and slowly, with greater safeguards than in the past. Now is the time to evaluate the corrective devices through the present and nex-7 technological aids. Because, once new water-using plants are built, it becomes very difficult for states to require expensive alterations. Further, we believe that when the term nondegradation is used for water standards, it should mean no further man-made degra- dation. Also, any regional or special area variances in temper- ature standard requirement allows the problem of competitive cost advantages to develop within industries. If careful planning in locating plants produces a cost advantage when equal standards are applied, then the regulating bodies have succeeded in their function. Thank you. ------- 2056 Mrs. D. Trump aspects of League efforts relate to local or broader problems, as an Inter-League Group, we concentrate solely on the preservation and improvement of the quality of Lake Michigan. We are encouraged to witness the continuance of the Federal-State Enforcement Conference and to see its concentrated approach to Lake Michigan and its tributaries. We believe that only through this type of regional, inter- state, and multi-level governmental action can the necessary complicated solutions to Lake Michigan problems be found and enforced, Basic to the League approach to the task of improving water quality, the League maintains that no one has a right to pollute public waters and that those who produce wastes should bear the cost of managing them. The question of placing thermal effluent in the category of pollutants is one that has been thoroughly debated. The premise upon which we base our assumption that thermal effluent, from any source, is a pollutant, is that moment when the thermal additives cause a deleterious effect upon the waters, the natural ecology within the waters, the environment surrounding the waters, or affects the use of the waters by area residents or visitors. Some authorities cite case after case of fish kill, ------- 2057 Mrs, D, Trump environmental hazards, or speed-up of eutrophication as a result of thermal additives. Other authorities claim that no proven case of known environmental or other effects can be found. League members can certainly claim no prescience to pick that group of scientists which will turn out to be correct. League members know, however, that the confident casual approach to looming problems has not been successful in any instance in the past. It seems that only after the damage has become an obvious danger has concern and control become visible and too little. Therefore, we encourage this Federal-State Enforcement Conference to consider the recommendations of the Federal Water Quality Administration which would main- tain lake water temperatures as close to natural levels as possible. We believe that American technology can find practical ways of achieving this high goal, thus preventing the addition of at least one type of pollutant to Lake Michigan, The League supports discharge requirements which we think are necessary for State and Federal enforcement, We find it difficult to see how stream standards could be reached and maintained without setting standards for effluent and monitoring at point of discharge. The use of mixing zones as a component of regulating thermal ------- 2053 Mrs. D. Trump discharge can complicate the regular measurement procedures and, in certain instances, confuse the possible identity of an unlawful discharger. We believe that it is good in intent but possibly unrealistic as a solution to require power companies to file contingency plans when applying for construction permits. These plans would outline remedial steps to be taken in case their thermal discharge proves harmful. If a power- plant discharges its thermal effluent into Lake Michigan for a period of some years before cumulative damage is observed, it is possible that an established dependency upon that powerplant by the consumer would necessitate continued functioning of the plant while the contingency plan was reviewed and implemented. How long would that take and what further damage could be caused in that period of time? Attention has been drawn to some of the recrea- tional benefits derived at the point of discharge by attracting large numbers of warm-water fish. Others have followed this point and have asked about the possible effects of a plant shutdown on this unnatural fauna. Would a false environment be established which would then require maintenance? Nuclear powerplants are now considered to be the major "new" source of thermal additives. If it is ------- 2059 Mrs. D, Trump determined that cooling ponds are the preferred technique for cooling the heated water, what are the guarantees that the recreational uses proposed for these ponds will not dangerously expose the users to radioactive leakage? This brings up another subject which is presently full of unknowns and causes conflicting judgment of accumulated data. League members have studied the questions involved enough to know that there are no easy answers and that simplistic solutions must be viewed in a suspect manner. The ultimate decision this conference reaches will certainly not please everyone. We urge caution and, if necessary, that error be made on the side of prevention. We ask that, whatever the final determination, a realistic and yet firm compliance schedule be arranged, and that continuing enforcement measures be incorporated and applied. We urge that opportunities be automatically given to the public to react and respond to powerplant construction proposals before site work has started. League members, along with the rest of the citizenry, must take a long hard look at our environment and its growing misuse by growing numbers of people. Perhaps it is time for new judgment values to be made on both population and economic growth. The estimates that ------- 2060 Mrs. D. Trump the affluent citizens of the United States are responsible for 50 percent of the world's annual consumption of natural resources is frightening rather than satisfying. We must grow up, we must change, we must make hard decisions. Here, today, is the chance to do this in time to save Lake Michigan, Thank you, (Applause) MR, STEIN: Thank you, Mrs, Trump, Are there any comments or questions? If not, thank you very much, (The following document was submitted by Mrs, Trump for inclusion in the record,) ------- MICHIGAN 2061 League of Women Voters LAKE MICHIGAN INTER-LEAGUE GROUP INDIUM Thermal Pollution April 1970 League of Women Voters 67 E. Madison Chicago, Illinois 60603 twenty cents quantity price on request Thermal pollution is the deleterious change in the normal temperature of water caused by the discharge of waste heat. "In specific cases where heated water discharges are causing actual death in an aquatic habitat, depressing repro- duction and growth of desired species, or degrading the environment to a point where less desirable organisms are favored, then we must consider that thermal pollution exists," says Raymond Johnson, assistant director, Bureau of Sport Fisheries and Wildlife, Department of the Interior. POWER PLANTS AND THERMAL POLLUTION The nation's need for electric power is doubling every ten years. Massive use of cooling water to condense steam in power plants is an integral part of the generating process. Almost half the water used in the United States is for industrial cooling, with the electric power industry using about 70 percent of this amount. It is estimated that by the year 2000, the need for water for industrial cooling will equal two-thirds of the nation's natural daily water runoff of 1,200 billion gallons.1 A single power plant now in existence requires up to a half-million gallons of water a minute for cooling purposes, running at full capacity around the clock, this would mean 720 million gallons a day. Some of this cooling water evaporates; most of it, however, is returned at a tempera- ture ten to thirty degrees above the temperature of the water from which it was withdrawn. The projected growth of the electric utility industry during the next two decades is expected to require the construction of about 40 new hydroelectric installations of 100 megawatts or more, 50 new pumped-storage hydro- electric installations of 300 megawatts or more, and 90 fossil and 165 nuclear steam-electric plants on new sites.1 Nuclear power plants now supply about 1 percent of the nation's power; by the year 2000 they are expected to provide about 50 percent. "U.S. Making Initial Move Against Thermal Pollution," by Gladwin Hill, New York Times, February 22, 1970. Joint Committee on Atomic Energy, "Environmental Effects of Producing Electric Power," October, November 1969. THE EFFECT OF INCREASED THERMAL POLLUTION ON LAKE MICHIGAN There is one nuclear power plant now operating on the shores of Lake Michigan. Nine more are proposed or in process, with all but one scheduled for completion by 1973. The ten plants will have an electrical capacity of 7,100,000 kilowatts. Major Fossil-fueled and Nuclear Power stations located on Lake Michigan2 • Coal Burning ' © Nuclear-operating • Nuclear-under construction (Numbers indicate power capacity in megawatts) ------- 2062 Existing fossil fuel3 plants, operating at full capacity, discharge an estimated 300,000 billion Btu1 per year in cooling water to Lake Michigan. Nuclear reactor plants discharge 40 to 50 percent more waste heat per unit of electrical production to the cooling water than do fossil fuel plants. It is estimated that the ten nuclear plants, when in full operation, will discharge 388,000 billion Btu per year to the lake. If all plants, both existing and proposed, were to operate at full capacity (and assuming complete mixing of the entire lake) the temperature of the lake would be raised a little more than 0.06°F annually.5 The above calculation assumes no reduction in the heat of the cooling water after its addition to the lake, but actually there will be much reduction through evaporation, radiation and other means. There will, however, be a resid- ual of the added heat that will be cumulative in the lake until an equilibrium is reached at a somewhat higher temperature than that due to natural causes. It is estimated that witn an average annual temperature of 50 F for the lake, the added heat would raise the average annual temper- ature at equilibrium by 0.05°F to 50 05°F. With increasing power production and no off-lake cooling, it is estimated the average annual temperature would be increased by 0.4°F in the year 2000 and by 2.0°F in 2023. This increase would nullify a two degree decrease in average annual temperature of the lake that has occurred, apparently from natural causes, in the past one hundred years.1 The possible local effects of increased temperature on aquatic life are cause for more immediate concern than the effect on the lake as a whole. Fish, and the aquatic organ- isms that serve as their food, are particularly sensitive to variations m natural seasonal temperature during repro- ductive and juvenile stages. The value of water for drinking and for recreational and industrial uses usually decreases at higher temperatures. Thermally polluted water is less capable of assimilating wastes While present use of Lake Michigan waters for irrigation is minimal, local temperature rises in areas near intakes for irrigation water might affect seedlings, plant growth rate, and crop yield. As temperature rises, nuisance plants, algae and rough fish flourish while more desirable life dies. The quality of water deteriorates as foul odors and algal slime appear. THERMAL POLLUTION AND THE AQUATIC ECOSYSTEM Thermal pollution can affect the entire ecological bal- ance of natural waters. Water discharged from power plants is often ten to thirty degrees warmer than the body from which it was drawn. A temperature change of only three to four degrees can, under certain conditions, have serious effect upon fish and other aquatic life, depending on the - Fuels such as coal, oil, and natural gas - British thermal unit, the quantity of heat required to raise the temperature of one pound of water one degree Fahrenheit - Statement of F W Kittrell, Chairman, Committee on Nuclear Power Plant Waste Disposal, at the Conference on Lake Michigan. U. S Dept. of Interior, FWPCA, Proceedings, Volume II, Febru- ary 1969. level, duration and rapidity with which the temperature change takes place. Some effects of thermal pollution on the ecological balances of natural waters are l)The addition of warm water may cause fish eggs to hatch so early in the spring that natural food organisms are unavailable. 2) Temperature changes act as signals for fish migration and spawning. If hot water from a power plant spreads com- pletely across a river or stream, it can form a thermal barrier preventing fish from swimming upstream to spawn or from passing safely downstream to carry out their life cycle. 3) Trout eggs will not hatch if incubated in water that is too warm, and salmon may not spawn. 4) The sensitivity of aquatic life to many toxic substances is heightened at increased temperatures. 5) Fish double their consumption of oxygen for each ten degree rise in water temperature. As water warms up, it can hold less oxygen, thus lowering the amount of oxygen available to aquatic life. 6) Within certain limits bacterial activity is increased. In a statement before the Joint Hearings on Atomic Energy, Dr. Johnson said, ... on June 25, 1969, temperature monitors installed by the Federal Water Pollution Control Administration (FWPCA) personnel near the mouth of the Florida Light and Power Company's Turkey Point fossil fuel power plant effluent canal recorded very warm water in Biscayne Bay. At this time biologists recorded high turbidity and evidence of significant kill of bottom living aquatic organisms. Large numbers of dead crabs, pistol shrimp, benthic fish, and dead or dying species of invertebrates and macroalgae were observed. The greatest concentration of dead crabs appeared to extend from the mouth of the Grand Canal into the bay about 1,000 yards. Further observations on June 28 found a variety of sponges, coral, green algae, crabs and mollusks dead as far out as 1,500 yards. While available data cannot rule out other factors, the most probable cause of death to these organisms was excessive temperature. THERMAL EFFLUENT AND THE ECOLOGY OF DEEP LAKES The most dramatic ecological events for deep lakes in the temperate zone are the seasonal turnovers. In the spring, surface waters warm to 30°F, sink and mix with the bot- tom water, bringing the nutrient-rich bottom water to the surface. The surface waters cool in the fall and again a turnover occurs. The algal blooms which follow these turn- overs are well known. The ecology of temperate zone lakes is largely determined by turnovers and by the stratification of the water into layers with varying temperatures during the intervening periods. The chemical, physical, and biologi- cal structure of lake ecosystems is keyed to these events. A power plant which places a layer of warm water on a lake surface may disrupt the circulation pattern and either prevent turnovers from occuring or change the time at which they take place. The effects of this on lake ecology can be drastic and possibly disastrous.4 ' "We're in Hot Water", by John Cairns, Jr., m Scientist and O'rizen, October 1968. ------- 2063 Reported fish kills caused by heated waste water discharges from electric power generation plants Date Aug. 6-8, 1962 Aug. 11, 1962 Sept. 7, 1963 May 28, 1964 Aug. 19, 1965 Aug. 20, 1965 Jan. 19-22, 1966 Sept. 2, 1966 Jan. 1, 1967 Jan. 17, 1967 Jan. 1, 1968 Jan. 2, 1968 Mar. 1, 1968 July 1968 Aug. 22, 1968 Dec. 16, 1968 Dec. 24, 1968 June 30, 1969 State Penna. Mo. II! Tex. Penna. Ohio Ohio Penna. Ohio Ohio Nebr. Ohio Utah Mass. Mass. W. Va. Ohio Fla. Stream or lake Raystown Branch, Juniata River Discharge canal to Montrose Lake Rock River Unnamed stream Schuylkill River Greater Miami River Ohio River Schuylkill River Sandusky River Sandusky Bay Lake Hastings Sandusky River Price River Cape Cod Canal Cape Cod Canal Ohio River Sandusky River Biscayne Bay Nearest town or county Saxton Ladue Rockford Victoria Reading Montgomery Toronto Philadelphia Sandusky Erie County Hastings Sandusky Castlegate Sandwich Sandwich New Cumberland Sandusky County Miami Degree of severity Heavy Heavy Light Light Moderate — Light Heavy - - Moderate - Heavy Moderate Moderate Light - - Number of fish killed 3,441 Several thousand - - 1,000 1 1 ,250 200 50,000 300,384 78,755 5,000 250,585 150 - - 9,500 3,000 - Thermal effluents might become a hazard to local aquatic life during the summer months when surrounding temperatures are higher (60-70°) inshore. In the mam, however, Lake Michigan is cool even at the height of summer. During the fall and spring overturning of the lake, a thermal bar, or barrier, is established several miles off- shore. The bar prevents the inshore and open lake water from mixing, and hence might trap the heated discharge waters and also the fish, because of their reluctance to go through the thermal bar. These close-to-shore effects, how- ever improbabie, are possible. The only effective counter- measure would be to shut down, or substantially reduce, the output of the station causing them. If this were to become a recurring phenomenon, serious consideration would then have to be given to use of cooling ponds or towers.2 SYNERGISTIC EFFECTS Of THERMAL POLLUTION Synergism is the simultaneous action of separate agents that, together, have a greater total effect than the sum of their individual effects In reference to water temperatures, synergistic action refers to the fact that temperature rises increase the lethal effect of many toxic substances to aquatic life forms and may also increase the susceptibility of the fish to disease. Since domestic and industrial wastes are numerous in the nation's waters, the synergistic action between temperature and toxicity is a relatively common occurrence. Fish kills have accompanied small temperature rises which might have been insignificant in a stream free of toxic substances. Thus the concentration of a substance may be harmless at one temperature, but may contribute to fish mortalities when combined with the stress imposed by higher temperatures. For example, the myxobacteria Chondrococcus columnaris, which can cause death through tissue destruction, becomes more virulent as temperature is increased * OPINIONS ON THERMAL POLLUTION AND THE AQUATIC ECOSYSTEM Industry. At the Michigan Governor's Conference on Thermal Pollution, July 1969, Wayne L Wingert of Michi- gan Electric Utilities reported, "Certainly, in some instances the thermal effects could be detrimental. In other cases, these may well be beneficial, as for example the improve- ment in oyster growth being demonstrated on Long Island Sound. We know of no problems which have resulted from the addition of heat to the waters of Michigan " In his report at the same Michigan conference, D. H. Brandt of Consumers Power company said "there appeared to be no gross thermal damage to the benthic (bottom- dwelling) fauna of the main plume area" at their Campbell, Michigan, site on Lake Michigan. Government Agencies. The Energy Policy Staff, Office of Science and Technology, said in their Considerations Affecting Steam Power Plant Site Selection In recent years we have come to realize that injecting huge quantities of heat into a waterway can create a new form of water pollution and for that reason the States, in cooperation with the Department of Interior's Water Pollution Control ~ "Nuclear Power and Thermal Pollution," by Philip F Gustafson m Bulletin of the Atomic Scientists (preprint), March 1970. - Industrial Waste Guide on Thermal Pollution, FWPCA, Northwest Region, Pacific Northwest Laboratory, September 1968 ------- 2064 Administration, have adopted temperature limitations for the nation's interstate waterways. The Atomic Energy Commission has no present juris- diction over the thermal effects caused by the siting of nuclear plants Many individual state legislatures have adopted water quality regulations. When selecting a site for a reactor facility, a utility must satisfy its particular state that it can comply with these regulations during the operation of the facility. Based on the data now available and experience with other wastes, it is only prudent that great care be exercised so as to avoid damage to the aquatic environment rather than to plan to correct gross problems after the power industry is heavily committed to the use of facilities which provide little or no control over the effects of their activities on the envi- ronment. The Federal Water Pollution Control Administration has declared that waters above 93°F are essentially uninhabit- able for all fish in the United States except certain southern species. Many U.S. rivers already reach a temperature of 90°F or more in summer through natural heating alone. The waste heat from a single power plant of the size planned for the future (some 1,000 megawatts) is expected to raise the temperature of a river carrying a flow of 3,000 cubic feet per second by ten degrees, and since a large number of power plants are likely to be constructed on the banks of a single nver, it is possible that many waters would become uninhabitable for fish. In a book produced by a Wisconsin utility, Dr. Glenn T. Seaborg, chairman of the Atomic Energy Commission, said "Growth of nuclear power will help abate air pollution, reduce traffic and noise in the area surrounding the power plant, and generally make the area a much more attractive and healthier place to be." A warning was issued by Lee C. White, the head of the Federal Power Commission for most of the Johnson Administration. Mr. White said some expeditious method of resolving disputes over the location of electric facilities must be found. Otherwise, the power industry's ability to supply electricity may, in many locations, soon be out- stripped by the apparently endless increases in public de- mands for electricity. The public will no longer be able to assume "there will be energy at the flick of a switch." PUBLIC OPPOSITION TO NUCLEAR PLANTS The public has actively shown its concern about the ten nuclear generating plants planned along Lake Michi- gan by 1973. These plants are in seven locations, three being double plants. None is designed to reduce the temper- ature of cooling water before it is discharged into the lake. The proposed Commonwealth Edison plant at Zion, Illinois, has stirred such critics as Senator Gaylord Nelson of Wisconsin and Chicago Alderman Leon Despres. Mr. Despres says the company should build cooling towers to reduce the temperature of the hot water before it is re- turned to Lake Michigan. Some biologists and ecologists say the hot water discharges will change the temperature of Lake Michigan and alter the lake environment of native marine life. INDUSTRY'S ANSWER Robert A Hirshfield, engineering consultant for Com- monwealth Edison, has said "many of the critics are misinformed or jumping to conclusions." He said the Zion Power generation, population, and power per capita in Chicago area, 1950-19802 I O 2 II u '-' il DOUBLING TIME Power per Capita 12 years Population 46 years Power Generation 10 years 05 I95O I960 1970 1980 YEAR nuclear power plant is designed to return cooling water to the lake eighteen or nineteen degrees hotter than when it came in. A 10-year study by Edison of offshore lake water temperature showed a maximum temperature of sixty-five degrees. A nineteen degree increase in the warmest water known to Edison would result in cooling water that would be eighty-four degrees, said Hirshfield, thus meeting federal and state water pollution standards (of eighty-five degrees for discharged cooling waters). REDUCING THERMAL POLLUTION OF NATURAL WATERS The alternatives developed thus far for reducing thermal effect on lake water quality are the use of cooling towers or of artificial lakes and reservoirs There are two types of cooling towers: Wet tower. Heat is removed by evaporation, cooling the water by twenty degrees. The main disadvantage in the wet tower is that large amounts of water are discharged into the atmosphere. For example, the towers for a 1,000 megawatt power plant would eject some 20,000 to 25,000 gallons of evaporated water per minute. Dry tower. The heat is transferred from the cooling water, through a heat exchanger, directly to the air without evaporation. The dry system costs two and a half times as much to build as the wet system. What Industry Says About Cooling Towers Mr. Hirshfield, Commonwealth Edison's engineering consultant, is opposed to the use of cooling towers at Zion, Illinois. He says cooling towers for a plant the size of Zion would increase the present cost of the project by $15 to ------- 2065 $22 million. They would stand as high as thirty stones and would reduce the temperature of used cooling water within six to twelve degrees of that when it entered the plant, depending on humidity. , "They are unsightly, they throw off huge amounts of mist, and they could fog up the whole town of Zion," said Hirshfield. "Cooling towers," he said, "can create fog for a distance of 3/4 of a mile." Consumers Power Company is planning to use a reservoir rather than cooling towers at their Midland, Michigan, project. "If we had planned to use cooling towers at Mid- land, we would be faced with an investment of $25 million. The artificial reservoir is estimated to cost $6 million less," said Harry R. Wall, senior vice president of Consumers Power Company, at the 1969 Governor's Conference on Thermal Pollution in Traverse City, Michigan. What Government Says About Cooling Towers5 Primary concern is with potential fogging conditions caused by cooling towers, but other possible adverse side effects are being considered. Because of the large amount of water vapor expelled from evaporative towers, extreme climatic conditions may cause condensation, resulting in ground level fog or drizzle. However, such conditions are not often encountered. A recent investigation of fogging problems from natural and mechanical draft towers presently operating in the eastern United States supports this conclusion. Reports indicate that natural draft towers did not produce ground level fog or drizzle under any weather conditions. Plumes rarely dropped below the top of the tower for an extended distance, and generally dissipated within a few hundred feet of a tower. Mechanical, induced draft towers reportedly produced substantial amounts of ground level fog, espe- cially during the winter. The area affected by the fog was very small, however, extending a maximum of about one- fourth mile from the towers. Carry-over of some water droplets was also noted from the mechanical draft type. Resulting precipitation occurred in the immediate vicinity of the towers, causing some minor icing problems up to 300 feet away. In general, undesirable meteorologic effects from towers can be prevented or controlled to a large degree through modern design that incorporates effective drift eliminators, air-flow control, etc. In situations where problems arise, the area affected is limited to that immediate to the tower installation. What the Public Says About Cooling Towers Proponents of cooling towers say that the $15 to $22 million quoted as the cost of cooling towers for Zion's nuclear power plant is only 10 percent of the capital cost (adding perhaps 2 or 3 percent to the electric bill). UTILIZING THE THERMAL EFFLUENT Waste heat may be used to prevent frost damage to orchards, or to extend the growing season of crops that bring premium prices in an early market. Cooling ponds can do double duty as recreational lakes. Thermal effluent might be used in desalination plants to aid in the evapora- tion process, or to improve efficiency of sewage treatment. Others suggest using the effluent for sea-farming with selected fish tolerant of warm water, for heating buildings, or for growing plants in water in a controlled way. ACTION TO MINIMIZE OR PREVENT THERMAL POLLUTION The Federal Water Pollution Control Administration of the Department of the Interior established a provisional set of guidelines for water quality in 1967 that includes thermal pollution. Maximum permissible water tempera- tures for individual species of fish are specified and units for the heating of natural waters for industrial cooling purposes are recommended. Senator Edward M. Kennedy has proposed that further licensing of nuclear power plant construction be suspended until a thorough study of potential hazards has been made. Senator Edmund Muskie's subcommittee on air and water pollution held hearings on thermal pollution in 1969 in many parts of the country. Thermal pollution control measures are costly and com- plicated. An estimate by the FWPCA places the cost of cooling facilities needed through 1972 at $1.82 billion. Other action suggested includes: l)Set specific peak temperatures for each locality to pre- vent fish kills from temperature fluctuations. These criteria, however, might not assure the maintenance of stable ecosystems in all their complexity. 2) Undertake studies of aquatic ecology. These studies might be financed by federal, state or private agencies. 3) Require the power company to prove that its use of the stream or lake would not impair other beneficial uses. 4) Monitor both existing plants and new ones as they go into operation to insure that preliminary estimates were correct and that operating methods are sound. LAKE MICHIGAN'S THERMAL WATER QUALITY STANDARDS Of the four states bordering Lake Michigan, Illinois and Indiana have temperature standards, approved by the Secre- tary of the Interior, that require the maximum temperature of Lake Michigan water not exceed 85°F after reasonable allowance for mixing. The Wisconsin standard, also approved by the Secretary, allows up to 89°F, after mixing, at the shoreline and in harbor waters. Some, but not all, of these standards also include various provisions limiting rates of temperature increase and increases over natural tempera- ture. The Michigan standard, which has not been approved by the Secretary, establishes no numerical limits, but is a general statement designed to abate or prevent injury of any kind, due to temperature, to any type of water use or value. The Federal Water Pollution Control Administration is m the process of formulating new water quality standards pertaining to thermal additions to Lake Michigan. Within the next few months the four Lake Michigan states and the Federal Water Pollution Control Administration plan to consider the adoption of uniform standards to control thermal pollution in the lake. ------- 2066 All four states grant approval for the nuclear power plants with the understanding that requirements may be revised if experience proves such a need. THE REAL CHOICE: THERMAL POLLUTION OR A SHORTAGE OF ELECTRIC POWER? The ultimate decision to be made seems to be just how much money and effort the public is willing to invest in cutting down heat pollution now in order to avoid future problems. It must be recognized, too, that even if the choice is made to invest to prevent heat pollution of the water, the waste heat fron the power generation is released into the air. Some scienlsts are concerned about the heat balance of the earth aid the effects of the increasing releases of heat and othir combustion by-products on the atmosphere - ultimate}} on the whole ecology. There is clearly a need for much more research to determine the amount of such releases fie atmosphere will absoib without permanent change. Alsqjiesearch is needed to increase the efficiency of power genention to prevent pollution from its by-products, and to irtlize such by-products, including heat. REFERENCES Brandt, D.H., "Ecological Studies and Temperature Surveys at Con- sumers Power Company Electric Generating Stations." Talk pre- sented at Governor's Conference on Thermal Discharges, Traverse City, Michigan, July 18, 1968. Bukro, Casey, "Pollution Toes Fear Atom Site," Chicago Tribune, July 6, 1969. Cairns, John Jr, "We're in Hot Water," Scientist and Citizen, October 1968. Clark, John R., "Thermal Pollution and Aquatic Life," Scientific American, March 1969. demons, Neil L., "Pollution Are Nuclear Reactors Safe?" Wall Street Journal, August 28, 1969 Conservation Report, National Wildlife Federation, "Hickel Recom- mends Strict Control on Water Pollution," March 1969. Energy Policy Staff, Office of Science and Technology, Considera- tions Affecting Steam Power Plant Site Selection, December 1968 • Federal Water Pollution Control Administration, Northwest Region, Pacific Northwest Laboratory, Industrial Waste Guide on Thermal Pollution, September 1968. Gustafson, Philip F., "Nuclear Power and Thermal Pollution," (pre- print) Bulletin of the Atomic Scientists, March 1970 Hill, Gladwm, "U.S. Makiij Initial Move Against Thermal Pollu- tion," New York Times, Febuary 22, 1970. Hmes, William, "New Way to Generate Electric Power," Chicago Sun Times, June 22, 1969. Joint Committee on Atoma Energy, "Environmental Effects of Producing Electric Power," Gbtober, November 1969. Radford, Edward P., "Staement of Concern," Environment, September 1969. "Thermal Pollution: A Thcat to Cayuga's Waters0", Science, Novembers, 1968. U.S. Department of Interior Federal Water Pollution Control Administration, Conference 01 Lake Michigan, Proceedings, Volume 11, February 1969. Statemeit of F. W. Kittrell, chairman, Com- mittee on Nuclear Power PlantWaste Disposal. U.S. Department of Interio: Water Pollution Problems of Lake Michigan and Tributaries, "Hie trie Power Plants," January 1968 Westmghouse Electric CorpoiUion, Infinite tnergy, 1967. Wingert, Wayne, "Present aid Future Development for the State of Michigan." Talk presented .is Governor's Conference on Thermal Pollution, Traverse City, Michigan, July 1969 This material may be reproduced in whole or in part provided credit is given to the League of Women ------- 206? R. G, Hill MR. STEINj Mr. Russell G. Hill, Executive Secretary of the State Soil Conservation Committee, has had to leave, and he has left his statement. Without objection, I would like to include it in the record at this point as if read. STATEMENT OF RUSSELL G. HILL, EXECUTIVE SECRETARY, STATE SOIL CONSERVATION COMMITTEE, LANSING, MICHIGAN MR. HILL: The Michigan Department of Agriculture has a concerned interest in pollution problems of the Great Lakes. Michigan, with the exception of about 1,500 acres in its southwestern corner, drains into the Great Lakes. Approximately 16 of our 37 million acres are used for agricultural purposes. The Department has several programs directly related to the management of this land and its surface water. Runoff water due to its dissolving and erosive powers carries a variety of substances which may be classified as pollutants. Likewise, mineral and organic participates blown by wind are transported many miles. These particles and the material they carry may also contribute to Great Lakes pollution. It is known that wind and water erosion, fertilizers, pesticides, ------- 206S R. G. Hill farm animal wastes and crop residues may if improperly used and managed constitute a part of the pollution problems. The volume of several of these pollutants has already been documented to your group by the U, S, Soil Conservation Service and other agencies. Their report shows that major Michigan streams annually contribute 1 million tons of sediment to the Great Lakes, It has also been strongly pointed out in other reports that farmland is not the only source of these pollutants. The contribution of runoff and sedimentation from subdivisions, home gardens, lawns, highways, stream- banks, industrial developments, utilities, and shopping centers is beginning to be officially recognized. The Michigan Department of Agriculture has responsibility for several programs which have direct relationship to reducing pollution in the Great Lakes, First let us look at insecticides. All insecti- cides in interstate commerce are registered by the U, S, Department of Agriculture and applications for registrations are routinely reviewed at the Federal level by the Public Health Service, the Food and Drug Administration, the Fish and Wildlife Service of the Department of the Interior as well as the U, S. Department of Agriculture, Under Michigan law, the Michigan Department of ------- 2069 R. G« Hill Agriculture may take further action to restrict registra- tion of a pesticide upon recommendation of Michigan State University Experiment Station. This latter provision in our law is a key to our regulatory action which we took against DDT in 1969• This action concerning DDT in Michi- gan was not a ban but rather an extension of previous restrictions on DDT registrations, Michigan canceled regis- trations for mosquito control in 196&. Michigan was one of the first States in the Nation to take this positive action against the use of DDT. Our action was based upon the fact that scientists at Michigan State University, aware of the long-range implications in the use of persistent pesticides, have been working for years to phase these materials out of our recommendations as suitable alternative materials are developed,. Also in 1969 under the leadership of the State Agriculture Department, an inter-agency pesticide review committee was established. Agencies participating in the agreement with the Department of Agriculture are the Departments of Natural Resources, Public Health, and the Water Resources Commission. More than 5»000 economic poison registrations have been reviewed by the Department of Agriculture laboratory since establishment of the cooperative agreement. Nearly 700 requests for review of ------- 2070 R, G. Hill labels have been received from participating agencies. The Michigan Department of Public Health was recently asked to review all labels and more than 600 have since been referred. Of about 70 objections to registration, 3# have been satisfactorily resolved and 32 are being studied. It should be noted that Michigan farmers have replaced most uses of persistent pesticides as agricultural research has provided alternative insect and disease controls. A recent survey of 5,100 farmers revealed that less than one in a thousand reported any use of DDT last year. Use of other persistent materials was very limited, mainly to control certain corn and livestock pests. Mr. B. Dale Ball, Director of the Michigan Department of Agriculture, stated that similar surveys of agricultural use of pesticides were also conducted in the other four Great Lakes States — Indiana, Illinois, Wisconsin, and Minnesota — as part of the five-State Governors Conference on Lake Michigan. A second program area within the Department involves soil and water conservation. The State Soil Conservation Committee is a division of the Department and has charge of the organization and supervision of Michigan's Soil Conservation District. The first district was established in Michigan in 193&. Since that period, ------- 2071 Ro G. Hill every county but one has organized similar districts. One of the primary objectives of these organiza- tions is the reduction of erosion by wind and water* These districts have been active in controlling erosion for over 30 years and have established an enviable record, fhe #4 districts in Michigan's 82 counties have about 5#,000 landowners as cooperators. In recent years, assistance has been extended not only to farmers but also to a great variety of non-farm land users, A major development has been the effort by soil conservation districts to have local units of government adopt erosion control regulations which would reduce sedimentation by many development activities. Several municipalities have already adopted such regulations and it is expected to spread. There may also be a move for Statewide legislation which would require land developers of all kinds to install proper soil and water control measures as recommended by their local soil conservation districts. Data submitted by the U, S, Soil Conservation through its "Inventory of Soil and Water Conservation Needs" show that our job is far from completed. Their data points out that large quantities of soil still reach the Great Lakes through our major river basins and that about two- thirds of our cropland must have soil and water conservation ------- 2072 R. G. Hill treatment either initially or recurring. Nearly one million acres of cropland are subject to severe wind erosion. However, we have the tools to do the job and the organization established. The State Soil Conservation Committee likewise acts for the Governor's office in processing applications for watershed assistance under Public Law 566, To date, 74 communities have submitted applications for Federal watershed assistance. Forty-eight of these applications have been approved by the State Committee; four have been disapproved; and twenty-two are before the Committee for consideration. Six watersheds have been completed and the U, S. Soil Conservation Service informs us that 10 additional projects are now in operation. In order to accelerate the watershed planning on the approved applications, the Michigan Legislature in 1970 provided funds for the State Soil Conservation Committee of the Michigan Department of Agriculture to employ a supplemental watershed planning party. This move should help accelerate the rate at which local communities are serviced for watershed assistance. Inasmuch as land treatment is a basic objective of these watershed projects, the furtherance of this program should materially assist in reducing sedimentation pollution ------- 2073 R. G. Hill which would eventually reach the Great Lakes. Here, too, it should be pointed out that we still have a long way to go. Approximately 140 watersheds have been identified as having potential need for Public Law 566 assistance. Many years of effort must be expended before this volume of work can be accomplished. Related to the soil and water conservation program is the use of commercial fertilizers which may pollute water. Reference is especially made to nitrogen and phosphorus. Educational programs now being conducted by soil conservation districts and the Cooperative Extension Service encourage soil testing as a guide for the proper application of commercial fertilizer. Research carried out in this State and in other States show that very little phosphorus reaches our water areas by under- ground sources. Excessive uses of nitrogen may provide some basis of contamination. Here too it is becoming more evident that the loss of these plant food minerals is probably due more to erosion than infiltration into under- ground water. Our efforts to control erosion, therefore, should also help alleviate the loss of plant nutrients from land and the subsequent contamination of water areas. Another related area is the farm animal solid waste disposal problem involving large concentrations of ------- 2074 R. G, Hill farm animals. The severity of this problem has also been documented for your use by other agencies. Soil Conservation Districts are closely working with the Agricultural Stabilization and Conservation Service and the Uo S, Soil Conservation Service, and the Cooperative Extension in developing and encouraging methods of properly handling farm manures. Nearly 100 requests from landowners with farm animal waste problems have been submitted to ASCS for cost-sharing and the SCS reports servicing about 50 of these requests. Pollution from this source can be severe under a variety of conditions, but through installation of proper surface runoff control structures and solid waste disposal units we are confident that this problem too can be brought under control. Pollution control regulatory authority in the hands of the State Water Resources Commission will also help bring about compliance of livestock waste disposal so that pollution from these installations will be minimal. Still another area in which the Department has a responsibility which relates to the Great Lakes pollution problem is inter-county drains. An administrative staff member of the Department serves as chairman of all inter- county drainage boards. It is recognized that properly ------- 2075 R. G. Hill constructed drains reduces excessive erosion and subsequent sedimentation of water. Educational and information efforts are being extended to encourage the proper engineering of drainage projects so that ditch banks may be properly seeded and stabilized and spoil banks treated so that erosion will not occur and life of the drainage structure extended. These are some of the major areas in which the Michigan Department of Agriculture are involved which directly relate to the pollution problem of the Great Lakeso We do not say that all problems are adequately under control or that pollution from these sources has been entirely stopped. We are saying that we are confident that the sources of agricultural pollution have been and are being reduced and that further reduction will con- tinually occur. New research in some areas such as farm waste control, pesticides, commercial fertilizer management, and erosion control on non-farm areas are needed so that the proper control techniques may be practically applied. Certain regulatory legislation may be necessary to force compliance in some areas. Nearly 50,000 acres of agriculture land are being transferred to non-agricultural use each year. There is little evidence that this transfer is being ------- 2076 J. F. Wilson accomplished with careful planning or in line with any long-time land use policy. The time is past due for the State in consultation with its citizens to develop a meaningful land use policy. The Department of Agriculture is giving leadership in obtaining action in developing such a policy. A widespread information and education program is essential in order to provide people with an understanding of their involvement in Great Lakes pollution problems, the corrective steps that must be taken, and assistance that is available to correct these problems. We pledge our continual effort toward these accomplishments. MR. STEIN: John F. Wilson. STATEMENT OF JOHN F. WILSON, DIRECTOR, WISCONSIN ECOLOGICAL SOCIETY, GREEN BAY, WISCONSIN MR. WILSON: My name is John F. Wilson, and my address is Green Bay, Wisconsin. I am a Director of the Wisconsin Ecological Society, and this paper repre- sents the views of the organization and its individual members. I would like to comment, before I present the ------- 2077 J. F. Wilson paper that I intend to present, on some of the views and thoughts expressed in the press this week by various scientists and engineers that are tantamount to creating in Lake Michigan a large, experimental tank. And I am appalled, quite frankly, at these suggestions made by ostensibly responsible people. I would like to also ask the conferees to seriously consider Dr. Bardach's suggestion about making the industrial users of our environment require — or require them to set up an environmental insurance program, I don't know exactly who might underwrite these activities, but I really feel that this is something we should seriously consider. I would like to present some material here that was developed in 1969 on the Fox River and in lower Green Bay by Professors R. P, Howmiller and A. M, Beeton. I am very quickly just going to summarize a few of the highlights of this report and then I am going to make some comments on it. This was a study made on lower Green Bay using the identical parameters and the exact sampling stations and at the same time of the year that studies were made in 1952 by some other University of Wisconsin professors. Now, this is an unpublished manuscript; it will ------- J. F. Wilson be published. Basically, what it says is that Green Bay is a relatively shallow, fertile arm of Lake Michigan, and it describes the bay and its physical condition. Pollution of Green Bay and concomitant concern have increased in recent years. The major tributary of the Bay, the Fox River, contributes an average of 125 milliliters per 3 seconds of grossly polluted water; D,00 content of the river water approaches zero, and it goes into a fairly — by this time — well known expose of the conditions on the Fox River and in lower Green Bay, He discusses in this paper some of the findings in 1952, He concludes the paper by saying — well, I will read two paragraphs: "Carr and Hiltunen (1965) documented changes in the benthos of western Lake Erie from 1930 to 1961, Some of the changes observed were similar to those occurring in Green Bay, Oligochaeta" — sludgeworms — "and Chirono- midae (Tendipedidae)11 — bloodworms — "increased in abundance while Hesagenia decreased to less than 1 percent of its former abundance. It appears that Hexagenia completely disappeared from the area in the years 1961- 1967 .... "Other changes recorded for western Lake Erie as a whole are unlike changes observed in Green Bay0 ------- 2079 J. F, Wilson Gastropoda and Sphaerlidae increased substantially from 1930 to 1961 ..«. However, in 196l, these groups and leeches and naiad clams were rare near the major sources of pollution; the mouths of the Maumee and Raisin Rivers and the western side of the Detroit River mouth. It appears that lower and middle Green Bay are ecologically similar to highly polluted areas of western Lake Erie but they are more degraded than open lake areas of Erie were in 1961. "The future of the Green Bay bottom fauna is not difficult to predict if pollution of the bay, via the Fox River, continues. We can then expect a large abiotic area around the river mouth. Also, midge larvae would be expected to decrease in abundance at stations farther north in the lower bay. Other groups would, of course, continue their demise, And this is basically the conclusion. There are some other details of it, but I am submitting the entire report to this conference together with the various charts that clearly document the condition of the Bay not in 196? or 1965 but in 1969. (The documents above referred to follow in their entirety,) ------- 2030 SOME CHANGES IN THE BOTTOM FAUNA OF GREEN BAY,1 LAKE MICHIGAN FROM 1952 TO 1909 P. Howraliler and A. M. Beeton ifemntng head: Changes in Green Bay Benthos Contribution tfo. 39, Center for Great Lakes Studies, University of Wisconsin-Milwaukee, Milwaukee, Wisconsin 53201 ------- 20&L ABSTRACT Bottom samples were collected In lower and middle Green Bay In May 1989 on the same date, at the same 27 stations, and using the same methods as a 1952 survey. In 1969 there were fewer Ollgochaeta and Chlronomldae in the vicinity of the Fox River mouth. Elsewhere In the tower and middle bay ollgochaetes and midge larvae were more abundant than In 1952 but most other benthlc Invertebrates were less abundant. The observed changes are Interpreted as Indicative of greater pollution and Increased eutrophlcatlon during the Intervening 17 years. ------- INTRODUCTION Green Bay la a relatively shallow and fertile arm of Lake Michigan (Fig. 1). The bay has long been Important for recreational ueea, shipping and commercial fishing. As early as the 1880,, undesirable changes In the bay were recognized. Smiley (1882) reported that sawdust pollution was an Important factor In the decline of the whlteflsh population la the 1870's. Pollution In Green Bay, and concomitant concern, hare Increased In recent years. The major tributary of the bay, the Fox Hlver, contributes an average of 125 ms/sec of grossly polluted water* The dissolved oxygen content of the river water approaches zero mg/Uter In summer months (Schraufnagel, et al., 1968). Even "pollution tolerant" benthlc Invertebrates are rarely found In the sediments of the lower reaches (Balch, et al., 19S6; Schraufnagel, etal., 1968). Water from the Fox Elver spreads out over the lower 1520 km of the lower bay (Schraufnagel, 1906) and dominates the character of this environment. The middle bay, from the Green Bay harbor entrance light north to Sturgeon Bay, Is affected by Fox River water mainly In the eastern half where river water may account for as much as 80% of the northward current (Modlln and Beeton, 1970) In this region the major Influence of the polluted water appears during the months of Ice cover (WSCWP, 1939; Schraufnagel, et al., ------- 20&3 9 1968, Howmlller and Beeton, 1070) when Urge areas suffer oxygen deficiency. Various public agencies have conducted chemical and biological surveys on the bay to assess the severity and extent of pollution (WSCWP, 1930; Surber and Cooley, 1952; Balch,et al., 1956; Sehraufnagel, et al., 1988). Bottom sampling, for analysis of benthlc Invertebrate animals, was a part of each of these studies. Surber and Cooley (1952) compared numbers of organisms at nine of their stations In the lover bay In May 1952 with data from nine comparably located stations sampled during the period November 1938 to February 1939. The Increased number of pollution tolerant midges and ollgochaetes led them to conclude that there was an Increase In pollution during the intervening thirteen years. A later report was less pessimistic. None of the samples taken In 1955 (January) contained populations of sludge worms (Ollgochaeta) In the numbers Indicated In either the 193839 or the 1952 studies (Balch, et al., 1956). Discounting the possibility that January samples were not taken at a population peak, the report concludes that "most probably, there Is a major reduction in the numbers of these forms (Ollgochaeta)." It Is not clear why the possibility of a winter minimum of population density was treated BO lightly. Great reductions In numbers of ollgochaetes may occur during winter months (Howmlller and Beeton, 1970). ------- 206k- 4 Howmiller and Beeton (1967) compared numbers of oligochaetes, midge larvae, and burrowing mayflies taken at stations in the lower bay in 1938 and 1966. In 1966, fewer oligochaetes and midges were found in the immediate vicinity of the river mouth but they were more abundant in the region 5-15 km from the river mouth (Beeton 1969). Nymphs of the burrowing mayfly, Hexagenia, taken at two of eight stations in 1938, were not found in 1966. Changes were interpreted as indicative of increased pollution near the Fox River mouth and increased eutrophication of the bay. Critical comparison of data from these past studies may be open to question because investigators seldom visited the same stations sam- pled in preceeding studies. They also generally failed to sample at the same season of the year. Thus year to year changes in animal numbers may be confused with normal seasonal variation in abundance. Further- more, these investigators did not always use the same apparatus and methodology as their predecessors. The present report discusses a study of changes in the benthic fauna of Green Bay which has attempted to eliminate these three sources of inaccuracy. METHODS On 26 May 1969 we sampled the benthos of lower and middle Green Bay at the stations shown in Figure 1. Samples were taken with a 23x23 cm (9x9 in) Ekman grab and screened immediately with a U.S. Std. No. 30 sieve. The residue on the sieve was preserved in 10% ------- 2Q35 formalin. Organisms were hand picked from the residue using low power magnification. APonar grab sample was also taken at each station. These samples were processed in the same manner as the Ekman grab samples. The Ponar grab samples were taken primarily for purposes not concerned with the subject of this paper, and data from Ponar grab samples are not compared directly with 1952 data but are simply mentioned in Table 2 to indicate that certain animal taxa did occur at stations where they were not taken in Ekman grabs. These same stations were sampled on 26 May and 27 May 1952, exactly seventeen years earlier, by Surber and Cooley (1952). They used, with one exception, a 15x15 cm (6x6 in) Ekman grab and processed samples with a No. 30 screen. The single exception is that a Petersen grab was used to take their sample at station 11 which was on a hard sand bottom. RESULTS AND DISCUSSION Aquatic oligochaete worms are commonly known as "sludge worms" and large numbers of these animals frequently have been cited as evidence of pollution. In general Oligochaeta have increased in abun- dance from 1952 to 1969 (Tables 1,2; Fig. 2). The only notable exception to this generalization is in the imme- diate vicinity of the river mouth (Stations 1-4). This cannot be inter- preted as a result of improved environmental conditions for there is a similar dearth of other benthlc life in this area. ------- Long periods of anoxia during summer months (Schraofntg«lt et al., 1968) probably make It Impossible for healthy populations of any animals to exist In the vicinity of the river mouth. Surber (1957), after studying reports from a number of lakes, concluded that,M. . . an abundance of tubtflclds In excess of 100 per square foot apparently truly represented polluted habitats." Wright (1955) and Carr and Hlltunen (1965) used the following numbers of ollgochaetes per square meter to designate pollution areas In western Lake Erie; light pollution, 100999; moderate pollution, 10005000\| and heavy pollution, more than 5000. Lower Green Bay Is, by these standards, heavily polluted (Table 2, Fig. 9). The middle bay (stations 1127), according to Wrights standards, was only lightly polluted1* In 1952 (Table 1) but was ft* least "moderately polluted" In 1989. Goodnight and Whltley(1980), working on a mldwestern stream, proposed .hat the relative abundance of ollgochmete worms In the benthos should be used as an Index of pollution. They con* sldered the stream In "good condition" If the bottom fauna were less than 60% OUgocfcaeta, "doubtful" If 6080% and highly polluted If more than 80% ollgoehaetes. In 1952 Ollgoehaeta accounted for an average of 66% of the beathlc organisms In samples from statlo«a 210 In the lower bay. In 1969 the average percentage of ollgochaeto* In these samples was 85. Thus It appears that this area has ------- t deteriorated from Borne doubtful condition to a highly polluted state In the Intervening seventeen years (Fig. 3). An Increased relative abundance of Ollgochaeta to more pronounced In the middle bay. At stations 1127, Oltgochaeta have Increased from an average of 23% to 64% of the total benthlc fauna la the years 19521869, Thus, by the standards of Goodnight and Whltiey, It has gone from a "good condition" to "doubtful" since 1952 (Fig. 8)* Surber and Cooley (1952) believed that, at the time of their collections, the majority of the Qllgochaete fauna belonged to the tobl- fIcld genus Llmnodrllus. They stated that a few Tublfex also occurred In the samples. They recorded the naldld genera Dero and Stylarla at, respectively, stations 2$ and 26, and stations 12 and 26. The ------- 0 In the lower bay, and Helobdella (Glos siphon! a) stagnalls in the middle bay. The 1889 collections included Erpobdella puactata, Helobdella atagnalts. and a fish leech (Plsclcolldae), lUlnobdella, which was represented by the five specimens In the Ponar grab sample at £$8Hoa 5. The fish leeches appeared very emaciated. The Glosslphonlldfte* Oloflslphonia and Helobdella,, commonly are predacious upon snails, ollgochaetes, and other email Invertebrates (Pennak, 1953). punctata. now the most common leech In the bay, apparently feeds heavily upon ollgochaetes. Two of fifteen specimens examined had ollgoehaete worms in their mouths at the time of capture. The decline of leeches in Green Bay may have contributed to the greater success of the Ollgochaeta. Snails occurred at ten stations of the 1952 survey but at oaly two stations in 1969 (Fig. 5). Collections in 1952 included Campoloma, Hellsoroa, Valvata trlcarlnata, and Viviparus. Empty shells of these taxa now occur at many stations In the lower and middle bay but the only one of the four found living in our recent Green Bay colloc- •••s tlons is Viviparus. Vlylparus d(d not, however, occur In 1909 sampling at atatlons^elng compared in this report. The snails found at stations 13 and 15 belong to the genus Amnicola. Fingernail clams (Pelecypoda, Sphaerltdae), like snails, ware much lest abundant la 1969 than In 1952 (Pig* 6). They decreased ------- 0 /roan an average of 16.5% of the total benthlc fauna to 3.3%. The species of Sphaerildae inhabiting Green Bay have not yet been deter* mined. As a group, the fingernail clams are known to be less pollution tolerant than most Ollgochaeta and many species of Chlronomldae (Keup, Ingram andMackenthun, 1966). While no naiad clams (Unlonldae) were reported In 1052, Lampallls elltquoldea was found at station 15 In 1969. This species baa recently been found at several other stations on the sandy sub- strates Just north of Long Tall Point but not elsewhere In the lower or middle bay. The presence of naiads generally Indicates clean water (Carr and RUtunen, 1965). In Green Bay It Is probably also closely related to the nature of the substrate. Soft muds, common over much of the bay, are not a suitable substrate for these large clams. While the distribution of amphlpods (Fig. 7) was very similar In 1952 and 1969, this group seems to have been much more abundant and to have comprised a larger proportion of the population In the 1952 collections. Surber and Cooley (1952) reported only Hyalella azteca Oammarus fasclatus from their collections. In 1969, ' ~ occurred at stations 7, 15, 25, and 27,' Gammarus fasclatus and Pontoporeia afflnle at stations 11, 24 and 25; and Crangonyx at station 27. ------- 2090 10 The Isopod, Asellus, occurred at too few stations to allow generalizations concerning possible changes la abundance or dlotrl- bution. Widespread sampling; in the years 1966-1969 Indicates that Asellus occurs farther south In the bay than the data In Table 3 suggest. Cooley and Surber (1952) Identified the Isopod present at that time as A. communls. Balch and co-workers (1956) recorded A* m lilt aria. The Isopod present In 1969 was_A. milltaris. The burrowing mayfly (Hexagenla) was once quite abundant In Green Bay. In years past, adult Hexagenla piled up by the bushel under electric lights In the city of Green Bay on many summer evenings (WSCWP, 1939). The report of 1939 (W6CWP) registered surprise at the small numbers recovered but recorded Hexagenla nymphs In 16 of 51 samples. At that time It occurred as far south as the vicinity of Long Tall Point. Surber and Cooley (1952) found Hexagenla only at station 16. In 1955 one burrowing mayfly "wa» ^ >d" at a station near the mouth of the Oconto River (Baleh, et al, 1956). Hexagenla was not recorded In the data of the report. Hexagenla did not occur to samples taken In 1969 or at any of 74 other widespread stations sampled by the Federal Water'Pollution Control Administration In 1967 and the Center for Great Lakes Studies, University of Wisconsin-Milwaukee In the years 19661969 (Howmlller and Beeton, 1970). It has apparently disappeared from Green Bay as It has from western Lake Erie (Carr and Rlltunen, 1965; Veal and Osmond, 1968). ------- 2091 II The aquatic larvae of midges (Chlronomldae) were the second most abundant and widespread members of the bcothlc fauna In both 1952 and 1969 (Fig. 8). The midges decreased markedly In the vicinity of the Fox River mouth - doubtless because of Increased pollution- Increased numbers of midges were found at most stations north of Long Tall Point. However, this Increase did not equal that of the Oltgochaeta with the result that midges decreased In relative Importance from an average of 48 to 37% of benthlc Invertebrates In the middle bay and from 37 to 26% for the bay as a whole. The Chlronomldae Includes many species adapted to a wide range of environmental conditions. However, as a group, the midges display pollution tolerance second only to the Ollgochaeta. Like many Ollgochaeta, the pollution tolerant midges have an abundant supply of hemoglobin which makes them very efficient at obtaining oxygen at the low concentrations associated with organic pollution, and In the profundal region of stratified eutrophlc lakes. The only animals found at station 1 In 1969, Peychoda larvae. are air breathers which are abundant In mud flats, drains, sewage fitters, and other habitats subject to total deoxygenatlon (Hynes I960). Erlstalls larvae, found at station 1 In 1952, are ecologically similar. Both these organisms have been reported from other rivers so grossly polluted that no normal river animals survive (Hynes, 1960). However, since they require contact with the surface to breathe, these cannot hare been viable populations at depths of 18-21 ft at station 1. These ------- 2092 12 animals must have been carried to station 1 by the current from shallow* water anaerobic habitats upstream. The common and abundant benthlc ne mat ode In Green Bay la 1969 measured about 4.5-5 mm long and 0.2 mm In diameter* An animal this size certainly cannot be collected quantitatively when a No. 30 screen (0.6 mm openings) Is used and, therefore, nematodea were not counted In our samples. In view of the abundance and wide* spread occur ranee of nematodes In 1989 (Table 2) It Is difficult to believe that they occurred at only one station In 1952 (Table 1). Perhaps samples were screened more vigorously and almost all nematodea were lost. Another possibility Is that they were so abundant In 1960 that sufficient numbers were retained as to be noticed. CONCLUSIONS There were marked changes In the bottom fauna of lower and middle Green Bay between 1952 and 1969. Two animal groups which contain many eutrophlc and pollution tolerant species, the Ollgochaeta and the Chlronomldae, have Increased In abundance over most of the bay. Most other benthlc Invertebrates were less abundant la 1969 than In B 52. These changes suggest that the deterioration of the bay environment, noted by previous Investigators, Is continuing. ------- 2093 IS Carr and HUtunen (1065) documented changes In the benthos of western Lake Erie from 1930 to 1961. Some of the changes observed were similar to those occurring in Green Bay. OHgochaeta and Chlrono- tnldae (Tendlpedldae) Increased In abundance while itexagenla decreased to less than 1" of Us former abundance. It appears that Hexagenia completely disappeared fron, toe area In the years 1961-1967 (Veil and Osmond, 1968). Other changes recorded for western Lake Erie as a whole art unlike changes observed In Green Bay. Gastropoda and Sphaerlldae Increased substantially from 1930 tp 1961 (Carr and Hlltunen, 1965), However, In 1961 these groups and leeches and naiad clams were rare near the major sources of pollution; the mouths of the Maumee and Raisin Rivers and the western side of the Detroit River mouth, It appears that lower and middle Green Bay arc ecologically similar to highly polluted areas of western Lake Erie but they are more degraded than open lake areas of Erie were In 1961. The future of the Green Bay bottom fauna Is not difficult to predict If pollution of the bay, via the Fox River, continues. We eaa then expect a larger abiotic area around the river mouth. Also, midge larvae would be expected to decrease In abundance at stations farther north in the lower bay. Other groups would, of course, continue their demise. The OHgochaeta, the only group which Increased In absolute and relative abundance between 1952 and 1969, would assume oven greater Importance In the benthlc community. ------- 2094 14 With the disappearance of other major groups further changes IB the bay environment must be assessed through changes In numbers of the Ollgochaeta and Chlronomldae and through changes In species eompo sltlon of these groups. A report on the distribution of ollgochaete species in Green Bay Is In preparation (Howmlller and Beeton, 1970). A study on the distribution of species of Chlronomldae, a taxonomlcaUy difficult group, Is planned for the near future. ACKNOWLEDGEMENTS This research was supported In part by the University of Wisconsin Sea Grant Program. It Is a pleasure to acknowledge the fine service of the personnel attached to the H/V "Mysis" and the willing help of J. E. Gannon which made the fleldwork efficient and pleasant. Mr. Ratko lilstic drew the figures. ------- 2095 BIBLIOGRAPHY Balch, a. F.t K. M. Mackenthun, W. M. Van Horn and T. F. Wls- nlewskl. 1956. Biological studies of the Fox Elver and Green Bay. Bull. WP 102, Wisconsin Comm. on Witter Pollution, 74 p., mlmeo. Beet on, A. M. 1999. Changes In the environment and biota of the Great Lakes, p. 150-187. In_: Eutrophlcatlon; causes, consequences, correctives, proceedings of a symposium. National Academy of Sciences, Washington, D. C. Brlnkhurst, H. O. 1967. Sampling the benthos. Univ. Toronto, Great Lakes Institute, PR 32, 6 p. mlmeo. Carr, J. F. andJ. K. HUtunen. 1965. Changes In the bottom fatma of western Lake Erie from 1939-1961. Llmnol. Oceanogr., 10: 551-569. Flannagan, J.F., A. L. Hamilton, P. G. Sly and W. F. Warwick. 1969. An evaluation of twelve commonly used bentholoflcal sampling devices. Unpublished manuscript, 7 p., mlmeo. Goodnight, C. J. and L. 8. Whltley. 1960. Ollgoehaetes as indicators of pollution. Proc. 15th Ann. Waste Conf., Purdue, p. 139-142. 15 ------- 2096 16 Howmlller, rt. P. and A. M. Beeton. 1967. Bottom fauna Investiga- tion In lower Green Bay. Paper presented to Midwest Benthologlcal Soc., Carbondale, 111., unpublished manuscript, 5 p. mlmeo. Howmlller, R. P. and A. M. Beeton. 1970. The ollgochaete Iauaa of Green Bay, Lake Michigan, le&e presented at the 13th Conference on Great Lakes Research, 1 nternatlonal Association for Great Lakes Research, Buffalo, April 1970. Hynes, H. B. N. i960. The biology of polluted waters. Liverpool University Press. Keup, L. E., W. M. Ingram and K. M. Mackenthun. 1966. The role of bottom-dwelling macrofauna In water pollution Investiga- tions. Public Health Service Pub. No. 999-WP-38, 23 pp. Modlln, a. and A. M. Beeton. 1970. Current studies In Green Bay. Unpublished report. Pennak, H. W. 1953. Freshwater invertebrates of the United States. Ronald Press, New York. Schraufnagel, F. H. 1966. Green Bay stream flows and currents, pp. 178-182. 'In; Lake Michigan pollution, governor's conference proceedings. Schraufnagel, F. H., L. A. Montle, L. A, Leuschow, J. Llssack, G. Karl and J. ft. McKersle. 1968. Report on an Investigation of the pollution In the lower Fox River and Green Bay made daring 1966 and 1967. Wls.Dept. Nat. Resources, Int. Kept., 47 p. mlmeo. ------- 2097 if Sly, P.G. 1969. Bottom sediment sampling. Proc. 12th Conf. Great Lakes Res., Int. Assoc. Great Lakes Res.: 855870. Smiley, C. W. 1882. Changes in the fisheries of the Great Lakes during the deeade 18701880. Trans. Amer. Fish. Cult. Assoc., 11: 28-37. Surber, E. W. and H. L. Cooley. 1952. Bottom fauna studies of Green Bay, Wisconsin, In relation to pollution. U.S. Public Health Service, Comm. Water Pollution, 7 p. mlmeo. Surber, E. w. 1957. Biological criteria for the determination of lake pollution, pp. 164174. In: Trans. 1956 seminar, H. A. Taft San.Engr. Cntr., U.S. Publ. Health Senr., Cincinnati, Ohio, W57-36. Veal, D. M. and D. S. Osmond. 1968. Bottom fauna of the western basin and near-shore Canadian waters of Lake Erie. Proc. llth Conf. Great Lakes Has., Int. Assoc. Great Lakes R«s.i 151160. Wisconsin State Committee on Water Pollution and State Board of Health In collaboration with the Green Bay Metropolitan Sewage Commission. 1939. Investigations of the pollution of the Fox and East Rivers and of Green Bay In the vicinity of the city of Green Bay. 242 p., mlmeo. Wright, 6. 1955. Llmaologlcal survey of western Lake Erie. U.S. Fish WUdl.Serv.,Spec. Scl. aept. •-Fisheries No. 139, 341 p. ------- 2098 Table 1. Abundance of benthlc Invertebrates, as Individuals per square meter, la samples taken at stations shown In Fig. 1 on 26 and 27 May 1052. g i 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 80 Oconto4(2i) Oconto-202) Ocaato-3g3) Ocatto-4(24) Ocoato-5(35) Oeooto-6 ------- 2099 Table 2, Abundance of benthlc in vertebrates, as Individuals per square meter, la samples taken at stations shown in Fig. 1 on 26 May 1960. 1 1 a 3 4 5 6 7 8 9 10 11 12 IS 14 15 16 17 18 19 20 ai 23 23 24 25 26 27 Nematoda 8 0 + 0 •f + •f + + •»• •#• + + •f + + •> + + + + + •• + + + •• + Oligochaeta 0 22657 8604 7227 29292 16921 11854 4264 2008 1032 1663 822 688 918 2792 1281 1109 229 4531 2658 5354 1740 899 9770 10325 23441 10095 Leeches \|\| 0 0 0* 0 0 0 76 0 19 19 0 0 0 0 0 0 0 0 0 0 0 0 0 19 0 0 0 oo •. 13 eg 0 0 0 0 0 0 0 0 0 0 0* 0 19 0 19 0 0 0 0 0 0 0 0 0 "0 0 0 1 CO I • o 0 0 0 0 0 0 38 57 631 19 172 994 268 19 1166 0 o 0 57 0 0 0 0 0 10 0 0 AxBpMpods 0 0 0 0 0 0 0 0 0 0 o 0 0 0 19 0 0 0 0 0 0 0 0 57 38 0 19 (0 >— i 0 0 0 0 0 0 0 0 0 0 o 0 0 0 0 0 0 0 0 0 0 0 0 76 38 0 0 i Other 0 gQPsychoda 38 688 440 2237 3155 1778 860 1759 76 402 1836 1644 3097 554 19 LampsUU 1128 918 707 2314 2065 803 1530 344 1300 631 1166 2275 Nematoda were very numerous In many camples but certainly not sampled quantitatively, hence not counted. Not taken in Efcman grab sample but animals la this category were recorded from Ponar grab sample taken at the same time. ------- 2100 FIGURE LEGENDS Figure 1. Lower and middle Green Bay, Lake Michigan, showing bottom sampling stations of 28 and 28 May 1952 and 23 M 1039. Figure 2. Distribution and abundance of OUgochaeta In the sediments -r of lower and middle Green Bay en 26 and 28 May 1932 (left) it and 26 May 1889 (right). Figure 3. Relative abundance of OUgochaeta, as percentage of total bottom fauna, In May 1952 and 1969. Figure 4. Distribution and abundance of leeches In lower and middle Green Bay In May 1952 and 1969, Figure 5. Distribution and abundance of snails In May 1952 and 1909. Figure 6. Distribution and abundance of fingernail clams In May 1952 and 1989. Figure 7. Distribution and abundance of amphlpods in May 1952 and 1969. Figure 8. Distribution and abundance of Chlronomldae In May and 1969. ------- 2101 ------- ------- 2103 ------- 2104 ------- ------- ------- 210? ------- ------- 2109 Curriculum Vitae RICHARD P. HOWMILLER Born: 9 January 1939, Milwaukee, Wisconsin Education University of Wisconsin-Madison, B.S., Biological Aspects of Conservation, 1963 University of Wisconsin-Madison, M.S., Zoology, 1966 University of Wisconsin-Milwaukee, Zoology (limnology), PhD expected June 1971 Employment Milwaukee Public Museum, Student Aide in Botany, part-time, 1961 Wisconsin Conservation Department, Conservation Aide II, summer 1962 SabishJr. High School, Fond du Lac, Wisconsin, Intern Teacher, spring semester, 1965 Wisconsin State University, Stevens Point, Wisconsin, Faculty Assistant, 1965-66 National Audubon Society, Greenwich, Conn., Staff Naturalist, Summer 1966 University of Wisconsin-Milwaukee, Teaching Assistant, 1968-69 Honors B.S. conferred with senior honors, 1963 Delta Chi Sigma, honorary science and mathematics fraternity, 1967 Phi Kappa Phi, honor society, 1969 Memberships in Scientific Societies American Society of Limnology and Oceanography International Association for Great Lakes Research Midwest Benthological Society Societas Internationalis Limnologiae Wisconsin Academy of Sciences, Arts and Letters Papers presented before scientific societies Fitzgerald, G.P. and R. P. Howmiller. 1966. Use of laboratory evaluations of aquatic herbicides and algicides. Weed Society of America. Howmiller, R. P. and G. P. Fitzgerald. 1966. The use of Lemna minor L. for aquatic plant bio-assays. Midwest Benthological Society. Howmiller, R. P. 1966. Duckweeds and detergents. Wisconsin Academy of Science, Arts & Letters. and A. M. Beeton. 1967. Bottom fauna investigations in lower Green Bay. Midwest Benthological Society. Howmiller, R. P. 1969. A cruise to the Galapagos. Society of Sigma Xi, Wisconsin State University-Oshkosh. ------- 2110 Howmiller, page 2. Howmiller, R. P. 1969. Limnological studies in the Galapagos Archipelago. Midwest Benthological Society. Howmiller, P. P. and A. M. Beeton. 1970. The oligochaete fauna of Green Bay, Lake Michigan. International Association for Great Lakes Research. Howmiller, R. P. 1970. Biological assessment of pollution and eutrophication in Green Bay. Wisconsin Academy of Science, Arts & Letters Publications Howmiller, R. P. and A. Weiner. 1968. A limnological study of a mangrove lagoon in the Galapagos. Ecology, 49_: 1184-1186. Howmiller, R. P. 1969. Studies on some inland waters of the Galapagos. Ecology, 50: 73-80. Howmiller, R. P. andW. E. Sloey. 1969. A horizontal water sampler for inves- tigation of stratified waters. Limnol. Oceanogr. , 14: 291-292. Howmiller, R. P. and K. Dahnke. 1969. Chemical analysis of salt from Tagus Crater Lake, Isabela, Galapagos. Limnol.Oceanogr., 14_: 602-604. Howmiller, R. P. and A. M. Beeton. 1970. The oligochaete fauna of Green Bay, Lake Michigan. Submitted for publication. Howmiller, R. P. and A. M. Beeton. 1970. Some changes in the bottom fauna of Green Bay, Lake Michigan, from 1952 to 1969. Submitted for publication. ------- 2111 A. M. Beet on Curriculum VLtae Present Address: 340 Park Circle, Cedarburg, Wisconsin Born: August 15, 1927, Denver, Colorado Married Education: Jackson High School, Jackson, Mich., graduate 1946 Jackson Jr. College, Jackson, Mich., 1946- Feb. 1949 University of Michigan, Ann Arbor, Mich., Sept. 1949-Feb. 1958. B.S. 1952; M.S. 1954, Ph.D. 1958. Experience Academic Appointments: University of Wisconsin-Milwaukee, professor of zoology, Feb. 1966-present. University of Michigan, Research associate in zoology, Sept. 1964-Feb. 1956; lecturer in civil engineering Sept. 1961-Feb. 1966. Wayne State University, lecturer (graduate limnology course) June 1957- Sept. 1961; instructor, Sept. 1956 -June 1957. University of Michigan, teaching fellow, Feb. 1956 -June 1956; Sept. 1954- June 1955; Sept. 1953-June 1954; Sept. 1952-June 1953. Government Service: U.S. Fish and Wildlife Service, Ann Arbor, Michigan (GS-3) June 1955 - December 1955; (GS-5) June 1956-Sept. 1956; (Fishery Biologist Res.) June 1957-Feb. 196G, Chief Environmental Research Program. Travel to India, Israel and Pakistan, 1063 and 1964, in connection with the Bureau's Foreign Currency (P.L. 480) program to review fishery research being sponsored through this program. Institute for Fisheries Research. Michigan Conservation Department, June • ;i 1962-£ept. 1962; June 1953-Sept. 1953; June 1954-Sept. 1954. Consulting Appointments 1967-69; U.S. Army Corps of Engineers, Buffalo District, New York. Member, Board of Consultants, on effect of Corps' dredging activities on pollution in the Great Lakes. 1968-present: Metropolitan Sanitary District of Greater Chicago 1968: University of Illinois. Academic Activities: Associate Director (Biology), Center for Great Lakes Studies, University of Wisconsin-Milwaukee, 19G6-present. Member, Executive Committee, Division of Biological Sciences, University of \7isconsin (all-university committee) 1966-67, 1967-68. Member, all-university Council for Marine Studies, University of V/isconsin, 1967-68, 1968-69. ------- 2112 A. M. Beeton, page 2 Honors, Grants & Awards University of Michigan, Lit. College scholarship, 1950-51 American Ornithology Union, student membership award, 1954 Herbert E. Boynton, graduate school scholarship, 1956. Phi Kappa Phi James, \V. Moffett Publication Award from U.S. Bur. Commercial Fisheries for best scientific paper publised (1968) in 1967. U.S. Army Corps of Engineers, Buffalo District, Contract 1968-69 ($20,005) to study the effects of dredging and disposal on the Great Lakes. U.S. Dept. Interior, Bureau of Commercial Fisheries, Grant($3,700, 1968; ($7,563, 1969) to study the population dynamics of juvenile alewife and core- gonids of Green Bay, Lake Michigan. National Science Foundation, Wisconsin Sea Grant Program, 1968-69, $11,400 to study various aspects of the eutrophication of Green Bay. Research Interests My major research interests have been in the behavioral physiology of Crustacea and the eutrophication of the Great Lakes, although I have made contributions to several aspects of the limnology of the Great Lakes (see attached list of publications). Studies on photoreception in the freshwater mysid, Mysis relicta, employ- ing behavioral methods, demonstrated the nature of spectral sensitivity, dark- adaptation, and phototropic response in this organism and established general methods for similar studies of this group of organisms in the marine as well as the freshwater environments. These studies have been duplicated by other investigators on marine mysids. The laboratory investigations of photoreception and photo response of M. relicta provided information essential to the proper interpretation of field data on the vertical migration of M_. relicta in Lakes Huron and Michigan. This latter study showed that light "triggers" and controls their migrations, while thermal conditions interact with and modify the influence of light. The field data showed that as the length of day decreased following the summer solstice, the mysids ascended progressively earlier each evening and descended later each morning. Moonlight and fog influenced the time as well as the amplitude of the vertical migrations. The mysids frequently migrated through the thermocline when first ascending, but later at night the majority occurred in or immediately below the thermocline. ------- 2113 Prior to 1959 the general opinion, was held that although the Great Lakes must be aging, i.e., undergoing eutrophicaticn, it v/as not recognized that eutro- phication could be demonstrated on bodies of v/ater as large as the Great Lakes. My study of environmental changes in Lake Erie, which was first presented at the meeting of the Lake Erie Fish Management Committee in May 19GO, and sub- sequently published in the Transactions of the American Fisheries Society in 1961, presented evidence of accelerated eutrophication in this Lake. This work directed attention to an important aspect of Great Lakes limnology that had been ignored previously. The significance of this contribution is reflected in the importance of studies of eutrophication in current research programs of the U.S. Bureau of Commercial Fisheries, U.S. Public Health Services, several universities, and other organizations. The results of my recent study demonstrate that several changes commonly associated with eutrophication in small lakes have occurred in the Great Lakes. These changes apparently reflect accelerated eutrojiiication in the Great Lakes, d ue to man's activity. Chemical data compiled from a number of sources, dating as early as 1854, indicate a progressive increase in the concentrations of various major ions and total dissolved solids in all of the Lakes except Superior. The plankton has changed somewhat in Lake Michigan and the plankton, benthos, and fish populations of Lake Erie are greatly different today than those of the past. An extensive area of hypolimnetic water of Lake Erie has developed low dissolved-oxygen concentrations in late summer v/ithin recent years. Professional Membership Phi Sigma , Beta Chapter, secretary 1954-55 Sigma Xi American Fisheries Society American Institute of Fishery Research Biologists American Society of Zoologists Societas Internationalis Limnologiae American Society of Limnology and Oceanography; Treasurer, 1962-present, member, Board of Directors International Association for Great Lakes Research, Board of Director, 1967 - present; Program Chairman, llth Conference on Great Lakes Research, May I960, Attendance - 550+. Midwest Benthological Society ------- 2114 J, F. Wilson MR. WILSON: Now, I would like to make my comments on this report. From the foregoing data, it is apparent that the condition of the bay is worsening and at a rapid rate Of primary concern is the fact that during this time, the rivers emptying into the bay and the sources of pollution on them have been under the scrutiny of the responsible Wisconsin pollution control agency. Using figures compiled by the Wisconsin Depart- ment of Natural Resources, we can make the following comparisons on BOD and suspended solids loading of the Fox River in a 20-year period ending in 196S. You get the picture here? In other words, I am going to be dis- cussing loading factors that have been repoted on BOD to the Wisconsin Department of Natural Resources as against the study that I have submitted in 1969 as to the condition of the bay. All right? In 194#, the municipal load was 23,9#0 pounds per day of BOD» The mill loads — paper mills altogether in the Fox River, 2##,020 pounds per day, giving a grand total of 312,000 pounds of BOD per day into the Fox River. The suspended solids load in 194# was 10,520 pounds per day. The mill load was 101,940 pounds per day, and the total was 112,460 pounds per day of suspended ------- 2115 J. F. Wilson solids in the Fox River, Now, I will read the 1963 figures — this is the end of the 20-year period. Municipal loading, 26,714 pounds per day BOD. The mill loading has dropped to 276,740 pounds per day — these are all admitted loadings. It is very important to understand this: that this is what the mills admit to dumping. Total, 303,454 pounds per day. In 1963, suspended solids loadings — municipal suspended solids loadings were not reported. Mill loading went from 101^940 pounds in 194# to 243,500 pounds per day of suspended solids. I can't give you a total because the municipal suspended solids load was not reported. The numbers applying to the Menominee, Peshtigo, and Oconto Rivers, while lower, show relatively the same changes. One might well ask, in view of what appears to be a net reduction in BOD — admittedly a very small one — how Professor Howmiller and Dr. Beeton were able to docu- ment such a drastic deterioration in the condition of the bay0 It is interesting to examine the suspended solids loading during this period. The contributions double. Might not a clue to the problem lie herein? It is also instructive to understand fully the ------- 2116 J. F, Wilson nature of the monitoring process, which is largely performed by the polluters themselves and, in fact, would include the contents of settling lagoons and basins that are regularly discharged to the river only under extremely rare circum- stances. I hope that is clear: that the settling lagoons and basins are reported under only extremely rare circum- stances* The Quirk-Lawler-Matusky study of the Fox River, funded by the Wisconsin Department of Natural Resources, included among its recommendations that *<,,. an economic alternative to advanced treatment facilities would be flow augmentation," We note that Michigan's pollution control agency has accepted this principle with regard to the huge new Mead paper mill at Escanaba, where the proposal is to, in times of low flow of the Escanaba River, pump water out of Lake Michigan and introduce it upstream from the mill. This is designed to maintain an adequate dissolved oxygen in this critical stretch of the river. Where, however, do the pollutants and solids go after they are thus diluted? Gentlemen, these measures have been proven unsatisfactory in the past. Why are they permitted now and accepted in future planning? In April, at the Lake Michigan Conference in ------- 2117 J. F, Wilson Milwaukee, I raised the question whether it was necessary to demonstrate that a specific pollutant crossed the State line in Green Bay before the Federal Government could exercise its jurisdiction in those waters. Mr. Stein interrupted at that point to indicate that the Federal Government viewed Green Bay as clearly within their purview. The question has come up again, however, and a conflict of interpretation within and between the FWQA and the State of Wisconsin has not been resolved. Wisconsin claims harbor areas and river mouths as being within the jurisdiction of Wisconsin statute. No one has defined how far out into the bay these areas extend. Unless some clearly quantitative limit is placed on rivers and harbor areas of influence, presumably all of Lake Michigan could be claimed as a mixing zone for one or another State's river or harbor. Apparently FWQA cannot or will not act in the Green Bay section of Lake Michigan until this matter is decided. In Green Bay, on June 23, 1970, in a hearing before the Wisconsin Department of Natural Resources, evidence was presented indicating that the Fort Howard Paper Company t«as now discharging some 40,000 pounds of BOD per day and 8,000 pounds of suspended solids per day into the Fox River as compared with their 196S loadings ------- 2118 Jo F. Wilson of 32,720 pounds of BOD and 27,SgO pounds of suspended solids per day. It was also brought out that they intended to reduce their loadings through the installation of advanced treatment facilities to 10 percent of their present con- tribution. Their new orders call for abatement to 25,400 pounds of BOD and 27,300 pounds of suspended solids per day. Why do they not call for a maximum of 4,000 pounds of BOD and SOO pounds of suspended solids per day? And why, above all, did it require the citizens to pool their money to legally force this information into the open? Why did not the Wisconsin Department of Natural Resources determine this information for themselves? As yet, we have not received a new order for this mill, although presumably it is forthcoming The joint municipal-industrial treatment plant to be built in the city of Green Bay is designed to treat the mill wastes from American Can and Charmin to effect a 90 percent removal. Green Bay Packaging is constructing a reverse-osmosis plant to remove 90 to 100 percent of their effluent load to the Fox River. But the State orders trail behind the technology available. In 1963, admitted loadings to the Fox River from both industrial and municipal sources totalled some 303,450 pounds of BOD per day. ------- 2119 J. F. Wilson Technology permits this to be reduced to 10 percent of that total. The Wisconsin Department of Natural Resources is calling for a reduction to only #7,065 pounds of BOD per day from the paper mills, plus an additional municipal load. We ask that total contributions to the Fox, Oconto, Peshtigo, Menominee and Escanaba Rivers be put at 10 percent of their present loadings, and that the ominous rise in suspended solids be immediately investigated at the source. We also request that this conference begin the procedures necessary to establish effluent standards on all waters affecting Lake Michigan, We request further that the States establish adequate and uniform monitoring of discharges that will permit complete public surveillance of all pollutional sources. And, finally, the Wisconsin Ecological Society would like to commend the excellent report, "Physical and Ecological Effects of Waste Heat on Lake Michigan," pre- pared by the Great Lakes Fishery Laboratory of the Fish and Wildlife Service of the Department of Interior. This is another piece of excellent work done by that able laboratory. For the first time, the actual physical process of introducing large amounts of hot water has been described. Rejecting the notion that the heated ------- 2120 J. F. Wilson water would intermix with the entire volume of water in the lake, and the equally simplistic view that the warm water plumes would spread out evenly over the entire lake and quickly evaporate, they have quite accurately delin- eated the complex routes possible to this huge mass of interjected hot water* We completely concur in the conclusion of the report that no significant discharge of waste heat into Lake Michigan should be permitted. (Applause) MR. STEIN: Thank you, Mr. Wilson. Mr0 Frangos. MR. FRANGOS: Just a few quick comments, I recognize that much of this presentation did not bear on the thermal question, but it is certainly important to the well being of the lake. I am not sure I understand it, but I think the best way is for me to say again — I said it at the last conference — we have no jurisdictional problem in Wisconsin from the State's point of view about Green Bay and the Fox River and the tributaries to the lake. We have included this in all of our listings to the conferees, and we have proceeded on a schedule that is compatible with the overall requirements of this conference <> On the Fort Howard situation, I really can't ------- 2121 J. F, Wilson comment, or I don't think I should at this time since this is under advisement by our Department's legal unit. But Mr, Wilson is indeed correct that a decision will be forth- coming in the near future, I hesitate to comment on the effectiveness of the reverse-osmosis in the Green Bay Packaging operation as a demonstration program, and I don't have the confidence in the capabilities of that process at this time that Mr, Wilson has, I think his points are well taken on increasing surveillance over pollution generally in the State and certainly on the Fox River. The Legislature has responded to our Agency's request for increasing our monitoring. We have been successful in getting funds, and we will be indeed increasing our surveillance, and we have designed a monitoring system for the Fox River, and we hope to have that on line within the next month, MR, WILSON: Mr, Stein, may I just respond to one point that Mr. Frangos has made? The hangup — if you want to put it that way — with the jurisdictional matter is simply that when you classify a stream as industrial cooling, you also extend the area of influence of that stream out beyond the harbor mouth. Now, the actual measurement of what that harbor ------- 2122 J. F. Wilson influence is, that area of influence by the harbor, the actual mileage out into the bay, has not been defined, and as I understand this from the highest people in the FWQA in Chicago, there is no way that they can insist that Lake Michigan standards be enforced in areas that you say, as the head of the Wisconsin — your pollution control agency — that you say are areas of influence. Now, does that clarify the problem? MR. STEIN: We have the highest people right to my left. Again, let me indicate what the situation is. We go over this again and again and again, and I keep quoting the same man — Oliver Wendell Holmes. He said; "Any bright young man can tell me what the law ought to be, but it takes a student to know what the law is and what we have to enforce." The Federal law is clear on this. We have to have two criteria present to have a Federal enforcement action if we are going to proceed on Federal initiative. The first thing, there has to be interstate waters or navigable waters. I don't think that is the question here. Then, if we are to proceed on our own initiative for a cleanup, whether it is under the standards provision or whether it is under the conference provisions as we have here, we have ------- 2123 J. F. Wilson to have pollution in one State endangering the health or welfare of persons in another State. You have to have both of those things. There is an exception to this. That is where we have been asked to intercede in intrastate situations by a State. As I read this, we have been asked in here by Governor Kerner on an intrastate situation in Illinois as well as an interstate one. We have never gotten a request like that from the Governor of Wisconsin. Therefore, Federal jurisdiction, in Wisconsin, is limited to pollution which is interstate as well as affecting an interstate or navigable water. This effectively pulls the teeth of the whole thing in Green Bay. But what you have just said is exactly what we are talking about. First of all, Lake Michigan is supposed to be suitable for all water uses. Now, the point is: What kind of an imaginary line is supposed to be drawn across the mouth of the Fox River? There is one, there must be, because if there was not then obviously the water does not qualify. Sir, what I want to point out is: while there may be an imaginary line, there is a very definite line which is the border of Wisconsin and the neighboring State, ------- 2124 J. F. Wilson and all of the waters you are talking about lie well within the boundaries of Wisconsin, and they are intrastate in nature. MR. WILSON: They are intra? MR. STEIN: Yes. MR. WILSON: Oh: MR. STEIN: At least the effect is within. The water may be interstate but the effects that you are talking about are also all within Wisconsin — the same State upon which the discharge that you are talking about has the alleged causal effect. Now, I would like to move back, and I think I may have misled you. The waters are interstate but the discharge point and the alleged damage point and the causal connection with them all relates to points within Wisconsin, and when that happens, our jurisdiction is limited unless the Governor asks us in, and that hasn't happened. Now, we have a proposed amendment to the Federal law which would remove this, but the Congress hasn't acted on that yet. MR. WILSON: What is the name of that bill? Do ------- 2125 J. F. Wilson you know that offhand? MR. STEIN: We can get that for you. But the House has not had hearings on this. Senator Muskie's Committee has had hearings, but we haven't had any movement of that legislation yet. MR. WILSON: All right. I think, sir — MR. STEIN: Let me continue on this. We recognize the problems in the law. But I would suggest that in those instances that you have to remedy the law or get the request of the Governor of a State in order for us to exercise jurisdiction, at least complaints about the efficiencies, etc., should be directed to the places where they can do the most good. This forum here can just carry this out. But I recognize this and the Administration recognizes this. We can't do anything else. MR. WILSON: In other words, now, if Michigan would request some action on Green Bay, they would claim that they were affected? MR. STEIN: Well, if they said they were affected — I never heard them say that. MR. WILSON: No. I see the problem. MR. STEIN: There is another feature in the law. If Michigan asks us, we have to go in there in a mandatory way. We have no option. ------- 2126 J. F. Wilson MR. WILSON: What about if Illinois asked you? MR. STEIN: What, that Green Bay affects Illinois? MR. WILSON: Would that have to be contemplated? MR. STEIN: Well, surely we would go in, but they sure enough have to contemplate it. We get this again and again, and I know you will be facing your citizens over and over again. We have had the same problem. It can be best illustrated by our case that is currently in progress on Lake Superior. People were complaining about discharges to Lake Superior from Reserve Mining Company, which all hands agree is putting out 67,000 tons — get that figure —a day of taconite tailings wastes into the lake at Silver Bay, Minnesota. They asked "Why, why, why couldn't you clean this up? Look at all this material coming out." Because we didn't have an intrastate request from Minnesota, we had to prove before we had jurisdiction that these materials were getting over into Wisconsin and, in fact, deteriorating water quality in Wisconsin. We had 30, 40, 50 miles of open lake to trace these pollutants across or this material across — I don't think the company considers them pollutants yet. We had to trace them across remarkably clean waters, and we had to ------- 212? J, F, Wilson spend a fiendish amount of money and resources to prove that* Now, this is the state of the Federal law now, and unless you people recognize that, you will have a very difficult thing to understand. We stand on what our juris- diction ie<. I know the people around the shores of Lake Superior who talk in the same terms you do of money, people and staff coming out, were very impatient with us in not being able to move in within days or weeks after we entered the case. But this was not possible until we felt or the Federal people felt that interstate pollution could be demonstrated, MR, WILSON: Thank you, MR, STEIN: I hope this is helpful, because we are going to run into this over and over again, MR, DUMELLE: Mr, Stein, let me just ask you a clarifying question, Mr, Ourrie, when he was sitting here a little while ago, talked about the chloride situation, and we have this allegation that some 1,500 tons of chlorides as sodium chloride are going into the lake at Manistee ever) day. Would it be necessary for us to ask Governor Ogilvie to point this out to the Federal people in order ------- 2128 J. F. Wilson to get to abatement of this discharge, in order to show an interstate effect? Or can we assume that Lake Michigan, because of its mixing, will carry this kind of a persistent discharge all over the lake? MR. STEIN: As I read the request from Governor Kerner which, as far as I can see, is endorsed by Governor Ogilvie, we already have this request from Illinois in sufficient terms to give us jurisdiction over that and investigate that and correct that if that is the problem* MR. DUMELLE: Thank you. MR. STEIN: This has already been done. May we have Mr. Winston? Is he here? Vance Van Laanen? Is he here? While you are coming up, Mr. Van Laanen, I would like to take this opportunity to introduce a telegram into the record from Carole Magnus, addressed to several of the conferees and Mrs. Edgar Wilkinson's statement — she had to leave — and Catherine Quigg's statement, who also had to leave. They have entered statements for the record. I would like to put those in. (The following telegram was received from Carole Magnus, Secretary, Manistee County Anti-Pollution Organi- zation .) "MACAPO fully supports strongest action to ------- 2129 Mrs. E. Wilkinson prohibit thermal pollution. Urge push for prejudgment, guidelines." STATEMENT OF MRS. EDGAR WILKINSON, SOCIETY AGAINST VIOLENCE TO THE ENVIRONMENT, HIGHLAND PARK, ILLINOIS MRS* WILKINSON: My name is Ann Wilkinson from Highland Park, Illinois, and a member of the Society Against Violence to the Environment, I am not speaking for SAVE but as a concerned citizen and as a mother. I grew up in Highland Park and used to enjoy swimming in Lake Michigan. I have a 4-year old and I wouldn't dare let her go in the lake in its present state. I hope she will be able to some day. If there is any doubt of the effect of adding heat to the lake from atomic powerplants or any other sources, we should not add any heat. We can't afford to take a chance. You've seen the button, "Don't Do It in the Lake." I don't think that anyone — business or private — should be allowed to put heat in the lake. ------- 2130 Mrs. C. T. Quigg STATEMENT OF MRS. CATHERINE T. QUIGG, HARRINGTON, ILLINOIS MRS. QUIGG: Electric utility companies to the contrary, nuclear powerplants are not man's good neighbors. Existing and proposed nuclear powerplants are designed to pour billions of gallons of heated water into Lake Michigan each day. The Zion plants alone will con- tribute 2 billion gallons of heated water a day to the lake. I am aware of the decline of the lake due to pollution and I am afraid that nuclear power siting with thermal discharges along its shore will hasten this decline. Not just the Zion plants but all powerplants being built around the lake deserve our serious concern with relation to their environmental effects. At the very least, we should insist that electric companies utilize current technology such as cooling towers and cooling ponds to prevent aquatic damage. Why don't we — for once and for all — dispel three power company myths: 1. The myth that cooling towers cause adverse atmospheric conditions. ------- 2131 Mrs. C. T. Quigg Investigations by the FWQA of fogging problems from natural and draft towers presently operating in the eastern United States refutes this position. Reports indicate that natural draft towers did not produce ground level fog or drizzle under any weather conditions. Plumes of steam from cooling towers rarely dropped below the top of the tower for an extended distance, and generally dissipated within a few hundred feet of a tower. The FWQA report, dated September 1963, went on to say, "In general, undesirable meteorologic effects from towers can be prevented or controlled to a large degree through modern design, such as effective drift eliminators and air-flow control. In situations where problems arise, the area affected is limited to that immediate to the tower installation•" Research on cooling towers by Eric Aynsley, research chemical engineer, Illinois Institute of Technology, confirms the above conclusions. Initial findings of his studies at the Keystone Generating Station near Indiana, Pennsylvania, state that local fogging problems and icing from tower plumes do not present a problem, 2. The myth that cooling towers are too costly. ------- 2132 Hon. Gaylord Nelson, U.S.S. According to recent studies, installation of cooling equipment to control thermal pollution from water discharges from powerplants would add about 30 cents a month to the average customer's electric bill, I'll pay that much to keep the lake alive. 3, The myth that cooling towers are so unsightly the public doesn't want them. This is the weakest argument of all. The choice between unattractive cooling towers and a dead or unsightly lake is an easy one to make, I recommend that we insist on alternate cooling methods for thermal powerplants near Lake Michigan, We should not allow Lake Michigan to become the power company's private waste sink at our great expense and that of future generations, MR, STEIN: Just in case you think I am out here on my own, I have received another telegram from another one of my bosses, which I will read into the record now: "Though the exact extent of potential damage to Lake Michigan by the introduction of massive quantities of waste heat is yet undetermined, there is enough evidence to make it clear that consequences could be catastrophic. Federal reports which have been presented to this conference ------- 2133 V. Van Laanen cite the dangers and demonstrate there are at least six reasonable and feasible alternatives to discharging heat wastes to the lake from powerplants. The conferees should act immediately to establish tough standards on these plants prohibiting the discharge of waste heat to the lake. There is no valid reason to gamble with the future of this priceless resource when, in fact, such a risk can be avoided with available technology," Signed Senator Gaylord Nelson, Mr, Van Laanen, STATEMENT OF VANCE VAN LAANEN, PRESIDENT, WISCONSIN RESOURCES CONSERVATION COUNCIL, GREEN BAY, WISCONSIN MR, VAN LAANEN: My name is Vance Van Laanen and I reside in Suamico, Wisconsin, I speak on behalf of the Wisconsin Resource Conservation Council of which I am President, and the newly formed Lake Michigan Federa- tion, of which I am Chairman0 During the past week, Mr0 John Wilson, who represents the Wisconsin Ecological Society, and I have concluded negotiations with the Wisconsin-Michigan and Wisconsin Electric Power Companies in lieu of intervening ------- 2134 V. Van Laanen in the licensing of their facility at Point Beach. I know it was earlier reported in the press that we had reached an agreement and that is partially correct. We had, in fact, reached an agreement in principle* In the wording of that agreement, however, the principle enforcement mechanism was to have been the Atomic Energy Commission itself. Subsequent discussions with AEC counsel, which I will not quote directly, disclosed the fact that the Commission had no intention of enforcing the agreement even though they did agree to accept the document for inclusion in the official docket for Point Beach unit number one. This original agreement had then to be renegotiated with different enforcement mechanisms and I believe that a portion of that document is relative to the proceedings here. I have included a copy of the agreement together with my remarks for inclusion in the record. (See Pp. 2141-2145) The agreement states in part: "The intent of this agreement, which all of the provisions thereto are understood to promote and establish, is to create an obligation on the Applicants to make every reasonable attempt to reduce all deliberately discharged radioactive wastes from Units 1 and 2 of the Point Beach Nuclear Plant ------- 2135 V. Van Laanen to zero." And again: "The Applicants will proceed forth- with to obtain proposals from Westinghouse and/or other suppliers for equipment or systems that are applicable to the Point Beach Nuclear Plant and that would result in reducing the discharge of radioactive substances in con- formance with the intent of this Agreement,1* I firmly believe that this language, arrived at through negotiation in good faith, firmly establishes the principle of zero release of radioactive materials to the environment as a technically feasible and econom- ically practicable reality. Further, I firmly believe that it demonstrates an awareness on the part of the utility industry, or at least that portion of it that is environmentally responsible, that the general public is not willing to settle for a lenient standard, even though no immediate danger to health and welfare can be estab- lished, when the technology is available, at reasonable cost, to meet more stringent standards, I commend the applicants, Wisconsin-Michigan and Wisconsin Electric Power Companies for their willingness to take this important step in environmental protection and I strongly urge the conferees here to require no less of the other utilities constructing reactor generating facilities around the lake. ------- 2136 V, Van Laanen During these same negotiations, the question of thermal loading of Lake Michigan came up, as you might suspect. The applicants asked iis to withdraw consideration of the thermal aspects as it was not relevant, in this situation, to the Atomic Energy Commission proceeding. We agreed with the applicants that Wisconsin regulations effectively direct the consideration of thermal discharges to this conference. We, therefore, request of this con- ference that it require the abatement of thermal discharges to the full extent that is technically feasible and econom- ically practicable, or more simply that it require the full application of the state of the art in thermal abatement techniques. I would like to take a moment or two to explain why I believe this request to be both reasonable and timely. The fundamental issue in thermal control involves the question of whether the utility industry, or any other, possesses the right to contaminate the environment beyond the limits of necessity. The question is not technical, it is a moral question. I say it is not a technical question because if you leave out all of the economic qualifiers, it is obviously undesirable to inject large amounts of heat into a natural cold water system. The traditional approach to pollution control in this country has been defensive and negative. This ------- 2137 V, Van Laanen approach has developed over a period of many years from an initial, basic, philosophy of using the environment to its maximum capacity to carry away wastes. The environment has been thought of as having a "self-purification capacity" that can and should be legitimately used for waste disposal. In this way, of course, the costs of waste control and dis- posal could be minimized, and it has been an accepted idea that to require additional waste treatment would be to place an unreasonable economic burden upon industry. So long as no obvious damage could be shown wastes from communities and from industry could be released to the environment without further justification. It thus became the practice to establish environmental and human protection criteria that were based upon a concept of obvious or provable harm. Once such limits are established, of course, they become "dumping" criteria, in the traditional sense that the costs of pollution control are customarily minimized by releasing the maximum amount of wastes that can be absorbed by the environment without evident and obvious harm. Quite obviously, this approach also results in the maximum pollution of the environment that is tolerable on a. short- term basis. We now have a history of attempting to clean up ------- V. Van Laanen pollution after the damage has been done, and that procedure is both expensive and unsatisfactory* It leads inevitably to an environment that is barely tolerable. What is required instead is a new approach to environmental protection which is based on prevention rather than cure. It should no longer be necessary for those desirous of protecting the environment to bear the burden of proof that each and every discharge will, in fact, result in X-amount of damage. The burden of proof should be on the other foot and the potential polluter should be required to show the absolute necessity of making any releases to the environment. Instead of making maximum use of the environ- ment for waste disposal, we must begin to think in terms of the maximum protection of that environment and the minimiz- ing of wastes dispersed to it. The crucial question must become not how much waste can the environment tolerate, but how much can be reasonably kept out? While the concepts of air and water quality standards have served adequately as a beginning in pollution control, we must take the next step and begin to place controls on the effluent discharges where they originate. The only supportable justification for the release of any contaminant to the biosphere now is the absolute demonstration of the necessity for it. The Fish and Wildlife Service has presented to ------- 2139 V. Van Laanen this conference a clearly viable alternative to the once- through cooling system. It has shown that these alternatives are technically feasible and economically practicable• There is no question that the prohibition of once-through cooling is the only reasonable response by the conferees. Finally, I suggest that adopting stringent thermal standards now would be not only reasonable but timely, A recent issue of Limnos magazine contained an excellent article by Mr, Mayo, In the article, he described ways for private citizens and conservation groups to be more effective in promoting sound environmental policies and even suggested some excellent strategems for environmental litigation. Let me insert here that I agree with everything Mr, Mayo said. What I deplore is that he had to say it at all! I suggest that the conferees here would be shocked to pick up tomorrow's morning paper and see an article by the Chicago Chief of Police outlining methods for citizens of this city to preserve law and order. In the area of crime control, we have long passed the time of the vigilantes. The democratic process in the area of pollution control, as I understand it, consists of legis- lative acts and regulatory enforcement. Yet everyone here is aware of a continuing necessity for litigation on ------- 2140 V0 Van Laanen environmental matters initiated by the citizen. Although litigation before the courts of the land is a viable extension of the democratic process, I suggest that it indi- cates some weakness back on the legislative and regulatory levels. Litigation is rapidly becoming unavailable as a tool for the private citizen. The costs involved are almost prohibitive. Conservation organizations are less and less able to mount significant environmental actions in the courts, but the need for such litigation has not abated. When the public is frustrated at the legislative and regulatory levels, and when the courts, for economic reasons, are no longer available, I suggest that the con- frontation over the environment will still occur. The logical destination in the democratic tradition for that confrontation is the street, I personally would deplore such a development as would most other responsible conser- vationists, but I would remind the conferees that the problems are severe, widespread, and increasing. More people are becoming aware and involved every day. As environmental degradation increases in intensity its visibility factor increases exponentially. This increase in the visibility factor will inevitably attract the attention of greater and greater numbers of the public, The time for strong, purposive regulatory action is now. ------- 21U V. Van Laanen (Following is the agreement referred to by Mr. Van Laanen.) AGREEMENT This agreement is entered into by and between Wisconsin Electric Power Company and Wisconsin-Michigan Power Company hereinafter called "Applicants" and John F, Wilson and Vance J. Van Laanen and a number of organizations represented by them as set forth in their petition in the proceedings before the Atomic Energy Commission of the United States of America under docket No. 50-266, including the Wisconsin Ecological Society, Inc. and the Wisconsin Resources Conservation Council, hereinafter called "Intervenors." Applicants have in said proceedings requested that the Atomic Energy Commission issue them an operating license for the Point Beach Nuclear Power Plant Unit number one at Two Creeks, Wisconsin. Intervenors have petitioned the Atomic Energy Commission for leave to intervene in such proceedings and for a public hearing in the matter of the issuance of such requested operating license stating as their view that it is desirable that no discharge of radionuclides be made to the environment and that the present state of the art is such that no radionuclides need be discharged to the environment. The intent of this agreement, which all of the ------- 2U2 V. Van Laanen provisions thereto are understood to promote and establish is to create an obligation on the part of 1, the Applicants; To make every reasonable attempt to reduce all deliberately discharged radio- active wastes from Units 1 and 2 of the Point Beach Nuclear Plant to zero* and on the part of 2, the Intervenors: That upon satisfactory demonstration of applicants* intention to meet the above stated obligation, to forthwith withdraw their petition to intervene in the pro- ceedings before the Atomic Energy Commis- sion under docket No, 50-266 and withdraw their request for a public hearing on the request of applicants for an operating license. The provisions agreed to by Applicants and Intervenors intended to implement this agreement are as follows: 1. That Intervenors will forthwith withdraw their petition to intervene in the proceedings before the Atomic Energy Commission under docket No, 50-266, and withdraw their request for a public hearing on the request of Applicants for an operating license. ------- 2143 V, Van Laanen 2. The Applicants will proceed forthwith to obtain proposals from Westinghouse and/or other suppliers for equipment or systems that are applicable to the Point Beach Nuclear Plant and that would result in reducing the discharge of radioactive substances in conformance with the intent of this Agreement. The Applicants will within 60 days after receipt of these proposals make their evaluations and place orders for such equipment and systems. 3. That the following paragraph will be submitted forthwith by Applicants to the Atomic Energy Commission with a request that it be incorporated into and become a part of the said operating license requested by Applicant for the Point Beach Nuclear Plant, Unit number one at Two Creeks, Wisconsin to wit: "On or before June 1, 1971» Applicants will submit to the Atomic Energy Commission application for modifications and/or additions to the Point Beach Nuclear Plant Unit number one to effect such changes in the equip- ment and/or operations that will reduce radiation exposures and releases of radioactive materials to unrestricted areas to as far below the limits specified in 10CFR20 as the state of the art in the reduction of such emissions will allow." ------- 2144 V, Van Laanen 4, That if and when the Atomic Energy Commission grants such application for modifications Applicants will proceed to effect the modifications as approved by the Atomic Energy Commission according to the time schedule approved by the Atomic Energy Commission, or, if no time schedule is so established, within a reasonable time, 5, This agreement shall also apply in all particulars to the proceedings relative to Applicants' Point Beach Nuclear Power Plant Unit number two under docket No, 50-301 before the Atomic Energy Commission, 6, In the event Applicants fail to comply with the provisions for implementing this agreement, provision number five (5) shall be voided, and Applicants shall not proceed with the fuel loading of Unit two of Point Beach Nuclear Plant, at Two Creeks, Wisconsin, 7, This agreement shall be enforceable by the Atomic Energy Commission and any successor agency to the Atomic Energy Commission and in any proper court of record and shall be enforceable in such court through the remedy of specific performance or injunction if the court con- siders such remedy or remedies proper. This agreement shall be executed in duplicate, one copy being retained by Applicants and one by Inter- venors. Provision number three (3) shall be duplicated ------- 2145 V, Van Laanen forthwith by applicant and submitted to the Atomic Energy Commission to become part of docket No, 50-266 if rules of the said Commission permit* Witness our hands and seals this 5th day of October, 1970. MR. VAN LAANEN: Thank you. (Applause) MR. STEIN: Mr. Van Laanen, thank you. Any comments or questions? If not, thank you very much, sir. MR. DUMELLE: Mr. Stein, I just want to ask Mr. Van Laanen — it is my understanding that the State of Maryland, in issuing its permit for the Calvary Cliffs Nuclear Plant, set the standard at 1 percent of the AEG 10CFR20 regulation, and that the State of Minnesota, I think, will set a 2 percent value. Am I to understand you think that these are too loose, and your standard would be zero for radioactive discharges? MR. VAN LAANEN: You get into an area here of what is zero and what is essentially zero. The Minnesota standards, as I understand them, and the Maryland standards are set right about at the point where the difficulty in calibrating the measuring instruments interferes with the ability to measure. So you are down in the area where it ------- 2146 V, Van Laanen doesn't really make much difference whether you are talking a tenth or two-tenths or three-tenths. I think it has been substantially demonstrated that the state of the art — in radiation control techniques — is well beyond the Federal requirements for it« And, as I say, I think that the willingness of the Wisconsin Electric Power and Wisconsin- Michigan Power to take on itself the extra burden of agree- ing to provide essentially zero releases amply demonstrates the fact that this is the case, I certainly don't want to criticize the Minnesota standards or the Maryland standards, I think they are both very good, MR, DUMELLE: What I am trying to establish isj Are your standards tighter than theirs, as you see them? MR, VAN LAANEN: Well, first of all, you are trying to compare apples with peaches here. I am not that familiar with the Maryland standards. The Minnesota stan- dards are — by the way, those are not statewide standards, if I am not mistaken, those Minnesota standards apply to the — what is the name of the plant? — Monticello plant. They are specifically designed to cover a General Electric cooling water reactor with specific conformation at Monticello, So the maximum permissible concentration factors ------- 2147 V. Van Laanen for different isotopes are going to differ with that which will be coming out at Point Beach. If you are asking which standards will be lower, I think that probably there will be a smaller standard from the Point Beach Plant simply because it is a pressurized water reactor, and you don't have the gas emission problems that are difficult to handle that you do with the boiling water reactor. I do not have it calibrated down into specific MFC's at this point. MR. STEIN: Any further questions? This has come up. Mr. Van Laanen, don't run off because I have one more question. With the background you have demonstrated, I think this is a good time to ask you the question that has come up and people have asked me from time to time. If the electric utilities demonstrate, as you indicated in Wisconsin, before they build the plant that they are going to get down and get into this refined philosophic discussion of zero tolerance — and I agree with your statements on that — of the protection of the environment from releases of radioactive material into the environment, how do these plants on the one hand get so far on radiation,when on the other hand they didn't give the same comparable assurances of protection from discharge of heated water? ------- 2148 V. Van Laanen MR. VAN LAANEN: Are you asking now the plan — MR, STEIN: No, no, it is a philosophic point. I am not talking, obviously, about the fossil fuel plants because this doesn't arise there. But if you are dealing with the nuclear plants and before the power industry goes ahead with that plant, they present full, complete, and documented assurances — and I think they do a pretty good job of it — MR. VAN LAANEN: Yes, they do. MR. STEIN: — that there won't be a nuclear dis- charge, and they have safety devices, etc., and have taken every precaution to protect the environment, the question is how come the plants already have done this with nuclear or radioactive material but they haven't done it apparently to everyone's satisfaction with the proposed heat discharges? Or should the industry, before it puts up a plant, be required to make the same kind of case, provide the same kind of assurances and the same kind of devices that it relates to protecting the environment from the discharge of heat as apparently it has done in assuring the protection from radioactive materials? ------- 2149 V. Van Laanen MR. VAN LAANEN: I would say absolutely, and I think the reason why they are not is because there has been a regulatory vacuum in that area. The other thing I would say is that since the implementation of the NEPA Act I think this will probably be done or at least done to a certain extent. However, you bring up another very interesting point here, in that I do not personally see how it is possible to separate the heat from the radioactivity or vice versa. For the most part, the radioisotopes which come out of the these plants with the exceptions of the noble gases will come out ae a part of the hot water discharge stream, and how are you going to physically or in any other way philosophically or ideally separate the isotopes from the waste heat in the waste disposal stream? I don't think it is possible. So I think it makes sense to do the same kind of study, the same kind on the noble gases — environmental reassurance sort of thing — with heat that you are doing with radioactivity because why the sense of water discharges, you can't separate them anyway. MR. STEIN: By the way, I would thoroughly agree with you, and I don't know if you are familiar with it, but before these plants -- at least the thermonuclear plants — cane on, we did have many enforcement cases involving the ------- 2150 V. Van Laanen uranium mining industry in the Colorado River Basin, and at this time I see a lot of parallels to where we are here. MR. VAN LAANEN: Yes. MR. STEIN: According to the Federal investigators and agreed upon by the State people, we went out and we at least determined there was excessive discharges of radium to those waters. These plants were operating. We got these pushed back, back, back. Then when the new plants came in the assurances were given that this wouldn't happen. But the restrictions for emitting radiation also applied to the existing plants. So in radiation this was carried on, in large measure, into all plants such as the thermonuclear plants. But I thoroughly agree with you that the protection of the environment is always one piece and you can't separate this. Any kind of emission that comes out of the plant that may affect the environment has to be accounted for. I am not just referring to the power industry. I don't want to single them out at all, because we have the same thing in mercury discharges. MR. VAN LAANEN: Yes. MR. STEIN: But it seems to me that if we have an example of how an industry can come forward and assure ------- 2151 T. MacDonald the public that it has taken all safety measures in pro- tecting the public from radiation discharges, we might be much farther ahead if they would provide that same kind of assurance as to other potential hazards to the environ- ment, MR. VAN LAANEN: You may get into this if you get a vigorous enforcement of the NEPA requirements, but I don't know if that will be or not, MR, STEIN: Thank you. May we have Ted MacDonald? STATEMENT OF TED MacDONALD, WEST LAFAYETTE, INDIANA MR, MacDONALD: Mr, Stein, and gentlemen of the conference. My name is Ted MacDonald. My home is in West Lafayette, Indiana, I also own property on Lake Michigan immediately adjacent to the Donald C, Cook Plant at Bridgman, I am involved in a lawsuit at the present time against the Indiana and Michigan Electric Company in company with eight of my neighbors to recover erosion damages that have been caused by the construction i of their plant. But I speak to you today as a private citizen ------- 2152 T. MacDonald interested in preserving Lake Michigan. I speak not only for myself but for dozens of people I know personally from all four States bordering the lake and uncounted hundreds of thousands I will never know, all of whom will need a living Lake Michigan in the years to come, a living lake to provide them with peace-preserving recreation, the fresh water they need to survive, and perhaps an essential food supply in an overcrowded world. And as I speak, I continue to be amazed that after all that has transpired, a few private citizens still must take it upon themselves to carry on such a major portion of the fight to save the lake — and it is a real fight. I have the financial scars and a depleted supply of midnight oil to prove it0 The people I speak for — and I am in close contact with them — feel there are some questions which need answering. Some positive answers to these questions must be found before further possibly lethal doses of hot water and radioactive waste are allowed to be administered to Lake Michigan. MR. STEIN: Mr. MacDonald, just a moment, please, I would appreciate it if the people would not talk in the back so the rest of the people could hear* Thank you. MR. MacDONALD: First question: Why do power ------- 2153 T. MacDonald companies regard the granting of construction permits and operating licenses as a foregone conclusion? What would lead them to believe that they are safe in spending many thousands, yes, even millions of dollars, on preconstruction work before the necessary permits are issued? They seem so sure of themselves that it makes one wonder. Just one example of many: At Michigan City, a powetplant discharge flume is already partially constructed but the permit to complete it has not yet been approved. Second question: Last March 30 at Grand Rapids, Michigan, Senator Philip Hart conducted a hearing for the Subcommittee on Energy, Natural Resources and the Environment of the Committee on Commerce of the United States Senate. At this hearing, Senator Hart questioned a top official of one of the power companies with regard to comparative costs of wet and dry cooling towers. The power company official replied, and I quote, "Let me say there are no nonevaporative cooling towers in the United States. The only experiment we are knowledgeable of in the foreign countries have not proven very successful as yet. These are under study by us but there needs to be a lot of development before they can be used." Whereupon, an official of the Federal Power Commission stood up, identified himself, and reminded the ------- 2154 T. MacDonald gentleman from the power company that a nonevaporative cooling tower is now being installed in the State of Wyoming by the Black Hills Power and Light Company. Now, the question is this: Are power company officials as pitifully ignorant of the problems they are creating and the solutions to those problems as the foregoing example indicates, or do they tend to play Mickey Mouse with the truth when it is to their advantage? Third question: When are State and Federal agencies which have power to grant power companies various permits and licenses going to get down to business and protect public interests? At the Donald C. Cook plant in Michigan permits for the intake outlet structures were all set for automatic approval until the facts came out at a hearing held only because of public demand. As a result, complete redesign of the structures was necessary. Why did the public have to hire consultants and attorneys to show government officials they were playing brinksmanship with the public interest? How many other permits already granted should be reexamined in the light of this incrim- inating example? Fourth question: Why does the power industry continue to spend millions of dollars on advertising to sell more electricity, while at the same time broadcasting ------- 2155 T. MacDonald the dangers of impending power shortages? A TV news program tells the story of the recent brownout in the East, The sponsor of the show is a power company, and the commercial urges us to heat our homes electrically. How ridiculous can this comedy of errors become? Who can attach any credibility to statements from people in the electric power business when they so grossly underestimate the public intelligence and so poorly manage their business affairs? Fifth question: When is the power to grant permits and licenses going to be shifted to State and Federal Government agencies which have some power to enforce such conditions and stipulations as the permits or licenses may contain? Such conditions and stipulations are usually in the public interest, but it has been my personal experience that it is up to the public to spend a bundle of its own nontax deductible dollars to do the enforcing. Sixth question: Why do government agencies, particularly at the State level -- although I've seen the Army Corps of Engineers do it, too — rely so heavily on people hired by the power companies for scientific information pertinent to the life or death of Lake Michigan? Here again it has largely been left up to the private citizens to bring forth and pay for their own ------- 2156 T, MacDonald reputable scientists to emphasize the obvious and proven fact that there are two sides to the story* I submit that John Q. Public is fed up to his ears with officials who have abdicated their responsibility to the people by swallowing the power company story hook, line, sinker, and contaminated bait* In conclusion, I submit that the public is not to be underestimated in its determination, or in its knowledge of the many facets of this problem. The public wants answers to their perfectly legitimate and logical questions, only a few of which I have mentioned. If the money already spent on this fight had been devoted to research to find answers to problems which already were there when the whole thing started, all of us could be attending to other important business today. Let me suggest that we stop wasting each other's time and money and get down to the business of finding ways to satisfy our power needs without destroying any irreplace- able natural resources in the process, I am grateful for this opportunity to speak. Thank you very much, (Applause) MR, STEIN: Thank you, Mr, MacDonald, Any questions? MR0 DOWD: I have one question, Mr, Chairman, ------- 2157 T. MacDonald While you are coming up with your question, I have to do my research in this room every day, and I forget it from one time to the next, but it always works. May I suggest that people who want to talk or hold conferences get outside that exit door. For some reason or another when you speak against that rear wall there in the next room, it is like an echo chamber, and your voices come right back up here, and there are some dead spots in the center where you can't hear it, but the noise level up here is rather loud. We have a lot of ante rooms available for private conversations and caucuses just outside. Thank you. MR. DOWD: I am Joseph Dowd, counsel for Indiana- Michigan Electric Company. Mr.. MacDonald, you mentioned that a dry cooling tower is presently under construction at a plant owned by the Black Hills Power Company. Do you know what the gen- erating capacity of that plant is? MR. MacDONALD: No, sir, I don't. It is on page 75 of that booklet you have in your hand. MR. DOWD: Does it specify the generating capacity? MR. MacDONALD: No, it does not, MR. DOWD: Well, that is what I was interested ------- 2153 T. MacDonald in. MR. STEIN: Are there any further questions or comments? If not, thank you very much. MR. MacDONALD: Thank you. MR. STEIN: M. A. McWhinnie. While you are coming up, Miss McWhinnie, I do have a clarifying statement from Mr. Sol Burstein, Senior Vice President of Wisconsin Electric Power, which I would like to put in the record. Some of you may recall we had a colloquy on the meaning of a quote from the Senate Appropriations Committee — and I guess I started this — and I think Mr. Burstein has clarified it0 There was a typographical error in his report which led to my questions and they used the word "Commission." "Commission" was inadvertently substituted for the word "Committee," which makes the thing fairly clear, and we will place this in the record because I think this is explanatory. (The letter above referred to follows on page 2159o) MR. STEIN: And I also have a letter from John Co Berghoff, addressed to Mr. Klassen which, without objection, can be put into the record as if read in toto. (The letter above referred to follows on pages 2160-2163.) ------- 2159 WlSCOnSin EleCtriC POWER COMPANY 231 WEST MICHIGAN, MILWAUKEE, WISCONSIN 53201 October I, 1970 Mr. Murray Stein Chairman Lake Michigan Conference Sherman House Chicago, Illinois Dear Mr. Stein: At the conclusion of the presentation of my prepared statement at the workshop session of the Lake Michigan Conference on Wednesday, Septem- ber 30, you asked for a clarification relating to the quotation of the Senate Appropriations Committee, which begins on page 15 of my statement and concludes on page 16. As you may recall, the question arose because of the word "commission," which appears in the first line of page 16. The statement has been checked, and I find that the word "Commission" was inadvertently sub- stituted for the word "Committee." The rest of the quotation is correct and is taken from the Committee's report on FY 1971 funds covering appropriations for pub- lic works for water pollution control and power develop- ment and the Atomic Energy Commission. Therefore, the statement does indeed rep- resent the thinking of the U. S. Senate Appropriations Committee, in response to your question. Sincerely, Sol Burstein Senior Vice President ------- 2160 JOHN C. BERGHOFF ATTORNEY AT LAW I I 5 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 6O8O4 TELEPHONE 012)431.2622 SEP 2 9 1970 RECEIVED EWIBONMENTftL PROTECTION STATE OF ILLINOIS September 28, 1970 Mr. C. W. Klassen, Director Environmental Protection Agency State of Illinois 535 W. Jefferson Street Springfield, Illinois 62706 Dear Mr. Klassen: LAKE MICHIGAN FOUR-STATE CONFERENCE Thank you for your letter of September 22 with respect to the reconvening of the Lake Michigan Four-State Conference September 28 on the subject of Thermal Discharges. Please accept this letter as a request for permission to present a brief oral statement at this conference, which I understand will be held at the Sherman House Hotel in Chicago, Illinois, on Friday, October 2, 1970. We appreciate the oppor- tunity to make a statement in the public interest at this important hearing. With kind regards. Very truly yours, JCB :hk ------- 2161 STATEMENT OF JOHN C. BERGHOFF FOUR-STATE CONFERENCE THERMAL POLLUTION STANDARDS CHICAGO, ILLINOIS - OCTOBER 2, 1970 My name is John C. Berghoff. I earn my living as Associate General Counsel of Swift & Company. I have spent most of my years living near the shoreline of Lake Michigan in Illinois, Indiana and Michigan. I am a member of the Council of the Illinois State Bar Association Section on Environmental Control Law. Today^s statement I make, however, in my individual capacity as a person who greatly values the natural resources of this area, particularly Lake Michigan, and who wants to see these resources and this lake pre- served for the 3routh of this generation and for generations to come. I have no quarrel whatsoever with the nation's need for more electrical energy nor with the concept of nuclear plants to provide this additional energy. I do strongly object to the way in which the pox^er companies are being permitted to use the nation's natural resources such as Lake Michigan as private indus- trial waste ponds. The nuclear plant now under construction with which I am most familiar is the one being built on the lake shore at Bridgman, Michigan - the Donald C. Cook Plant. This plant will, when completed and if permitted to do so, draw two billion gallons of fresh, cold, Lake Michigan water aach day, use it as a coolant in its nuclear processing and spew it back into the lake at the end of the day some 20 to 25 degrees warmer than when it was withdrawn. The American Electric Power Company which has announced that this plant will cost 400 million dollars is not planning to spend one ------- 2162 -2- single dollar to moderate this extreme elevation of temperature, nor for that part is it planning to spend one single dollar to assure zero or near-zero radioactivity of the water which will be returned to the lake. It simply, if permitted to do so, will treat Lake Michigan as its own private waste pond. I strongly feel that the interests of this nation, and more particularly of the people who live in these four states which form the shoreline of Lake Michigan, deserve to have this natural resource protected by reasonable thermal pollution criteria adopted by the federal and state governments involved. Further, it is my personal view that the top managements of the electric power companies involved, despite the great number of highly-qualified and highly-paid expert witnesses whom they have presented at this hearing, would welcome the promulgation of tough and uniformly enforced thermal standards. Under our free enter- prise system, these companies cannot be expected to take the lead in protecting the public interest when it clashes with the private interests of their shareholders. Once a determination has been made as. to what reasonable thermal standards are required to protect the public interest, however, and once the appropriate governmental agencies have adopted these standards, I am sure we will find the power companies conducting themselves as good citizens in compliance therewith. I urge it to be the responsibility of each of the four states here involved and of the Federal Government to adopt meaningful, unambiguous thermal pollution standcirds, avoiding intricate mixing zone formulations which will only lead to costly ------- 2163 -3- compliance problems and will not give the nation and its citizens what is required to preserve these resources. You will best serve the interests of the conservationists and, though tney may not admit it, the power companies as well, by adopting and enforcing uncomplicated, reasonable but firm thermal standards - you will have met the nation's need for expanding electrical energy without permitting our national resources to be ravaged in the process. ------- 2164 M. A. McWhinnie MR. STEIN: Would you go ahead? STATEMENT OF MARY ALICE McWHINNIE, PROFESSOR, DEPARTMENT OF BIOLOGICAL SCIENCES, DePAUL. UNIVERSITY, CHICAGO, ILLINOIS DR. McWHINNIE: I am Mary Alice McWhinnie, Professor in the Department of Biological Sciences at DePaul University, with an earned doctorate from Northwestern University, and Director of the DePaul-EPRO Ecological Study of Lake Michigan. My credentials for speaking to this board of conferees relates to my professional experience in crustacean biology in study of effects of temperature changes on invertebrate animals in freshwater and Antarctic marine water, and to the work in which we are engaged on Lake Michigan, Mr0 Chairman, and conferees, ladies and gentlemen. I am grateful for this opportunity to present some views and concerns which I share with most, if not all, present at this workshop. I am aware of the serious responsibility each of us accepts in such participation, because of the unprecedented external pressure against nuclear-powered electric generating stations which ------- 2165 M. A. McWhinnie pervades into an area of knowledge in which we find our- selves lacking in sufficient information to answer satisfactorily all of the questions placed by the non- scientist, I offer that the disparity of views presented thus far at this workshop attests to the inescapable reality with which we are faced: l) the necessity and commitment to protect the environment; 2) the increases in population density; 3) the continuing demands for available energy; 4) the intolerable slowness with which definitive knowledge accumulates. Though disparities clearly exist, as judged from the statements made at this workshop and elsewhere, there is within these multiple views (at least) one point of common agreement: more study is needed and the dif- ferences in existing and/or planned electric generating plant sites require individual study. I should like to focus on what I believe led to the development of workshops of this kind, but I will not burden this statement with repetition of the long litany of data available on the topic of thermal modification. Rather will I include for the record statements prepared for the recent hearing conducted by the Illinois Pollution Control Board held in this city 25-26 September 1970, With the approval of the following authors, I ask to have ------- 2166 M. Ao McWhinnie entered the statements of Dr. Philip F. Gustafson — who I understand presented his yesterday — Director of the Great Lakes Program, Argonne National Laboratory (See Pp. 2179-2190); Dr. Charles Collinson, Head, Sedimentology Division, Illinois Geological Survey (See Pp. 2191-2201); Mr. John D. Harper, Director, Environmental Parameters Research Organization (EPRO) (See Pp. 2202- 2209); and my own, as Director of the DePaul-EPRO Ecological Study of Lake Michigan (See Pp. 2210-2219). The objective of Dr. Gustafson's presentation on "Thermal Discharges and Lake Michigan," is to illuminate the facts of natural thermal increments as they relate to man-induced thermal increments in Lake Michigan water. He states that the volume of water which would be involved in the operation of six nuclear powerplants to be in oper- ation by 197$ "... tends to stagger the imagination and perhaps to blur reason." In recognizing the wide variation in Lake Michigan water temperature, seasonally and vertically, he questions the real meaning, and points to the ambiguity of the term "ambient temperature," Considering the long period of operation of fossil-fuel plants at Waukegan, State Line, and Oak Creek, he notes the lack of any profound impact on the aquatic environment especially when compared with sewage and ------- 216? M. A. McWhinnie chemical waste outfalls. With respect to temperature, he shows a river water inflow to the lake which is at a temperature 5 degrees to 19 degrees Fahrenheit greater than the lake, and that this is near or comparable to the thermal input to the lake from a given nuclear powerplant; yet the former is not generally considered as "thermal pollution," The advantages and the disadvantages of the alternates to once-through cooling water are discussed and a "field program to determine best options" is urged; without this ",,, we will never know what reasonable thermal standards are ,.,," Dr, Gustafson recommends, in conclusion, that a plan be developed to allow present and near-ready facilities to operate to allow for the conduct of sound scientific investigations, Dr, Collinson laid emphasis upon the scant evidence available concerning the sedimentary and chemical composition of Lake Michigan and that data must be gained before its original character is degraded. He points out that localized areas already give evidence of change, e.g., the oxygen demand of southern Lake Michigan sediments is approximately three-fold that of Lake Huron, A program to study unconsolidated sediments with respect to atmos- pheric dispersal and surface water pollution as indicated by trace metal accumulation was started in 19&9, From the ------- 216$ M. A. McWhinnie data thus far obtained, heavy metals appear to be accumu- lating (10 to something more than 90 p.p.m.) as is organic carbon. These two categories are directly correlated and may indicate that sediments with a high organic content may in time have a high metal content; changes should be closely monitored. Sediment type distribution and stratigraphy are also being studied. The main impression of their study is: "..o a very serious absence of basic scientific data about Lake Michigan ..,'. "Reservations are held about the effectiveness and correctness of any blanket temperature standard ... at the present time." If a thermal input is allowed the site should be thoroughly studied before, and monitored after operation. MIn final analysis ... our knowledge is so small ... and the resource so valuable ... we would welcome the exclusion of any input ... to the lake ...." The thrust of Mr. John Harper's statement is that a mutually agreed upon moratorium be struck by the utility companies and the regulatory agencies. Such a moratorium would allow adequate study of completed or in-construction powerplants which would serve as the field experiments whose results would lay to rest the continuing debate prevailing in the absence of definitive information. He further states that under such a plan, power companies ------- 2169 M. A. McWhinnie must be prepared to change their cooling methods if such is found to be necessary. In my own statement, I presented the findings of several laboratories subsequent to study of "real situation" thermal modification of the aquatic environment, as well as in-laboratory duplications. In a number of such published studies no persistent biological alterations were demon- strated. Results were comparable for freshwater and marine organisms as would be expected of living systems. The temperature preferences of some plant and animal species were cited within this context. The implicit limitations of "fixed number policies" in establishing the maximum limits of thermal increments, or fixed distances for mixing zones, are presented just on the basis of the characteristics of a natural environment for which data were given. Based on those considerations, a position, finding agreement with most scientists, is taken that we can delay no longer in the procurement of hard data to provide the answers needed. The full text of these four statements is presented as an appendix to this one. Within the context of this workshop, I should like to present some reflections on what I consider to be the questions which lead to such, and for which we are seeking some reasonable solutions: ------- 2170 M, A, McWhinnie !• What is the true nature of the problem, described to be a temperature increase in the Great Lakes in general and Lake Michigan in particular? My own answer to this can be no different from that of all persons present. Briefly, it is a scientific question directed at the physical, chemical, and biological modifications that will result when one factor, in the complex web called "nature," is varied Many scientists have spoken on this subject and presented evidence that must be reckoned with, and some of that evidence has not corresponded with intuitive feelings expressed by others. It is necessary to state that a tone or climate appears to have come to prevail in this workshop such that it might be more appropriately characterized under the title of a trial. In my opinion, it is unfortunate that by the second day of this week the words "testify," "witness," and "cross examination" became common language. My inter- pretation was placed in some doubt when on Wednesday it was stated that this meeting was to engage in a discussion; however, my first impression persisted. Information emerges from both types of activities but the former deals with an objective problem to which all seek solutions; the latter, however, leads to impugning motives and credibility. ------- 2171 M. A. McWhinnie If science has nothing to say or to contribute to our environmental problems, then our solutions will be less than adequate; they shall have no more justification than expediency; objectivity becomes nonexistent, the scientist will return to his laboratory and our society will lose, 2, My second question could be called the first: From what source(s) can those convened here, and all Ameri- cans, holding diverse priorities, seek the information essential to reasonable decisions? The answer must be those persons who, by virtue of an earlier academic preference, pursued study in depth of those disciplines called physics, chemistry, biology, meterology, geology, and engineering — and the environment is all of these. These men have no special omniscience, but in their area of competence they have knowledge, experience, insights, and a deep curiosity to "know," If our judgment of their data is influenced by the wby-linew over which their name is given, and the persons to whom they speak in a civil society, we fly in the face of honesty, we dis- credit without evidence, and as a Nation we demonstrate a schizophrenic personality, seeking the benefits and by-products of science on the one hand as we discredit it on the other when it does not support a fear or uncertainty ------- 2172 M. A. McWhinnie which we might interpret as fact. If the proof of "no damage" to the environment rests upon the user, to whom can he turn for the proof? If he seeks those qualified by training, by research, and by objectivity, the latter are viewed with skepticism, if not discredited, and the former are said to be "fighting the issue," Yet so recent as 29 September 1970, the "Chicago Sun Times" carried an article stating that Mr, Stein said, ",.« industry <>•• and not the public ••• should prove that its projects pose no threat to the environment or public health," It is with deep concern over this conflict that I submit the view that Lake Michigan belongs to scientists, too. With a high hope to obtain answers essential to the making of supportable decisions and acceptable to an irate public too quick to judge and too concerned to be silent, the DePaul-EFRO study was initiated in the field in June 1970; a multidisciplinary study conducted by a confederation of 10 scientists from private, public, and governmental agencies, responsible and concerned, as are the conferees and all participants here, to reach for answers proportionate to the urgency of the issue. Their data are only now beginning to accumulate but their motives ------- 2173 M. A, McWhinnie have been publicly impugned; yet they stand independent of all vested interests, and this is well understood by all persons on both sides of this question. Gentlemen of the board of conferees, if scientists are the only appropriate segment of our society to study the science-based issues of our environment, can they be written off because someone doubts their motives? If study of the environment is not really needed, why did a conferee ask this week, "... could any meaningful conclusions be drawn from a one-day study ..." as it was reported by one of the speakers? If lack of study is not our critical problem why was the Kittrell report, for the FWPCA, of 1963, so thoroughly detailed as to what had to be done that we might "know"? Perhaps more critical is the problem that that study was not, to my knowledge, undertaken. Is that part of why the answers are not always forthcoming? If this was not true would we have come to be impatient with what is increasingly called a wait-and-see policy? Is the character of that phrase intended to encapsulate the view of or paraphrase scientists? If so, I urge that we recognize that erroneousness is insidious, it is defeating; it is divisive in a society already fraught with doubts, suspicions, and credibility gaps. ------- M. A, McWhinnie 3. What will be the effect on the biota subse- quent to thermal modification of Lake Michigan? Throughout this workshop, highly qualified scien- tists have presented their own data and that published by others; similarly, biological data have been presented in the "white paper" of the Department of Interior, In my own statement of recent time, submitted herewith (See Pp. 2210- 2219) and previously this year, I too have called upon the scientific literature. I think I shall add little to cite still more titles for the record. I should like to add another consideration with respect to temperature effects on living systems. May I say first that the subtleties of the capacities of living systems are profound and exquisite and continue to amaze even those who have devoted their life to such studies. Many of these subtleties pervaded the answers which Dr» Raney offered to your questions. He, as well as others, could not concur with the view that plus 1°F., or plus 5°F., or plus 3°F., or plus anything had any significant meaning to organisms in a dynamic system, one changing from moment to moment to constant fluxes in the natural environment. If some fixed value is the maximum permissible for cooling water entering the environment, such as plus 5°F0, or other, ------- 2175 M. A. McWhinnie a) Is this meaningful when it is 50° plus 5° in the same context as when it is 60° plus 5°» or 70° plus 5°? In terms of ease of understanding for those unfamiliar with biological phenomena it may be. For living systems, and those who have some understanding of them, each condition is dynamically different as it slides along the temperature-response curve for each species and for each vital function for each species. As a consequence, such a regulation would have less than rea] meaning in the biosphere. Indeed the living systems we work to protect pass through such oscillations in a diurnal (daily) cycle, and more; further, those endemic to the waters we seek to conserve live through approximately 32.5°F. to approximately #0-#5°F. on an annual cycle. Dr. Raney's comments on the yellow perch which have a range from the southern States to these latitudes are the biological evidence of the range of tolerance and adjustment. I hold this point as valid, even in the light of others made by the authors of the "white paper." Given the opportunity to discuss this in depth, I believe we would not find those two views so diverse; but the requirement of "yes" and "no" answers obscures biological realities and creates an erroneous polarity. ------- 2176 Mo A. McWhinnie Delicately shifting biological phenomena cannot fit into "legal boxes," In this context, and all the nuances that it implies, what meaning does a fixed thermal increment have? b) If plus 5°F., or other, is a fixed limit for natural water resources, is it for any water--water relatively free of high concentrations of naturally-occurring elements (phosphorus, nitrogen, silicon, calcium, etc.); 'or water with some given concentration of these; or water deteriorated with chemical waste, with toxic compounds, with phenols, cyanide, acid waste? No single environmental factor can have an uncomplemented effect. How will a fixed thermal increment cope with the phenomenon of synergism? May I note that Dr. Pritchard stated that temper- ature does not cause eutrophication; rather do inorganic, and organic nutrients. The verification of this may be evident when in late August at these latitudes, an algal bloom of enriched waters in summer declines, while yet the temperature is high or higher than previously. The decline in algal growth occurring at elevated temperatures corresponds with the decline in nutrient due to massive utilization. As the temperature then declines naturally into fall, another algal bloom occurs in October as a result of a new rise in nutrient and yet the temperature is lower. ------- 2177 M. A. McWhinnie Is it then temperature which causes eutrophication; and what does a fixed thermal increment mean in this context? I have another concern, and it is with reluctance that I note it, for it is "ticky-tacky," and it could be subject to disproportionate criticism. Under other circum- stances, I would not speak to it, but as I noted earlier, erroneousness is defeating and only for that reason shall I mention it. In the now well known "white paper," three references cite the periodical, "Chesapeake Science," Volume 10, Numbers 3-4 (19&9) of that periodical was devoted to the studies which were reported at the Second Thermal Workshop of the U, S, International Biological Program, and 29 papers were given. Of the three references to this periodical in the "white paper," one was to the introductory opening remarks to the workshop, and another was to a resume, I wonder why some of the data presented in the other 28 of those papers did not find their way into the "white paper"? I ask this question because some of the data which I cited which show no thermal effect were taken from that same volume and numbers). In conclusion, may I say the problem we are dis- cussing is, in my judgment, scientific; it is complex in the extreme; it cannot be resolved by debate; it must not be confused with intuitive feelings; and, it shall not be ------- 217S M. A. HcWhinnie resolved if scientists leave the world of contemporary prob- lems in our society. Rarely does the opportunity arise to attest to your convictions and defend your profession in order to serve the society and civilization of which you are a part. I am grateful that you have made this possible. Thank you, (The papers cited in Dr, McWhinnie's presentation follow in their entirety,) ------- 2179 Thermal Discharges and Lake Michigan P. F. Gustafson Argonne National Laboratory Argonne, Illinois At the present time the states bordering upon Lake Michigan and the federal government are wrestling with the questions raised by dis- charging waste heat into the Lake. The deliberate release of waste waters at temperatures above that of the Lake at the point of input is not a new practice; it has been part and parcel of human occupation of the land along the Lake and has increased at a rate connensurate to or exceeding that of population growth. 1,'hat is new, however, is the fact that the wisdom of this practice is now being questioned, and indeed being subject to regulation by the appropriate agencies. This ai^sticri- ing and probing is a healthy sign, a further indication of the awareness on the part of a growing number of citizens that our resources arc not endless; that the natural environment - be it air, land, or water - dees not have a limitless capacity to absorb wastes and other forms of insult and assault. The matter of thermal discharges into Lake Michigan has been brcu^t to the fore by the construction of six large nuclear power plants (a total of ten individual reactors to be in operation by 1978) which intend to use Lake Michigan water for condenser cooling, and discharging this water di- rectly back into th 2 Lake. The sheer magnitude (volume) of water involvcu, coupled with the ri'.e in temperature over the condenser, tends_to__star/g2r the imagination and perhaps_tq_b]_ur_reason. ------- About 4,600,000 gallons per minute (gpm) or 10,000 cubic feet per second (cfs) will be required for cooling purposes by the nuclear plants now under construction. This figure does not include the Bailly nuclear unit now being considered. The cooling water will gain an average of 20.5°F across the condenser. Cooling water for the nuclear plants will be taken from some distance off-shore, and in most cases from near the Lake better,. Hence, the cooling water will usually be belcw the ambient temperature of the surface waters when it enters the plant, and as a result the tem- perature difference between discharge water and lake surface temperature will be significantly less than the AT across the condenser. The objective of this statement is to attempt to place the cooling water discharged from nuclear power plants in a reasonable perspective, to discuss what is known and what is unknown concerning thermal parameters in Lake Michigan, to ex- plore the alternatives to direct Lake discharge, and finally, to suggest a course of action to answer pertinent scientific questions, to alleviate economic and operational stress, and to provide adequate electric power to residents of the Lake Michigan region. Perspective Lake Michigan is the fifth largest body of freshwater in the world. It is of sufficient depth that it is thermally stratified during the summer (roughly May to November), and is thermally mixed from top- to bottom each spring and fall. The primary source o~~ heating of the Lake is direct solar and atmospheric radiation, with river c.nd surface water run-off providing a relatively minor additional natural heat input to the Lake proper. Major ------- 2161 man-made sources of warm v/ater discharges Include industrial discharges, municipal sewage treatment plant effluent, and cooling water from steam generating facilities. The waste heat from this latter category is most readily documented because of the rather direct relationship between electrical output and heat loss across the condenser. In addition, de- tailed records of power generation make it possible to determine not only annual heat discharge but to break it down into daily or even hourly seg- ments. The present electrical generating capacity situated on Lake Michigan, * and using Lake water for cooling, is about 8000 MWe. Except for 75 HV.'e which comes from the Big Rock Nuclear Plant at Charlevoix, Michigan, all this power comes from coal- or oil-burning plants. Older fossil fuel plants such as these have an efficiency of about 30-35% (although fossil fuel plants built recently achieve about 40% efficiency) for converting heat into electrical energy. Of the 65-70% waste energy as it were, about 15% is lost up the stack. Thus, from the 8000 MWe from fossil fueled power generation, there is between 17,000 and 19,000 MH of waste heat produced, of which 13,000 to 15,000 Ml) is released to the condenser cooling water. The present type of nuclear power reactors have a conversion efficiency of about 33% (heat to electrical energy), and effectively (a few percent may be lost directly to the atmosphere in tha plant) all of the waste heat (67%) is released to water across the condenser system. Therefore, we see that for each unit of electricity actually generated (per kilowatt, for example), 20-35% more heat (50% more when compared to the most modern fossil plants) is discharged to cooling water from a nuclear plant than from a conventional fossil-fuel installation. It is also true that the present trend in power * 3000 megawatts electrical, a term describing generatini capacity. ------- 2132 plant construction is in terms of blocks of 500 to 1000 Mite per generating unit. This means that the heat released is concentrated in a localized area, and is somewhat more aggrevated in the case of nuclear plants because of the greater aqueous heat loss per unit of power produced as discussed above. In terms of heating of the entire Lake, the discharge from generating plants makes an insignificant input. Calculations show that if none of the heat from present power plants and those proposed through 1978 were to leave the .Lake over an annual cycle, the temperature increase would be a few hundredths of a degree centigrade throughout the entire Lake. Of course, such a situation does not exist in nature, as there is continual heat loss to the atmosphere by evaporation and non-evaporativs processes. It is also true that the discrete thermal discharges from power plants do not mix throughout the entire Lake, but are essentially localized entities of warm water. It is because of this phenomenon of relatively restricted volumes of warm water, present in one general location near shore, that raises questions about biological effects and other aspects relating to water quality. Except at times during fall and spring when the Lake is thermally mixed, the temperature is not uniform throughout the Lake. In suirmer, the mixed surface layer (which may extend down to depths of 60-70 feet) is anpreciably warmer (10-25°F) than the underlying waters. Conversely, in the winter, surface waters may actually be colder than those at greater depths. Further- more, there are variations in surface water temperatures over fairly short distances (less than a mile) and/or short time intervals (less than an hour). These variations are particularly evident near the shore, and are due to the upwelling of cooler water, warm surface water being blown onto the shore, and ------- 21 $3 5 other wind and current phenomena. These variations make the term ambient temperature somewhat ambiguous other than in a general or average sense. As mentioned earlier, there are already a number of generating plants situated on Lake Michigan which draw cooling water from the Lake and return the heated effluent to the Lake. Three of these begin to approximate the generating capacity and thermal discharge of the nuclear stations now under construction. These larger plants now in operation are Haukegan (1108 M'.-!e), Oak Creek (1670 MWe). and State Line (964 MWe). A feeling for the magnitude and the environmental effects of thermal discharges may be obtained by looking at and around these plants which have been in operation for a number of years. The initial impression is that these plants have not had a very profound, or obvious effect on the Lake, certainly not an adverse effect as annears to have been the case with some other discharges such as sewage and chsmical discharges. Determinations of the lateral extent and the depth of the warm water discharges (called thermal plumes in analogy to smoke plumes) have been made by infra-red over-flight techniques and by making direct temperature measurements in the water. A thermal discharge is wanner than ambient Lake water and tends to float because it is less dense, spreading out as it floats in a manner dictated by wind, current, and the velocity of the discharge it- self. The Lake thermal plumes studied are a few feet (6-8 maximum) thick and have temperatures which are measurable above ambient (about 1°C) out to a mile or so from the discharge point. The initial decrease in water temperature from the outfall to the measurable edge of the plume occurs primarily through mixing with the cooler water surrounding the plume, with some loss directly to the atmosphere as well. Over a matter of a day or so ------- 2184 the bulk of the heat is lost to the atmosphere. Other than providing a warmer region for swimming, and a more ice-free region of limited extent during the winter, and occasional periods of local fog, there are no obvious physical effects from the thermal discharge. Biological effects are equally hard to discern. Fish are noted to congregate near the outfall, particularly in winter-time, but increased algal bloods, differences (cr lack of) in bottom organisms and other indications of biological change have not been documented. Bottom organisms probably are not truly good indicators of the thermal situation because of the surface-floating character of the warm water. The fact that changes have not been documented in part implies they are difficult to see, or are slight if not non-existant. On the other hand, it must be said that not a great deal of research has been devoted to looking for thermally-induced changes. So we are faced with a situation in which obvious changes have not been observed, but secondary, more subtle, effects at some distance from the point of input may take place. Additional information as to possible thermal effects can be obtained from examining stream and river plumes in the Lake. The prime example as far as Lake Michigan is concerned is the Grand River vhich has an average flow of between 1500 and 7700 cfs depending upon the time of year. This compares with the flow rates of 3260 and 3500 cfs specified for the Ziori and Donald C. Cook plants, respectively. The Grand River is also warmer than the average surface temperature of the Lake, varying from 5°" above Lake surface temperature in March and Seotcniber to as much as 19°F in July. During part of the year the actual r^at carried irto the Lake by the Grand River in BTU/day, for example, closely approximates that which would bs ------- 2185 7 released from the largest nuclear plants now under construction on the Lake. From March through July the Grand River dumps between 200 and 340 billion BTU/day into the Lake, whereas if run at peak capacity for 24 hours a day the Donald C. Cook and Zion plants would discharge 390 and 340 billion BTU/day, respectively. It is interesting to observe that the Grand River is not generally thought of as a source of thermal pollution. Alternatives On the basis that adverse effects may be taking place now from the presence of thermal inputs or the mode of introduction, or that such chanqes may occur if the inputs increase, one must consider other means of disposing of waste heat. This can be done in several ways; through increased volume of cooling water, diffuser systems which increase mixing, cooling ponds, cooling towers, or combinations of these. It is also apparent that in the main, the summer months are the more critical time; hence, the time when more elaborate cooling measures should be taken. There is, of course, a further option open and that is to not site power plants or other heat sources along the Lake at all. This is a solution for future siting, but hardly helos in present circumstances. From a strict economic sense, direct cooling is least expensive in terms of initial investment and annual operating costs. It may, in fact, turn out in the end to be the most reasonable use of a natural resource, namely the Great Lakes. Each of the various alternatives will be considered in terms of their advantager, -nc1 disadvantages. 1. The condenser discharge could be mixed with additional water before* entering the Lake. This would serve to reduce the difference in temperature ------- 2136 between the plant discharge and the Lake itself; however, it would not reduce the total heat input to the Lake. Such a procedure involves the expenditure of energy in pumping, and the larger volume of relatively high velocity water might produce both physical and biological effects such as scouring of the Lake bottom, or influencing fish movements. The advantage would be that modifications to present facilities could be done at or near the Lake shore in most instances, and v/ould not require the use of additional land. 2. Diffuser systems. Multiple nozzle or aspirator systems will allow rapid mixing with cooler surrounding water, and when spray devices are used, direct heat loss by evaporation is achieved. Such systems will reores&nt sone expense, and the durability and maintenance of such devices has not been field tested on a large scale. I/here actual sprays are involved the water loss from the Lake system will increase due to evaporation. 3. Cooling ponds. These would require considerable land adjacent to the plant to be used for this purpose - approximately two acres per MV.'e is a rough figure for cooling pond size. The loss of water from evaporation would be comparable to or somewhat greater than if the heat were put directly into the Lake itself. Confined bodies of warm water such as this may become algal beds, and require attention to prevent their being a source of odors. The quality of cooling pond water will decrease with time as solids left behind by evaporation accumulate. 4. Cooling towers. Wet or dry cooling towers for oower plants in the 500-1000 ''!We range renresent a sizable capital investment. The Davis-Besse Plant in Ohio is spending $9,000,000 on cooling towers ""or a 872 MK'e facility. They will also consume power in their operation, and require nariodic maintenance, ------- Such towers are fairly large in size, both height and base area. Wet towers will be more wasteful of water in that they depend heavily upon evaporation for heat removal. Solids left behind in evaporation must be removed, as must slime and algal growths, usually by back-flushing into the Lake. Such a procedure will produce periodic inputs of concentrated chemicals into the Lake. The evaporation may lead to fog and icing under appropriate meteoro- logical conditions. Dry cooling towers do not waste water, but are limited in their cooling abilities by the ambient air temperature as cooling is done by exchange to the air passing over the cooling coils. Experience with dry towers is,limited to fairly small (200-300 MWe) installations. In seme locations, objections have been raised concerning the appearance of cooling towers and their effect on the landscape. Cornoi nations A combination of methods might prove most acceptable in the long run. Direct discharge except in wsrm seasons, when cooling towers could be used, is one possibility. This would also avoid the fog and ice problem during the winter months. A cooling pond-direct discharge is also in this category. It should be emphasized that from the standpoint of water conservation, direct discharge of heat in the Lake is most conservative of this resource. As demands for Lake water increase, the diversion of water for cooling towers and ponds may be regarded as an unacceptable use of water, Field Program to npterrnne^ Best Options Two things seem apparent: 1. That demonstrable physical and/or ------- 10 biological effects from present thermal discharges are hard to find on the Great Lakes or elsewhere. 2. There is a need for well-planned intensive and extensive field work to determine what effects, if any, do exist. It would also seem reasonable to not be overly restrictive on thermal discharges in light of present observations. In reality we will never know what reason- able thermal standards are until adequate field work is done, and to do this it will be necessary to have thermal discharges to study. Otherwise an unwise alternate, the consequences of which are, in fact, less clearly understood, may be chosen. There are environmental costs to be borne in any event, and what must be done is to minimize these costs in conjunction with their socio-economic impact. This should be the prime objective of regulation. There is a conservation principle involved here related to the conservation of energy principle. In fact, energy is the real culprit. Feasible methods of steam electrical generation ara inherently limited to maximum efficiencies of the order of 40-50%. This means that half or n^ore of the heat produced must be discarded, and the name of the game is to discard this heat in the manner least offensive to the environment or to use it beneficially in some manner. There is a feeling, based upon plenty of evidence to be sure, that whatever man does in terms of waste disposal is probably wrong. It is possible that in the case of heat, discharge to Lake Michigan is an appropriate, and acceptable use of a natural resource. It remains to be proven, however, and the natural caoacity of the Lake to receive and to eliminate heat must be determined. The source of support to do the necessary research is always a problem. But consider the manner in which monies are now being spent. For example, the Davis-Besse nuclear plant on Lake Erie is qoing to spend $9,000,000 on ------- 2139 11 cooling towers, plus operating and maintenance expenses annually. This exceeds the total amount spent annually on research in the Great Lakes which is at all relevant to the pollution question, and greatly exceeds the annual support of thermal research on the Great Lakes* The ooint is that more money could be reasonably spent to determine whether or not cooling towers are a) necessary, and b) desirable, rather than going ahead and building them without further consideration. The money involved could go a long way toward answering some of the uncertainties, without ir- reversibly harming the Lakes, and perhaps would even save expenditures in the long run. Lako Mi chinan PI an A suggested plan for determining thermal effects and thermal capacity is to allow present facilities, and those under construction, to operate, but to conduct sound scientific investigations of the environmental effects of such operation. At present, theory is inadequate to predict the con- sequences; only experiments v/ill do. This doss not mean a license to operate indefinitely in the face of evidence of deleterious effects. If such effects manifest themselves, corrective action must be taken. Such a procedure could be conducted under a Lake Michigan Environmental Agreement between the oublic (throunh their representatives) on the one hand and thermal dischargees on the other. The results of field investigations should be reviewed by a Commission composed of federal, state, and local representatives, in- dustrial representatives, and members of the concerned public such as ------- 2190 12 conservation groups, environmental committees and the like. If the findings indicate environmental change, the Coraiission must make a judg- ment as to its seriousness and recommend that corrective action be taken promptly, and may even recorrmend what corrective action be taken. The details of this approach must, of course, be worked out. The main point is, however, that some reasonable course be followed which does not blindly trade one environmental situation for another which is even worse. ------- 2191 TESTIMONY FOR T1I2 ILLINOIS POLLUTION CONTROL BOAIO Field Museum Chicago, September 25 and 26 Thermal Standards for Lake Michigan Charles Collinson Illinois State Geological Survey, Coordinator for Geological Research in Lake Michigan The Illinois State Geological Survey has long had an interest in. Lake Michigan, going back ir-ore than 75 years to the days of Levci'ett, whose works arc still standard descriptions for the lake region, and extending up through the tine of M. 1.1. Leighton and J. Karton L'rctz, whose works bring us up to the present day. The Lake researches 01 those years wore studies of the historical lake, however, and consisted mainly of descriptions of the physical aspects of the lake shores, the beach ridges, wave terraces and outlet drains. These studied have provided us with a knowledge of the history of the lake and v/ivn it a.i appreciation of the unique resource that the 13,000 year old glacial la'.ie represents. On the other hand, such studies did not produce the kir.c o- basic information our growing lakcshore population now requires. Last year, in exa:,:ining information sources about the living lake, our staff concluded that the lake- sediments have received scant attention as far as seuir.ientary and che.viical composition are concerned and th;.t time is running out for the gathering of data before the origin.;.! character of glacial Lake Michigan has been scriou<;iy degraded. Localized areas already are undergoing environmental changes—large populations of sludge-worms nourished oy organic nutrients disc.-.argec. iii'co the lake have bcon found in bottom sediments along the porin.ote.' of the iL.outhfiVi. half of the lake (A;djral 'u'ater Pol] ution Control Ad.i.ini^tratio.-i, 106o, Lake Michigan Uaiin Report, physical and chei.v-cul ------- 2192 2. quality conditions). In addition, surface water run-off, atmospheric fall-out and industrial discharges appear to have contributed significant amounts of chemical trace elements to the southern Lake Michigan Basin (Figure 1: Illinois State Geological Survey Environmental Geology Notes 30 and 32, 1S70). The overall result is that the oxygen demand of the southern Lake Michigan sediments is about three times that of Lake Huron, indicating considerable organic enrichment (Benton, 193S, Univ. Wisconsin, Milwaukee, Contribution No. 7). In response to the need for more information on these conditions, the State Geological Survey, in cooperation with Prof. Harry V. Leland of the University of Illinois Department of Civil Engineering, began an extensive examination of uncor.solidated sediments in the southern lake basin. Sampling was begun in mid-year 1959 from research vessels of the University of Michigan Great Lakes Research Division and "che Bureau of Commercial Fisheries. Lazer use was made of samples taken off Y/aukegan and Zion by Professors Mc'.V'hinnie and Murphy from BePaul University, samples furnished by the Federal Water Pollution Control Administration, and samples taken from a private vessel. The program has t\vo objectives. Dr. Leland and his associates in the University are determining the extent of atmospheric dispersal and surface water pollution in the lake and particularly that which can be measured in tanas of trace metal concentrations. In the analyticaJ chcmi::try laboratories oi the Gcolo/i~«j. ourvey this study has been cxtcr.dcci to include analyses for xho major elements and minor constituents: alu:.:i:u;m, silicon, iron, calcium, magnesium, potassium, sodix::.;, inorganic carbon, organic carbon., titamu:.., :.:ai:,.\inc:3o, mercury, phosphorus a:...! Sijlphur . Trac<.v e) i...,or.ts doi crr.ir.cd arc- boroa, bury 1 li;:..i, bvo,...;-.o, cadii.ii...i, cub.ilt, clii'oiaiiiiii, copper, lanthauui'i, nickel, load, sc.iadiu..i, ------- 2193 wise Wouregan 05 ,30 20 Z5 KILOMETERS J Q -J I '- Pi£. 1 - Vopc~rj-i3hy of tho Ir.'.re fleer, soutr.crn Lake :achi^an. Contour-s ropro depth in i"cet boiov ;:.ca,i low-v-a-tor- l^vol (5'/6.8 feet). Contourir.^ is based en U.S. /ov.y Corp.-, of ^rcir.car^ L:.J:o Survey District churts. Takcp. fron i-'i^. 2, l.S.G.S. ;.:iv.'.:'o:i. Coo] . :;otu No. 30. ------- 2194 var.adiuia, zinc, arsenic and mercury. In. the clay analysis laboratories, the sample fraction of less than a micron size clay and the clay mineral composition are determined. Already one report, Illinois State Geological Survey Environmental Geology Note 32, has been produced on distribution of chemical constituents in the lake iloor sediments. Little has been known of the extent of accumulation of in- organic elements in the lake floor sediments, especially so for the toxic metals: lead, copper, chromium, cadmium, arsenic and mercury. This is where our chemical studies boar directly on the problem of standards for thermal input into Lake Michigan. These early stages of chemical research have shown (I.G.S. Environmental Geology Note 32, 1970) that lead, bromine, zir.e, nickel, arsenic, mercury and chromium have accumulated and probably are still accumulating in the upper few centimeters of lake floor sediments. Concentrations, which reach levels ranging from 10 to more than 90 parts per million, correlate directly with the organic carbon content of the sedi- ments and somewhat less directly with the less than 2 micron size clay fraction in the sediment (Figure 2) . T.-.is fraction constitutes as much as 50'7o. of the sediment in some areas of the lake floor. Thus it appears that sediments with high organic content in time will also be high in toxic metals. Although it is speculative at this stage, because v.e do not '.'.::o;: the source of the organic matter, the point to be made- in this respect is that local increases in productivity of algae and ether plankton duo to local temperature •..".creases could possibly cau.,o co.icon- ir^tior... oi' partJculatc organic c.-r-jon th.. , might fix sig; ificn/.t U:..,V.:,V-L-; o..' iG.x-c v.-li . ..;::tt,. V.-.c-rc tk<_-L;«j ooou;' -.'. tl.o :;naiiov; \;a i.ort, o^" the l^ko, "i.i'iuy could '.o oi' t,x.nou.y concern. ------- 2195 c C" -s tr Z o cr \ \ \ ------- 2196 Additionally, inasmuch as we do not know the procedures whereby the metals beco.v.e fixed by the scdirr.er.ts, we should closely follow any changes in the lake that might significantly increase the bioniass and should study in detail the conditions existing before any thermal or other input is considered and then continuously r.cr.itor the area for signs of significant changes in water quality, plant ar.d ar.irral communities, and sediment composition. Coequal with the geochcr.dcal studies of the Survey has btsn a coupreher.oive program for napping sediments of the lake fleer and describing the stratigraphic sequence, composition and thickness of sediments under the lake (Figures 3,4). The cores, which range fro:. 3 to 20 feet in length, penetrate the soft lacustrine clays, sands an>a silts and occasionally encounter the underlying glacial till that occurs over most of the southern lake basin. These studies have provided great quantities of new data and unexpected discoveries. For exa-pie, the lacustrine units are of special interest in that their water center.: ranges betv/een 90 and 2007o of dry weight (Figure 5). In addition, they are thixotropic, that is without bearing strength when disturbsc, but otherwise appearing solid. These sediments range up to 30 or -10 feet in thickness and cover :nore than a thousand square rr.ilcs of la::a floor. Their mineralogy, chemistry, age and stratigraphy are only no-.; being- detailed. Their role, if any, as reservoirs of sublake water should ~u taken into account in any lake water or heat budget. In brief, the main impression gained fro:.! our st-c.lc-s is -..:at there is a very serious absence o.J basic .icicntific data abo'.t Lake Michigan, vl.at uuat be gathered if ve aru to effectively r.ch^.vc- ar.d )..a^.ntain the good healtn ar.d co/.'cii.ac.c; u.-r.oJalnc-JS o^ ~ho la.:^. ------- 2197 H a '.I o°'i Woukcqon o j:; • .;. • •;:::•; Sheboygan South Hoven , -J \| — _. Carm: <-• i— ' , , LJ • —-r—- - I i i. Scnc on beeches Soft, dork grey to brown scr.o/ s..t to sand, end gravel Dark groy silty clay v/ith bicck ieds cr- mottling; more compact tn", V.coke Wcmoer Dcrk brownish gray day; c few and sorne biack mottling Reddish brown clay Wilrnsite Sec • DcrK groy clcy v/ifh sorr-.e o ::••. ^ea; Reddish brown cloy Reddish grey cloy Sond, scndy pebbly c!cy, s..r, c.ic Pvjbble conglomerore u;.a ,1-lyin.s .,C'UU:iCi\i '^a.ic ;-:j..\..: .".. ------- 2198 a,.,. 4 ^ O o o ------- 2199 GRAIN SIZE (%) CLAY MINERALS (Relotive o&unaonce based on diffraction effects) CALCITE/OOLOMlTE RATIO NONCLAY MINERALS s % g B E ii 100 ISO IOOJO O20JO4O10607O8O5OIOO 1056 76 1 A3 2 ?ig. 5 - Grain size and mineralogy of core 145. Taken from Fig. 4, I.S.G.S. Environ. Gool. Noto No. 30. ------- Surface sediments on the bottom of Lake Michigan 2200 v,V."'^V~ ."• r'r\ ^ \ \ LAKE • • V \ \ \ \ FCR.-IST . Aj \ \ \ \ : ^ \\\ \ V. \ \ \ \ - 4 , - \ \ -• V \.^ Vx • L.X-'. ' ^ \ \ ~\ V s /' \ fj . ' * \-:\'J b.f FALO ------- 2201 5. "Here arc our specific views on thermal input standards for the lake: We have reservations about the effectiveness and correctness of any blanket temperature standard that mieht be imposed at the present time. Among other things, lake water, temperature, current velocity and direction, turbulence, wind force and direction, as well as the wind exposure of the facilities, rainfall, lake depth, bottom, topography, bottom sediments and the biota are all elements that will control the effect of thermal input and distribution. Because of the large number of these seasonal, daily, even hourly variables, which are different for each input site, each site should be considered and controlled as a separate entity. If input to the lake is allowed, then we recommend that each site be thoroughly studied before construction and closely monitored thereafter, not only for temperature levels, but for effect on.the various components of the lakes. Various scientific, governmental and private organizations could combine to accomplish such studies much as is now being done in the Waukegan-Zion area. In final analysis, however, our knowledge of the lake is still so small and the value of the lake resource so valuable in terms of its use for hundreds of future years, we would welcome the exclusion of input of any kind to the lake that does not equal or exceed the optimum conditions now existing in the lake. ------- 2202 TESTIMONY OF JOHN D. HARPER, DIRECTOR ENVIRONMENTAL PARAMETERS RESEARCH ORGANIZATION SUBMITTED TO LAKE MICHIGAN ENFORCEMENT CONFERENCE WORKSHOP CHICAGO, ILLINOIS SEPTEMBER 28 THROUGH OCTOBER 2, 1970 FOR INCORPORATION INTO THE RECORD PREVIOUSLY SUBMITTED TO ILLINOIS POLLUTION CONTROL BOARD SEPTEMBER 25, 1970 ------- 2203 TESTIMONY OF JOHN D. HARPER BEFORE THE ILLINOIS POLLUTION CONTROL BOARD FIELD MUSEUM CHICAGO, ILLINOIS SEPTEMBER 25 AND 26, 1970 Mr. Chairman, Members of the Board, Ladies and Gentlemen: My name is John D. Harper. I reside in Hanover Tov/nship, Cook County, Illinois. My education and training is in engineering, both civil ond mechanical. I am a Director of a non-profit Illinois foundation known as Environmental Parameters Research Organization, or by its acronym, EPRO. EPRO's chief function is the scientific investigation of problem areas in our society. EPRO is funded by private contributions and foundation grants and derives no part of its income from vested interests, either pro or con, on the subject matter under investigation. For example, the EPRO program for an ecological study of Lake Michigan's western shore between Waukegan and Kenosha is not funded in any part by either the power companies or governmental, federal, state or local, regulatory agencies. In a publication entitled, Water Pollution Problems of Lake Michigan and Tributaries, January, 1968, issued by the Department of Interior, FWPCA, Great Lakes Region, a recommendation was made on page 66 as follows: "14. A special investigation be made of the effects which the installation of large power plants, both fossil-fueled and nuclear, have on Lake Michigan; this investigation to include studies of benthic fauna, radioactivity, water temperature, heat diffusion and lake currents.!l At the four state conference on pollution of Lake Michigan and its tributary basin held January 31 through February 7, 1968, the conferees recommended the formation of a ------- -2- special committee on nuclear discharges and thermal pollution aspects of nuclear power reactors. This committee, chaired by F.W. Kittrell, did its work and reported to the second session of the four state conference on February 25, 1969, with several recommendations, two of which I would like to point out at this time: "6. FWPCA coordinate a comprehensive study of the effects on water quality and aquatic life of thermal wastes from a large nuclear power plant on Lake Michigan, with attention to various methods of cooling water dispersion. 7. FWPCA coordinate a study of the effects on water quality and uses of radioactive wastes from a large nuclear power plant on Lake Michigan, with especial attention to the concentration of radionuclides in aquatic life." In the fall of 1969 I inquired of the then FWPCA, now FWQA, what action was intended commensurate with the recommendations of the Kittrell committee. It was my understanding that because of budgetary considerations, the recommendations to study the pre-operational ond post-operational site of a nuclear power generating facility could not be undertaken to the extent recommended by Kittrell's committee. Recognizing that it would be imperative to have data obtained in-situ upon which to evaluate the impact of a nuclear power generating facility on the local environment, several scientists and other individuals including myself formed a group to initiate and conduct a multiparameter ecological study of the western shore of Lake Michigan centering about Zion, Illinois. In the publication, Physical and Ecological Effects of Waste Heat on Lake Michigan, issued by the U.S. Department of Interior, Fish and Wildlife Service, September, 1970, it is stated on page one: ------- 2205 -3- "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 needed now; since it is not available, however, interim standards must be set for Lake Michigan on the basis of existing knowledge." On page 91 of the same report the concluding recommendation ?s: "11. On the basis of the above points, it is concluded for ecological reasons that no significant discharge of waste heat into Lake Michigan should be permitted." I agree with these two statements as I do with most of the material presented in the report. As is so often the case, when decisions must be made effecting the utilization of any of the • Great Lakes, be it Lake Michigan, Lakes Huron, Superior, Erie or Ontario, the decisions are based upon little, if any, knowledge that we possess of these lakes concerning their biological, chemical, physical, geological and meteorological characteristics. The scientific research activities in the Great Lakes, and now let us confine ourselves to Lake Michigan, have been minimal in the last three or four decades and practically non-existent before that. Some educational institutions bordering Lake Michigan namely University of Michigan, University of Wisconsin at Madison and at its Milwaukee campus, and DePaul University in Chicago, have recognized that in depth multiparameter scientific studies of Lake Michigan are imperative if answers are to be found for the many questions confronting us today. One of the major reasons why research in Lake Michigan and the other Great Lakes is so far behind similar oceanographic research in the saiine waters in the Atlantic, Pacific and other oceans of the world is the unique fact that the Great Lakes have no military application. ------- -4- 2206 No submarines are permitted to operate in the Great Lakes by treaty with our neighbor to the north. Those submarines that are in the Great Lakes have their propellers removed and are strictly for training purposes in the former Corn Belt Fleet of the U.S. Naval Reserve. Now it may seem odd that the lack of military application to the Great Lakes would be a factor in our present limited knowledge of these bodies of water, but when you realize that a great preponderance of the data collected in saline waters is to determine the conductivity and temperature of the water for the express purpose of plotting the transmission and propagation of underwater sound waves which in turn has a great bearing on underwater military capabilities, it becomes obvious that with no need for this data in the Great Lakes because of the absence of submarines, the basic data we need, along with all the attendant biological, chemical and physical data that is simultaneously obtained, is lacking. Now there have been scientific cruises on Lake Michigan conducted by the University of Michigan on their ships and conducted by the University of Wisconsin on ships of convenience, usually the Ludington car ferries. DePaul University has availed itself of the opportunity of using a research vessel that is operated by EPRO for the purposes of graduate instruction in the aquatic sciences and for biological research and surveys of existing pelagic and benthic life. In the context of a complete over-all picture of Lake Michigan, it is necessary, it is imperative, that research activities in the lake be conducted continuously throughout the year at innumerable vertical and horizontal stations. This one shot, one observation approach as has been conducted by so many of us can be disasterious if as we find, extrapolations are made on the data presented involving a host of complex issues such as that which is before this Board today. I would liken the data from the present state of Lake Michigan research, if I may, to information sent by the wife here in Chicago of a Gl in Viet Nam who has written that the temperature was 92 degrees in Chicago in mid-September, ------- -5- 1970. The Gl's buddy may have received a letter from his family also in Chicago a few days prior or later that indicated the temperature was 47 degrees. The picture they have so far removed from the scene, as far removed from the conditions in the lake as we are now, seem vastly different and would be confusing. While the data that has been collected to date is of extreme value, it is all we have; and it is necessary to obtain considerably more before the momentous decisions effecting regulatory agencies, such as this Board, can be enacted with the degree of certitude so necessary on such complex issues. The major reason there is a dearth of information about the lakes is that funding sources are practically non-existent. The Sea Grant Universities of the University of Michigan and University of Wisconsin have some small funds that can be earmarked for activities in the lake. Other universities, including DePaul, that have evidenced interest are hampered by budgetary considerations that preclude a viable effort in the lake. If no funds are going to be available, which has been the case to date, then we shall continue to be ignorant of the many complexities that we should bs aware of when decisions effecting all of us, such as the siting of once through cooling water power plants, must be made. I respectfully urge the Board to do everything in its power to make available the means whereby institutions desiring to conduct studies of Lake Michigan are adequately funded. Some regulatory agencies occasionally engage in water and bottom sampling for the purpose of determining existing criteria as it relates to their operations. This is to be commended and encouraged, and it is hoped the data that is obtained is made available to all wishing to utilize it. One factor that influences the frequency of sampling is the capabilities of the watercraft the agency utilizes to take the samples. Lake Michigan, as you gentlemen are well aware of, is moody and reacts quickly to changing meteorological conditions. ------- 2208 -6- It is often said by the foreign flag seamen that they prefer the North Atlantic to our Great Lakes at their worst. The combination of storms and squalls can impart heavy damage on shore-site facilities, underwater construction and ships and boats on station in the lake. Very seldom can a 16 ft. outboard be used in Lake Michigan as it could in the Des Plaines River for limnological studies. Even a 30 footer in the lake must take all precautions because of the rough sea situation that can occur. EPRO employs a 54 ft. steel hulled vessel and will have in operation next year a 100 ft. research vessel for the purpose of greater capability in the lake on a more consistent basis. The ship time operating cost on the lakes for research purposes approximates that in dollar value of those research or oceanographic vessels operating on the oceans. For those agencies that are oriented along the lines of a 16 ft. outboard doing all the work for them, this can be quite shocking. To conclude now, gentlemen, I would like to emphasize that considerable additional research is needed in Lake Michigan now and that the funding to conduct this research must be obtained if the questions we are being asked today about the eutrophication of the lake are to be intelligently answered so that we may wisely utilize and preserve this great natural resource . The position of myself and the organization I represent is that at the present we do not have enough knowledge on what impact the introduction of heated cooling water from nuclear or fossil-fueled plants will have on the lake's biota and chemical and physical characteristics. Without sufficient data upon which to base an educated appraisal of the situation, I suggest ihat a Moratorium, voluntarily accepted by the power companies and the regulatory agencies, be immediately established on once through cooling water power plants, be they nuclear or fossil fueled. It should be agreed between the pcrties that those generating stations now ------- 2209 -7- nearing completion or completed employing the once through cooling water system should be permitted to operate contingent upon the establishment of provisions to modify deleterious effects if they become evident, that application for construction of once through cooling water type plants be suspended and/or modified to comply with future regulations to be promulgated after the investigations of existing once through cooling water facilities are fully known. This Moratorium on future once through cooling water type electrical power generating stations should satisfy reasonable men that all efforts are being made to serve society with both ecological and economic consideration. ------- TESTIMONY 2210 HEARING ON PROPOSED THERMAL STANDARDS FOR LAKE MICHIGAN ILLINOIS POLLUTION CONTROL BOARD Chicago, Illinois 25, 26, September 1970 Mr. Richard J. Kissel, Hearing Officer I am Mary Alice McWhinnie, professor in the Department of Biological Sciences at De Paul University in Chicago, and Director of the De Paul-EPRO Ecological Study of Lake Michigan. My credentials for speaking to this Board relates to my professional experience in crustacean biology in study of effects of temperature changes on invertebrate animals in fresh water and Antarctic marine water, and to the work we are engaged in on Lake Michigan. Mr. Chairman. I am pleased to respond to the need for infor- mation on the complex topic of the ecological influences of industrial use of water resources in general, and Lake Michigan in particular. I believe that the need is high, first because of the long term plar.s which call for the use of lake water by the rapidly expanding devel- opment of nuclear powered electric generating stations, and second, because of the unprecedented concern for environmental quality. The plans for the future are increasingly well known but, for co- herence of presentation I shall briefly restate them here. In an AEC report of June, 1970 it was stated that: 16 nuclear plants were operable at that time, producing, 5,073,700 !-"• 54 were in construction, to produce, 43,755,90C ;~. 34 were planned, to produce, 32,591,OCC I-~ 8 were in earlier stages of planning, to produce, 7,539,000 }7. giving a total of 113 plants within the U.S., to reach an expected production of , 89,010,6^ C }7. 100 of these are in the eastern one-half of our country ar.d ------- 2211 all are expected to be in operation by 1978. As of September, 1970 a longer term projection was published by the U.S. Department of the Interior under the colloquial term of a 'white paper1, wherein the predictions were confined to Lake Michigan. The values cited there were derived principally from a report by Acres (1970) and represent the sum of both 'fossil-fuel plants and nuclear powered plants. It is realistic to treat the two types of plants together since heat, the topic of these hearings, is a common by-product of any electric generating station. Briefly, assuming, a) no change in stations planned; b) no change or improvement in technology throughout that time; c) no increased efficiency in energy production or utilization between 1968 and 2000, the growth in electric power production and heat loss have been estimated to be: 1968 2000 Increase Kilowatts (at 7,600,000 73^500,000 9.6 fold full capacity) Energy loss as 29.85 414.67 13.8 fold heat (billions, BTU's/hr.) Other sources of heat addition to Lake Michigan are negligible in contrast. However, whatever its source, the question we are asking is, "what are the ecological consequences of heat addition to Lake Michigan, and what are our alternatives concerning policy and standards"? It has been recorded in many places that the present state of knowledge on the environment and the complex interdigitation of physical, climatic, chemical and biotic characteristics is too poorly under- stood to state, with certitude, what the effect of thermal additions will be on the ecosystem and that only a thorough ecological study of an area to be influences, will provide the information essential to knowing whether such technological developments can be borne by the ------- 2212 environment. Alternate views hold that in.'terms of the possible effect of such heat additions (based on the projected growth), caution directs that an upper limit on thermal increment be set or, that no increment should be allowed. These views have taken the form of three proposals which, in general, state that use of natural water shall not increase its' temperature, more than • 5 F (or 3 F) above 'natural ambient1 terr.p- erature; it shall not exceed S5°F (29.4 C) or, it shall not exceed 37°F (2.8°C) to 77°F (25°C) depending upon the season, or, that heat at any level shall not be added to a natural body of v/ater. I have at least a limited appreciation of the need for, and the responsibility of, regulatory policies to protect our environment. However, within the context of existing data I do not believe that we are in a position to justify a fixed value, such as these are, as a consequence of the variables with which we are faced. I am aware of the fact that such a statement as this provides no support or assistance to policy making bodies; I appreciate that a degree of risk prevails when delays are encouraged in the interest of establish- ing securities against environmental deterioration. I ain further aware of the most difficult of truths relative to seeking 'best estimates' concerning the development of policies; namely, that one who is concerned about thermal dangers can cite published scientific data which indicate that certain selected species of organisms have been shown in laboratory study (or field) to have upper lethal temp- erature values which will be reached with waste heat addition; contrariwise, others recognize such a possibility but take a more moderate view, and can also cite publi: hed scientific data which show that certain selected species are taken to their biological optimum when provided a warmer environment. Each is right, each is honest, each is scientific and each is supporting his views to the best of ------- 2213 existing knowledge; they differ in their intuitive sense and their disparity reflects the presently unacceptable reality that we do not have definitive information which will provide the solid plat- form of knowledge upon which reasonable and realistic policies should be based. In this context I should like to present some data which of necessity y$ selected, but that which will hopefully place in balance the perspective of persons who have the responsibility to deal with this problem. The following unpublished temperature data have been derived from Lake Michigan in the vicinity of Waukegan and Zion, Illinois during the summer of 1970: Vertical Water Temperatures (6 July 1970) CDT Waukegan Sta.S 52 (0945) 16.5°(61.4°F) 16.4 15.5 15.4 15.3 15.0 Vertical Water Zion Sta.£ 1 (1115) 16.3° 16.2 16.0 15.5 14. 8 14.5 Temperatures (30 Sta.= 7 (1530) 17.0°(62.'6°?) 17.1 16.4 15.9 14.5 12.9 June 1970) (132 Waukeaan Sta. if 50 17.2 15.6 15.3 14.0 Sta.i 51 16.7 16.0 14. 8 14.6 14.0 11.2 Sta.£ 52 16.7 16.5 15.8 14.6 14.4 14.3 Sta. 2 53 18.2 15.1 14.3 14.2 14.0 Sta.= 55 19.4 16.2. 14.0 13.5 13.2 13.1 ------- Waukegan Sta.£ 51 20.2 20.0 19.4 18.9 17.4 15.2 Sta.S 52 20.9 20.9 19.4 19.2 16.5 14.0 Sta.# 53 21.0 21.0 23.0 19.4 18.6 2214 Vertical Water Temperatures (24 Aug. 1970) Waukegan ta.a 50 Sta.S 51 Sta.g 52 Sta.jt 53 Sta.S 54 Sta.3 55 21.3 20.2 20.9 21.0 21.2 21.6 20.6 20.0 20.9 21.0 21.2 21.6 22.2 20.8 21.2 19.8 20.0 18.4 18.4 16.4 15.6 These values have been given to indicate that: - a policy limiting thermal incremontc u_> less thafy, "a 1-degree Fahrenheit rise over natural water temperatures at the point of dis- charge" , caTinot in my opinion be achieved since, in practice, most, ifhot all, uses of water result in some thermal increment, if for no other reason, residence within the facility using the water; - a policy limiting thermal increments to + 3°F (1.6 C) or •f5 F (2.8 C) must also qualify under what solar heat input level, or at what tine of day?, or at what point in space .(and 'I understand 'at the outfall1)?,.and under what current (and wind) conditions? a policy limiting a thermal increment to a mixing zone whose length or radius is 5280 Ft. or less does not reckon with currents and/or wind action; there are some data which suggest that under certain wind conditions a 'tongue1 of warmed water may extend 2-3 miles in what is apparently a narrow band along a shoreline current; this will in all probability apply to any body of water warmed by any means. At this point I am concerned that these points can lead to the notion that, "about nothing can we be sure", and further, that due to the complexity of physical factors we cannot reach a realistic and practica-ble standard with respect to thermal modification of the aquatic environment. While there is some truth to this I dofnot see ------- 2215 the disabling objections to be unsurir.ountable. I do see them to be significant in their call for study and, in their call for a reluctance to specify a numerical limit with respect to any environmental para- meter with our present state of understanding, in particular, " x°F " or, " x ft. " for a mixing zone. It can be legitimately asked, how can a biologist view that which is more widely held as an environmental threat, with such seeming insensitivity? In answer, may I offer: - I do have reasonable concern for thermal increments in the aquatic environment; - I do recognize that the environment has a finite "carrying capacity" for chemical and physical additions or variations; I am in full agreement with Sorce (1969) that while a hear dissipating source may raise the temperature of a receiving body of water only a few degrees within a limited area frcrr. the discharge canal, an accumulation of heated effluent frcr. many sources could prove disasterous over many r.iies. Thus, the projected increase in number of sources using Lake Michigan water in the next 30 years could prove to be ecologically critical. The limit of heated effluer.-s which an ecosystem can endure without adversely altering ics biological balance can only be determined by a total ecoicgical study of an area. - I do recognize that biotic communities respond differentially to variations in physical or chemical qualities in -heir environment. This notion has been fundamental ro the principle of succession as evidenced in ecological systems; seme ds-a I have presented for fish can be cited again, Fish Species Temperature Preference Carp 32°C (89.6°F) (Cyprinus carpio) Perch 24 C (75.2°F) (Pc^rcji f lave scons) White Fish 13°C (55.4°F) (Coregonus cluooaformis) I am aware of the direct effect of temperature on natural phenomena and thus on biological systems; I recognize that temperature increases are often employed to increase biological actjvity. ------- 2216 I am convinced that while highly controlled laboratory physiological studies on particular plants,animals and microorganisms have contributed significantly to cur understanding, that we cannot extrapolate these findings directly to the natural environment; these tv;o approaches complement each other, — they are not a substitute for each other. With these and other considerations I should like to cite sorr.e data which bear on this subject. In a study of benthic fresh water protozoa, Cairns (1969) has reported that small gradual increases in temperature have no effect on the protozoan community of the Savannah and Potamac Rivers; this conclusion prevails after 9 years of a study still underway. The temperature increase was downstream of a heated water discharge ar.d the water temperature was "a few C over ambient". On the other hand Cairns had previously shown (1968) that a sudden temperature shock caused major changes in the number of species present. The differences between 'chronic' and 'acute1 temperature changes are well known and apply generally to all species of organisms. In the 1969 study a temperature shift of 20°C to 35°C (ca. 95°F) within 10 minutes and sustained for 6 days showed an increase in protozoan species on the sixth day after an immediate decline from 26 to 7 species apparently surviving. In another- similar experiment where the experimental temperature was shifted abruptly from 21°C (69.8°F) to 31°C (87.8°F) the number of species fell from 34 to 21 and within 32 hours had returned to the initial value though the temperature regime lasted three days. Shock effects such as these are not likely to occur in nature and thus the effect on species diversity would also be less. In any case these data indicate no effect on a protozoan community. ------- 2217 At an earlier time (1956) this author showed that different terr.p- erature levels did influence the relative predominance of algal groups, e.g., diatoms were the predominant types at 20°C (63 F) o o and below; green algae were predominant at ca. 33 C (91.4 F) while blue green algae developed maximally at 40°C (104 F) ; this pher.oner.cn has been called competitive exclusion and relates to the earlier reference I made to succession of biotic communities as enviror.-er.zai conditions shift in any aspect. Benthic marine molluscs (mussels) and fishes were shown to be more .sensitive to temperature increases (Pearce, 1969) and, while the commercial mussels had somewhat different tolerances to ter.p- erature depending upon their point of origin (intertidal or lirtoral) o n at 24 C (75.2 F) abnormalities appeared (attachment, clustering, ezc.). However, their southward range was a region of 26.7 C (ca. 73.5 F) indicating perhaps tolerances developed in larval life not capable of adjustment in adult life. In this same study starfish ar.d snail o o feeding activity declined at temperatures above 20 C (63 F). Nauman and Cory (1969) studied benthic animals by way of test panels placed at the intake and outfall of the Chalk Point, Md. fossil-fuel plant in the Patuxent River. The temperature difference be-ween intake and outfall was approximately 6.3°C (ca. 11.5 F). Ccr.p arisen of the animal populations showed a 3-fold increase in biomass at the outfall relative to the intake with little or no change in species composition between the two. The epifauna represented considerable diversity including some 25 species from 8 major animal groups (including nemertean worms, flntworms, annelid worms, arr.phipods, bryozoans, anemones, clams, protochordatos, and a variety of crustaceans). The temperature range of the effluent, seasonally, varied from ca. 10°C (50°F) to 37°C (98.G°F) arid production '..-as ------- 221S based on dry weight. Species diversity, a ratio of number of species present to the total number of individuals present, did differ between the two points and was generally higher at the outfall. Some species disappeared at the effluent at certain seasons but were found in abundance just outside of the effluent canal (thermal preference/ gradient). An increase in size of barnacles occurred at the outfall and higher production occurred there even with fewer species present (ca. 3-fold greater than at the intake). Summarily, in the epifaunal community there were differences in species number (more, though some species disappeared at certain months), total number (more), biornass production (more),and species size (greater) as a consequence of a thermal increment. During the warmest months (July, August) fewer species were present at the outfall. Barnett and Hardy (1969) in a summary report of marine ber.zhic clams (Tellina tenuis) studied a coastal environment (Scotland) for four years before a heated discharge appeared in the environment ar.d for five years after. They report that there were large seasonal fluctuations in Tellina but that none of the changes were attributable no warm water effects. Conversely, Tellina grew more rapidly in the post-effluent years with the greatest difference being in young stages /L. ^Y^'^^O^X^o and there was no evidence oftne spawning characteristics between, the two studies (pre-, and post-). Kowever, the snail Xassarius rericulatus while not different in population density, showed thinner shells than others in the species range which were not influenced by the thermal increment. Advanced breeding and egg hatching occurred for a species cf snail, 'a copepod and amphipod in the vicinity of the thermal i:is- charge. These species are irrtertidal; no effects were observed in sub-tidal bottom communities. ------- 2219 The scientific literature is available for anyone to obtain examples of this kind. As I noted earlier, scientists have, and probably will continue to present, examples that place emphasis on various aspects of biotic responses to changes in environmental temperature. Despite this, regulatory agencies are unable to set realistic and meaningful limits concerning the use of natural water resources for excess thermal discharges, —- because we lack an understanding of the carrying capacity of them. As time passes and more uses are planned for water sources we must cease to be in this position and, in my judgement, only hard data will make that possible. Literature CjLted (in sequence presented) U.S. AEC News Release, Vol. 1 June, 1970 U.S. Dept. of Interior, Fish and Wild Life Service (September, 1970) Physical and Ecological Effects of Waste Heat on Lake Michigan Acres, H. G., Lts. 1970 Thermal inputs to the Great Lakes 1968-2000. Inland Waters Branch, Department of Energy, Mines, and Reservoirs Canada Centre for Inland Waters. Niagra Falls, Ontario. Unpublished Data, from De Paul-EPRO Project: Ecological Study of Lake Michigan. (Data available from the Director) Sorge, E.V. 1969 The status of thermal discharges east to the Mississippi River. Chesapeake Sci. 10:131-138. Cairns, J., Jr. 1969 The response of freshwater protozoan commun- ities to heated waste waters. Chesapeake Sci. 10_:171-lc5. Cairns, J., Jr. 1968 Rate of species diversity restoration follow- ing stress in protozoan communities. Univ. Kansas Sci. Bull. _£:': 209-224. Cairns, J., Jr. 1956 Effects of increased temperature on aquatic organisms. Indust. Waster. .1:150-152. Pearce, J.B. 1969 Thermal addition and the benthos, Cape Cod Canal. Chesapeake Sci. X£:227-233. Nauman, J. W., and R. L. Cory 1969 Thermal additions and epifaun:! organisms at Chalk Point, Maryland. Chesapeake Sci. XO : 2LS--21 i . Barnett, P.R.O., and B.L.S. Hardy 1969 The effects of tempcratur ; on the benthos near the Hunt orston generating station, ficotlr...c. Chesapeake ScJ. 30:255-256. ------- 2220 M« A McWhinnie MR. STEIN: Thank you, Professor McWhinnie. (Applause) Are there any comments or questions? MR8 JETTERQLF: Tes. Dr. McWhinnie, I believe you are speaking strictly as a scientist who has been working in plume areas, and lest there be any doubt, could you cite some of the sources of the funds, the money that enables you to do this work? DR. McWHINNIE: There is a moment every day when I grow facetious and I never know when it is going to hit. But let me say that a year ago, the Environmental Parameters Research Organization was founded and incorporated within the State of Illinois as a not-for-profit organization about which I knew almost nothing. Only later did I come to know about it. And I learned that its director and founder did, in fact, on his own obtain from a proprietary interest of his funds that would go into this non-proprietary organiza- tion. Perhaps like any power company or any other such group, he reached out to try and find scientists who might have a commitment to the environment, and thus he did come upon some of us, and the program was worked on through last winter and it was initiated in the field last springs But the funds were rather limited, and I regret ------- 2221 M. A. McWhinnie to say that in my own inimitable fashion I went screaming to the president of the university and said, "I have to have money.1* And, as everyone here would know, if you don't request it a year ahead of time, and if you don't get it written into the budget, there isn't any. But somehow in his own commitment, which was demonstrated when, as chairman of the department of biologi- cal sciences in the early sixties, he held the first privately sponsored water pollution conference in Illinois — and I am delighted to say that Mr. Murray Stein was its luncheon speaker in 1962 — I am not sure he remembers — but, in any case, that man is now president and he brightened my life and gave me a little money and we are once again at the edge of those funds. I have two choices. Let us not be so foolish as to think that those of us who undertake such a project as this are not attracted to those upon whom the press of information is the greatest. You call them power companies. Yes indeed, ladies and gentlemen, they have attempted in, I believe, their own motivation to finance this; they have tried to give us money. I am grateful for a typewriter and a carbon copy. For anyone present, we can demonstrate that in a state of destitution we had the guts to say, "I am sorry <> I can't take your money." ------- 2222 M. A. McWhinnie And, as the president said to me recently when I said, "You know, I have these people on the payroll and I don't have any money." He said, "We will try and find it someplace." How unfair is an American public that demands that the burden of proof is on the user, and they deny the scientist the right to use those moneys? But this is where we have been put and given an infinite commitment to the objective reality of truth, I should say, "By God, we will do it." And I don't know where the money will come from. MR. STEIN: Do you have any other questions? Miss McWhinnie, I appreciate your statement, but let's go over some of your points here. As you know I am a lawyer. I know I have met many old friends among the legal profession attending during this week, as well as a lot of new ones. As lawyers always do we have listened to the jargon of the scientists and I have no quarrel with it; I appreciate it. I think your paper is couched in those terms. But when you talk about the discussion and use terms such as "testimony," "witness," "cross examination" — and I think I have allowed questioning to approach that because it seems that is what the people want to do inasmuch as in the profession that is the way they conduct their business — I think you have to recognize that we were ------- 2223 M. A. McWhinnie employing the jargon of the lawyers and that is how we do our business. This was in no way a trial. This was a workshop and a discussion. However, the participants in this workshop were lawyers — lawyers by long training and by long experience. They didn't shed their personalities when they came in here as the scientists didn't shed theirs, and we have to expect that. So I think in that sense those terms got into this, but no testimony was given under oath. We permitted the witnesses latitude in question. We didn't require proper foundation or we didn't require the technical rules of evidence. I really do think that we all understood the rules under which we were working here. So I wouldn't place too much credence on this. I think we have an amalgam here of both the legal jargon and argot and the scientific jargon. I have no preference for either, but I think everyone has to do his own thing and say it his own way if we are going to try to achieve an accommodation in these matters. DR. McWHINNIE: May I — MR. STEIN: Yes. DR. McWHINNIE: I would only caution that we do not drive the wedge against the credibility of scientists ------- 2224 M. A. McWhinnie across this land. Today did we not hear a Representative use an expression "paid mercenary experts"? This has deep impact, MR, STEIN: Professor McWhinnie, if you are sensitive to that — and I appreciate you might be — we lawyers get called that all of the time and this is, I think, a price you pay, DR, McWHINNIE: That is the price I would not pay 'when, in fact, funds might have been available to carry on a study that this Agency needs carried on, MR, STEIN: Well, I think you are talking about — the funds is another matter. As a matter of fact, I don't know the details of that at all, I really don't, DR, McWHINNIE: No, no, no. My point is: Do not put us out of credibility. The American people need every segment of society. MR. STEIN: Surely. DR. McWHINNIE: But already there is such doubt cast upon the scientists that his data will convince no one, MR, STEIN: It may. But here is the point. We don't have a plutonian elite running our socity, Tou may probably from your point of view point up those disciplines that — that we have to get the answers. We can't get them from "legal boxes." I don't believe we ever have "legal ------- 2225 M. A. McWhinnie boxes" for those disciplines — physics, chemistry, biology, meteorology, geology, engineering and the environment. It would be nice, and I know you think it would be nice to have this. But I think we have heard from the public here, and long ago, as Clemenceau said, "War is too important to be left to the generals." I think we have heard that the public feels that the environment is too important to be left to the scientists, the public officials and the lawyers. (Applause) That is why they are here. We have to face this. Now, the hotel is signaling, and we will be out in a few moments. Now, the other point I think is that the lawyers have a way of looking for the truth, too. It may not be scientific truth, but it is the kind of truth as proven by our society that can arrive at an accommodation within our form of government where we can move forward to the next step. Truth in the abstract is always a problem. I am not talking about that. But I am talking about truth in the sense that when we have divergence such as we have here it may be the great seamy part of society, but that is the miserable job that we lawyers have in trying to get all of these elements together — trying to get to the truth as best we possibly can, groping toward it as expertly as ------- 2226 M, A. McWhinnie we can tt come up with a conclusion so all parties know the rules and we can at least hopefully move forward. Now, I recognize that from many philosophic or scientific points of view you may not consider this the ideal way to move, DR. McWHINNIE: I do not have any grief with lawyers, if it is true — and I think that this is a science- based problem — but then we must not close the door on the scientist; we need his answers just like we need the lawyer's answers, MR, STEIN: That is true. But, ma'am, if we are faced with the situation — I am reminded of Senator Hart's telegram, and I don't think he said much different, I just raise this as a question that you pointed out as a conclu- sion, but I will get to that in a moment. The point that Senator Hart raised was, in view of the fact that we are dealing with a complex scientific problem where every answer is not yet in, should we not employ the technique that we have employed many times in our society in getting some kind of change, either to society or our environment, by using the principle of burden of proof? And that is what he suggested, and I certainly have not talked to Senator Hart about this. We have been having enough discussions about mercury and heavy metals to get ------- 222? M. A. McWhinnie into other issues lately. But I think his telegram seemed to me to get to the same point that I was making, and I think Attorney General Scott made the same point. Maybe this is the point that comes from our professional back- ground, and when you get a complicated situation like that the way you take the first step is to fix the burden of proof and let the parties who are responsible come forward with the scientific evidence or any evidence which will cause you to move* DR. McWHINNIE; I agree. But when the burden is upon them do not deny them the only group who might be able to provide it. And I regret that distinguished scientists this week — one a member of the National Academy of Sciences to which neither you nor I are good enough to be so named — was not even allowed to scientifically answer the charges against his work because he had gone home. And this is not common in my community. Scientists speak freely to each other. They don't get put into "legal boxes," so that they cannot reach each other. This is all I seek. MR. STEIN: Oh, we have another rule in the law, and that is — and I guess we have to do this — what we do is give people an opportunity to be heard, and that is just an opportunity. If they are not here and don't avail them- selves of it, what can anyone do? The hall is open. The ------- 2223 M» A. McWhinnie notice is out. You have to show up in order to be heard, and if you leave, that is your privilege, but there is no way that we can chain a man here when we are not exercising subpoena power* DR. McWHINNIE: Whatever was the mechanism I do not know. But I think those questions should have been placed to those scientists by those who later stated them at the time that it was fresh in the mind of the conferee and fresh in the mind of the participant, MR. STEIN: I have one last point, and I hope you won't take this too personally. But you talked about some "ticky-tacky" point on quotes from a "white paper" where part of the information was put in and part not. I believe you were here for most of the week. I believe you have talked before public bodies in the past 15 or 20 years — congres- sional committees and many other public bodies — and yet what do I find? When you criticize the "white paper" — and I am not commenting on your criticism of leaving something out and putting something in — and from the precis I find — after you have probably heard my views all week and remember me possibly from 1962 — that I get a quote that you attribute to me from a newspaper. DR. McWHINNIE: Oh, please, sir, this I would not do. Please read the text — ------- 2229 M. A. McWhinnie MR. STEIN: Yes, I read it. DR. McWHINNIE: ~ in which it was stated what Mr. Stein said because I, too, have deep concern for the accuracy of the press. MR. STEIN: I have no concern, I repeat, I have no concern about the accuracy of the press. I want to say here that these concerns I hear about the press not reporting things right is not a fair criticism. I find we get fair reporting practically all of the time. But, Professor McWhinnie, the question here is that if we are seeking the truth, I would prefer to go to your work that I have heard of, or your statement or your verbatim testimony than use any quote in the paper. However, I might rely on that paper as an expression of your view. DR. McWHINNIE: I must not speak clearly. That quotation is only to emphasize the position that I think has been taken — "The burden of proof is upon the user." It is known everywhere. It is even said of Mr. Stein in the Chicago Sun Times. Now, if this is true, don't close the door. MR. STEIN: Again, let me make my position clear, because I don't think this is what I said. I raised the question for the conferees. I didn't come to a judgment, ------- 2230 M. A. McWhinnie I raised the question to the conferees. They have to make this judgment; I have not come to the conclusion but I am raising the question with them. This is the essential point of this conference. One of the major issues I hope to speak about.in the executive session is: Is the way to handle this through the burden of proof? If it is, on whom should that burden of proof be? Should it be on the Government, or on industry, or a city which wants to use a natural resource? This is a judgment that they are going to have to make. Now, I don't even know whether they want to take this approach, but I have framed this question again and again. I say independently a lot of other people have come forward with the same kind of question. All I ask is that I think this is a legitimate matter for the conferees to consider, to see if they want to adopt that approach. I have by no means said that I endorse at this point the burden of proof rests on anyone or is the avenue through which we will handle this case. DR. McWHINNIE: May I just — MR. STEIN: Just go ahead. DR. McWHINNIE: I don't care upon whom the burden of proof depends; either side will need scientists. ------- 2231 M. A. McWhinnie MR. STEIN: Thank you, I think we are all agreed. We are both agreed on that. Now, are there any questions? MR. OLIN: My name is Harold Olin. I am not a scientist, and I am not a lawyer; I am an architect, and I am proud to say I am a conservationist. I would like to cross-examine this witness with your permission, but it will be brief. MR. STEIN: Well, let me tell you — MR, OLIN: It will be brief, sir. MR. STEIN: Well, you know we have to be out of this room. MR. OLIN: Okay. Can you state categorically from a scientific point of view that the 40 or 50 billion B.t.u.^per hour which are being dumped into the lake at the moment are not damaging to the lake ecology? DR. McWHINNIE: No, sir, I cannot. May I ask you a question? MR, OLIN: As soon as I am finished with you. Thank you. MR. STEIN: Pardon, sir, I am afraid — MR. OLIN: I only have one other question, sir. MR. STEIN: All right. Go ahead. I am not sure ------- 2232 M. A. McWhinnie how much there will be, MR. OLIN: How long do you think it would take to get consensus in the scientific community that it is or is not damaging? How many years? DR. McWHINNIE: I would say we do not seek consensus, we seek evidence. I would further say that 2 years annual cycle multidisciplinary study preoperational is essential; 3, 10 postoperational. MR. OLIN: Possibly 15? MR. STEIN: I am sorry. You can continue this; we just have to give up the room. MR. OLIN: Thank you. MR. STEIN: I will tell you where the next room is, and you can have the floor. We will reconvene in about 15 minutes in the Randolph Room. You can find the Randolph Room on the lower level. Take the entrance down- stairs through the College Inn Arcade on the main level, and we are all set up in the Randolph Room, and we will reconvene. (Short recess.) MR. STEIN: We will reconvene, if we may. I don't know — Professor McWhinnie, do you want to get up again? I think if any questions are going to be asked, I am going to ask the person on the floor to get near Mrs. Hall, of course, and speak loudly. ------- 2232a M. A. McWhinnie MR. OLIN: I have one final question. You have indicated that you could not state categorically that the heat is not damaging to the lake<> You have also indicated that it would take some- where between 12 and 15 years in order to do an exhaustive study — scientific study, of course, and I am just wonder- ing whether you are proposing that we continue our current practices in the interim. DR. McWHINNIE: May I ask a question? Given that what you say is true, the answer is no. MRo OLIN: What are you saying I said? I am basing my questions on what you said, Professor McWhinnie, not on what I said. DR. McWHINNIE: Under the moment of confusion, would you resay what it is? MR. OLIN: Certainly. My first question was: Can you state categorically that the 40 or 50 billion B.t.u.s per hour which we are currently dumping into the lake are not damaging to the ecology of the lake? And if I might remind you of your answer, your answer was that you could not state categorically that it is not damaging. My second question to you was: How long would it take to get scientific consensus on whether the heat discharges into the lake are damaging or not? And you said ------- 2233 M. A. McWhinnie that it would take an initial 2-year study and perhaps a 10-year study after that. And ray third question to you now, based on your two earlier responses, is: Do you propose that we continue the same current practice of dumping all of the heat from industries and from powerplants, municipal treatment plants, into the lake while these studies are being performed? DR. McWHINNIE: With respect to the first, we do not know. We have information on which we make reasonable judgments. I would ask you: Would you not expect to see deterioration due to heat increments at the Waukegan plant after 40 years of operation? May I ask if you would be kind enough to try and answer that? Would you expect this? MR. OLIN: May I suggest that you haven't answered my third question and you are posing a question to me? I will be glad to answer but, you see, I am not a scientist; I am only an architect and an observer. MR. STEIN: I am sorry. Again, I am going to have to act like a nasty old lawyer. MR. OLIN: I would like the record to show that Professor McWhinnie has not answered my third question. MR. STEIN: The record will show what you said. Now, what I am going to have to ask is that you ------- 2234 M. A. McWhinnie handle one question at a time. MR. OLIN: Which I did. MR. STEIN: J.ust ask one question at a time. Do you have a question to ask or a comment to make to Professor McWhinnie? MR. OLIN: The question was: Do you propose that we continue our current practice while these exhaustive studies are being made by the scientific community which might take, as you have indicated, anywhere from 10 to 12 or 15 years? That is my question. You have a choice. DR. McWHINNIE: May I correct your 10 to 12 years or 15? I said 2 years before, 2 or 3; or $ or 10 afterwards. You only added up the last numbers. And there is a danger in this. It is my own plan and that of all of this confederation of scientists that surely we shall have supportable information 2 years, quote, preoperative; 3, postoperative. But we are not satisfied with an interim answer. I would like to remind you that that lake does belong to the scientists also who share the concerns of everyone here. As a consequence, we will continue our studies when the public has long since gotten tired, but we will continue. For that you have your 12 to 15 years; not for ------- 2235 M. A. McWhinnie an answer to the public, MR. OLIN: Professor McWhinnie, I am not clear on what your specific recommendation to the conferees is with respect to a thermal standard, and that is exactly what I am trying to get to. These gentlemen are here to find out what you and the scientific community ought to be doing about a problem which exists now, in the view of many of your colleagues. And somehow your specific recommendation to me at least is lost in all of the scientific rhetoric. What is it you specifically recommend to these gentlemen here? DR. McWHINNIE: In answer to that, I included in my testimony — Mr. Stein, sometimes called a statement — the position expressed by implication by Dr. Gustafson, by explicit wording by Mr. Harper. Let us, before debate defeats us, recommend a moratorium, but let us have an experiment and, thus, my recommendation would be in this category within the options open to this board of conferees but significantly also look at what the States of Michigan and Illinois have recommended and, of course, the third alternate, the Federal Government. Based upon the probability, not the possibility — anything is possible — it is indeed possible that when I step out of this room, I shall be trampled to death by a ------- 2236 M. A. McWhinnie team of elephants, but I don't think it is very probable. Within the world of probability, I believe, that with the information that we have, the recommendation from the State of Illinois, does not bode badly for Lake Michigan, and with a moratorium we can come to provide the answers that are needed when the moratorium would be left, MR, OLIN: What do you mean by a moratorium? A moratorium on standards or a moratorium on thermal dis- charges, Professor? DR. McWHINNIE: A moratorium with respect to the number of plants to be placed on Lake Michigan, MR, OLIN: Is it your recommendation, then, that we should hold the status quo and not permit any additional plants on Lake Michigan? DR0 McWHINNIE: I would feel that the plants that are^or are in construction,would provide us the experiment we need, I would leave it to this board of conferees to make the decision, quote,"how manyJ'Mhow soon?" MR, OLIN: Thank you, MR, STEIN: Are there any other comments or questions? MR, READ: My name is Herbert Read, Your comments about a number such as plus 5 on top of 50 or on top of 70 interests me0 As I understand ------- 2237 M, A, McWhinnie you, your number — a plus 5 may be acceptable under certain circumstances but a plus 1 or plus 2 may not be acceptable under other circumstances, is that correct? DR, McWHINNIE: You, too, must be a lawyer, Do not read what isn't there, I am saying that it is unrealistic to say plus anything, and I carefully kept indicating "or, etc." If, by example, I can use one number, it is only an example, and, thus, the plus 5 or the plus 1, or the plus 3» I am saying it is unrealistic within the context of oscillating temperatures in an envir- onment, variability in organism adaptation, they face from 32 to #5 every year anyway. What kind of sense could this board offer to prove the reasonableness of why they said plus something? MR, READ: All right. In other words, since there seems to be no consensus of plus 1 or plus 5 or plus 10, either over 50 or 60 or 70, would you say the only way that we could be sure of anything is plus zero? DR. McWHINNIE: If you are afraid of the possible, and you have no interest in the probable, plus zero, you are required to ask for, I face what is probable, MR, READ: All right. In dealing with proba- bilities, then, can you come up with any number — here again dealing with probabilities — can you come up with any number ------- 223S M, A. McWhinnie that these gentlemen should consider? DR. McWHINNIE: I have indicated that I believe reasonableness is represented by what the State of Illinois has been attempting to do. MR. READ: Now, is that a number question here? DR, McWHINNIE: I think this is a maximum #5 at any time. MR. READs I am from Indiana so I am not familiar with the Illinois situation. MR. STEIN: Mr. Currie. MR. CURRIE: If I may clarify that just a bit. There is an existing 85-degree standard in Lake Michigan water quality standards adopted by the State of Illinois. There is in addition a requirement that cumulative temper- ature changes be not more than 5 degrees from the ambient temperature, and that not more than 2 degrees difference be permitted within any given hour. There are presently for consideration before the Illinois Pollution Board two proposals to change those standards, and the State of Illinois has not so far either through my board or through Mr. Klassen's agency proposed any thermal standard for this conference. MR. READ: All right In view of the explanation here, the State of Illinois, under the explanation that was ------- 2239 M. A. McWhinnie just given, did de"al with figures, and government agencies do have to ultimately deal with figures. We had a figure plus 5 mentioned, plus 2, under certain other circumstances. Then, is that the figure that you think that we could live with dealing with the proba- bilities? DR. McWHINNIE: Dealing with the probabilities, I would say that I think we could live with considerably more than plus 5* MR. READ: Well, then, what? DR<» McWHINNIE: I am sorry, sir, I will not name a number. There is no data that would support me. MR. READ: Would you say that in the absence of data the safest thing to do, then, would be plus zero? DR. McWHINNIE: I don't like to take that kind of logic to its ridiculous extreme0 But in the absence of certainty that I am not going to be killed on the street, I should stay in bed in the morning. On these grounds, forgive me, but based upon the existing data, I would suggest that plus 5 is restrictive; 80 to #5 is realistic, in the receiving body. In those areas where plants are presently operated — operating — because I must emphasize the Waukegan fossil fuel plant has been operated for 40 years, and I am not supposed to speak until I have data —— ------- 2240 M. A. McWhinnie but I can say this to you: that through 3 months of intensive effort this summer, I am sorry, we ain't got the evidence to support the position of concern which you show* I show con- cern but I will not react to that which is possible. MR, READ: All right. So I want to state that at least I was able to obtain a statement of your position. I have been trying to determine what that was, and thank you very much. MR. STEIN: Yes. MR. COMEY: David Comey. Miss McWhinnie, I am not a lawyer, so donft worry about my cross-examining you. I used to be an attorney though. You spoke about the difficulty of finding funds to conduct thermal research on Lake Michigan. DR. McWHINNIE: Only as for funds so you under- stand where I stand. MR. COMEY: Well, I was in a similar position last year, and had to turn down a very interesting 6 -figure contract to do a thermal pollution study near Chicago because the government agency that was funding it had some restric- tions about publication which we didn't feel were consistent with academic freedom, so we turned it down. So I think on the moral level at least I can come into this conference ------- 2241 M. A, McWhinnie with some sort of basis of perhaps equal with you. The problem that I have is that I am basically concerned now with the public reaction, and you talked in your presentation this afternoon about capacities of the lake. Now, I think really this is what the public is objecting to and I would like to ask you — DR. McWHINNIE: Excuse me, before you go on. I did not speak about the capacities of the lake. I did speak about the capacities of living organisms, and I think the record will show that. MR. COMET: All right. Could I extend that a little bit further? Do you believe there are such things as assimilative capacities to natural bodies of water for distinction of pollutants? DR. McWHINNIE: I love the expression. Presented in the National Water Pollution Conference papers of I960 in which the, quote,. "Purifying Powers of a River, etc., etc., etc." — yes, I do believe in this. I would be a fool to fly in the face of evidence that the living world is in dynamic equilibrium with its environment, and it will oxidize out, and it will take that which is organically useless, return it to a usable form for plant life, and the cycle goes on and on, and this was so ably pointed out then. The only problem is, our inputs are now too close, ------- 2242 M. A. McWhinnie and we get so that the normal biological processes cannot carry on to completion what once they could, given the time. MR. COMEI: You, I gather from previous statements before this in the Illinois Pollution Board feel that field studies are far preferable to laboratory studies. DR. McWHINNIE: They are essential. MR. COMET: Let me ask you this: Would you be willing to conduct a controlled experiment on injecting cyanide, lead, mercury, or other pollutants of this sort not in a controlled laboratory situation but measuring rather large amounts of them out into Lake Michigan in order to determine exactly what the effect on the biota would be? DR. McWHINNIE: I am deeply concerned over the constant analogies which don't fit together. You cannot ask of a living system a question in the physical word, called thermal, and use as a fair example a toxic compound. This abuses knowledge. MR. COMEY: Well, I would extend the abuse a little further, I would say that if a graduate student came to you with funds proposing to measure a capacity.such as the following: Exactly how many rapes per hour a woman could tolerate; you would turn that down, and advise his graduate advisor. Similarly you would turn down any biological experiment on children with respect to how many beatings ------- 2243 M. A. McWhinnie per hour they could take, I think what the public is saying is: We are not interested in measuring parts per million of pollutants or B,t.u.'s per hour; if the technology exists, we want it all out. And that is what they are saying, DR. McWHINNIE: I understand their question. I would like to know why you started to call it thermal pollution. You made a decision. I am not prepared to make it. Earlier at this conference, Mr. Stein speaking with some speaker — I have forgotten — asked: "Are you turning to the possibility of enhancement?" And the reply was, "Yes." And I wonder why we don't see two sides of every coin. Who started the word "pollution"? Could they not have restricted it to thermal modification?1* Why has the decision been made? But it has. MR, COMEY: Well, I believe that when I first began hearing the term in the middle 1960's, it was in indus- trial magazines such as Chemical and Engineering News, Nucleonics News attempted to change it in about 196$ to thermal environment' but scientists changed it instead. Well, I am concerned about the attitude that you have expressed, and I think that, very frankly, if this ------- 2244 M, A. McWhinnie thermal conference is unable to remember something of this question and to adopt the idea of the zero standard, the public is going to be very disappointed. As a matter of fact, in Mike Royko's column the other night he talked about a rather interesting gentleman in King County he called Fox, who has been very carefully setting up outfalls and covering over caps of smokestacks. His most recent exploit was to dump in an aluminum company the 50-gallon excrement that came out of their outfall. And I am afraid that the public may view this thermal enforcement conference as a test case and if in several months nothing has come forward, I am afraid the Foxes may multiply. DR. McWHINNIE: May I speak to that? The public should not be so ready to decide that this scientist or that one or the other one who cannot concur with them because of knowledge J-s their enemy. Let the public further know that I loved that lake long before they did. MR. COMEY: But you also made the very patroniz- ing remark — DR. McWHINNIE: Let me finish. When the public takes it into its own hands to step beyond the normal course of events and hand it into the hands of our leaders who ------- 2245 M. A. McWhinnie shall not act highhandedly, it shall be those who contribute to the anarchic breakdown of a country I live in and love. Let it be remembered that lake belongs to us. Our concern is not different from yours. Our experience may help us reach a solution that you too want. But don't you outdo us with your anarchy. (Applause) MR. PETERSEN: I think, Mr. Chairman, at the risk of interrupting, we have been here for sometime. May I please suggest that this not be a colloquy of questions that are going to be asked. Let the questions be asked not speeches from the floor. MR. STEIN: Sir, the other night I was here very late and let only largely representatives of the power companies proceed in their own manner. I think the admonition is well taken. But the point is that in a workshop such as this we have to remember that where we don't have professionals asking the questions, they have to do this irrespective of their personalities. I asked you to be brief. If you can I think this would help because I think Mr. Petersen has made an excellent suggestion. And while philosophically, morally, and emotionally I agree with him thoroughly, I don't think in the exercise of my official capacity I can really enforce ------- 22^6 M. A. McWhinnie it. MR. COMET: I would only finish the comment I tried to make before, and that was that I did regard your statement that the scientists would be there after 15 years caring about the lake when the public had long gone back to its fun, games and dancers. I find that a very patronizing remark. DR. McWHINNIE: I do not mean it to be so. I regret that you have taken that interpretation. MR. STEIN: Are there any further comments or questions? If not, thank you very much, Professor McWhinnie. DR. McWHINNIE: I am sorry for the time. MR. STEIN: It wasn't you. Now, we have several people here who have filed statements. Ted Falls, President of the Porter County Chapter, Izaak Walton League, had to leave and will submit a statement next week. (See Pp. 2345-2349) Mr0 Seymour Altman, Commissioner, Highland Park Environmental Control Commission. (See Pp. 2248-2249) Mrs. Bieker, Indiana Division Board, American Association of University Women. (See P. 2250) ------- 2247 Mrs. S. Troy And Mrs. Robert McKimpton, Independent Citizens' Water Pollution Research, Inc., Hammond, Indiana. (See Pp. 2251-2254) They have all submitted statements for the record and without objection they will be entered into the record as if read. Now, I have a job as an administrator as well as doing this, and sometimes I recognize the force and the reluctance of the scientific community to come up with a figure or a definite answer on something. But when they come in for the grants for a project, they sure want a definite answer from me on what the figures are, and the money they are going to get before they start. John Berghoff, Is he here? Mrs. Jack M. Troy. STATEMENT OF SYLVIA TROY, PRESIDENT, SAVE THE DUNES COUNCIL, MUNSTER, INDIANA MRS, TROY: I am Sylvia Troy, President of the Save the Dunes Council, a conservation group of 3,000 members, formed in 1952 to establish and protect the Indiana Dunes National Lakeshoree It will be bitterly ironic if after all the years (Continued on P. 2255) ------- ARCHITECT S ALTMAN-SAICHEK ASSOC. 300 W WASHINGTON ST CHICAGO, ILLINOIS October 2, 1970 PHONE 726-8,15 Federal Water Quality Administration Great Lakes Region Department of the Interior Chicago, Illinois Gentlemen: I am Seymour Altman. I appear here as a representative of the City of Highland Park Environmental Control Commission. I am also a co-chairman of an en- vironmental organization, the Society Against Violence to the Environment, as well as, an individual --a resident of a community bordering Lake Michigan and in close proximity to the proposed Zion Atomic Energy Power Plant. We have sat through these days of bearings, with increasing disquietude, as industry has paraded forth an impressive array of very sincere, technicians and engineers --to show us that it is impossible to prove that adding enormous amounts of heat, albeit dutifully diluted, to our Lake will harm the Lake's en- vironment. We are not certain whether we should be horrified by this nightmare, or whether we are to laugh grimly and treat this as some satirical, existentialist theatrical production. Apparently they would have us all believe that the burden of proof is on the public -- that we must risk further pollution of the Lake now and in the future. Gentlemen, this summer the residents of Highland Park were made aware of the effects of past pollution of our Lake based on the same premise. Our beaches were closed for swimming. This came as a shock to people who had always considered that they could enjoy the privileges inherent in living in a community on a Lake. The closing of the beaches, in itself was a worthwhile symptom of the dangers to which our natural surroundings are exposed. We have become increasingly aware of the confluence of pollutants in our area. Add to this pollution large amounts of heat -- what do we get? What is the cynergistic effect on the Lake and on us? Industry would have us believe that the only way to find the answer is to "try it and see. " We have been through that one before. Look where it got us. ------- 2249 - 2 - The simple/and logical answer is this: nothing more in the way of additives which might change the Lake is to be allowed to be introduced into Lake Michigan. This Lake belongs to the people. As such it is our responsibility to protect it and safe- guard it. If someone wishes to use it -- they must show, beyond any doubt, that they will not harm it or us. Till such a time, it is our prerogative, and our duty, to prohibit their transgression of our rights. SA: s s s ^4w^wxW% eymour Altman ------- 2250 AMERICAN ASSOCIATION OF UNIVERSITY WOMEN Indiana Stale Division October 2 1970 1154 Ridge Road, Munster In 46321 Lake Michigan Enforcement Conference Sherman House Clark and Randolph Sts Chicago, Illinois Gentlemen: The Indiana Division of the American Association of University Women wishes to go on record in support of the Department of Interior's criteria for protecting Lake Michigan waters against thermal pollution. This department has shown the most informed interest in protecting the environment in the public good and would be the best informed and dependable in guarding conditions. We have waited too long for this Conference to bring forth a clear protective policy. We have waited too long for our own state of Indiana to enforce what standards we already have or to support a strengthening of the criteria concerning lake water quality. We see no bright hope in the states surrounding the lake agreeing on a set of standards that would be to their mutual advantage and equal enforceability. We hope therefore that the regional Directed of the Federal Water Quality Administration will officially designate the Secretary of the Interior and his department as the federal authority estab- lishing federal standards. We w ould recognize that they w ould be pressured by heavily weighted vested interests who would gain by freedom to misuse the lake. The Department of Interior has demon- strated that they are capable of acting in the over-all public good and we favor their firm stand on criteria that would not permit lessening quality of the lake water. Yours sincerely rs. L. W. Bieker Division Board Indiana Division AAUW ------- 2251 F3D3IIAL I7AT3R QUALITY HEAD' Chicago, Illinois October 2., 1970 prepared by i;-:D3Pi::.D3i;T cims^s1 WATER PCILUIIC." .13S3A.CH, lire. 7515 I:ew Hampshire Avenue Hanrnond, Indiana 45323 area code - ?19 344-1590 ------- 2252 I.JI.J.J . J. ~-i X -I.J > 737^ •>'""T ' > * , 751 C -~ew Hampshire Avenue Hammond, Indiana 45323 area code - 219 344-1590 The i:;Tr,?i2L.D2i:ir ciriz"-.:^1 ;;Arz^ POLLuric.: ^s?2Aiicn, i:.c. is s unique non-profit organization in that it was created for ir.ore than one purpose. \s its iia.no indicates, one of our primary pur- poses is to sample and analyse waters, both public and private, and to demonstrate the conditions of those waters. Another pur- pose of our corporation is to keep the public aware of the condi- tions of waters sampled and analyzed. A third purpose which ex- cludes I.O.'./.F.n. , Inc. from being strictly an analytical corpor- ation is our efforts to work for more stringent anti-pollutior. statutes and regulations as a result of our studies and research. .lepre Rents tiven of our corporation have coine in contact with and dealt with governmental agencies such as the Indiana Stream Pollution Control Board, the Federal .Jater duality Administration, the Indians State Board of Health, the lake County Board of Health, and the Army Torps of llii^ineers. In each instance in dealing with each of these agencies, we have found an awareness of the sever- ity of the present pollution problem?. In each instance in deal- ing with each of these agencies, we have also found ineffectiveness, evasiveness and. lack of direction. For example, in thn statr of Indiana, the legislature has established the authority for the creation of the Indiana Stream Pollution Control Board, its powers and regulation of enforcement ------- 2253 o 2 in statutes 68-517 through 58-543 inclusive. These statutes allow the. SPCB to establish and enforce stringent criteria and control of these criteria, but the SPCB has not done so. The SPCB has, instead, adopted weak and inconsistent criteria and regulations. These criteria include Lake Michigan open water, Lake Michigan shore water, Lake Michigan inner harbor basin, Indiana Harbor Can- al, Grand Calumet River, Little Calumet ?%iver flowing into Illi- nois, and Wolf Lake. The criteria for these interstate waters were requested and approved by the Department of Interior. r,o samples to be used for proof of a violation by any entity can be from effluent discharges, but must be fro:n the body of v/ater it- self after dilution; but no stipulation in given as to what con- stitutes a dilution or mixing zone* The substances included in the criteria for thses interstate waters varies so that not all the same substances appear in all criteria lists. It has been proven that industries, municipalities and indi- viduals have not and will not atterapt to reverse their polluting d£e to social conscience. The only solution, therefore, is strength in the federal, and subsequently state, agencies respon- sible for controlling, regulating and enforcing anti-pollution regulations. The government is the only possible means through which the pollution crisis in our country can be solved. Study commissions, conferences and meetings of all types have proven to be mere dead ends from which very little positive action emits. ------- 2254 Public dissatisfaction grows stronger day by day with tha ineffectual handling of our deteriorating environment, The governasntal agencies, especially the F>ro.\, must begin immediately to act with :.:ore authority. Compromise end ineffectual gestures must coar.e. The 7:r^. must require compliance by the states in stiffling the progressive deterioration of our water and air. Ignorance is no longer a valid excuse. The health and welfare of this country's people is now a necessary priority. ihe .Tetter of t her r:\al. pollution is just another in the long list of pollution sources. The ?:~^A has the opportunity and the power to bs It this source before it is allo"-?er to become another mfjor p o1luUant„ It is for these reasons stated that i::D2?3;-,DS.-.T Cini-^S1 TAiZ-L POLLUTIC.: "^iSIA^K, I'/C. recommends to the "acretary of Interior that the ther.;>?l criteria be removed free the 2nforce- ::.er;t Conference ar;d pl?ccd directly in the authority of the Feder- al :/ater ?;jality -.dninistration ap sn agency of the Department of Interior. ------- 2255 Mrs. S. Troy we labored to secure the National Lakeshore, its 13 miles of beaches will not be usable by the public — and that is a very real concern. The beaches farther west in Indiana — at Whiting and Hammond — have already been closed to public use* All of Northern Indiana Public Service Company's major electric generating facilities are on the shores of Lake Michigan, despite the fact that the company services the entire northern third of the State, They presently have three plants and propose to build three more — a total of six utility plants — on a 30-mile span of Lake Michigan shoreline and five of those plants border land dedicated to public recreational usec At the proposed Michigan City plant at the eastern end of the Indiana Dunes National Lakeshore, #75»000 gallons of heated water per minute (heated to a maximum of 25 degrees above lake temperature in winter, though the company refers to a 14-degree rise, when 14 degrees is the average temperature) will be discharged adjacent to sewage effluent coming from Trail Creek in Michigan City, •,• Slide o•• I do have a slide, a map of the Indiana Dunes National Lakeshore, Harold, would you mind indicating where that Michigan City plant is? The areas in white are ------- 2256 Mrs, S. Troy the designated areas of the lakeshore. The currents here move in a westerly direction along the shore and this area has been designated for intensive public beach use. The shoreline erosion in this area is particularly acute. According to the Army Corps of Engineers figures, the erosion rate is 9 feet of shore- line per year and is due primarily to the Michigan City harbor breakwater which disturbs the natural littoral drift. More than 300 lots are underwater and over a mile of road has been washed away in the past year. The heated utilities discharge moving along the shore will most certainly melt or soften the natural ice barrier formed along the shore which normally acts as a protective shield to the ravaging winter and spring storms, aggravating and accentuating an already critical erosion problem. At the western end of the lakeshore, the Bailly nuclear plant is being proposed. Here, the vast amounts of heated water, trapped by the Bethlehem landfill and joined by the chemical wastes of the Bailly coal-burning plant and other wastes from Burns Harbor will be forced to move in an easterly direction and have a similar melting effect on the protective ice ridges along the shoreline, thereby creating further erosion and pollution problems, I would like to counter the statistical ------- 2257 Mrs. S. Troy contortions of the power industry who are attempting to prove that dumping of vast quantities of heat will not be harmful to the lake — they even have the effrontery to assert that it may be beneficial — with the evidence of what is happening to Lake Michigan, Here is algae collected from the east end of Beverly Shores in the Indiana Dunes National Lakeshore near the Michigan City plant of Northern Indiana Public Service Company. This is a recent development and proof of the acceleration of the eutrophication process. Each year there is more and more of it along the shore. Have industry scientists explored the synergistic effects of waste heat in shallow water already heavily contaminated with chemical and sewage effluent? Would the electric power industry be willing to post a bond of several million dollars or perhaps a billion dollars to support their assertions that heat will not adversely affect the fishing industry or recreation potential of the lake or deteriorate its quality or disturb its biota? What is the credibility record of the industries along the Lake Michigan shores? What is the credibility record of the utilities at the southern end of the lake? Twenty years ago when my husband practiced medicine in Whiting, Indiana, and phoned Commonwealth Edison Company ------- 225S Mr s<> So Troy State Line Generating Plant to complain about the air pollution, the officials came to see him and assured him that every possible measure was being taken to clean up their stacks. Last week, finally, the city of Chicago sued Commonwealth Edison for violations, NIPSCO's promises on their Bailly plant were never kept. The dirt plumes are visible 10 miles away. Lake Michigan would normally have a life span of 25,000 more years. Responsible biologists say the lake may be dead in 15 years if we continue on our present course. And is industry heeding this warning? No, They are pursuing the same destructive, mindless, short-sighted policies and they now propose to use Lake Michigan as a heat sink as well. The quality of Lake Michigan has not improved since 196 5» In fact, it may have deterioratedo Here is the record of Indiana industries since the passage of the Clean Water Act, U, S. Steel Gary Works has actually increased daily discharges of oil. In 1965, they discharged 54,000 pounds of oil daily. Now, 5 years later, supposedly with enforcement procedures under way they have actually increased their discharges to 67,317 pounds of oil daily and they dump 306,7$1 thousand pounds of suspended solids as well. Inland Steel Company discharged 23,791 pounds ------- 2259 Mrs. S. Troy of oil and 103,617 pounds of suspended solids. The figures for Youngstown Sheet and Tube Company is 11,000 pounds of oil and 46,000 pounds of solids. Perry Miller of the Indiana Stream Pollution Control Board, ever an apologist for industry, is quoted by Chicago Daily News, August k, 1970, as admitting industry is still discharging large quantities of oil but says "... these are large facilities and large bodies of water." Ten years ago Blucher Poole refused to be concerned about possible wastes from Burns Harbor. It is no surprise that the industries and utilities prefer Indiana State standards and State enforce- ment and object vigorously to Federal interference. The record of the Indiana Stream Pollution Control Board in reversing water pollution trends in the State is abysmal (with the exception of some recent actions). The conditions of the Grand Calumet and Little Calumet Rivers are as deplorable as ever. Lack of staff and an antiquated and politically controlled judicial system also hamper them. Governor Whitcomb has not acted to request the State L egislature for maximum funding to quality available Federal grants to build needed municipal sewage treatment plants. Industries prefer to locate in Indiana where they ------- 2260 Mrs. S* Troy can manipulate and control the local and State regulatory agencies* The extent of air and water pollution in the Calumet region, despite the Federal Clean Air Act and Clean Water Act in 1965, despite local and State laws, is a National scandal and the record of the local and State anti pollution agencies ought to be investigated. There is an increased awareness by the public of the threat to Lake Michigan as evidenced by the growth and proliferation of conservation groups in Indiana and the attendance of over 1,000 people at the public hearing on the proposed Michigan City NIPSCO plant. We are prepared to take legal action, if necessary, against the State Water Pollution Control Board for failure to protect the public interest. We wish to applaud the courage and integrity of the Federal Water Quality Administration and the Department of Interior in taking a firm and unequivocal position against thermal discharges into Lake Michigan. The feasi- bility of alternate methods of cooling with costs that will not be excessive to the public offer no excuse to the utilities for not acting immediately to use this technology. Utilities' threats of blackouts and brownouts is reprehensible. Indeed it reflects their lack of efficiency and organization. They prefer to put the blame ------- 2261 A. J. 0'Conor on the conservationists, A vigorous approach is necessary if we are to save the lake. May we urge the State of Indiana to finally come into the Twentieth Century and approve the thermal criteria as requested by the Department of Interior. Thank you, (Applause) MR, STEIN: Thank you, Mrs, Troy, Any questions or comments? If not, thank you very much, Mrs, Troy, Andrew 0'Conor, STATEMENT OF ANDREW J. 0'CONOR, ATTORNEY, OF THE FIRM OF BERRY AND 0'CONOR, OTTAWA, ILLINOIS MR, 0CONOR: Mr. Stein, members of the conference, ladies and gentlemen. My name is Andrew O1Conor. I am an attorney, for better or for worse, from Ottawa, Illinois, LaSalle County, which is located approximately 100 miles southwest of where you are sitting, I am here on behalf of a group known as the Brookfield Township Land Committee; the Illinois Agricultural Association, a group of approximately 190,000 members; the ------- 2262 A. J, O1Conor Illinois National Farmers Organization; the Illinois Farmers Union; the Fox River Valley Community Action Council, which consists of twelve locals of the United Auto Workers from Streater to Woodstock, Illinois; and we are here to present our position which to many of you may seem to be totally unrelated to the thermal pollution of Lake Michigan, Actually we are here because of what we think is an attempt to avoid thermal pollution of Lake Michigan by the Commonwealth Edison Company, which company services part of the territory which I represent. The relationship is direct and is caused by their attempt to avoid violating the thermal differential regulation which has been propounded by the Department of Interior, as I understand it, since 196#, and which affects the Illinois River, which is a Federal navigable stream, and which receives into it the Chicago River, waters from Lake Michigan, and the confluence of the Fox or the Kankakee and DesPlaines Rivers to form the Illinois River in our part of the State, MR, STEIN: This is outside the conference area, isn't it? MR, 0'CONOR: Well, I think it is, Mr. Stein, and in deference to you I did talk to Mr, Wright, and I don't intend to really go beyond this except to — from Washington ------- 2263 A. J. 0'Conor — and I did suggest that perhaps it was outside the con- ference area, but he asked me to come anyway. This was by telephone on Thursday, and I don't — Joseph Wright — I don't attempt to presume on the time of the committee and I will make it very short. MR, STEIN: Yes, because I think if you have a legitimate problem — and I don't doubt you do — this is clearly the wrong place to take this up because we have absolutely no jurisdiction in that area nor are we direct- ing it there, MR. 0'CONOR: Well, I think we have this message, if I can put it this way: We have appreciated and do appreciate all of the information we have received here about the feasibility of the alternate means of cooling for thermal powerplants'. I would suggest that they are equally as applicable to our problem which consists of the Commonwealth Edison wanting to take 7,000 acres of prime farmland instead of taking 7>000 acres of idle, marginal, unproductive land, and we feel that the information put out by the Department of Interior on these alternate methods of cooling, such as the towers, etc,, etc,, are equally solving of our problems as they are for the utilities around Lake Michigan0 The third and perhaps most important part of our ------- 2264 A. J. 0'Conor message — and this I mention to you gentlemen and to the people who are here from the various power companies — I think if you feel that by removing these powerplants from the Lake Michigan shores to an inland site, and thereby at least appear to temporarily solve the thermal pollution of our lakes, you have solved the problem, you are wrong, because you will run into just as vigorous opposition from land-based groups such as I represent unless the selection of the site is compatible with the land use and the land sought to be taken, in terms of what is good land as opposed to poor land. And I would like to just make that point for the conference. I think that is important. MR. STEIN: By the way, 1 think I agree with you. I think the way our Federal law is now, if it were ever true in the past, that industry could go from one place to another and avoid tight regulations, it doesn't apply today. I am not just referring to the power industry, because as many industries know — and I am not sure how well they like to see me — they find wherever they go in the country, there I am. MR. 0'CONOR: Right, and this is precisely our problem. (Laughter) Not you, particularly, but I mean wherever the power companies go, that is our problem. I didn't mean that in reference to you. ------- 2265 A. Jo 0'Conor We do feel, though, that before you relocate — and you take this home — there is a lot more to just relocating away from Lake Michigan or any of the Great Lakes than simply picking out a site and looking at it from an economic standpoint — that is from the company's economic standpoint and thinking then that because you have the supposed power of condemnation that all of the people who are interested in this good land are going to surrender. They are not going to do it, and there is going to be some regulations, truly some ground rules laid out about land use in relation to utilities in the future, MR, STEIN: Thank you very much, MR, 0'CONOR: Thank you. (The following document was submitted for inclusion in the record by Mr, O1Conor,) ------- 2266 LET'S TELL IT LIKE IT IS! In view of the confusion about and distortion of the Brookfield Township Land Committee's true position in relation to the Commonwealth Edison project, we herewith submit oui position and the reasons therefor. This position and the points supporting it has remained constant and unchanged since the original announcement of the project in the spring of 1970. 1. Apparently some persons are under the impression we desire to force Commonwealth Edison Company to leave this area entirely. Such is not the case nor has it ever been the case. We do desire and insist, however, that Commonwealth Edison Com- pany not use the prime farm land which it now seeks but rather locate the plant and its facilities upon idle, unproductive, or marginal farm land, of which there are thousands of acres in this area, both within and without LaSalle County. In this regard, the original plan of Commonwealth Edison use was to a considerably smaller tract of land (5600 acres) than that now sought and which land was located directly along the south bank of the Illinois River south of Seneca and three miles north of the proposed site. Several thousand acres still remain in this general area which we believe could still be used for the same purpose and which could include a cooling lake. Despite the assertions of Commonwealth Edison Company that it can not use this type of land, engineering advices indicate otherwise. Full engineering plans were and are drawn for this original site. The land taken at Dresden, both for the first nuclear plant as well as for the second nuclear plant, is for the main part highly marginal, unproductive land. The same poor land quality and characteristics prevail in large part in the Lake Kincade area and we are informed the same marginal quality of land is ------- 2267 sought to be taken in the Cordova, Illinois area near the Quad-Cities. The Brookfield Township Land Committee acknowledges the need for additional electrical energy. This statement has been made repeatedly to Commonwealth Edison Company and to the public generally. We are, however, unalterably opposed to the taking of prime farm land for the present proposed site and further oppose ^ropoood future similar takings of prime and good t< 1.1 farm land, which must be taken according to the utility industry press releases, literature and projections. If this is so, why was the poor quality of land taken at Dresden, Cordova and Kincade? On the contrary, there is in fact available to the utility industry literally tens of thousands of acres of idle, unused and unproductive land which can, through modern engineer- ing techniques, be adapted to and for the construction of the nuclear energy plants and facilities. Since the initial Common- wealth Edison Company announcement was made in early spring, the Commonwealth Edison Company has repeatedly stated that "its studies" and "its engineering research" indicate that none of the tens of thousands of acres of idle, unproductive lands in this area or, in fact, throughout all of Illinois - which they have allegedly reviewed and surveyed - are adaptable or useable for nuclear energy plant sites. This we deny. Repeatedly, our group, through its attorney and its various representatives, has asked the Commonwealth Edison engineers to release and reveal all of their so-called in depth engineering studies and data to permit us and our engineers to analyze such data and research. Not once has Commonwealth Edison as yet responded to such a request. We again challenge them ago MI to here and now release this information immediately so that we and all who are inter- ested in the agricultural industry might have an adequate and fair opportunity to thoroughly analyze and inquire into the Commonwealth Edison studies. The only answer we have received ------- 2268 from Commonwealth Edison engineers when such requests have been made is "we are sorry, we can not release this information at this time. Eventually you will receive it". Eventually, why not now? We ask you, Commonwealth Edison, to play fair with us and all of the agricultural industry and release all of your studies immediately! Actually most of the Illinois Valley area from a point immediately west of Seneca on through west of LaSalle and Peru is all served by the Illinois Power Company. It is a known fact that the electric power sought to be generated at the Brookfield site will not be used here but will be transmitted to the City of Chicago and the Cook County area. We have no fear that Commonwealth Edison will leave this area if they are re- quired to put this plant on idle, less productive ground. Commonwealth Edison has every intention of being in on the "economic kill" of this valley when it develops. 2. About the suggested job loss to this community: If this plant is removed to the original site proposed for it by Commonwealth Edison, to-wit, some three miles north of the Brookfield site or to some other site in this area, no jobs will be lost. Obviously, the jobs will still be there and the economy of this community will in no wise be effected. Persons regularly travel many miles daily to their regular places of employment, i.e., Caterpillar-Aurora, Caterpillar-Joliet, to Owens-Illinois at Streator from Ottawa, and from Libbey- Owens-Ford at Ottawa from Streator, etc. Moreover, there might well be more jobs created should Commonwealth Edison Company abandon the cooling lake project and invoke one of the several alternatives available to them as suggested by the Department of the Interior of the United States Government, to-wit: A. Dry cooling towers, B. Wet cooling towers, or C. Spray canals. ------- 2269 While Commonwealth Edison has only casually referred to these alternatives, they do exist and, in fact, are successfully in use in dozens of places, not only in the United States but throughout the world. They have proven satisfactory and are constantly being constructed in lieu of and in preference to cooling lakes. Cooling ponds are objectionable in the following major particulars: A. Cooling ponds by their very nature have a low heat transfer rate and thereby require large surface areas - they have been considered by numerous engineering authorities to be impractical. B. The quality of cooling pond waters will decrease with time as solids left behind by evaporation accumulate. C. Cooling ponds by the nature of their construction concentrate dissolved solids. t. Cooling ponds further collect impurities since large surfaces are open to the atmosphere. The primary reason for cooling ponds ±a because they are one of the cheapest and least expensive methods of water cooling. Any environmental contribution is purely secondary and incidental to their primary purpose and use. 3. Much is said about tax loss. Actually, there would be not tsx loss but a tax revenue gain if Commonwealth Edison were to build on the idle or marginal land, three miles to the north of the proposed site or were to build on idle, marginal land located elsewhere in LaSalle County. Remember Commonwealth Edison also owns large acreage in the Utica area. Much of this acreage is idle and unproductive. Should Commonwealth Edison build on marginal land: ------- 2270 A. The new plant and plant site would be located on marginal land now producing very little tax revenue, and this in turn would become high tax revenue producing land. B. The present highly productive and highly taxed prime farm land in Brookfield Township would still be available for present and future taxation and would continue to contribute its regular tax share. 4. About the right of condemnation or the taking of the land: We have been advised by many of the land owners and tenants that certain of the Commonwealth Edison land agents have indi- cated that the company has the absolute right of condemnation and that if the land owners and tenants do not agree to the prices and propositions presently being offered by Commonwealth, they will receive less at some future condemnation hearing date than the prices and propositions now proposed. Such statements are absolutely false. Neither the Commonwealth Edison Company nor any utility in Illinois, has the absolute right of condemna- tion. The Illinois Public Utilities Act, under which Common- wealth Edison must file its application for a Certificate of Convenience and Necessity, requires the concurrent action of the petitioning public utility and the Commerce Commission to vest the power of eminent domain. Commonwealth Edison does not have the right of eminent domain under this act until and unless the Commission issues its certificate finding that the public convenience and necessity exists for the facility. Before any action is taken by the Commission extensive public hearings must be held under the law and will be held before the Illinois Commerce Commission. If adverse to the Brookfield Group, the decision will be taken through the entire appellate court system of Illinois for adjudication. The final determination of whether or not the power of condemnation, in fact, will be granted is at least two or more years away and possibly ------- 2271 considerably longer. For authority that Commonwealth Edison does not have the power of condemnation, we refer you to the case of Central Illinois Electric & Gas Co. v. Scully, 161 N.E.2d 304, at page 307, wherein the Supreme Court of Illinois (195S) recited as follows: "The necessity for the improvement requiring condemnation and the manner of its construction are for the consideration of the condemnor, subject to the decision of the commission as to convenience and necessity. The condemning petitioner does not have the right of eminent domain until the commission issues its certificate". We challenge Commonwealth Edison and its counsel to contradict this holding of law announced by the Illinois Supreme Court in the above case and which law governs today. Commonwealth Edison has been totally silent on this point. Don't be mislead by statements to the contrary! 5. The effect of deep wells on the surrounding territories not taken: Commonwealth Edison admits it must sink numerous deep wells in the area to supply the pure water needed for steam generating purposes. Tens of thousands of gallons of pure water will be needed twenty-four hours every day, 365 days a year. This fact is not in dispute and is conceded by Common- wealth Edison. The present average well depth in Brookfield Township is now approximately 600 feet. Water is consistently and regularly available at this level to Brookfield Township residents for all purposes. Commonwealth Edison says it will take water from deep well veins. All well enough! In recent years industries locating near Ottawa and Seneca who likewise take extremely high gallonages of water daily from deep vein levels made the same statement before sinking their wells. Ask the farm and city residents who live in northwest Ottawa and beyond in the country, as well as in the Village of Seneca, Manlius Township and parts of Grundy County, what happened to their relatively shallow depth wells once industries started ------- 2272 tapping the deep vein wells in these areas. You've guessed it! Their wells went dry. Consider also the disastrous effect on raising livestock, to say nothing of human needs should this occur! Commonwealth has been totally silent on this point. 6. The effect of the site and its facilities upon drainage in Brookfield TownsKip: The area proposed to be taken presently contains approximately forty percent of the total tiling systems of the entire Brookfield Township area; Commonwealth Edison Com- pany personnel have stated unequivocally that all drainage tiles proceeding through this area will be permanently cut and termina- ted; that the number of tiles proceeding through this territory is, in fact, unknown both as to quality and quantity and that for a long time subsequent to the installation of this project there will be a severe and substantial backing up of under- ground drain waters and permanent flooding of lands not to be taken but presently under cultivation surrounding the perimeter of the proposed site. Without question this constitutes a serious and permanent threat to approximately an additional 2,000-3,000 acres of land adjoining the perimeter of the site proposed to be taken. Based upon competent engineering advice, this committee believes that regardless- of the technological efforts made by Commonwealth Edison Company, it is both an engineering and physical impossibility to keep the entirety of the perimeter of 2,000-3,000 acres from being permanently flooded and destroyed for cultivation to a greater or lesser extent. Commonwealth Edison has been totally silent on this subject. 7. About Lake Brookfield: Again much has been said regard- ing the recreational and conservational value of the proposed Lake Brookfield. We invite you to examine and consider just what Lake Brookfield will consist of. Firstly, it will average about 10 feet in depth. It will average 95 degrees water ------- 2273 temperature. It will be filled with whole, "live",untreated Illinois River water. The Illinois River water contains a high percentage of human and industrial sewage particulate as well as a high brine content despite treatment processing. The Illinois River further contains a high content of phosphate and nitrates. Lake Brookfield will have a system of channels separated by numerous dykes which will protrude above water. We are advised Lake Brookfield will not be a solid uninterrupted mass of water from one shore line to another in any direction. It will resemble water canals as in strip mine diggings. Lake Brookfield will evaporate an estimated 96,000 tons of pure water every 24 hour period at an average annual water temperature of 95 degrees - guess what will be left after normal evaporative losses have been added to the high heat induced losses? Right - you guessed it! How recently have you enjoyed a refreshing swim in the water Illinois Rivex/? How recently have you enjoyed fishing in the Illinois River, plus the further pleasure of eating the clean, wholesome fish you have caught? How recently have you enjoyed the delightful aroma from the Illinois River? How recently have you noticed the green algae scum that forms on both the Illinois and Fox Rivers' during the summer months when the water "lake" reaches a warm temperature point? Bear in mind this/water will be totally untreated and will average approximately 95 degrees annually. In this connection, it is interesting to note a letter recently written by Mr. Thomas G. Ayers, President of Common- wealth Edison, under date of July 31, 1970 to Mr. Daniel N. Beal, Cashier of the Verona Exchange Bank, Verona, Illinois, wherein he states and we quote him directly: ------- 2274 n The original water to fill this lake will come from the Illinois River and the daily evaporative loss will be made up from the river. Because the Illinois River is biologically impure, we are not sure at this point what level of aquatic life the lake will be able to support " And what about Lake Kincade which Lake Brookfield is supposed to duplicate? Lake Kincade is fed by three natural pollution-free water courses. It was formed as a result of a dam on Clear Creek about a mile upstream from the south fork of the Sangamon River. It has an average depth of feet. Because of its low pollution content, it is able to support aquatic life. However, at certain low water seasons of the year there are extensive mud flats adjoining the perimeter of Lake Kincade which prevent people from reaching any of the waters thereof. The average annual temperature of the water of Lake Kincade we are told is 45 degrees to 50 degrees because Lake Kincade receives the discharge waters from the Commonwealth Edison Kincade power station which is FOSSIL FUELED AND NOT NUCLEAR FUELED. Fossil fueled plants discharge about 50$ less heat per kilowatt than nuclear power plants. The two lakes are in no way comparable. 8. About the alternatives-to a cooling lake: Commonwealth Edison as well as all utilities have been aware for years about cooling towers, both wet and dry, as well as spray canals. The United States Government, through the Department of Interior, recommends the use of dry cooling towers or spray canals. We would be pleased to hear from Commonwealth in this regard. It is a known fact that cooling towers require no fan operating power, occupy a fraction only of the ground space required for cooling lakes, reduces hot and cold water piping costs, generate no noise, and discharge their steam or vapor at a high level. ------- 2275 We quote from "Cooling Tower Newsletter", Number 4, issued April, 1968, published by Research-Cottrell, Inc., Harmon Cooling Tower Division, P. 0. Box 750, Bound Brook, New Jersey, as follows: "For extremely large installations such as power generating stations, natural draft towers should be considered. These have significantly higher initial cost than mechanical draft units, but they require no fan operating power, they occupy substantially less ground space, they reduce hot and cold water piping costs, and they offer minimum maintenance over a long service life. In addition, they generate no noise, and also discharge the steam plume at a significantly higher elevation, thus eliminating the problems of low level fog and drift." 9. Commonwealth Edison claims there will be little or no fog arising from Lake Brookfield during cooler or cold weather. You don't have to be an engineer to appreciate the fog potential Lake Brookfield will contribute for many miles to the surrounding territory. Based upon engineering advices serious air pollu- tion conditions may arise throughout the year which will effect a substantial number of lands and acreages within a several ~'.-r >»H mile distance of said lake site, causing fog, mist /general air pollution, and all of which will further effect and produce abnormal weather conditions, thus possibly adversely effecting the cultivation of large areas surrounding the proposed lake site. None of these points have ever been discussed by Common- wealth Edison Company. 10. Regarding the economic loss to the community: The entirety of the 7,040 acres proposed to be taken, with the excep- tion of the area taken for easements for roads and natural water- ways, is highly productive and superior farm land, is rated as Number 1 or prime farm land for eighty percent thereof, and rated as Number 2 or good farm land for twenty percent thereof; that the records and statistics of production of farm products of all kinds, including livestock, grain, and allother farm items produced by this agricultural community approximates one ------- 2276 and one-half to two million dollars worth of retail value annuallyJ the value of all products and services consumed and purchased by the Brookfield Township group, as a direct result of the agricul- tural and retail economy produced by this area approximates $700,000 annually. The area proposed to be taken directly produces approxi- mately 700,000 bushels of feed grain annually, together with 2,000 head of livestock annually, all for public consumption. It is a fact that food shortages can and do repeatedly develop throughout the world and that the present rate of soybean and corn consumption on both the national and international market has soared to thirty to forty percent within the last six months alone to say nothing of the serious corn blight loss problem we are now faced with. The actual feed grain reserves of this country do not constitute in excess of one yearfs supply as dictated by the needs of the national economy and will be further shortened and reduced according to some agronomists. That annually more than one million acres of land are now taken out of production in this country due to developments of one sort of another, i.e., highways, house and building con- struction, and the like; that our populatipn continues to expand and soar and is looked upon as one of the grave issues not only for the present but in the future as well; highly productive andsuperior producing Number 1 farm land should not be taken out of permanent production when other totally non- productive and idle lands available by the thousands of acres can and could be utilized for nuclear energy site facilities. ONCE THIS LAND IS TAKEN IT WILL BE TOTALLY AND PERMANENTLY REMOVED FROM PRODUCTION FOREVERMORE AND WILL, IN FACT, MOREOVER PERMANENTLY ADVERSELY EFFECT A SUBSTANTIAL ADDITIONAL ACREAGE SURROUNDING AND ADJOINING THE SITE. ------- 2277 11. Just what kind of land is Commonwealth Edison proposing to take in Brookfield Township? Much has been said about the average or inferior type of land proposed to be taken. Nothing could be further from the truth. Of all of the 7,000 acres proposed to be taken not one acre is in the soil bank. Approxi- mately acres is in what is known as the Federal Farm Program. This program is entirely distinct and separate and is formed for totally different purposes. This is a year to year program and is designed to balance supply and demand and to keep in reserve a sufficient acreage for future food needs of this country. This reserve, which has long been a factor in American agriculture, is no different from the electrical energy reserve Commonwealth Edison hopes to acquire for electric energy users. It is simply a sensible way of controlling highly productive farm land and has long been recognized by agricultural experts as a method of insuring adequate food supply for the nation:' at all times. 60% of the land proposed to be taken is classified as Number 1 farm land by the United States Department of Agriculture. Number 1 farm land is defined as land which will raise a minimum of 125 bushels of corn per acre with an expenditure of not to exceed $20.00 per acre for fertilizer, and would raise a mini- mum of 40 bushels of soybeans per acre. The remaining 2Q% of the land proposed to be taken is classified as Number 2 farm land by the United States Department of Agriculture. Number 2 farm land is defined as land which will produce not less than 100 bushels of corn, with an expenditure of not to exceed $20.00 per acre for fertilizer, and produce not less than 35 bushels of soybeans per acre. To remove all doubt on this point we are indebted to Mr. Truman Esmond, a local realtor for many years, and who has ------- 2278 been the chief architect and representative of Commonweaxth Edison in attempting to acquire the land in question. In an interview with Kr. Esmond taken on February 26, 1970 by Joan Hustis of the Daily Times under the lead title "Huge Land Acquisition Proposal Under Study", Mr. Esmond had this to say about the character and quality of the land he and the other land representatives of Commonwealth Edison now dispute: "About 7,000 acres, or almost 11 sections, of "prime farm land" are involved in the proposal, according to TrumarT Esmond, the local realtor representing the corporation." LET'S TELL IT LIKE IT IS I Who is for the Brookfield Group? To name a few: The First Presbyterian Church of Grand Ridge, Illinois, United Methodist Church of Ransom, Illinois, Brookfield Presbyterian Church of Marseilles, Illinois, St. Mary's Roman Catholic Church of Grand Rapids Township, St. Patrick's Roman Catholic Church of Ransom, Illinois, Illinois National Farmers Organization, Illinois Farmers Union Fox River Valley Community Action Council, consisting of United Auto Workers Locals 145, 184} 285, 872, 881, 904, 922, 954, 1030, 1088, 1175 and 1615, consisting of 8,000 members in locals from Woodstock to Streator, Illinois, First National Bank of Grand Ridge, Illinois, Cooperative Grain & Supply Co., Laurence Gage, Ruth Gage, Michael Kennedy, Velma Kennedy, Max Ugolini, Coleen Ugolini, Charles O'Laughlin, Geraldine O'Laughlin, John Looft, Cyrus Trowbridge, John Ryan, Louise Ryan, Paul Ryan, Cyril Ryan, Helen Ryan, Joseph Heaton, Mabel Heaton, Larry Heaton, William Heaton, Jerome Heaton, Roy Spaulding, Robert Gage, Doris Gage, William Ross, Lois Ross, Plus an additional 5,000 people who have signed our petitions in the last 90 days. Respectfully submitted, BROOKFIELD TOWNSHIP LAND COMMITTEE By Ruth Gage, Laurence Gage Mary Ann Muffler, Donald Muffler Jean Widman, Mark Vvidman, Jr. Michael Kennedy, Velma Kennedy Max Ugolini, Coleen Ugolini William Ross, Lois Ross John Looft, Ruth Widman, and Robert Widraan, Co-Chairmen KEEP THE FIELDS IN BROOKFIELD/ ------- 2279 ILLINOIS COMMERCE COMMISSION, On its own motion vs. COMMONWEALTH EDISON COMPANY POWER COMPANY, CENTRAL ILLINOIS UNION ELECTRIC COMPANY, ILLINOIS PUBLIC SERVICE COMPANY, CENTRAL ILLINOIS LIGHT COMPANY, IOWA-ILLINOIS GAS & ELECTRIC COMPANY, ELECTRIC ENERGY INC., INTERSTATE POWER CO., MT. CAEMEL PUBLIC UTILITY COMPANY, PEOPLES GAS LIGHT & COKE COMPANY, and NORTHERN ILLINOIS GAS COMPANY. Investigation of Air Pollution in the State of Illinois so far as Illinois Public Utilities are involved. ^ ;«/' 55321 PETITION TO INTERVENE Now comes the First Presbyterian Church of Grand Ridge, Illinois, United Methodist Church of Ransom, Illinois, Brookfield Presbyterian Church of Marseilles, Illinois, St. Mary's Roman Catholic Church of Grand Rapids Township, LaSalle County, Illinois, St. Patrick's Roman Catholic Church of Ransom, Illinois, Illinois National Farmers Organization, Illinois Farmers Union, Fox River Valley Community Action Council, consisting of United Auto Workers Locals 145, 184» 2#5, 872, BBl, 904, 922, 954, 1030, 1083, 1175, and 1615, First National Bank of Grand Ridge, Illinois, Cooperative Grain & Supply Co., Laurence Gage, Ruth Gage, Caroline Whittaker, George Whittaker, Lillian Briner, Henry Briner, Gladys Hallowell, Clifford Hallowell, Michael Kennedy, Velma Kennedy, Kathryn Fleming, Margaret Carey, Max Ugolini, John Kennedy, Helen Kennedy, Stacia Hynds, Hugh Killelea, Mary Danaher, Charles O'Laughlin, Geraldine O'Laughlin, James Kennedy, John Budach, William Bieneman, George Looft, John Looft, Cyrus Trow- bridge, Walter Chrest, George Chrest, Florence Marsh, Dominic Ugolini, Arlene Ugolini, Ronald Briner, Caroline Briner, Emmet Kennedy, Margaret Kennedy, Edwin Morrow, Donald Muffler, Mary Ann Muffler, ------- 2280 John Ryan, Louise Ryan, Paul Ryan, Cyril Ryan, Helen Ryan, Robert Carey, Emmett Moran, Carrie Moran, Joseph Heaton, Mabel Heaton, Larry Heaton, William Heaton, Jerome Heaton, Roy Spaulding, Ronald Frye, Rose Frye, Luella Beacher, Mildred Myers, Thomas James, Benoit Hallett, Marjorie Hallett, John Feidler, Nancy Feidler, Margaret Kennedy, Robert Gage, Doris Gage, David B.edeker, Darlene Bedeker, Raymond Bedexer, Elizabeth Bedeker, Carrie Lou Cleve, Forrest Cleave, Caroline Gage, Melva Gage, Edward Caputo, Venita Caputo, William Ross, Lois Ross, Kenneth Edwards, Parnell Maier, Anna Maier, Elmer Maier, Felicia Maier and Orel Logsdon, by Berry & O1Conor, their attorneys, and petitions this Commission for leave to intervene in the instant proceeding and in support of their position, allege as follows: 1. The various petitioners above named and described are landowners, tenants and other persons, religious and lay organi- zations and groups either residing within or residing closely without and on the perimeter of the territory proposed to be taken by Commonwealth Edison Company of Chicago, Illinois for a nuclear energy generating plant site in Brookfield Township, LaSalle County, Illinois. All of said persons, corporations, organizations and groups have organized to promote and maintain the present and long-standing environmental quality of agricultural and environ- mental life which has prevailed in Brookfield Township, LaSalle County, Illinois since its development as a highly productive and highly valuable farm community and center for over 100 years last past. These petitioners represent to the Illinois Commerce Commission that they will all be subjected to a permanent and total change in environmental land use and development both within and without -the area effected if the taking of said land is per- mitted, for the following reasons: ------- 2281 A. The entirety of the 7,040 acres proposed to be taken with the exception of the area taken for easements for roads and natural waterways for highly productive and superior farm land is rated as Number 1 or prime farm land for eighty percent thereof, and rated as Number 2 or good farm land for twenty percent thereof; that the records and statistics of production of farm products of all kinds including livestock, grain, and all other farm items produced by this agricultural community approximates one and one- half to two million dollars worth of retail value annually; that the value of all products and services consumed and purchased by the above persons, organizations, and entities, all of whom are from the Brookfield Township community, as a direct result of the agricultural and retail economy produced by this area approximates $700,000.00(f«ven h"n;rf? annually. thousand dollars; That the area proposed to be taken directly produces approxi- mately 700,000 bushels of feed grain annually, together with 2,000 head of livestock annually, all for public consumption. That it is a fact that food shortages can and do repeatedly develop throughout the world and that the present rate of soybean and corn consumption on both the national and international market has soared thirty to forty percent within the last six months alone. That the actual feed grain reserves of this country do not consti- tute in excess of one year's supply as dictated by the needs of the national economy. That annually more than one million acres of land are now taken out of production in this country due to developments of one sort or another, i.e., highways, house and building construction, and the like; that our population continues to expand and soar and is looked upon as one of the grave issues not only for the present but in the future as well; that highly productive and superior producing Number 1 farm land should not be taken out of permanent ------- 2282 production when other totally non-productive and idle lands available by the thousands of acres can and could be utilized for nuclear energy site facilities; that once this land is taken it will be totally and permanently removed from production for- evermore and will in fact adversely effect a substantial additional acreage surrounding and adjoining the site. B. That immediately to the north and adjoining this property lies approximately 5,000 acres of rough, unproductive land, a large portion of which is already owned by Commonwealth Edison Company; that this land is, in fact, available to the Commonwealth Edison Company and its availability as an alternate site should be considered and inquired into in depth by the Illinois Commerce Commission in connection with its general inquiry into this sub- ject matter. That to date hereof the Commonwealth Edison Company has refused to. reveal its engineering data or studies as to the feasibility of developing this alternate site or any other alternate site, except by general statements indicating increased costs would ensue but without divulging any particulars. It is the opinion of these petitioners, based upon competent engineering consultation and advice, that in fact, the 5,000 acre tract adjoining to the north could be equally utilized and developed for identical atomic energy producing purposes; that the 5,000 acres of rough, unpro- ductive land to the north produces little or no agricultural products, is largely idle, and could well be utilized as an energy producing site; that a visual inspection and comparison Of the two areas clearly reveals a total and complete distinction in soil fertility and productive capacity and quality. C, That the area proposed to be taken presently contains approximately forty percent of the total tiling systems of the entire Brookfield Township area; that Commonwealth Edison Company ------- 2283 personnel have stated unequivocally that all drainage tiles pro- ceeding through this area will be permanently cut and terminated; that the number of tiles proceeding through this territory is. in fact, unknown both as to quality and quantity and that for a long time subsequent to the installation of this project there will be a severe and substantial backing up of underground drain waters and permanent flooding of lands not to be taken but presently under cultivation surrounding the perimeter of the proposed site. That this constitutes a serious and permanent threat to approximately an additional 2,000 acres of land adjoining the perimeter of the site proposed to be taken. That based upon competent engineering advice, these petitioners believe that regardless of the technological efforts made by Commonwealth Edison Company, it is both an engineer- ing and physical impossibility to keep the entirety of the perimeter of 2,000 acres from being permanently flooded and destroyed for cultivation to a greater or lesser extent. D. That these petitioners have further been informed that the surface of the lake area will constitute approximately 4»500 acres; that the temperature of the water being emptied into this lake, after cooling the generators to be located on the proposed site, will vary between 70 and 110 degrees; that by reason thereof these petitioners state, based upon competent advice and counsel, that serious air pollution conditions may arise throughout the year which will effect a substantial number of lands and acreages within a several mile distance of said lake site, causing fog, mist, general air pollution, and will further effect and produce abnormal weather conditions, thus, adversely effecting the cul- tivation of large areas surrounding the proposed lake site. E. That these petitioners further state that the Common- wealth Edison Company proposes to take from the Illinois River tens of thousands of water a day and that this water, which ------- 2284 contains a substantial percentage of salt and sewage, will be pumped into the proposed lake in the middle of the farm community of Brookfield Township. That engineering estimates indicate some 60,COO tons of water will evaporate daily from this lake site and that since mainly clean water will evaporate, the brine and sludge particles pumped from the Illinois River will remain behind and settle in the lake; that by reason thereof opprobrious odors may well result and that further the environmental quality of the lake will be seriously reduced and hampered due to the resulting sludge and brine condition. F. That to supplement the water supply to be taken from the Illinois River, the Commonwealth Edison Company intends to put down numerous deep wells to pump thousands of gallons of water a day from the basic water table underlying all of Brookfield Town- ship; that although the Commonwealth Edison Company proposes to draw water from a deeper level than that presently serving Brook- field Township, repeated similar deep well drawings heretofore carried out by other industries in other parts of LaSalle County have conclusively shown that the current water levels used for general consumption by the public of this area located at 300 to 500 to SOO feet sublevel in these other areas have been greatly effected and depreciated by such other deep level -withdrawals of -">ter. That, accordingly, these petitioners believe the value of the remaining land will be greatly reduced throughout all of the township despite precautions and engineering techniques Commonwealth Edison Company might introduce as to this factor. 2. These petitioners further state that, in their opinion and based upon competent engineering advice, it is technically possible for Commonwealth Edison Company to locate their proposed nuclear ------- 2285 generating site upon and within the 5>000 acres of rough and unproductive land located immediately north of the proposed site or upon other unproductive lands located elsewhere in the State of Illinois and thereby significantly and totally remove all of the environmental loss which must and will ensue to the Brookfield Community if the Commonwealth Edison Company is permitted to ob- tain the proposed site. 3. The Illinois Commerce Commission has the responsibility and power to protect the public safety and environmental welfare by ordering the Commonwealth Edison Company to remove and relocate its proposed site to either the site immediately north and which is presently available to it or to some other site within the State of Illinois; that, in fact, the Commonwealth Edison Company has used lands of extremely inferior value, being those located in Christian County, Illinois for their electrical generating site near Kincade, Illinois; that further, in fact; the land heretofore used and presently being used by Commonwealth Edison Company at its Dresden, Illinois plant located outside of Morris, Illinois, is inferior land and of extremely poor quality, none of which is in any way productive or comparable with the Brookfield Township properties proposed to be taken; that, in addition, the site proposed to be used by Commonwealth Edison Company for its plant located near the Quad-Cities, at Cordova, Illinois consists of very sandy type soil and is of thin and marginal quality and productiveness. That, in addition, to the rough site located to the north and presently available to Commonwealth Edison Company, there are literally thousands of acres of rough and unproductive land located throughout the State of Illinois upon which all of such proposed site could be located. These petitioners state that current costs of transmission are no longer a factor as witness the Kincade plant and Quad-Cities plant, independent ------- 2286 engineering counsel also confirms this. Accordingly, there is available to Commonwealth Edison Company a multitude of sites which should be considered and inquired into by the Illinois Commerce Commission. 4- These petitioners further state, based upon the literature available to them and published by the utility industry, that it is the proposal, not only of Commonwealth Edison Company, but of other utilities to install throughout all of northern Illinois plant sites located upon similar land and that presumably 7,000 to 10,000 to 12,000 acres of farm land comparable to that proposed to be taken will be needed for each site. That, accordingly, the pro- posed Brookfield Township taking is indeed significant and will set a precedent not only for this particular area but for the entire State of Illinois and these petitioners respectfully and urgently request the members of this Commission to make full and due inquiry in all particulars and thus meet its responsibility to these petitioners and to the public. WHEREFORE, these petitioners request leave to intervene in this proceedings and to be treated as parties to this proceeding and ask the Commission to grant the following relief: A. To order Commonwealth Edison Company to utilize existing technology to the maximum feasible extent in relocating its proposed nuclear energy site upon unproductive and unfertile land lying idle and having no agricultural value, and B. That the Illinois Commerce Commission expand its inquiry on its own motion under and within its investigative docket to include all activities of all Illinois utilities which might create or cause deleterious effects upon or to agricultural and all other environmental land uses as the same are subjected to utility uses from time to-time. ------- 2287 C. Require the Commonwealth Edison Company to show that it has exhausted all reasonable and proper alternatives to the proposed Brookfield site. D. That it deny to the Commonwealth Edison Company any use whatsoever of the proposed Brookfield site for nuclear energy generating purposes. E. To grant such other relief as will protect the health, safety, agricultural and ecological environment of the Brookfield Township area and the citizens thereof. Respectfully submitted, BERRY & 0CONOR, Attorneys for Petitioners, STATE OF ILLINOIS ) ) ss. COUNTY OF LASALLE ) VERIFICATION ANDREW J. 0CONOR, being first duly sworn upon oath, deposes and states that he has read the foregoing petition by him sub- scribed and that the matters therein alleged are true and correct to the best of his information and belief. Andrew J< 0'Conor Subscribed and sworn to before me this /f- day of August, 1970. ,<> Not otary Public. BERRY & OfCONOR Attorneys for Petitioners 130 East Madison Street Ottawa, Illinois Telephone: (&L5) 434-6206 ------- 22&B D. D. Comey MR. STEIN: I have a statement from an old friend of the conferees, I guess, John Chascsa, Lake Erie Cleanup Committee, and I would like to put it in the record as if read without objection. (The statement above referred to follows on Pp. 2239-2290.) MR. STEIN: Do we have Frederick M. Brown? David D. Comey? He was here before. There he is. STATEMENT OF DAVID D. COMET, DIRECTOR, ENVIRONMENTAL RESEARCH, BUSINESSMEN FOR THE PUBLIC INTEREST, CHICAGO, ILLINOIS MR. COMEY: Mr. Stein, a funny thing happened to me on the way to the conference. A couple of weeks ago I wrote to Mr. Klassen and asked if I could appear today, and I didn't get an answer from him. But yesterday his secretary called my secretary and said that I should be prepared to testify at 9:30 a.m., Tuesday, October 6, and I find when I come here today that, alas, we are not scheduled. So since I have taken so much time already today, I would like with your permission to submit a written ------- 2239 September 23, 1970 Lake Michigan Snforcercent Conference Sherman House 100 tfest Randolph 3treet Chicago, Illinois Attentipns Chairman, Murray otein, Chief iinforceaent Officer Interior's Federal .Vater Duality Administration Dear i'ir. 3tein: It is indeed encouraging to learn that all types of Pollution are being investigated by your Coraraittee. '.Ve have, on many occasions, heard that one type of waste after another is responsible for the condition of our Lakes, Hivers and streams. In some instances we have condemned the use of our waters ar> durapAn-^ grounds or hiding places for unwanted waste sewa/je, rofuse and hot water from large Industries, However, it took our President, Hichard .•;. Nixon to open our eyes to the serious dangers involved in permitting Thermal Pollution to further complicate our Snvironaental problems. 3o, if Hiscayne Uay can Beccrae a living mass of Algae interspersed with dead and dying marine and bird life, this could and would crente a very nauseating stench in the area, (which by the way is the location of our Southern «hite House, it inn't used much, but it i« th-ire.) You can im'.r^ino what could ha j?p«n to Lake Michigan, Lake Srie or for that •natter any of our inland Lakss. La're Michigan is the moat vulnerable though, and then Lake -Srie. Lake Michigan from Muskegon to -'^»ry, Indiana, and then on to Chicago is (as you km--") the natural pocket with no pl^ca for the water to flow. This area has for many years received all sorts of wnste, it has been the cause of many illnesses, much fish and wild fowl rnort slity, and could become a hot bed of mora of the same, if permission to use Lake Michigan ware granted to cool industrial or municipal hot water. Why must the general Public have to accept the loss of the use of a Public Lake, Stream or River, and be ex ected to pick up the tab for cleaning up the mess when it becomes too unbearable? There are, as you have pointed out, many ways to cool and purify water and there are some that have not even been considered. ------- 2290 page 2 Mr. M. otein Sept. 23, 1970 Perhaps the state of Michigan's Fisheries Departaent are expecting to use the warmer water to escalate the growth of the Coho that is being planted by them, or perhaps this is a good way to get a ready cookad meal* Seriously, the Lake Krie Cleanup Committee supports your stand on pro- hibiting the use of our Lakes as a depository of Thermal Pollution, or any other form. Knowing the area around Ludington, I would suggest that these combined systems be used - such as an inland cooling Pond with spray and return canals for re-use in the plant or into the Lake. Due to unforseen circumstances I am unable to attend this conference, but would Like to take this opportunity to voice the opinion of the Lake Srie Cleanup Committee, and the Monroe County Hod and Gun Club , and to thank you for this presentation. for a better Environmental tomorrow, I remain. Sincerely,-, John Chascsa, President ./Lake Srie Cleanup Committee, Inc. ec: Conferees: Illinois Environmental Protection Agency, Wisconsin Department of Natural Resources, Indiana Stream Pollution Control Soard, Michigan Water Resources Commission ------- 2291 D. D. Comey statement to be entered into the record at a later time« MR. STEIN: Can you get that in next week? MR. COMEY: I will get it to you by Tuesday. MR. STEIN: It will be included in the record. MR. COMEY: Thank .you very much. MR. HARPER: Mr. Stein, since this gentleman — MR. STEIN: Come on up here. We can't hear you. MR. HARPER: I am John D. Harper, and I would like to know what this gentleman's testimony will relate to next week. I want to know if I am going to be missing anything as to what particular line of thought he has on this. I wonder if he could just very briefly — since he has previously expressed himself — if he could very briefly just encapsulate a couple of his views. Would you be kind enough to do this? This is with your permission. MR. STEIN: Oh, surely, he can respond to this if he wishes. MR. FETTEROLF: May I ask who Mr. Comey represents ? MR. COMEY: I am representing Campaign Against Environmental Violence, a Chicago not-for-profit corpora- tion organized in April 1969. MR. STEIN: I guess I might have read that. Do you want to respond or not? ------- 2292 D. D. Comey MR. HARPER: I can appreciate that off the cuff it may be difficult, but it would be appreciated if you could just encapsulate somewhat briefly your views while we are all present. MR. COMEY: Well, briefly what I was going to talk about, Mr. Harper, was that it is my feeling that the time for research and for study is past. I think — I won't say is past, but with respect to setting a thermal criterion for Lake Michigan, at the present time, I think it is past. I think that at the present moment the Federal paper which was presented last week to the public ought to be supported by the four other conferees, and I hope that if they see their way to supporting that, this entire issue will be resolved before the enforcement conference wends its way through the ISO-day procedure. MR. HARPER: I concur with you and I have indi- cated in testimony I too support this. I support this on the basis of the last conclusion for ecological reasons, and I am sure you do. I think we are all people of good intent. For ecological reasons we support this. But for ecological reasons we should not be in this auditorium. The carbon monoxide level here right now may be 9 or 10; the permissible level is 13 p.p.m. So,"for ecological reasons "does not always govern, and I just make this point, ------- 2293 D. D. Comey that we live in a society that is a rather magalopolis from Milwaukee to Gary, and you must take into context a number of these factors if we are going to present to the board all of the testimony for the past week or 10 days, I am glad to have your view. I agree with you wholeheartedly. For ecological reasons we should stop the heat — for ecological reasons. Something I am far more concerned with is the chemical degradation, but ecological reasons do not always govern. It is unfortunate but that is the way of life. I didn't mean to — MR. COMEI: There is probably one other thing that I shall point out in my written statement, and that is that based on all of the industry projections — and these were brought out in the Federal paper — the number two paper on the alternatives to thermal discharge — the incremental cost of providing alternatives of cooling are very small. Now, the Federal paper chose to use busbar costs. I think that is somewhat unfortunate because the public is not aware that the percent increase in busbar costs is considerably higher than in the incremental cost to the con- sumer. Normally busbar costs are about 21 percent of power charges. So that even assuming that the 9 percent for just cooling towers is the busbar incremental cost, this would represent less than a 2 percent additonal cost, ------- 2294 D. D. Gomey and that on the average house-holder's bill it would be approximately 24 cents a month. Now, for a quarter, if we save Lake Michigan — MR. HARPER: For a quarter, I am sure, for a dollar even. But if you put this off on the American public what are they going to do? What has the experience been in the proliferation of trash? We are no better. But for a quarter — and what is before the board here now is the determination to come up with either a standard or some means that is consistent with the needs of society and the people that vote, and these people have in mind that, "Oh, it is all right; let the American public pay another 25 cents.H As you say, it may not set too well. It is unfortunate but it may not. So we are in agreement there, and I am glad to have your views. I think the value of this whole confer- ence is the diversity of opinion, and as long as we have this forum, it is essential. I think that this board — if I might just proselytize a little — Mr. Stein has shown remarkable objectivity to me — not to me personally but to the diversity of views. How these gentlemen can sit through a week of this is beyond me. We are drawing to a conclusion now, fortunately, I would imagine. I think that the point is well taken, but I ------- 2295 D. D. Comey would just like to emphasize the ecological reasons do not always govern, unfortunately. The pristine purity of Lake Michigan can never be restored to the time that Kinsey was first living on its shores, MR, COMEY: Mr, Stein, may I be permitted to ask you one question? MR, STEIN: Tes, Is the colloquy completed? MR, HARPER: Yes, thank you, MR, STEIN: Go ahead, MR, COMEY: Supposing by December the other four conferees from the States are unable to agree upon any standard or criterion for thermal discharges to Lake Michigan? Is it possible for the Secretary of Interior upon recommendation of the Federal Water Quality Adminis- tration and other constituent bodies with the Department of Interior to lift the thermal criterion out of the enforcement conference and set Federal standards? MR, STEIN: Well, whenever you ask a question of a person in the field you get the same kind of problem we had when we asked Professor McWhinnie something in her field. One, I would suppose that — because of my past experience with these conferees, and I have been working with these States for a long, long time — ------- 2296 D. D. Comey we are going to come to an agreement, and I am very confident that we will. The remarkable thing about our process of govern- ment or this process is, untidy as it may seem to many, we can resolve problems and come up with solutions even though we can't agree on philosophy, professional discipline, jargon, or what we think is the right way to express some- thing. However, we have two operations here: One, we have an enforcement conference; and, two, we have a standard- setting procedure. If we adopt the standard-setting pro- cedure and we hold a Federal standard-setting conference, we have to give notice; we have to put that out. We will have to give the States six months to protest, and it is all built into the law. That is a rather time-consuming process. MR. COMEY: You are talking about the ISO-day procedure? MR. STEIN: No, I am not talking — as I say, the law is very complicated. If we would set a Federal standard, we hold the conference with the State, have all you people in again, make another record, and then we set a Federal standard. Then we publish that in the Federal Register — first, we publish it before we go out, then we ------- 2297 D. D. Comey publish it again. Then we give the State six months to file a disagreement. Then if they do, we have a hearing. We are in a process like that with Iowa thermal standards, among other things, and that is taking quite a time. I think if I sensed the feeling of the four States here as well as the Federal Government, we recognize the urgency of this problem and except as a last resort we will not permit ourselves to embark on a confrontation course between State Government and Federal Government which, by virtue of the time consideration, that is built into our statute, would place a resolution of this problem maybe a year off. So I think we are all going to make a valiant effort to try to solve this by negotiation and discussion through this conference technique. Otherwise if we go the other way, it is at least going to be probably a year away before we can promulgate a Federal standard which should stand up, assuming that it is not modified in any way by the procedures that we have to go through in between. MR, COMEY: So I take it that what you are saying is that this will be solved far sooner than the one year that would be necessary under the other procedure, MR, STEIN: I am always optimistic. That is why ------- 22 9S H. B. Olin I am here, and that is why we go into the night* There isn't a place we won't go, nor a place or something we won't sit through, and patiently sit through, all of the evidence to try to cut that time down. If we wanted to sit on our bureaucratic doubts and just act the way we are authorized to act under the law, sure we can kick these procedures off, but it will take a long, long time before you would get a resolution, I think this is the best way and the fastest way, I would like to give it a chance, MR. COMEY: Thank you, MR, STEIN: May we have Harold B, Olin? STATEMENT OF HAROLD B. OLIN, AIA, MEMBER, BOARD OF DIRECTORS, LAKE MICHIGAN REGION PLANNING COUNCIL, CHICAGO, ILLINOIS MR. OLIN: Mr0 Chairman, members of the con- ference, ladies and gentlemen, I am appearing today on behalf of the Lake Michigan Region Planning Council, a 4-State planning organization sponsored by the American Institute of Architects Chapters of the States of Wisconsin, Illinois, Indiana, and Michigan. It is the objective of the organization to study resource problems from a ------- 2299 H. B. Olin regional point of view and recommend courses of action to governmental units and agencies. The shores of Lake Michigan are ringed with a deadly necklace of some thirty power generating plants and a multitude of industrial plants spewing their waste effluent into the lake in ever-increasing amounts* Power- plants alone in 1963 were dumping almost 30 billion B.t.u.Afe per hour of waste heat into the lake and the total for all industries and sewage treatment plants is over 40 billion B.t.ufeper hour. By the year 2000 these figures are expected to increase almost 11-fold to431 billion B.t.u.Vs per hour. Department of Interior and independent scientific studies document the devastating effect of these thermal discharges into the lake. Professor John Bardach of the University of Michigan, whom you heard earlier today also testified recently at several hearings on powerplants as follows: "One electrical generating plant will have some adverse effect and several of them would exacerbate conditions in a more than additive manner, due to the prevailing hydrographic conditions set forth below0 vSome scientists believe that heated water remains on the surface and quickly loses heat to the ------- 2300 H. B. Olin atmosphere rather than to the water. However, present knowledge of water-air heat exchange and heat exchange between water masses in the regions of Lake Michigan to be affected is incomplete as there is not available informa- tion on all possible weather conditions such as patterns along the shore under which these exchanges would take place, Nevertheless, and especially if there are a dozen electri- cal generating plants along the shoreline and if the currents flow along this shore as they are indicated to do, long-term adverse effects of heating the shallow water are likely to occur and eutrophication is likely to be accelerated," The First Annual Report of the Council on Environmental Quality states the problem in different words but with the same thrust. It also highlights the need to curtail thermal discharges, and I quote: "Waste heat is one of the most serious emerging sources of water pollution. The electric power industry, which currently discharges over #0 percent of all the thermal heat into the Nation's waters, doubles its capacity every decade. The trend toward larger, nuclear plants, which creates 50 percent more thermal pollution in water per unit of power than fossil-fuel plants, could result in damage to aquatic systems, if it is not controlled. ------- 2301 H. B. Olin With the tremendous thermal pollution potential of projected power production, it is fortunate that waste heat from electric generating plants can be adequately controlled. Waste heat and thermal pollution can be reduced by improving the efficiency of the plants; by making productive use of heat; and by the use of cooling towers, cooling ponds, or spray ponds." Recognizing the need for additional power to serve the needs of a burgeoning economy, the Council's report recommends a National power policy based on broad based regional criteria of sound planning and environ- mental protection, which we heartily endorse. The Coun- cil's report says: "For example, the need for a National energy policy is clear. As the demand for power increases rapidly, new power facilities have to be built. Power- plants will pollute the air with oxides of sulfur and nitrogen, the water with heat, and the landscape with mammoth towers and obtrusive power lines." In his message to Congress transmitting the report of the Council, President Nixon emphasized: "Unless we arrest the depredations that have been inflicted so carelessly on our natural systems — which exist in an intricate set of balances — we face ------- 2302 H. B. Olin the prospect of ecological disaster .... "Natural systems are generally 'closed systems. Energy is transformed into vegetation, vegetation into animal life, and the latter returns to the air and soil to be recycled once again. Man, on the other hand, has developed 'open* systems — ending all too often in an open sewer or an open dump. "We can no longer afford the indiscriminate waste of our natural resources; neither should we accept as inevitable the mounting costs of waste removal. We must move increasingly toward closed systems that recycle what now are considered wastes back into useful and productive purposes. This poses a major challenge — and a major opportunity — for private industry." The concept of closed systems endorsed by President nixon implies not just minimal discharges, but zero discharges into the lake. We support that stand and urge this conference to adopt a standard which would prohibit any thermal additions to the lake from any source. Thank you. I have a personal remark at this point. I am reminded of a statement made by a knowledgeable observer about a year ago, who pointed out that Lake Michigan, and ------- 2303 H. B. Olin especially the southern tip of it, is very much like a pus-filled appendix on the "bowel of civilization." I myself could use simpler terms to describe the same phenomena but in any case I want to point out that the patient is critically ill and surgery is needed immediately and I urge the conferees to take appropriate action — very drastic action — as soon as possible. Thank you. MR. STEIN: Thank you, Mr. Olin. Are there any comments or questions? If not, thank you very much, sir. I have a statement I would like to put in the record as if read from A. J. Boehm, Executive Vice Presi- dent of American Fishing Tackle Manufacturers Association. (The letter above referred to follows on P. 2304.) MR. STEIN: I think we called on these names before. Mrs. Paul Kaefer. (The following statement was submitted to be entered into the record as if read.) ------- CENTRAL 6-0565 • AREA CODE 312 2304 AMERICAN FISHING TACKLE MANUFACTURERS ASSOCIATION 20 NORTH WACKER DRIVE • SUITE 20M CHICAGO, ILLINOIS 60606 October 2, 1970 Mr. Murray Stein, Chairman Lake Michigan Environment Conference Sherman House Chicago, Illinois Statement of A. J. Boehm, Executive Vice President American Fishing Tackle Manufacturers Association Over the past four days much has been said pro and con about heated water from atomic power plants damaging Lake Michi- gan. We do not propose to reiterate these arguments; rather, we desire to have the records show that this Association sup- ports the U.S. Government's proposed maximum of one degree heat rise in waste water discharged into the Lake from power generating sources. Also, we would like to speak for the fisherman. Approximately 25 per cent of the 30-some million people who live in the four states surrounding Lake Michigan are fishermen. As fishermen, they violently oppose taking any risk that may jeopardize the fish, their sport, and also as a food supply. The public is aroused and rightfully deeply concerned. The public is not of a mind or mood to accept any tinkering with their natural resources. The public is not objecting to any increased costs for the installation of cooling facilities at generating plants. The pub- lic has learned that it is much easier to prevent pollution before it starts than it is to stop it after it has begun. Lake Erie is cer- tainly an example. True conservationists who have studied the deterioration of our environment recognize the need for caution. Their watchword is "When in doubt, don't". Signed A. >J. Soehm Executive Vice President ------- 2305 Mrs. P. Kaefer STATEMENT OF MRS. PAUL KAEFEE, CITIZEN, NORTHBROOK, ILLINOIS MRS. KAEFER: My name is Mrs. Paul Kaefer. I live at 3921 Oak Avenue, Northbrook, Illinois. As a citizen I feel that the lake is my resource. A When I use it I have a responsibility to not abuse it. All citizens, utilities, and industries have this responsibility, None of us must interfere with the nature of the lake. I ask you to set standards that would permit no heat to go into the lake. In this age of space travel and other technical achievements, it is imperative that utilities and industries use such technological knowledge and devise methods so that no heat enter the lake. I have a family to return to and my responsibili- ties do not permit me to stay past 11:30. I came at 9:30. I want my testimony entered into the record. MR. STEIN: Mrs. Robert Herlocker. ------- 2306 Mrs. R, Herlocker STATEMENT OF MRS. ROBERT D. HERLOCKER, CALUMET AREA BRANCH, AMERICAN ASSOCIATION OF UNIVERSITY WOMEN, MUNSTER, INDIANA MRS. HERLOCKER: My name is Mrs. Robert D0 Her- locker of Luast^r, Indiana. I am representing the Calumet Area Branch of the American Association of University Women. The thermal standard proposed by the Department of the Interior gives us a ray of hope that man will have the intelligence to take action in time to avert disaster,. We do not ask, we do not request, we do not urge, we demand that the States adopt the recommended standard. Most of our members live in Indiana in the Calumet region. In efforts to do something to clean up our environment, we encounter nothing but excuses and buck- passing between the State and local agencies: "We don't have the manpower to do the job." "fcfe don't have the monitoring equipment." "We don't have the money." "These things take time." "The laws aren't strong enough." "Industry has a timetable." We say to you now, and I address myself primarily ------- 2307 Mrs. R. Herlocker «, the Indiana representatives, all y.u need is the «isdom, Q«H the backbone to accept these recommenda- the integrity, ana ™ ou are net servants of the Republican ~aMr rty, <»r of industry; you are Party, of the Democratic servants of the people -_ said: "To every thing there is a Ecclesiar ^o every purpose under heaven." This season, and a tiff .fill your purpose in the public interest. is the time to fEIN: Thank you, Mrs. Herlocker. MF MILLER: I only have one comment. all my time in public service if there is know it is that I am a servant. I always have one tr ilways will be. MRS. HERLOCKER: And you tell them in Indianapolis .blic is after you and they have got to do something. MR. STEIN: Thank you, Mrs. Herlocker. May we have H, R. Thoke? Is H. R. Thoke here? Mrs. Winston? Mer. Berghoff? Mr. James Sloss? (See P. 230S) Mr. Michael R. Rouse? (See P. 2309} Mrs. Maynard J. Seidmon? (See P. 2310) Mrs. Lyman Barr? (See P. 2311) Mr. Aaron Wolff? (See P. 2312) ------- JAV1ES SLOSS SOS SKOKIE LANE GLENCOE, ILLINOIS SOO55 U rta RECEIVED SEP28S70 ,,- r i ------- I \ I \1 ( 0 ------- ------- 2307 Mrs. R. Herlocker to the Indiana representatives, all you need is the wisdom, the integrity, and the backbone to accept these recommenda- tions. Remember, you are not servants of the Republican Party, of the Democratic Party, or of industry; you are servants of the people. Ecclesiastes said: "To every thing there is a season, and a time to every purpose under heaven." This is the time to fulfill your purpose in the public interest. MR. STEIN: Thank you, Mrs. Herlocker. MR. MILLER: I only have one comment. In all my time in public service if there is one thing I know it is that I am a servant. I always have been and always will be. MRS. HERLOCKER: And you tell them in Indianapolis the public is after you and they have got to do something. MR. STEIN: Thank you, Mrs. Herlocker. May we have H0 R. Thoke? Is H. R. Thoke here? Mrs. Winston? Mer. Berghoff? Mr. James Sloss? (See P. 230#) Mr. Michael R. Rouse? (See P. 2309) Mrs. Maynard J. Seidmon? (See P. 2310) Mrs. Lyman Barr? (See P. 2311) Mr. Aaron Wolff? (See P. 2312) ------- 2303 JAMES SLO55 EOS 5KDKIE LANE GLENCDE, ILLINOIS BOO52 RECEIVED ENVIRONMENTAL Pf.CTECHDft AGi^Ci STATE Oril'JSKS ------- 2309 uv RECEIVED '~VN _-A / ' I . t^t t>c w -^ w* dt&Jc- fciM-^tt c csW \|A £WN tc g^p 2 9 1970 ' — StSS "" . G&A : e( 4 & It C ^.-t x u . ili ^^i LJ , at - C C cuJ^C;a- l^c^Xxi-^ '-^^^^t«,<^- ^^>^t^ . Vt ^ t ^ ------- 2310 MRS. MAYNARD J. SEIDMON 1064 SKOKIE RIDGE DRIVE, GLENCO£, ILLINOIS 60022 , _ RECEIVED SEP 28 1970 l~~4.^ ^£< XJU, .XU-A^ ------- 2311 (The following letter, dated September 25, 1970, from Mrs. Lyman Barr, 1005 Wade Street, Highland Park, Illinois 60035» was received by the Environmental Protection Agency, State of Illinois, on September 23, 1970, and was submitted for inclusion in the record.) Mr. Clarence Klassen Illinois Environmental Protection Agency 535 W. Jefferson Street Springfield, Illinois 62703 Dear Sir: I feel it is of the utmost importance that the k-State Enforcement Conference on Lake Michigan Pollution should adopt the strictest possible standard in respect to thermal pollution — that announced by the Department of the Interior. I urge you to do everything you possibly can to bring this about. Yours truly, (Signed) Lucy M. Barr ------- SEP 2 8 1910 2312 AARON S. WOLFF II SOUTH LA SAULE STREET AREA CODE 312 CHICAGO 6O6O3 FRANKLIN 2-5461 ,\ r ' l!" '•"" September 24, 1970 Mr. Clarence Klassen Illinois Environmental Protection Agency 535 West Jefferson Street Springfield, Illinois 62706 Dear Mr. Klassen: Since you are head of the Illinois Environmental Protection Agency, I strongly urge that you do all in your power to avoid thermal pollution of Lake Michigan. At the forthcoming Federal-State Enforcement Conference on pollution of Lake Michigan, I certainly hope that you will push for adoption of the strictest standard under consideration. This would be that of the Department of the Interior which would sanction only the minimum possible waste heat to be discharged into Lake Michigan or a 1° F. rise over ambient at the point of discharge, whichever is less. Very truly yours, Aaron S. Wolff ASW:sf ------- 2313 Closing Remarks - Mr, Stein MR. STEIN: I guess that is all the people's names I have. Now, does anyone who hasn't been called feel that they want to say something now, because we are going to close? If not, I would like to thank a lot of you for bearing with us. I know some of you have stayed with us all week, and I think we have amassed quite a record. There is one thing I would like to say for this process, and I have always been proud of this in a way. I think we have a document here in the transcript of this conference which is going to be invaluable. I find when we finish these things that the researchers, the planners, the analysts through the years in going for hard information that they can use constantly turn to these transcripts. Now, again, the pride I have is this: If Government — I don't know, maybe industry is a little bit wealthier — but if the Government were to amass this kind of thing through the other processes that they have in grants or contracts, I will bet that this would cost about a half a million dollars — what we have here. We got this and a good portion of this has been a contribution to the public good, and we couldn't have gotten it without the volunteer action of the citizens, ------- 2314 Closing Remarks - Mr, Stein the municipalities, the industries, the State Government, concerned. And certainly all of these groups have brought in scientists, consultants, other interests that one would have been beyond the capacity of the Government alone — any government — to assemble, and certainly beyond our budgetary capacity. That is one of the great things about these democratic institutions—that we have drawn on the kind of talent and the considered statements that we could draw on for the past week, and we were able,without I think getting really out of hand from the standpoint of a disciplinary way,to have a cross-examining of ideas and questioning as far as we could, I think you all must appreciate that this is a very difficult thing to do, because we have people from disparate backgrounds, disciplines, and ways of doing business coming here. These conferences are a lot easier to handle when we just have the conferees asking questions, or you have a much easier job if you just have lawyers arguing back and forth or questioning back and forth or presenting evidence under their rules — at least what we think are rules — or if you have biologists or you have engineers or architects who know how to operate, I think the wonderful thing is that we could ------- 2315 Closing Remarks - Mr» Stein hold a meeting like this and get all of the people with different backgrounds and different disciplines to focus on the problem, and I think that the people who have been here — I would say about 99»44 percent of the material put in was germane — germane to the problem, and that also is wonderful. You may not have agreed with it, but it was what someone thought we should know about the problem. Now, I have this to suggest to the conferees, and I don't want anyone to think this is a suggestion that I haven't floated around for the past day to see what its acceptance would be. In view of the complexity of the matter, I would ask that the conferees go back to digest this material, caucus and advise with their technical staffs, as I will. I know next week a lot of us are committed to be in Boston where the Water Pollution Control Federation is holding its meeting and we are going to need the week anyway. I would suggest possibly the week after that, I would ask the conferees — and I would like to keep this meeting as small as possible, if we can, for participants, because we are going to try to come out with an agreement and a program — that the conferees meet with their views and their proposals, and we sit down and try to come up with conclusions and recommendations which we can present. ------- 2316 Closing Remarks - Mr. Stein I would urge the conferees to get together with their neighboring States, Federal representatives, and others, caucus as much as you like, and I think the more caucusing you do before you get there, the better off we are going to be, whether you do it in Boston or over long distance telephone, or any other place . I am optimistic that we will be able to arrive at a conclusion when we meet, say, the week after next. But if we can't, at least see how many areas of agreement we can sign off on, and whether there are any areas that we have to put off because we can't come to an agreement. There is just one more thing. This problem is on us. I don't think it is going to go away, I don't think it is going to wait, and I don't think — while I haven't made a poll, I don't think the public is going to wait very long for an answer. I want to again thank you people. Right now the ball is on this side of the net. The Federal and State officials have got it right in their court, and I think we will have to move from there. Do any of the conferees — MR. CURRIE: Yes, Mr. Chairman. I would like to introduce into the record a letter which I sent to Secretary Hickel on September 17> ------- 2317 Closing Remarks - Mr, Stein making certain suggestions for the format of future pro- ceedings in the conference, among other things suggesting that the conference publish an agenda in advance so that we know what we are to discuss at our meetings; in addition that conferees and expert witnesses be asked to supply reports in advance so that we have time to understand them; and among other things reconvene the conference every three months 0 And I would like to make that suggestion now, Mr. Chairman, that we meet again in three months after we have solved, if we have solved, this thermal pollution question, in order to consider other pollution problems that are equally pressing, MR, STEIN: We will consider all those sug- gestions and, I think, without objection, that letter will appear in the record, (The letter referred to above follows on Pages 231S-2320.) ------- 2316 STATE OF ILLINOIS OOLLUTIOM carvrrROL. BOARD 189 WEST MADISON STREET CHICAGO. ILLINOIS 6O6O2 _ TEL. No. 312-793-3620 September 17, 1970 Secretary Walter J. Hickel U. S. Department of the Interior Washington, D. C. 20242 Dear Mr. Secretary: On September 28 the Lake Michigan Enforcement Conference will reconvene in Chicago for a five day "workshop" session. The Illinois Pollution Control Board is the agency charced with statutory respon- sibility for the adoption of water quality and effluent standards. In view of the Conference's concern with state regulation as well as with the collection of information, Mr. Clarence Klassen, Director of the Illinois Environmental Protection Agency, has written to the Conference Chairman, Mr. Murray Stein, requesting that the Illinois Pollution Control Board be designated an official participant, in the Conference. In anticipation of our designation as a participant in the Con- ference I am listina below some proposals designed to make the Con- ference a better vehicle to accomplish its purpose to save Lake Michigan. Conies of this letter are being sent, to other parties in order that they may have sufficient time to comment or endorse these proposals if they wish. The Council on Environmental Quality in its first Annual Environ- mental Quality Report to President : ixon has criticized water pollution control enforcement conferences and recommends new legislation. The proposals listed below will make the coming Enforcement Conference and future sessions more democratic and more responsive to public interest as well as better directed toward Lake Michigan's specific problems. The following proposals which can be put into effect without new legislation are offered: 1. Publish an agenda for the Conference immediately. The notice of the Conference is not clear as to whether the Conference will deal only with the proposed thermal pollution standard or with all pollution matters affecting Lake Michigan. 2. Require that all reports by parties to the Con- ference and by expert witnesses be submitted in writing in advance to the Great Lakes Regional Office of the Federal Water Quality Administration, there to be made available for public inspection. ------- 2319 -2- Secretary Walter J. Hickel September 17, 1970 In past Conference sessions, voluminous and detailed reports have been presented with no time for the conferees or the public to thoroughly review them. Comments and questions would be much more meaningful if advance copies are required. Permit questioning of witnesses and agency represen- tatives by the public where new information can be gained. This procedure is followed by our Board in its public hearinqs, and it would serve to make the Conference more democratic and more informative. Reconvene the Conference every three months until December 31, 1972. Every State has already sub- mitted seven checkpoint dates for all construction required by listed polluters. Frequent and public checks on adherence to these dates will be necessary in order to avoid the excessive time slippage en- countered in the Lake Erie Conference. Publish within three months a comprehensive waste inventory for Lake Michigan to be prepared by FWQA with the assistance of tne States. A Chicago Daily News story of August 3, 1970 based upon FV.'OA data argues that 51.3 tons of oil and 223.2 tons of suspended solids are now being discharged into Lake Michigan every day by just three Indiana industries. No one knows the total amount of oil, solids, phenols, chlorides, and other significant pollutants going into Lake Michigan every day. Yet this information is easily obtainable through the States and merely needs to be compiled. It would serve to identify the major problems and major sources. Identify, with FV7QA assistance, all significant pollu- ters affecting Lake Michigan and not presently listed by the State of location as coming under the Conference jurisdiction. Four industries in the Manistee, Michigan area are said to discharge almost 1,500 tons of salt to Lake Michigan daily and yet are not under the Con- ference purview. We evidently cannot let each State be the judge of what constitutes "significant" pollu- tion of Lake Michigan, It is most important that pollution discharges to tributaries of the Lake be included and controlled. ------- 2320 -3- Secretary Walter J. Hickel September 17, 1970 Accelerate the deadline for phosphorus removal at municipal and industrial sewage treatment plants from Decert\ber 31, 1972 to December 31, 1971. Phosphorus renoval technology is well known and can be installed at any stage of any existing sex^age treatment plant, and reinstalled in a plant expan- sion. If phosphorus removal is indeed the key to Lake Michigan's survival then we must keep as much phosphorus out as soon as we can. Very truly yours, David P. Currie Chairman DPC: jb CC: Board Members Mr. Clarence Klassen Ass't. Secty. Carl Klein Comm. David D. Dominick Asst. Comm. Murray Stein Mr. Francis T. Mayo Mr. Ralph Purdy Mr. Thomas Frangos Mr. Blucher Poole ------- 2321 Closing Remarks - Mr0 Stein MR. SHELDRICK: Michael Sheldrick, McGraw-Hill. Can you tell us where the meeting will be, and I assume — am I correct in assuming that it will be an executive session? Where, what time, pertinent details? MR. STEIN: We haven't decided on a place yet and I generally don't decide on a place until I confer with the conferees and the people back in Washington. But this will be made known to you, and the kind of meeting we will have will be determined by the conferees. It will be an executive session. MR. SHELDRICK: Can you give us the date perhaps? MR, STEIN: No, I can't. MR. SHELDRIGK: Other than a week. MR. STEIN: No, again, we have all been away from the office for a week. Let me just go off the record here. (Discussion off the record.) MR. STEIN: Back on the record. The putting together of a 4-State conference with Federal officials, given the pulse and the mandatory appearances of these people, is something that we have to work out. We have always worked them out in the past, but I don't think that until these people, who have been away ------- 2322 Closing Remarks - Mr» Stein from their offices, could get back and touch base that we can set that up now, MR, SHELDRICKs Did I hear you right when I thought you said that you were hoping to meet the week after next? MR. STEIN: That is right. That is what I was hoping for, MR. FETTEROLF: Mr, Stein, did you make a decision that it would be an executive session? MR. STEIN: WeHl, yes, in the terms — you know what we mean by executive session? Only the conferees will speak. I can't say yet whether it would be open or closed. MR, FRANGOS: Mr. Stein, just in response to Mr. Currie's suggestions on meeting, I believe that you also have a request or a suggestion from the State of Michigan concerning the frequency of meetings and, as you point out, this does take a considerable amount of time, and it drains not only our own capability but our staff's capability. Perhaps rather than increasing the frequency to every three months we might be able to devise a better communication system so that these conferees know what is going on in each of these States, and then indeed if there ------- 2323 Closing Remarks - Mr. Stein are some questions, we can meet, but my own feeling is that three months is awfully soon. MR. STEIN: Sir, I would prefer at this stage — I know Mr. Currie has made some suggestions. I said if it is agreeable. I think we should hold those off because I know a discussion on these — I know the conferees and other people have had experience here, and they have many, many differing views on the mechanism of holding the conference, and they run the entire gamut. I know repre- sentatives of other States have quite different views, and I think another place is the place to discuss procedure which is only of interest to another bureaucrat rather than here at this time. So I would like to set that off for a little while. We will discuss it when we hippopotami get together by ourselves. Are there any other comments or questions? Again, I would like to thank you for coming and the workshop stands adjourned. (The conference adjourned at 5:5^ p.m.) (The following documents and communications were received following the conclusion of the conference for incorporation in the record.) ------- 2324 "~ " T°: C. 7. Kl?ssen, -Technical Secretary, Illinois Sanitary ,ifjter Board, 6l6 State Of i ice Building, Springfield. 111. S r\nf. SEP 281970 62706.' f* SOtaiENTftL FKOttCTiOH ftiiiu* We, the undersigned, believe that It is both technically and economically feasible for industry to aeet the proposed Federal Water Quality Administration's temperature standards of a one degree P uaxlmua teipersture i,ncre.ise of all -raters returned to Lstke Michigan. Thus, we urge ths adoption of these standards in the state of Illinois. Hespectfully, Concerned Citizens rf) o V/ K> TMLsJ.* j ;^ <{;'> ..\>/^J . t'f/IJS - ------- 2325 379 Jacks on Ave, GJencoe, 111. 60022 Sept. 24, 1970 Mr. O.W, Klassen . ~ vl Director " ": Environmental Protection Agency ,. ., • ,"•""} c/o Illinois Sanitary Water Board '> s1 1717 W. Taylor T Chicago, Illinois ' f ; " ^rr ;fe t , i>?:.'rt f EH!»: Dear Mr. Klassen: Thank you yery much for keeping me informed on the Septem- ber 28-October 2 Workshop of the Lake Michigan Conference. The Glencoe League of" Women Voters will not be testifying at these workshop sessions, but I understand that the Lake Mich- igan Interleague Group plans to speak on thermal pollution stan- dards. I am very interested in the subject matter to be dis- cussed, as I have personally studied thermal pollution problems and standard-setting questions. However, our League has nox yet completed a formal study and consensus position and is therefore unable to testify. I plan to attend at least two of the sessions; and I hope to be able to thank you personally for so considerately offering our League time on the agenda and keeping us up to ,date on the content of the Workshop sessions. Very truly yours ' Mrs. Richard Schnadlg Action Chairman Glencoe LWV ------- 2326 - V? Orchard Lane Benton Harbor, Michigan Ii9022 September 21, 19?0 Mr. Murray Stein, Chairman Federal-State Enforcement Conference on Pollution of Lake 1,'d.chigan Federal Water Quality Administration Room U10 33 East Congress Parkway Chicago, Illinois 6060£ Dear Mr. Stein: Your announcement of August 31 of a ivorkshop for presentation of viewpoints on pollution of Lake Michigan has been received, Speaking as a private citizen '.vhose water supply and many recreational pleasures come from Lake Michigan, I am opposed to the siting of any nuclear power plants on the shores of Lake I£ichigan. In terms of the risk of radioactivity and thermal pollution nresentad by these plants, the benefits of siting on Lake Michigan are inadequate, particularly since alternate sitings are technologically feasible and economically -within reach. A more complete statement asking a ban on placement of nuclear reactors on lake Michigan is presented in ray- letter to Governor William Milliken of my home state of Fdchigan, a copy of -which is attached. If it be -within the scope of the format of the workshop, I would ask that this letter, as well as the attached letter to Governor MLlliken, be read into the record on September 28 or 29, days listed as dealing with problems of Public Utilities, Thank you for your consideration of this request. Very trulv yours, W. D. HDHR, P.E. cc: Mr. Francis T. Mayo FlYQA, Chicago ------- 2327 152 Orchard Lane flenton Harbor, Michigan U9022 July X, 1970 Governor William Milliken Office of the Governor State of Michigan Lansing, Michigan W903 Dear Governor Millikeni This letter is to request that you and your administration actively seek a ban on nuclear reactors on the shores of lake Michigan. Background The hearings in progress at Kalamazoo by the AEG Licensing Board with regard to the provisional operating license for the Palisades Plant of Consumers Power Company have produced indication that the AEG will seek or consent to oversee water quality effects of nuclear reactors, including thermal effects* The passage of laws by the Congress of the United States in 1969 and 1?70, namely, the Federal Water Quality Act, and the National Environmental Protection Act, require both a broader interpretation of the Atomic Energy Act than the AEC has previously been willing to assume and active steps by the A3C to enhance the environment. With the A3C about to enter juriadiction formerly held by the Department of Interior and the several states, a new opportunity arises to control our environment* Concise leadership on the part of the State of Michigan, due primarily to our central location and important dependence on the Great Lakes, can be greatly rewarding for decades and centuries to come. Specific Technical Elimination of thermal effects by use of cooling towers, and prohibition of discharging radioactive liquid waste* to the lake as an operational practice, may well come from AEG activities* These raoves are inadequate to protect Lake Michigan* The naxiaiua accident involving a nuclear reactor on the shore of Lake Michigan is to picture it chopped into small bits and dumped into the lake. This accident, however remote the possibility, would be unpleasant to Michigan. The 100-year holdup time of Lake Michigan would mean elimination of the resort and farming industries for decades. . The source of drinkingwater for millions of people would be contaminated. The radioactivity passing through the Great Lakes and the St. Lawrence River would imperil millions more. Boonomic If the alternative were EITHER nuclear reactors OR no electricity, this letter would not be written. But in truth, the ------- 2328 - 2 - Governor William MilUken July 1, 1970 economic tradeoff involved in this matter has not been discussed, let alone decided in a dispassionate Banner. And an economic tradeoff does exist* tticlear reactors sited on Lake Michigan get cheap cooling water. Non-evaporative cooling towers, which would permit the plants to be sited in inland regions of low population density, add to the cost of plant investment* The question involves "How much?" and "Is it worth it?" A Maryland report on the Calvert Cliffs plant presents estimates of $28 million and $itO million for additional plant investment on a base plant size of $200 million* Estimating plant investaent increase at 20$ for non-evaporative cooling towers, and recognizing that the cost of producing electricity is a minor fraction of the "delivered1 charge to the consumer, the added cost to the public would be less than 1D% on the electric bill Evaluation TKe evaluation requires the tradeoff of leas-than-lD^ on the electric bill, known and regular, against the cost (colossal) of an event of unpredictable rarity (gross disintegration of a nuclear reactor)* Considering the unique properties of Lake Michigan, true wisdom requires us to choose the course of accepting the nominal increase in exchange for preventing the rare possibility of catastrophe to the lake. Practical Present It is tny request that you, as Governor of this state, take the leadership in the administration of state government by undertaking steps that will produce a ban on nuclear reactors on Lake Michigan. In consort with the AEG, the Department of Interior, and the governmental units of the other states fronting on Lake Michigan, this ban should be worked out with dispatch. Very truly yours. W. D. MOHR, P.E. General Distribution ------- 2329 SH W £ <8 ~ K £ •5 .' S s I .§ KM 8 Ul U] At O O CM o Ul o >• ^tf M < H> x x> U. • A. w xx M M r- >• ts «s x >• At O -4 A; M 3 At £ -1 U. H> Z Z H> X Ul H< H> E < * Ul O A. £ U. CO Z Z X Ml ui A: «c z 5 I t» Ul H> - o X Z J O Ul < «-« «c A K Ul U. Ul Ul Z CO X • 3 < u • Z A < U) Ul l» CO O 4 < Z X Ul w u A: •c MI o Ul S Ut U. A Z Ul O X Ul O < M u • i-» Ut Ul X X o z < M) • -a E Ml H> Ul Ul 3 X X .4 H- Ul X -1 >• HI < H> £ »-« W AS J C9 Ul < At X 3 3 H Of »-« A: ui • x Z U. H> Ul tM CO 9 Ul Ul CO A « At Z e ui < u. > Ul Ul H. M At O Ul A Z •-« Z < 5 - H> Ul Ul J 9 X < < X Z -1 < • c* U, H> -4 • X At O Ul Ul •-» -» 9 £ Ul S Z -a < • CO •c •-« Ul « u z Z -4 z u. H CO Z Z y w S& CM Z 11 Ut »-t X Ul Ul U. X Z • H> •• x z x H. S H» M i- •HI 9 Hi 9 < W O Z MI Ul »-* X Ul X A. A5 .4 A Ul AS U Ul H> • Z co Z A: Ul M .J O CO J Z • t-4 (O X o x z Ul Z > Ul H> Ul CO U. Ul 4» • H> A X CO O H« CO Ml CO Ul _)=>•: CO £ O Ul Ul At X 9 A. H> •> Ul CO X 3 H* O A Z W H Ut X O H» U\| A: H* 3 A: • • • AS U. A, X H> Ul Ul M) U M 9 A3 3 H> CO • CO Ul CO 3 l O Ul £ MI 5 - ,- ~ X « Ml Z «-> • Ul < X £ H < Z Ul H> » H> H< CO MI CO O M) H< Z < Ul Z Z HI < Ml CO 19 Ui < 3 >-» X J £ X H> A C* < Ul Ml U. 9 £ • A CO Z Z < Ui • XX p- fa OT ------- 2330 October 8, 1970 11653 N. Wauwatosa Road ?6 W. Mequon, Wisconsin 53092 Mr. Francis W. Mayo, Regional Administrator Federal Water Quality Administration 33 W. Congress Street Chicago, Illinois Dear Siri My- understanding, according~io-Krs» Rheta Pierre, .Secy, to Murray Stein^ is that the written statements may be submitted for the Official Record of The Lake Michigan Enforcement Conference, Chicago for one week, following the close of oral presentations, Friday, October 2, 1970„ I would please request incorpoation of the enclosed letter into the official record, which indicates very recent "happenings?* as the licensing of Point Beach, on Oct. 6th by AEC. I would appreciate receiving a. copy of the Lake Superior 1970 Enforcement Con- ference proceedings, I received copy of the Oct 1, 19&9 proceedings today, and have already Underscored the text through to Page 24-9* CONSERVATIONALLT YOURS, ------- 2331 LAKE MICHIGAN ENFORCEMENT CONFERENCE It was my understanding that the thermal decree of 1 degree was enforced as such, though* still in question and "still negotiable". It would have been comforting if it would not be the burden of the public to "defend" same, for 1 day, while power companies (by coincidence had their convention in Chicago simultaneously with their presentation dayso».Monday, Tues. Wed, 9-28-29-30) One can only guess the impact of expense paid testimony,by experts, versus presentations by citizens,laboriously and expensively establishing their own private environmental data libraries, subscribing on their own to outga'-geo'usly expensive scientific periodicals and publications, without benefit of a federal agency repository for scientific research (research. grants paid for through taxes and oft with FtfQA funds.) Since the newly created Environmental Protection Agency wviich became effective Oct. Ihjftddjybut had a 60 day "grace" period, requested by the President, just in time to LICENSE POINT BEACH NEUCLEAR PLANT at Two Harbors on October 6th, 1970, Tuesday. So things weren't in Limbot In effect, while FWQA incites and excites the engineering debate of the century, negotiating under corporate & political pressure, buying jus.t enough time for a' fox to his piece de resistance. (EPA includes FWQA., NAPCA, Bur. Solid Waste Mgmt, Bur .Water Hygiene & Environmental Radiation protection functions of AEC & p^esticide registration of USDA.) All this, under direct control of the President (to whom all things are negotiable). (As if corporate structure hasnft always known political pressurepointsj Please refer to FWPCA bulletin of Sept. 1969 "HEAT CAN HURT - Better Water for America" indicating research being carried on at the Natl, Water Quality Laboratory at Duluth (I've toured same & don't remember the project) & reference to research at the Natl. Marine Water Quality Lab., W. Kinsington, R, I. WET wasn't the benefit of this research introduced to advocate the Public's and Taxpayer's re-vested interest? ------- 2332 2. I refer for your research 'people (if you are not already aware of the article,) "Thermal Pollution & Adquatic Life by John R. Clark, in Scientific American, March 1969. I have dozens of papers from scientific journals, and 1-\| inches of articles clipped out of newspapers, touting public interest and concern. It is suffice to say, that inasmuch as you are charged with the responsibility to protect our public waterways, (fron whatever deleterious matters, and affects from whatever source) regardless of political and corporate pressure, 'from WHATEVER source, for whatsoever reason, do so, forthrightly and with integrity. Given the foresight to, predict, even with 100$ total inaccuracy, in FAVOR OF the total environment and the citizens of the Great Lakes Basin Region, it' would be a far wiser error, than with hindsight, in retrospect 50 years hence, to discover that our beautifully precious Lake Michigan (& Superior) have attained the dubious distinction of becoming another errie "Erie" becaused you "chanced it". Stick by your l^F thermal decision, let technology & cryogenics manipulate the means, and dedicate yourselves immediately to pesticides, phosphates, chemicals etc. Since the Bureau of the Budget regulates your questionairre activities from Industry, do not, in the name of justice, thwart pollution evidence, from whatever state or source, by keeping it from the printed record. When will the DETERGENT industry, PETROLEUM & CHEMICAL cartels be confronted, as was Reserve Mining in the L. Superior Enforcement Conference? ^ Please keep in mind a. potential xium...THE QUALITY OF OUR ENVIROlMSllT IS NOT NEGOTIABLE. J^VA ( ConservationaJJttp'jcd^rs , ) \ ^Cv GRACE 11653 Mequoh, Member of Natl. & Milwavucee Audubon Society (Bdard) & L'eglslativertbtee for Audubon Society Natl. Convention - 1971 - K Wisconsin Resource Conservation Council League Milwaukee River Restoration Council -Save LakevWiperior Association Citizens Natural Resource Association Wise. Acade'my of Science, Arts & Letters National Wildlife Federation - 1970 Conservation Summit, Estes Park, Colo. ------- 2333 t 2 0 m w \_ U s "^ Q ti _i Q ki -j X M 2 II 2 — rt rt QA C u «^ ss _c_5 "i V d .0 1 U O .S '6 "^ £ •M M js d. C\J i— O o O "1 Eft 9v r»- U, o A Z Ul UI ac ft. (-1 CM O CJ 01 Z Ul o A Z C9 O Ul Z -I (O A < A £ X ftt < to Ul C H. 5 W A ^ Ul < IK UIX Ul X H» O HI O CO < £ a < z »-* < H> Ul H H« Ul ft. » (M & -3 Ul Ui f-> Ul Ul •y* tp^ L^ z si* •c ui {3 -r« > K ui O W •-« »-» Z tfl Ul Ul I—I >-1 CO < « »"^ ^ ^ ^ »"^ iM ^W u, o ui H- i. ; •e M •-« ft. • ui < Ul -4 Z •-• O Vl flu •: < z ui /) C/) H Z < 3 ft. X < Ul H> Ul H« Ul X Ul • < W> Ul • A H> >-• U. 3 A ft; 9 « < S X H f-i Ul H. H- < O > X /-s O O «•» C9 3 x z' -* X »-» 5 ut w ^ CO O • (39 > -» Z < o en c < •: x w UI UI Ul Z Z I- Ul Z < H< ui ca x < ui a x «-t • ui ui X Z X s: M U X 3 E- Z A K t- U\| 9 H. J ZZ xui >Z < • 3 Ul X Ul Ul a • ^ 5 5 X A h-i M X < 1-1 A < • H- to >• C9 Z X Ul J Ul X 1-4 » A Ul • 96 > 9 < H> Ul Z M Ul (O Z 1-4 C/l X A O A H- O ------- 2334 September 28, 1970 Mr. Murry Stein, Conference Chairman Thermal Pollution Workshop Sherman House 100 West Randolph Street Chicago, Illinois Dear Mr. Stein: Enclosed you will find a copy of the Michigan State Chamber of Commerce's Policy on Thermal Effects which was adopted by our Board of Directors on January 21, 1970, Ptease enter this into the proceedings of the Department of Interior's Thermal Pollution Workshop currently underway in Chicago. Sincerely, George P. Graff, Manager, Natural Resources GPG/sfc Enclosure cc: Francis T. Mayo x Ralph Purdy ------- 2335 MICHIGAN STATE CHAMBER POLICY ON THERMAL EFFECTS The Michigan State Chamber of Commerce has long recognized the need to and enhance the quality of the environment in the State of Michigan.- Cooperative efforts of both the public and private sectors are necessary to effectively promote this objective. The Waters of the State of Michigan are an important segment of the environ- ment and should be so respected. The potential effects of thermal discharges to these waters are not fully understood. However, it is known that in some instances these effects are detrimental to legitimate uses, while in other instances they are beneficial. Recognizing that there are many,needs and objectives in society, and that they cannot all be satisfied in their entirety, the State Chamber strongly recommends that the Michigan Water Management Program, with particular reference to thermal effects, be guided by the following principles: 1. That no single set of regulations is adaptable to all situations. 2. That the management program provide for beneficial water uses, with joint consideration of alternative costs to society and the objective of preserving environmen- tal quality. 3. That water quality standards regarding thermal effects adopted by the State are consistent with the water use management program which recognizes the needs of our society and further that Michigan industry will comply with all state standards. 4. That any use which has potential of causing significant environmental effects be carefully monitored to determine theo extent of any effects and the possible need for corrective action. 5. That prompt corrective action be taken whenever effects detrimental to legitimate uses are detected. 6. That thermal effects research be promoted in an effort to obtain sound data from which intelligent judgments can be based regarding thermal discharges. The State Chamber commends the responsible State agency's accomplishment? in the area of water quality control and pledges its continuing support and coopera- tion in efforts to provide an improved environment and high quality water in the State of Michigan. ------- 2336 F. SCAMMON BARRY 611 HUNTER RD. BLENVIEW, ILLINOIS Sept. 27,1970 Francis T. Mayo, Dir. Regional Office, US Dept. of the Interior Federal Water Duality Adm. 33 East Congress Pkwy Hm 4-10 Chicago, 111. 60605 Dear Mr. Mayo: I urge you to use all of your influence to get the 4-state Enforcement Conference on Pollution of Lake Michigan to adopt the strictest standard under consideration for thermal pollution. I believe that is the standard announced by the Dept. of the Interior. This opinion states: "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 rise over ambient at the point of discharge. This will preclude fche need for mixing zones." ^ lours truly, /F. Scammon Barry ------- 2337 September 28, 1970 Mr. Francis P. Mayo Director, Great Lakes Regional Office IT. S. Dept. of Interior Federal Water Quality Administration 33 E. Congress Expressway Room lilO Chicago, Illinois 6o6o5 Dear Mr. Mayo: I would like to voice my support for the establish- ment of strict standards controlling heat discharges into Lake Michigan and other waterways0 There should be no difference in waterway and discharged water temperature that cannot be attributed to error in measurement. It is time to take decisive action. Caution must be exercised now. It will be easier to ease restrictions in light of future findings than it will be to view useless bodies of water and wish there had been more foresight. Yc/urs truly, C,' .'" f ^ «, E. M. Davey ------- 233S September 26, 1970 Kr. "Francis T. Kayo U.S. Dept. of the Interior Federal Water Quality Administration 33 E. Congress Chicago, 111. 60605 Dear Sir: I am a member of and dissentient from the Committee on Lake Kichigan Pollution. I have several comments on heating of the lake . 1. The bad effects of heating are not now proved. The hot water discharge from Waukegan steam plant of Commonwealth Edison has made good fishing for years. Likewise, the waters of the warm Carribean have good fishing. 2. The real problem faced is what to do about Lake Lichigan when we think the heat discharge may have deleterious effects. These effects must be balanced with the effects of a shortage of electricity. 3. Ecology is important; so is justice. It is not just to have several government bodies approve the Zion nuclear plant, and then demand that L'dison spend more millions than planned. This is particularly the case when the alternative heat exchange to the atmosphere has unknown effects, also. 4. The proposed standard of the Dept. of Interior that will prohibit heat discharges of more than 1° above ambient is absurd. It would prohibit swimming. It would prohibit small motors. It would prohibit dumping a thtnblefull of boiling water. It would permit the discharge from Zion nuclear station as long ss Edison spent uoney on more puraps to push thru a larger volume of water. If there is any kind of limit, it should be stated in btu's per minute, or other units of power, .and it should not apply in the -.'inter. Yours very truly, nobert Dover 917 Chestnut Ave . V/ilmette, 111. 60091 copy: James ;jriffith . on L. I ich. irollution ------- 2339 PETIT, SAFEBLADE, LITTLEJOHN & GLASS ATTORNEYS AT LAW ~T,«= -r.-, HARRIS BANK BUILDING ADELOR J. PETIT, JR. ADELOR J. PETIT (1892-1951) JOHN A.SAFESLADE I" WEST MONROE STREET WILLIAM L.LITTLEJOHN CHICAGO 6O6O3 BRADLEY M. GLASS EDWARD ATLAS AREA CODE 312 DAVID C. FALLS 726-IO25 JAMES P. MSCARTHY, JR. 263-3O6O ROY E.OLIN OF COUNSEL September 30, 1970 Clarence Klassen 111. Environmental Protection Agency 535 West Jefferson Street Springfield, Illinois 62706 Murray Stein, Conference Chairman Federal Water Pollution Control Administration Department of the Interior Washington, D. C. 20242 Francis T. Mayo, Director, Great Lakes Regional Office U. S. Department of the Interior Federal Water Quality Administration 33 East Congress Parkway, Room 410 Chicago, Illinois 60605 Gentlemen: I am taking the occasion of this week's Enforcement Conference on pollution of Jiake_Mi.chj.ganL to register with you my deep concern for the need to establish and enforce strict thermal pollution standards. Commonwealth Edison has been quoted as urging reten- tion of Illinois' present standards (permitting a water temper- ature increase of up to 5°) on the ground no evidence exists proving conclusively that heated water discharges will adversely affect the Lake. I disagree with this approach. In this matter, so directly affecting the public interest, the evidence must prove conclusively that such discharges will not adversely affect the Lake. Our Lake belongs to the people. It cannot be replaced. ------- 2340 Page Two Clarence Klassen Murray Stein Francis T. Mayo September 30, 1970 No harm must come to this priceless resource. Whatever legi- timate doubts exist regarding the safety of discharging waste heat into Lake Michigan must be resolved in favor of the over- riding public interest. Accordingly, I wish to pledge my support for the pre- viously stated position of the U. S. Department of the Interior that: "The minimum possible waste heat shall be added to the waters in Lake Michigan. In no event will heat discharges be permitted to exceed 1° F. rise over ambient at the point of dis- charge." Yours very truly, Gl fa. Mb*-— Bradley M. Glass, Republican Candidate for Representative in the General Assembly, First District BMG/ak ------- MRS. LYMAN BARR 1005 WADE STREET HIGHLAND PARK, ILLINOIS 60033 2341 %. £$JL 0 o b o v ------- 2342 Mr. Francis T. Mayo Re?io---il Dlroot.Tr Federal Water Quality Control Administration 55 E- O-v-e-js parkway iouyj, Illinois Dear Mr. Mayo: DO NOT PLUNGE US INTO HOT WATER! THERMAL POLLUTION is th'j deleterious change in the normal tenporaturs of water caused by the discharg-3 cf Kn-jte heat. THE RISK OF TAMPERING WITH THE LAKE MAY CAUSE THESE DISASTROUS EFFEC1S, 1. Fill fish 2- Sp.= ad the aging or eutrophiCation (decrease the oxygen) process of the le ------- 2343 He I e n Ku toj ov 5493 Cornel I Chicago, IL Karel Wo Ifson 5210 Dorchester Ch icago, IL Mr. & Mrs. R. V. Wee lew 5429 South Harper Chicago, IL 60615 Diehl Cohen 1357 E. Park Place Chicago, IL Brian Dosch 5403 Wood I awn Chicago, IL Bruce Fischer 1414 E. 59th St. Chicago, IL Nancy Stetton 5950 Dorchester Chicago, IL Jean Spencer 5201 South Cornel I Chicago, IL Mrs. Seals Sayles 1337 Beechwood Boulevard Pittsburgh, PA 15217 Marc Kaplan 5112 Hyde Park Chicago, IL A I i ce Ru bov i ts 4940 East End Avenue Chicago, IL 60615 Wei I and F. Buchanan 5555 Blackstone Chicago, IL John D. Alexander 6219 S. Chapel Chicago, IL Evelyn C. Trugran 1606 E. Hyde Park Chicago, IL Joyce A. Solomon 1410 S. Rockdale Place Chicago, IL 60615 Harvey Mantel 1005 E. 60th Street Chicago, IL 60637 J. Albrechs 1462 E. Park Place Chicago, IL 60637 K. Majewaki 5314 Cornel I A Chicago, IL Diane Broadbart 5824 Kimbark Ch icago, IL Paula Foster 5749 Dorchester Chicago, IL Marjorie Feren 5738 Blackstone Chicago, IL Pam EmiI 5450 East View Park Chicago, IL 60615 Helen Bergstrom 5405'S. Wood I awn Chicago, IL Judith A. Baer 5345 S. Ellis Ave. Chicago, IL Pamela H. Pearson 5541 1/2 Wood I awn Chicago, IL 60637 Ann Palkovich 5824 S. Kimbark Chicago, IL Mary Kay O'Brien 5824 S. Kimbark Chicago, IL 60637 ------- 2344 Eric Anderberg 4821 South El I is Chicago, IL 60615 Robert E. Mann 5539 S. Horner Chicago, IL 60637 ------- DEDICATED THE PRESERVATION OF OUTDOOR 2345 AMERICA 9?aafe Walton league of America PORTER COUNTY CHAPTER, CHESTERTON INDIANA 46304 To: Federal Conference on Lake Michigan and Its Tributary Basin, Federal ¥ater Pollution Control Administration, October 2, 1970 Submitted by: Ted Falls, Pres., Porter County Chapter, Izaak Walton League, Wheeler, Indiana Ij6393. Gentlemen: I would like to offer these observations on some of the papers presented to the Conference this past few days, to stand on their own merits and without further qualifying myself. I must take personal responsibility for the technical matter here presented, but my Chapter stands committed to the position I 'state. My first reference is to the discussion of the value of Dr. Peter J. Colby's labotatory work on the effect of temperature on the time for hatching eggs of one species of whitefish. Dr. John C. Ayres has condemned this work in a widely published paper, and made reference to this position in his talk before this Conference. "Evidently, nature knew something important that did not bear in the laboratory-tank experiments, but what was it?" he wrote. "Patently, laboratory- tank biology was not what was going on in that warm-water plume." A remarkably strong effort was made, in the questioning following Dr. Colby's presentation to this Conference, to discredit his work as inapplicable to actual Lake conditions. There was an important point to Dr. Colby's work that was not brought out in the discussion. So long as temperature remains within certain boundaries, the fundamental process of germination responds to temperature so as to increase the rate of germination as temperature increases above the lower boundary, then decreases as the upper boundary is approached. The relationship of temperature and time is non-linear. A study of the temperature effect on a particular species in the laboratory will permit the determination of a temperature-time constant for each temperature, provided that all other factors are controlled to duplicate the conditions in nature. In a field application of laboratory findings, two things will be verified: tha applicability of the temperature-time constant, and the precision by which the other conditions of nature were dupli- cated. To discover the values in a curve it is necessary to measure at least four points. preferably five, if the curve is always rising, or always falling. It is of the utmost importance to learn if Dr. Colby used this technique. In fact, the curve he studied rises to a peak as temperature increases, then falls as it approaches the upper limit of temperature. With this in mind, Dr. Colby evaluated nine points in a 12 deg. C range. This gave him, in essence, five points for each ------- 2346 FCET5R COTKTY CHA-FTBR. I2AAK WALTCK LEAGUE Sheet 2. direction. His result was a continuity of the temperature-time constant useful for field application. Nature sums the temperature-time constants through the succession of temperature changes, producing a hatch when the sum reaches its proper point. Every farmer, and most students of biology are aware of the occurrence of early and late crops in different years due to the vagaries of weather, and correctly recognize the importance of temperature in this effect on the many functions of plant and cold-blooded animal growth. Mien Dr. Colby turned to the field, it became necess- ary to measure the succession of temperatures in order to sum the temperature-time constants he found in the laboratory, which he did. The 98$ precision he claims is an achievement of the first order: a 90^ precision would be highly credible, and useful in future predictions. \'e are able to observe the temperature-time effect in many phases of plant and cold-blooded animal growth. The phenomenon has been discussed in scientific literature for two or three generations. For many years it has been roughly approximated in the mean annual temperature of the region. Hence, the northern boundary of the growth of wild palmettos in the Carolines has been related to an isotherm stated to a tenth of a degree, soil conditions being equal; and the development of these plants increases southward as the mean annual temperature increases. Spanish moss grows wild at the southern tip of few Jersey along the coast due to the warming effect of the Gulf Stream, far north of its normal habitat: the mean annual temperature indicates a suitable sum of the temperature- time constant within the boundaries required by this plant. "•Dach species has its own temperature-time constant and boundaries. When nature has established a regular succession of temperature changes, with only minor variations from year to year, various species will become established according to their adaptation and adaptability. The fact that there are local, natural ' temperature changes of the waters of undisturbed Lake Michigan is irrelevant: these are normal for each season, and are repeated year by year. They are within the boundaries tolerated by the species that have become established. .Jhen the temperature-time summation and the temperature boundaries are changed, there will be changes in response of established species; and as the factors change progressively there will be changes in the species present. It is obvious, with a cursory inspection of the shoreline of Lake Michigan, that the present undisturbed Lake is at the lower boundary for growth of certain alqae. A mile away from the present Michigan Citjr power plant there is a growth of algae on piles and rocks that has appeared in the last ten years, and was never there before. That there is a probable increase of temperature is confirmed by several statements to this conference, reporting the results of careful studies. The vigor of the growth of algae increases as the power plant is approached, and is rank close to the outfall where the temperature-time summation is greatest. It is true that there is a discharge of nutrients from the Michigan City sewage disposal plant ofl Trail Oreek, and from the nitrates formed in the combustion chamber of the power plant. ~"e would expect the dispersal of the nutrients into the outer waters of the Lake to be much slower than the dissipation of the heat, favoring a more uniform growth of algae along the shore if heat were not an effective factor. I hold that Lr. A^-res is greatly mistaken to attack the validity of the work of Lr. Colby, and that he has failed to take into account directions for study that are of the greatest importance in evaluating the impact of huge quantities of heat on Lake Michigan. There are certain characteristics of a plume that seem to be ignored or not realized in most of the discussion of this Conference. The water of the plume ------- 2347 PCRT3R COUCTY CHAPTER. IZAAK •ffiLTOy L5AGIT Sheet ;. moves through it at a relatively rapid pace, disappearing eventually in the body of water in the Lake. The plume is persistent. Tor it is continuously supplied. The plume wanders over a fixed area greater than that of the plume itself, in a slow march as it is affected byi currents. The rapid rate of flow within the plume has a direct effect upon the water-borne planckton and nymph stages that might be caught within it. These forms do not have the means of locomotion to move out of it with any rapidity. Such as may survive the heat shock of the passage through the condensers do not have time to increase before they are swept into other waters in the Lake, where they join their fellows. The question of eventual survival, having withstood the condenser shock, is an easy one to answer, for a sample can be taken almost without contam- ination by unshocked individuals from the surrounding water. These can be studied in the laboratory tank under optimum conditions, comparing them with samples from the surrounding Lake as a control. In the papers giver. I missed a comparison of samples from the condenser discharge and from the area close before the intake, to show the immediate effect of heat shock, I would like to quote from the article by Er. John C. Ayres entitled "Remarks On Thermal Pollution In The Great Lakes", a passage in the Position Paper distributed by MPSCO in August and subsequently: In the plume "there was no cloud of excess algae in the warm water and no aquatic insects emerged for mating flights into air that was too cold to let them fly". Er. Ayres forgets, or chooses to ignore, the fact that the temperat\ire-time constant summation for the tine to pass through the plume is very nearly zero in the division cycle of algae and in the life cycle of aquatic insects. The persistence of the plume is another matter, affecting all the fixed life forms that it can reach. In this category are the forms of algae that grow attached to stationary objects, and the fish eggs attached to the bottom or to debris locked to the bottom. These are subject to shorter or longer exposure to temperature from the plume, responding to the temperature-time constant and the boundaries. The effect is very real, and under certain conditions must be deleterious. The wandering of the plume negates the conclusions based on the concept that the plume is a fixed body, and gives us a key for an analysis by which we can predict the effect with some accuracy. Since the response of fixed life forms is the summation of the temperature-time constants, the analysis of a plume should be a mapping of the area over which it will flow in the course of time, taking into account the temperature-time factor. This will show the true area affected by the plume: heat-sensitive pictures of a plume at any instant are deceptive. In Dr. Donald W. Pritchard1 s paper, the concept of the plume in Case IV is very attractive on first consideration. There are several controversial points, however. J'o doubt Er. Pritchard made sure that there is enough energy in the stream at the outlet to create the turbulence that is the key to the reduction of temperature that he predicts. This is the essential factor in his proposal. It is important to picture the nature of turbulence to evaluate this proposal. There seem to be several conditions of flow in a tvirbulent fluid body: vortices of great and small dimensions; sheets of varying thickness and shape, and of short duration; and pencils of odd shape of cross-section and varying dimension and persistence, all forming and reforming progressively outward from the source. One can see the process in slow motion in cigarfctte smoke floating in a shaft of sunlight in an apparently still room: in a space of such large dimensions there is turbulence even though we are not aware of it by the feel on our skin. In the case that Er. Pritchard sets up, turbulence will be rapid and massive. ------- 2348 PCRTSR COUNTY CHAPTER. IZAAK mLTON LEAGUE Sheet h_. In turbulent water, the laws of heat interchange will still apply. Bodies of water will interchange heat as they are mixed, assuming the median temperature, just as in the mixing of cups of water in the Hi&h School laboratory. This means that there will be a temperature gradient from the discharge stream outward, just as in any plume, considering temperature measurement with ordinary instruments that average the condition in the medium in which they are immersed. An instrument capable of instant response, fixed in a flowing plume, would show a rapidly fluctuating temperature as the various vortices, sheets and pencils pass by. The range of the temperature fluctuations would decrease as the instrument is moved outward from the initial stream. In this turbulent body planckton entrained in the original stream will be caught in the turbulence as the stream "peels off". Mostly, they will follow the bodies of water involved in the process of dispersion, suffering such temperature change as might occur in the mixing process. Some will transfer directly from warm water to cooler water adjacent, perhaps a temperature shock. Further, all planckton entrained in the cool water drawn into the turbulence will in their turn be subjected to a sharp temperature change as their water is mixed with the warmer water from the initial stream. This temperature change will be graded according to the temperatures involved. Some of it will be extreme. All in all, it seems that more destruction of planckton will occur in Case IV than in any other proposal. Unfortunately, the case is offered to justify the highest temperature discharge of any of the several methods. Dr. Pritchard is quite correct to predict that the highest temperature to reach the surface will be materially reduced from the temperature a£ the discharge point. The average temperature of the plume at the surface will be much less than that of a flume spreading the hot water over the surface. The consequence of this is that heat dispersion to the atmosphere by radiation and evaporation will be reduced: a greater quantity will be retained in the Lake. In turn, the summation of the temperature-time constant will be effective over a greater area of the Lake. Further, turbulence is induced over 360 degrees of the section normal to the direction of the originating stream. This means that heat will reach the bottom of the Lake as well as the top. This will affect any plant or animal life that might inhabit the area. From the consideration of the heat effects of Case IV, we cannot accept the proposal as a likely solution of the heat problem in Lake Michigan. In our personal experience we have learned that there is more chance that an unforeseen gimmick will destroy an attractive idea than that the idea will be successful. With this in mind, we have scanned a number of possible side effects that might develop in the application of Case IV. Two need to be examined. There is a possibility that a hydraulic jump will form near the end of the jet of hot water before it is entirely dissipated. It can be avoided by controlling the velocity of the discharge: it could very well be that the planned velocity will not be of a value to produce the condition. More likely is the possibility that the discharge from the pipe will produce a rip. Both will be a hazard to small power boats that will want to use the area. Theseaand other problems can be resolved by a model study. We are intrigued with certain aspects of the economy of power production. The heat discarded by a power plant is money, as was remarked this week. Looking at this cursorily, a fossil fuel power plant with a revenue of ?;!?00 million annually for the sale of electric power is discarding a potential market value of $563 million or more, and spending money to do it, if electric power is truly competitive with other forms. For a l^OO million annual revenue from nuclear ------- 2349 PCRTSR COOMTY CHAPTER. IZAAK WkLTOK LEAGUE Sheet 5. nuclear power, the value of the power discarded becomes more than $1 billion ann- ually. These values must not be confused with the actual cost of the power discarded, which, of .course, is much lower but still formidible. In either case the gold vein is worth prospecting. The electric companies have been peculiarly reluctant to develop and market by-products. Revenues from the discarded heat amounting to only 20f? of the above figures will support a heavy investment in research and plant. T.Je believe that the ultimate development of power companies will be to locate in the center of an industrial park, surrounded by heat consuming industries, or other heat consuming activities requiring space. With proper planning there will be the necessity for a relatively small dry cooling tower to balance the demand for heat with the demand for electric power. By locating on a lake shore a power company is reducing its areafor this option by half; located on the lake shore between a large public park and a high level residential community, the option is barred entirely. Considering that the evidence is clear that heat degrades Lake Michigan in more than a small degree, and that the increase in generation of electric power, coupled with the additional heat discarded by industry will approach and exceed the tolerance of nature; and considering also that the proposals offered for the control of heat disposal are inadequate, we take- the position that it is correct to limit all discharge of water to a. delta T of 1 degree. We think that industries that cannot meet this specification should locate elsewhere. We feel very keenly that Lake Michigan is of the greatest value as we found it, and that it should be preserved. ------- 2350 AMERICAN ELECTRIC POWER Service Corporation 2 Broadway, New York, N. Y. 10004 •(212) 422-4800 October 8, 1970 To The Conferees The Lake Michigan Enforcement Conference Mr. Murray Stein, Chairman Mr. David Currie Mr. Thomas Frangos Dr. F. T. Mayo Mr. Perry Miller Mr. Ralph. Purdy Gentlemen: At the conclusion of the Workshop Session of the Lake Michigan Enforcement Conference, on Friday, October 2, you heard discussion of a vital point that-needs further consideration. This was the dialogue on who should bear the responsibility for measuring the effects of warm water discharges. Chairman Murray Stein and Dr. M. A. McWhinney set forth only part of the problem. In this matter, as an observer of the five days of your Workshop, I would like to present additional comments. The bearing of responsibility should be recognized for two purposes - for enforcement, and for support of a permit of use. For an enforcement action, many states have laws that require that the enforcement agency must obtain and present the technical evidence used to judge and convict a violation. For the use of a resource such as a public water, many states insert into permits for withdrawal or for discharge, the requirement that the user must obtain and submit suitable observations to determine whether or not he is doing harm by the specified use; and these states reserve the right to withdraw or revise the permit if harm is found. In the discussion between Chairman Stein and Dr. McWhinney, there may have been some confusion as to which type of responsibility was to be borne by whom. ------- -£- J.U/0//U 2351 Certainly, the federal agencies and the state agencies should collect and present evidence used for any enforcement action. In addition, they should maintain a degree of observation sufficient to verify the conclusions offered by the user from his own studies. It should be required that the user of a resource bear the burden or the responsibility of supporting sufficient evaluation and research to, show that no harm is done by his use. This evaluation and research should be according to advance plans that have been approved by the agency that is authorized to permit the use. It is often to the benefit of the whole community to have a third-party evaluation - a citizens group that is free of the possible biases of the permit issuer and the permit recipient. The type of study or research and the processes of decision are often confused. Should these be investiga- tions using all of those scientific disciplines that should be applied? Should the validity of judgments of these scientific studies be subject to legal review? Or, should the rule of "the street people", the pressure of hysteria, replace such deliberative actions? Last week, we heard intimations of unlawful actions if the governmental agencies did not move quickly and to the satisfaction of the "street people." Should the scientists be considered as capable of maintaining objectivity without regard to the source of their financial support? We have heard a great deal of talk suggest- ing that any scientist who accepts support from an electric utility is bound to find biased data in his studies, and to give dishonest conclusions. We have heard this claimed even in cases where the utility paid no money directly to the scientist but only had a contract v/ith his university. Such a financial contamination process could be applied to other scientists from the same university - even to those who have expressed contrary conclusions. If the utility will contaminate any scientist whose university accepts a research contract with the utility, and if the utility will contaminate any scientist who works more directly for the user, how can the utility find out the truth? And,-how can it obtain evidence showing whether or not it does harm by its use? ------- -j- lu/o/yu 2352 If financial support is a basis for disqualification of scientists, how can either side of a dispute present expert testimony? Will only the expert testimony of third parties be allowed? Chairman Stein and Dr. McWhinney touched on a little of this, in their noteworthy discussion in Chicago. In many cases today, the electric utility is required to support elaborate research by experts who were approved in advance by the responsible agencies. Then, the work done by these experts is checked by various of the government experts. This process is yielding a vast amount of honest information on the effects of warm discharges. This process should be continued - and even expanded. Very truly yours, T. A. Miskimen Senior Engineer TAM/fkr ------- 2353 MRS. MAXWELL MCCROHON ROUTE i. STUENKEL ROAD September 30, 1970 CRETE, ILLINOIS 6O4I7 Dear >ir. l-layo; Please be vigorous in opposing any installations alon% our lakeshores v;hich discharge ^ater heated more than one decree over the normal lake temperature. I am also disturbed about the improper land use which accounts for industries situating on disappearing scenic and recreational v/aterfronta^es which are already inadaquate to the bur^eonin^; metropolitan populations. By denying the nrivala^e to private companies to make use of the lakeshores tnere will be more impetus to findin,;; adaquate alternatives. Thank-you very much for your kind attention. Very truly yours, ------- ->^- 2354 DAN HARPER -BOX £t©, ROUTE 3, CRETE, ILLINOIS 6 y • 7 ui.s. 07 L ?- ~ -T o ; p - y C 7 i cX- / /. ------- ROBERT McCLORY 12TH . '(STRICT. ILLINOIS JUDICIARY COMMITTEE SUBCOM MITTEESi ANTITRUST SUBMERGED LANDS I.S. INTERPARLIAMENTARY UNION DELEGATION 2355 Congre&S of tfje 33niteb of Eepresentattoe , 33.C. 20515 ROOM 426 CANNON HOUSE OFFICE BUILDING (202) 225-52Z1 DISTRICT OFFICE: POST OFFICE BUILDING 326 NORTH GENESEE STREET WAUKEGAN, ILLINOIS 60085 (3U) 336-4554 September 9, 1970 The Honorable Carl Klein >-A Assistant Secretary of Interior Department of Interior Washington, D. C. Dear Mr. Secretary: It has come to my attention that conferences will be held in Chicago from September 28 through October 2 to consider a new Federal policy directed against Thermal Pollution of the waters of Lake Michigan. At the time of the application for authority to erect the nuclear power plant for Commonwealth Edison at Zion, Illinois (in my Congressional District) 1 called attention to the need for careful study and resolution of the Thermal Pollution problem. Notwithstanding the Commerce Department and AEC approval of this application, the various charges persist that a dangerous level of heated waters will be discharged into the Lake with possible adverse effect on marine life and other appropriate uses of the Lake waters. While it would appear to be most unreasonable at this juncture to impose new standards which were not anticipated by Commonwealth Edison Company at the time its nuclear generating project was initiated, I feel it is entirely appropriate to require that company to utilize such technology as may reduce to a minimum the heat which may be in- volved with effluents from its nuclear generating plant. It is my further hope that your hearings may lead to information or research which can eliminate thermal pollution entirely. I regret that 1 will be unable to attend your conferences personally. However, 1 hope to have a representative present and that I may sub- sequently receive a report of the conferences which you have arranged. Robert McClory, M.C. RMcC/gc cc: The Hon. Clarence W. Klassen, Director, 111. Environmental Protection Agency. ------- 33 ^ 2356 JAMES 5LO5S EOS SKOKIE LANE GLENCOE, ILLINOIS 6DD22 v 35 y j. Z-6- ^7o Ln,*-,- s > E— - ,Lt.X,- ^ i /• -J / / / T i f -> r_<.^ "--c-t <•'•- ^ < A ^-C-t -v\(J^ Ct'>^^-^- f _r o."-^ ------- 2357 MRS. MAYNARD J. SEIDMON 1064 SKOKIE RIDGE DRIVE, GLENCOE, ILLINOIS 60022 ------- 2358 AARON S. WOLFF M SOUTH LASALLE STREET AREA CQDE 3\|2 CHICAGO 6O6O3 FRANKLIN a-5481 September 24, 1970 Mr. Murray Stein, Conference Chairman Federal Water Pollution Control Administration Department of the Interior Washington, D. C. 20242 Dear Mr. Stein: Since you are Conference Chairman of the Federal Water Pollution Control Administration, I strongly urge that you do all in your power to avoid thermal pollution of Lake Michigan. At the forthcoming Federal-State Enforcement Conference on pollution of Lake Michigan, I certainly hope that you will push for adoption of the strictest standard under consideration. This would be that of the Department of the Interior which would sanction only the minimum possible waste heat to be discharged into Lake Michigan or a 1° F. rise over ambient at the point of discharge, whichever is less. Very truly yours, Aaron S. Wolf] ASW:sf ------- 2359 AARON S. WOLFF II SOUTH LA SALLE STREET AREA CODE 312 CHICAGO 6O6O3 FRANKLIN September 25, 1970 Mr. Francis T. Mayo, Director Great Lakes Regional Office U. S. Department of the Interior Federal Water Quality Administration 33 East Congress Parkway - Room 410 Chicago, Illinois 60605 Dear Mr. Mayo: Since you are the Director of the Great Lakes Regional Office, I strongly urge that you do all in your power to avoid thermal pollution of Lake Michigan. At the forthcoming Federal-State Enforcement Conference on pollution of Lake Michigan, I certainly hope that you will push for adoption of the strictest standard under consideration. This would be that of the Department of the Interior which would sanction only the minimum pos- sible waste heat to be discharged into Lake Michigan or a 1° F. rise over ambient at the point of discharge, whichever is less. Very truly yours, Aaron S. Wolff ASWtsf ------- 2360 MRS. LYMAN BARR 1005 WADE STREET HIGHLAND PARK, ILLINOIS 60035 ^ &jfc$ GU/Hv S^AAjLlA/L^.-- ------- 2361 F. SCAMMON BARRY. M. D. 1761 RIVER DRIVE GLENVIEW, ILLINOIS — Sept. 27,1970 GL. 1-5353 Mr. Murray Stein, Chmn. Federal Water Pollution Control Adm. Dept. of the Interior Washington, D.C. 20242 Dear Mr. Stein: I urge you to use all of your influence to get the 4-state Enforcement Conference on Pollution ©f Jake Michigan to adopt the strictest standard under consideration for thermal pollution. I believe this is the stand- ard announced by the Dept. of the Interior. This opinion states: "the minimum possible waste hear shall be added to the waters of Lake Michigan. In tho event will heat discharges be permitted to exceed a 1 degree rise over ambient at the point of discharge. This will preclude the need for mixing soneA." 3 F. ScamMon Barry ------- 2362 Lake St. Clair Anti-Pollution League P. 0. Box 63 St. Clair Shores, Michigan ^080 Mr. Murray Stein Chairman Lake Michigan Enforcement Conference c/o FW/QA 33 E. Congress Parkway Room HO Chicago, Illinois 60605 Dear Mr. Stein: We wish to thank you for this opportunity to express our views regarding thermal pollution of Lake Michigan. As you may know the pollution of our lakes, rivers, and oceans is of primary concern to our group. It is our contention that pollution in any form is detrimental to the health and well being of the citizens of this country and the world, and is becoming quite acute. The argument that only a small amount of hot water will be dumped into Lake Michigan will not, so to speak, hold water. This pollution added to all the other pollutants that are being dumped into the lake will only make the problem worse. As noted in the Clean Water News , thermal pollution will, according to a report from the U.S. Department of the Interior, have a significant adverse ecological effect on the lake. We feel therefore that thermal discharge into Lake Michigan should not be condoned or allowed. As there are cooling systems available which will apparently work and are feasible to use, we feel adequate cooling systems should be made manditory for water cooling before dumping into the lake. Careful site selection surveys should be made to prevent other potentially dangerous ecological changes from occuring. Thank you again for this opportunity. ------- T -S-Ol D V\. 2363 . .OLLxfi t^£-ii.v oJL .'t ------- 2364 September 28, 1970 Mr. Murray Stein Conference Chairman Federal Water Pollution Control Adm. Dept. of the Interior Washington, D. C. 20212 x>ear Mr. Stein: I would like to voice my support for the establish- ment of strict standards controlling heat discharges into Lake Michigan and other waterways. There should be no difference in waterway and discharged water temperature that cannot be attributed to error in measurement. It is time to take decisive action. Caution must be exercised now. It is easier to ease restrictions in light of future findings than it is to view useless bodies of water and wish there had been more foresight. Tours truly, E. M'. Davey ' ------- 2365 ------- 2366 Summary Preli.tmin.ary Report on Sanitary Sewerage System and Water Pollution Control Facilities Whiting^ Indiana - Russell, Schubert, Hanilton and Associates,, lac,,, Indianapolis 1» Existing (a) Dry weather flow to Haramoad for treatment with effluent discharge to Grand Calumet River west to Illinois Waterway o (b) Combined sewer overflow (intermittent) to Lake Michigan,- Storm water pumping station discharge to Lake Michigan, 2. Proposed (a) Plan A & B - Dry weather flow to Hammond :, storm water disinfected and discharged to Lake Michigan -, (b) Plans C9 D and E • All flow treated and discharged to Lake Michigan with alternate for discharge to Indiana Harbor Carialo Plan A and B •• $7 s (A 3, 000 and $75022,000,, respectively Flan C, D and E - $6,2^1,0009 $63,360^000 and $5,338,,0005 respectively Alternates for discharge to Indiana Harbor Canal $260,000 to $380^000 DiEcu3sj.pn Whiting is served by a coinbined sewer system,, Tlie dry weather wastevater flov, from the City of Whiting is discharged to the Hamnond Sanitary District at the Robertadale pumping station for treatment by Hammond <> This procedure has been in effect since the late 40 ''s An overflow a-c one point in the Whiting sower system near -ohe Lake discharges to the Lake -when the lift station malfunctions or when the newer dovmstream from the lift station is surcharged,, Whiting also maintains a storm water pijmping station near the Robertsdale pumping station* At times of runoff fyom rainfall, storm water is discharged to Lake Michigan. The Implesnentation plan of the Water Qualj.ty Standards required Whiting to prov5.de treatment and disinfection of sewage snd storm water overflow on. or before the end of 1970, When it became obvious that the City would not aeet this schedule ^ the Board scheduled acci issued an administrative order to provide the necessary facilities <•• the final order which was issued on July 21 ,, X970j provided for completion of a project to provide for treatment and disinfection of sewage and storm water overflow by May I, 19?lc The order also recommended that Whiting continue to pump its wastewater to ttie Hammond Sanitary District <- ------- .?„ 2366-A Suiatiaty , ^f.d^'-r^^l. - Tae, preliminary report. which was received on September 8 .i.9?Uj,Tiraf ' copy rfccuivsd Augus. 14-1 provides information on 5 plans aad recommends Plan E as IL^ most Favor able . i, Flans A arid B. which ai^e essentially the same, provide for separation of th-i sewer system with discharge of wastewater to Hammond and disinfection of storm va'-e-r with discharge to LaJkf Michigan. The acawx separation construe'! ion coat is estimated to be in excess of $3.,cto»,ooo., -?., Plans C_ D, rir.d E propxse minor improvements to the, sewer system* a 3 raga aeti.T'atv>d slodge-'.ype ^reatsient plant and a 30 sag storm water dttt,«5ntion bdsiri., with provision for treatment of storm water at the rate of I mgd prior T>o discharge of effluent, to Lakt Michigan « \JLternat«;£ are indicated for tertiary treatment at an estimated cor.t of $500,000 and discharge of the effluent to the Indiana Harbor Canal in lltr.u of" to Lake Michigan. Comnifcnts Sufficient detai.'t is nut provided on the proposed treatment facility arid tertiary treatment undur plans C, D? and S to determine whether or not the cost estisaatt is feasible-. Sufficitnt data are not provided on stor.ro water runoff to assure that a 3^ fl^S storage basin is adequate to retain all fltsws with treatment capability of only 1 mgd above dry weathar flo\v\- Cost, data is rot provide-;} on estimat&c! operation and maintenance <ost» in oi-dtT to cuapartj the annual cost to Whiting if it built its own plant vi th «:h: cost of continuing to discharge to Hammond „ Ko i/ifonnation is provided on the feasibility of utilizing the sewer piitns and detention basins a.&. proposed under plans C8 B,, &nd E with dlsertargt- to haraaorid on a scheduled basis rather than construction --f a V«rrt- b '> Th<; repcrt con-,tjaree thfc (.-onstrucTioft ctjst only of Plan E with th« Construction cost and Li"eatHK-nt charge by H TVi'.'f« 4iC inccnsistsncie-^- and obvious errors in the report, so th«t a proper i-, valuation of all uspecf;s Is not possible. Tbt proposal by Whaling to provide its own trt5at.nH.-nf provide for dirfect discharge T-O fch<; Laku or via the Indiana Harbor Canal,. Whit'. ".;'' plat.i r>n , on - Thar i hf proposal, fcr construction of a treatment plnt and dischargf- v,o LA\«: Michigan or a trib^rtary thereto no-v be OKHer;;; 9/30/70 ------- c-7 Ci / I ; •/ -f-- < 0.0. die ,i y s - e «vv v ^ •» ctf ^ A O ' - -.-) w( 'I (" d.L sdl O^r^lO f t (- £ / /-I/ <^C^l^'e- -j c\ L, i /n/ f" (f « et> ^C ^<~ c 2367 ------- —^±:^ mbol. The filing time shown 32)UUMA170 M «KAt®3 AS ?1F WAUKESHA «1S 2 07AC1T HURRAY STEIN CARE LAKE MICHIGAN ENFtRCEWEUT CONFERENCE SHERMAN HOUSE CHGO FAVOR STAN1 AGAINST WATER POLUTION. AM OWNER OF 10N1S IN CONSUMERS POWER ENV1ROMENT MOST IMPORTANT MRS 1ETTY PRIEBE SF120KR2-65) ------- Klfits. DAN HARPER-BOX 216, ROUTE3, CRETE, ILLINOIS 2367 O.C. ic ;i:i <— . c-1 t W^ s , ,, J - ------- CLASS OF SERVICE ^ This is a fast message unless Us defected char- acter is indicated by the proper symbol. TELEGRAM SYMBOLS DL = Day Letter NL-Night Letter -p ^International ^ Letter Telegram j The filing time shown in the date line on domestic telegrams is 1OCAI TIME at point of origin. Time of receipt is tOCAL TIME at point of destination CT 2 AM 9 17 2368 SNA003 <32> ------- CLASS OF SERVICE ^ This is a fast message unless its deferred char- acter is indicated by the proper symbol. S. ^ STE TELEGRAM S SYMBOLS DL=Day Letter NL-Night Letter LT «mernat'onal w Letter Telegram ^ The filing tune shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination m 3 AM 9 [7 W MWAS23 EM NL P» < EX MILWAUKEE MIS i 2 SN CHAIRMAN MURRAY STEIN, ILY 75 FEIL WATER PtLLUTItN CtNTR«L A1VINISTRATIVE HEARING SHERMAN H«USE CHGt WE URGE YtUR CtNTlNUEl EFFtRT T« SET STAN1AX1S FtR LAKE MICHIGAN AT THE TtLERAlLE LIMIT F WE PERCENT THERMAL AllITItN AB»VE WATER TEMPERATURE ACC«R»ING Tt SECRETARY tF THE INTERIOR WALTER HICKEL STATEMENT. WE THE GENERAL PU1LIC MAY NfT IE V«CAL 1UT YfU HAVE »UR FULL SUPPiRT. HAPPY NEW YEAR BEAR MR STEIN T« Y«U AN1 YOURS STAFF «F VIRGINIAS 1EAUTY SALfN 49< EAST SILVER SPRING ELEANfRE GRACE MANAGER. SF1201(R2-65) ------- CLASS OF SERVICE This is a fast message unless its deferred char- acter Is Indicated by the proper symbol. \\7 1L1 CV 1 WJcoJL TERN UNION TELEGRAM ' SYMBOLS ^ DL = Day Letter NL=Night Letter ^ ^Letter Telegram^ The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination 1970 OCT 2- AM 9 I? 2370 SNA992 (25)(10)MC®3i SN M SB A003 SV NL ft SHEBWGAN VIS »CT 1 MURKY STEIN SHE1MAN HtUSE CHGt THE SMEBtYGAN CHAPTER tF THE IZAAK WALT«N LEAGUE tF AMERICA AN1 THE SHEBtYGAN CHAPTER MEMBERS SERVING AS OFFICERS ANB BIRECTtRS 9 THE STATE LEAGUE HARBLY ENBtRSE THAT THE WATER TERMPERATURE INCREASES BY NUCLEAR PtiER PLANT LtCATEB tN LAKE MICHIGAN BE HELB Tt tNE BEGREE THE STATE LEAGUE IS REPRESENTEB BY MEMBERS ANB THE SHEBtYGAN CHAPTER BY 215 MEMBERS E K B«RN PRESIBENT SF1201(R2-65) ------- CLASS OF SERVICE This is a fast message unless its deferred char- acter is indicated by the proper symbol. N /" STERN TELEGRAM SYMBOLS DL-Day Letter ML = Night Letter LT ^International "Letter Telegram The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination SNA00J M WSA043 JB PB ASV STEVENS POINT WIS 2 1100A CBT MURRY STEIN, SHERMAN HOUSE CHGO THE CITIZENS NATURAL RESOURCES ASSOCIATION OF WISCONSIN STRONGLY SUPPORT SECRETARY HICKELS STANBARB OF ONE BEGREE INCREASE IN WATER TEMPERATURE FROM ATOMIC POWER PLANTS F « 1AUMGARTNER PRESIBENT CNRA (1130). 2371 SF1201(R2-65) ------- F CLASS OF SERVICE I This is a fast message I unless its deferred char- I acter is indicated by the I proper symbol. S / WESTERN UNION TELEGRAM SYMBOLS DL = Day Letter ML = Night Letter LT = .International Letter Telegram The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination SNA005 <33M15)MBOf3 CL065 CC SNAOQ4 BY PBC 5 EXTRA SN CHICAGO ILL 2 >OSA CBT 1970 OCT 2 MURRAY STEIN, CHAIRMAN, CARE SHERMAN HOUSE	------- CLASS OF SERVICE Tills is a "st message unless its deferred char- acter if indicated by the proper symbol. WESTERN UNION TELEGRAM SYMBOLS V. DL= Day Letter NL-Night Lettet International T -T- ^international Letter Telegram The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination SNAOOg (07)(05)CTBO?2 WJ019 W SNB002 HH GOVT PBB SN WASINGTON 1C 2 1©43A EBT 2373 K'URRAY STEIN SN SHERMAN HOUSE HOTEL CLARK ANB RANDOLPH ST CHGO BEAR MR STEIN IT IS MY UNBERSTANBING THAT THE FWQA WILL BE .CONCLUBING AN ENFORCEMENT CONFERENCE TOBAY CONCERNING THE POLLUTION PROBLEMS OF LAKE MICHIGAN ANB THAT THE MAJOR PROBLEM ON THE AGENBA MILL BE THAT OF THERMAL POLLUTION FROM POWER PLANTS. WHEREAS THE SCIENTIFIC EVIBENCE REGARBING THIS PROBLEM IS ABMITTEBLY INCONCLUSIVE, IT IS MY HOPE THAT IT WILL BE REGARBEB AS SUFFICIENT TO PERMIT AGREEMENT ON A SPECIJIC THERMAL STANBARB FOR ALL PLANTS ON THE LAKE. ANY SUCH STANBARB WILL .NCESbSARILY BE AN IMPERFECT APPROXIMATION OF WHAT IS NEEBEB. YET IT WOULB APPEAR NONETHELESS TO BE AN IMPROVEMENT OVER THE CURRENT SYSTEM IN WHICH BIFFERENT PLANTS ARE HELB TO BIFFERENT STANBARBS OF SF120I(R2-66) ------- 2374 i^aafe Walton league of America INCORPORATED DEFENDERS OF SOIL. WOODS, WATERS AND WILDLIFE DIVISION Of FICFRs Sept l'!70--Sept 1971 \\OMFV-) VI' 919 Uc>* 4Vh -We. Gary. Indiana 46408 PRESIDENT Wajne Stapf 1 i34 E Raymond plamfield, Indiana 46\w sOU'lHWEST VP RR3, Box 233 Maitmbulle, Ind. 4bl51 SECRETARY Mrs. Barbara Rux 1613 Washington Michigan City, Indiana 46360 NORTHEAST VP 260 Manchester Ave. Wab,ish, Indiana 46992 TREASURER Gale S Atwood 3625 Lincoln St Gary, Indiana 46408 E CENTRAL VP 416 W. Foster Kokomo. Indiana 46901 W CENTRAL & lfat VP George Leedy RR2, Box 47 Plamfield, Indiana 46168 NORTHWEST VP 5808 E. 10th Ave Gary. Indiana 46403 EXECUTIVE SFCKLFARY las E Dustm. 1802 Chapman Rd , Huntertown, Ind 46748 . Ph. 219-637-6264 October 2, 1970 To: Federal Water Quality Administration Statement of: E. Eugene Minney, President Interchapter Council Indiana Division, Izaak Walton League of America 228 N. Raymond Griffith, Indiana Gentlemen: I am E. Eugene Minney, president of the Interchapter Council, an association of Izaak Walton League Chapters in the three northwestern counties of Indiana—Lake, Porter and LaPorte. These are also the Lake Michigan counties of our state, so we know you will appreciate our exceptional interest in this Lake Michigan Enforcement Conference. In our region of the state are approximately 1200 of Indiana's League membership, the vast majority of whan see Lake Michigan almost daily, and use it recreationally many times each year—for swimming, boating, fishing, and simply enjoying the change of pace which the Indiana dunes' region uniquely provides. We commend the Department of the Interior for recommending a 1°F limit for temperature elevation in Lake Michigan. We would like to observe that there has been a good deal of utility propaganda flowing from this Conference, most of it, we suspect, for public consumption in far off places, and not especially for the edification of the Conference. Perhaps some of the officials of the four Lake Michigan states may feel you have been overly restrictive in recommending a virtual zero-tolerance for Lake Michigan thermal pollution. We don't think so, and we fully and without qualification endorse that recommendation. If in recommending that tolerance you mean to tell the utilities to move off our Lake Michigan shoreline, and to design inland plant capacity with completely self-contained pollution control systems, then our endorse- ment is just that much stronger. Because that is what we think they should do also. The utilities have made much point about choosing between more electricity ------- Page 2. 2374-A and the maintenance of high environmental quality. We don't think this is a choice they should be able to make. Lake Michigan does not belong to the utilities; it belongs to all of the people, and we are all entitled to it in an unimpaired condition. The utilities have produced nothing at all to suggest that their thermal effluents will be harmless to Lake Michigan. And a great deal of expert testimony and documentation suggests that it will be very harmful indeed. It is not gur burden to prove that their activity will further destroy Lake Michigan. We are not dealing in :the_ir estate; they are dealing in ours. And this is a distinction the public and its agencies have not made very well in the past. Other than a lone biologist who seems willing to be quoted by the utilities—and whose views have been contra- dicted by other more independent experts—there is no basis at all for allowing any more utilities to discharge warm water to Lake Michigan. It would be maddness on our part—raw maddness—to bet the life of Lake Michigan on the say-so of one or two company-retained biologists, who have at very least the appearance of conflict of interest. If our Federal or state agencies allow so much as one more utility or any other industrial installation to add its pipe to the lake, to discharge anything warmer or of poorer quality than natural lake water, then such Enforcement Confer- ences as this one will no longer have a shred of credibility. We have not rolled back the wave of pollution here in the past five or six years. The very best that can be said is that the lake is getting worse at a slower rate. This is because neither the people nor their governments at various levels have stood firmly enough. We have rational- ized and equivocated. Let me point out just one evidence of the grave environmental injustice the utilities are expecting all of us to absorb. The National Water Resources Council has predicted an immense increase in water needs by the year 2020. Water development agencies are more than pleased to flash these gross figures around, in order to stimulate public support for the billions of dollars it will take to provide that water. But what the people DON'T realize is that while municipal, agricultural and industrial interests account for a relatively modest part of this increased need, it is the utilities which account for MORE THAN 50% OF THE ENTIRE INCREASE; and that is for cooling steam generating plants. The immense cost of pro- viding that water is to be borne by the public. Why should WE pay for their hot water pollution, and then face them again in an iron ring around Lake Michigan—polluting our water, graying our skies, and uglifying our shorelines. It is long overdue for a reckoning and a re-balancing of these environ- mental books. The utilities scream to the people of this land that they must double their capacity every 10 years to stay abreast of demand; then they go forth and create that demand. They ominously forecast blackouts ------- Page 3. 2374-B and brownouts when their 19th Century methods of operation are questioned. But if such methods are calculated to pave the way for a new permissive- ness toward untreated high-sulphur fuels or a free hand in thermally polluting Lake Michigan, those methods will fail. The fact is that in environmental engineering the utilities have done a miserable job, born of regional monopolies and other exclusivities. It is too bad we haven't yet come up with a way to put the utilities in the cauldron of competitive economics the way the rest our society has to operate. At this time, we can't buy somebody else's product if we don't want NIPSCO's. But if we can criticize the utilities—and they have much of it coming— it is also up to all of us to help them make the transition from laissaz faire environmentalist!! to ecological environmentalist!!. They are right when they say the cost will be great. They are wrong when they fail to begin creating the atmosphere in which the cost will be acceptable. They are wrong when they oppose every effort to tighten anti-pollution laws; and they have done this, at every hearing in the state of Indiana, where our representatives consistently testify for better conditions. If the utilities cannot support the clean water and air proposals that Interior and H,E.W. have been making, we would think the least they could do is to relax their fight against these efforts. By following such a course, their position in requiring all of us to help with the costs would be quite understandable and defensible. Their present position can only lead to the conclusion that their primary interest is in corpor- ate profit, not public service. They apparently see themselves apart from the rest of us, instead as a member of the same team. We will have to recognize our share of the cost burden, but the utilities will have to recognize that the environment they are polluting is not theirs to pollute, but ours—everybody's—to enjoy and live in harmony with. On September 20, the Indiana Division of the Izaak Walton League—with the full support of our northwestern chapters, adopted a 10-point proposed policy for Lake Michigan. It accompanies the testimony of our state executive secretary, and I will not reiterate it here. But we feel that policy could be the start of the kind of new attitude toward Lake Michigan which can begin to produce results. Whether some of its points need changing, or other points added, it recognizes Lake Michigan as an integral environmental unit. Our generation MUST stop seeing Lake Michigan as an estate that can be chipped away piece at a time. It must be seen as a whole, and we must soon decide what kinds of activities are acceptable in its context, and what types are unacceptable. ANY more thermal pollution must be judged unacceptable. And 100% effluent standards must be the next goal we set. If are serious—genuinely serious—about saving Lake Michigan, then there are no real alternatives to such a policy. ------- 2375 ' i -v v vi/\ '' --<>\^-'+'^~ /J i / ^ ~T~ a^j" -U^-L -dL&' ^ ------- 2375-/? ------- Oct. 3, 1970 Mr. Murry Stein, Federal Yfater Quality Administration, Department of the Interior, '.Washington, B.C. Dear Mr. Stela* I found the following telegram awaiting me when I returned home from the Lake Michigan Enforcement Conference - Octe 2nd. I -was sorry that I did not have it in time to include it in the statements made that day - but would like to have you enter it into the records - Telegram - "Regret I am unable to leave "Washington to attend the meeting to be held in connection with standards to prevent the further pollution of Lake Michigan on October 2nd at the Sherman House0 Wholeheartedly support a program to make certain that no significant heat be allowed to enter the lake from Nuclear Plants. As my activities in the past have demonstrated, particularly as they apply to halting the dumping of dredgings into the Lake by the Corps of Engineers, reflects my deep concern with the problem of pollution not only of Lake Michigan but all the Great Lakes. Please feel free to call upon me at any time if I can be of assistance in my capacity as an Illinois Congressman in pursuit of efforts to improve ecological conditions." Congressman Harold R. Collier 10th District - Illinois Do hope something constructive and positive comes out of that meeting - to assure the safety of the Lake,, The loss of it would be a major catastrophy for millions of peoplel Sincerely, _^ The time to take action is nowll MRS. J. F. VOITA 229 North Taylor Ave. Oak Park, Illinois 60302 ------- State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES L. P. Voigt Secretary October 8, 1970 MADISON, WISCONSIN 53701 Mr. 'Murray Stein Assistant Commissioner Federal Water Quality Administration Department of the Interior Washington, D. C. 20242 Dear Mr. Stein: Enclosed is a copy of a statement of the Wisconsin Wild Life Federation submitted by Mr. Les Woerpel of Mosinee, Wisconsin. I would appreciate your including this statement in the record of the workshop sessions of the Lake Michigan Enforcement Conference. Very truly yours, Division of Environmental Protection Thomas G. Frangos Administrator Enc. ------- Wisconsin Wildlife Federation Affiliated with National Wildlife Federation Post Office Box 7, AAosinee, Wisconsin 54455 September 30, 1970 STATEMENT TO BE ENTERED IN THE CONFERENCE IN THE MATTER OF POLLUTION OF LAKE MICHIGAN. The Wisconsin Wildlife Federation would like, first of all, to express it's approval of the United states Department of Interior's proposed regulation not to allow waste heat discharges into Lake Michigan to exceed one degree Fahrenheit rise over ambient at the point of discharge. The question of thermal pollution must be decided now, because, if a tight limit is to be kept on heat discharges into the lake the pattern of building future plants will be affected, and it may be equally as economical to build plants in other locations than on the shores of ready water supplies. If Power plants are permitted to discharge waste heated waters into the lake the precedent will have been set for future concentrations of these plants around the lake. If allowed to dump heated wastes more leniently the time will surely come when the orders will have to be tightened up, and it will be next to impossible to secure compliance with desired waste heat discharge goals. Regarding Industrial and Municipal discharges of wastes into Lake Michigan or any of its tributaries, the Wisconsin Wildlife Federation has long been on record that they should be mitigated and stopped as soon as is humanely possible. No material progress in cleaning up these waters can be made with a lienient attitude toward polluters, whether of private or governmental origin. An example is the doubling of the solid waste load in the Wisconsin River over the past ten years, a period when everyone thought great effors were being exerted to cut the amounts of such wastes being discharged into the river. We therefore urge that every effort be made by the various state pollution agencies and the Department of Interior to set standards which can realistically attain a goal of lower discharges into the waters of Lake Michigan and its tributaries in a reasonable period of time, And that the goal not be reduced percentages of waste from a plant or municipality, but reduced total discharge regardless of expansion of operations. Signed, Les Woerpel, Secretary Wisconsin wildlife Federation. ------- STATF OF ILLINOIS ENVIRONMENTAL PROTECTION AGENCY SPRINGFIELD, ILLINOIS 62706 October 9, 1970 AREA 217 ' 525-6580 Mr. Murray Stein Conference Chairman Lake Michigan Enforcement Conference United States Department of the Interior Federal Water Pollution Control Administration Washington, D.C. 20242 Dear Chairman Stein: The authors of the enclosed letters were unable to be present at the September 28 - October 2 Workshop relative to the question of thermal discharge into Lake Michigan. They therefore would like to have these letters made a part of the official record of the Workshop. Sincerely, C.W. Klassen, D i rector Ends. THE NEW ILLINOIS imodato ------- bOA 2rar, nuU i t Jfr, CHt 1t, <"<"//7 n , I* ,, RECEIVED -v^'f-1- pr.oTECT!:;j. AGCNCY TATE orra'-!:io:3 ------- MRS. MAXWELL MCCROHON ROUTE I. STUENKEU ROAD CRETE. ILLINOIS 6o4i7 September 30, 1970 Dear Mr. Klassen; Hopefully you will support Open Lands and all the environmental organizations which oppose the discharge of heated water into Lake Michigan and propose a standard of discharge no higher than 1 decree at the point of emtrdssion of heated water. The effects of heated water are not known at this time. V/e can no longer afford to pursue traditional practices which have accounted for the cesspool conditions affecting our inland waters. Thank-you for your attention. Very truly yours, EiVED OCT 51970 rrj. PROTECTION AGENCY STATE OF ------- 6 \J '3 I •> p. SCAMMON BARRY, M. D. I7SI RIVER DRIVE Sept. 2? ,„ » OLKNVIBV.miNOl. SIM - Clarence Klassen, 111. Environement Protection Agency 535 W. Hefferson St. Springfield, 111. 62706 Dear Mr. Klassen: I urge you to use all of your influence to get the 4— state Enf6rcement Conference on Pollution of Lake Michigan to adopt the strictest standard under consideration for thermal pollution. I believe this is the standard announced by the Dept. of the Interior. This opinion states: "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 rise over ambient at the point of discharge." Thank you. for your attention. Yours truly, P. Scammon Barry ------- NINETY-FIRST CONGRESS _ EDWARD A. GARMATZ, MD., CHAIRMAN LEONOR K. (MRS. JOHN P.) SULLIVAN, MO. WILLIAM S. MAILLIARD, CALIF. FRANK M. CLARK, PA. THOMAS L. ASHLEY, OHIO JOHN D. DINGELL, MICH. ALTON LENNON, N.C. THOMAS N. DOWNING, VA. JAMES A. BYRNE, PA. PAULO. ROGERS. FLA. FRANK A. STUBBLEF1ELD, KY, JOSEPH E. KARTH, MINN. WILLIAM D. HATHAWAY, MAINE WALTER B. JONES, N.C. RICHARD T. HANNA, CALIF. ROBERT L. LEGGETT, CALIF. MICHAEL A. FEIGHAN. OHIO FRANK ANNUNZIO, ILL. SPEEDY O. LONG, LA. MARIO BIAGGI, N.Y. THOMAS M. PELLY, WASH. CHARLES A, MOSHER, OHIO JAMES R. GROVER, JR., N.Y. HASTINGS KEITH, MASS. G. ROBERT WATKINS, PA. HENRY C. SCHADEBERO, WIS. JOHN DELLENBACK, OREG. HOWARD W. POLLOCK, ALASKA GEORGE A. OOODLING, PA. WILLIAM G. BRAY. IND. PAUL N. MC CLOSKEY. JR., CALIF. LOUIS PREY, JR.. FLA. JACK H. MC DONALD, MICH. ROBERT J. ABLES CHIEF COUNSEL ROBERT J. MCELROY CHIEF CLERK {jETOttttttlttCC Olt _-^ , V. 5$t&tUTC 31X0 0<"« %)tmst ©ffice JBuilbins i, B.C. 20515 October 12, Honorable Walter J. Hickel Secretary Department of the Interior Washington, D. C. Dear Mr. Secretary: I wish to bring to the attention of your agency certain matters with regard to the Four State Lake Michigan Enforcement Conference dealing particularly with waste heat emissions into Lake Michigan. It is my wish that this communication be included in that record and that it be carefully considered by you in con- nection with actions to be taken on heat emissions into Lake Michigan. I would call to your attention your responsibilities under Public Law 660, as amended, dealing with different forms of pollution, including heat emissions. In addition to this, I would very forcefully direct your attention to the Environmental Policy Act of 1969 which imposes upon you the duty to interpret your fundamental statutory and regulatory authority and responsibilities so as to assure a clean, wholesome and desirable environment. Your agency is even required under Section 103 of the Environmental Policy Act to submit statements as to how you pro- pose to bring your regulatory and statutory authority into con- formity therewith, and upon failure to be able so to do, to report to the Congress advising this body of how your statutory powers, duties and authorities should be changed to come into conformity with the policy statement of the Environmental Policy Act. Pollution of the Great Lakes system is a major aesthetic, conservation, environment and resource problem. Lake Michigan is perhaps the most endangered of all the Great Lakes because of the ------- - 2 - low level of flow into that Lake and the long time that pollutants of different kinds remain there before being carried out by flow of water. Massive heat emissions of the kind contemplated by the chain of thermonuclear and conventional generating plants around its shores not only will be a major source of pollution, but will constitute forces bringing about significant changes in the ecology and environment of the Lake. In addition to this, massive heat emissions will increase the effect and hazard of other pollutants dumped into the Lake by industry and cities. It is my understanding that most of the operators and those associated with the nuclear and conventional generating plants which have appeared before your agency have given you to understand that the choice is between heat pollution and no plant. I wish to bring to your attention that this is not the choice, but that there are a number of alternative methods whereby the emission of heat into the Lake may be reduced or avoided altogether. Cooling towers, settling ponds, holding basins and dilution of the water by pumping of extremely cold waters from the depths of the Lake are all available to the users in addition to a number of other technologically and economically feasible devices. I specifically call to your attention the fact that the National Science Foundation has made a significant grant to Scripts Marine Laboratory in California to study pumping of water from extremely deep levels to be used both for cooling and dilution of cooling returns so as to restore the water to temperature approxi- mating that of the surface levels of the recipient water body. I wish you to know of my strong feelings on this matter, and I sign this letter as Chairman of the Subcommittee having jurisdiction over the Environmental Policy Act, which I would have you know imposes a far higher lej«»±-«f responsibility on you than many of the witnesses appearing before you have had you believe. John D. Dingell. Chairmant Subcommittee on Fisheries and Wildlife Conservation ------- Oct. 13, 1970 Mr, Murray Stein, Federal Water Quality Administration Department of the Interior, Washington, D.C. Dear Mr, Stein: On the last day of the Lake Michigan Enforcement Conference (October 2, 1970), mention was made of the fact that additional statements would be accepted for the records, if mailed to you during the following three or four weeks. There is so much I would like to say in this regard - much of it already said by other excellent speakers that day - and yet I would like to add my part to all the opinions expressed. I thought it could probably be best said by a letter I recently wrote to Mr. Donald C. Cook of the American Electric Power Company, for whom the Nuclear Plant at Bridgman, Michigan has been named. And so - am enclosing a copy of the letter, together with the enclosures I sent to him - all of which are relevant to this matter. Please consider these copies as my statement. Thanking you for this opportunity to help in the matter of trying to save Lake Michigan for future generation si Sincerely, MRS. J. F. VOITA 229 North Taylor Ave. Oak Park, Illinois 60302 ------- Copy to - ftr. f»10aa wr« ;ioaal r,tt«ad^ijo« all three d-yt of fch« hn^ri (-; i« to the iftllsados --tomie -sorgy Hl«nts - hold la Salaraazoo roe&atly, IM only ^lonned on »tt»rKti:i{ tho seseic-.is the first day, bat fotiad them aa ifeaoinmti.if; that It srfta im- possible to stay away, y-u to Juaw -was that 1 was doll-htsci with the •asy yo« oc/wlaofoM t.» ma^ti-tg » ye»-sr opwjj-ratadednsBs throughout • ec«J y«;r ^irana ir. »rfi»t I felt tae tho right 'c . ~. wlu si" '» of tba rao;rfci;sg» For, swrel^', as you eul<2, f^ero i»r-> setters that nrarie.* fUrthar co.it; idaruti it bofors ths> permit oo-.ld be i^^pueti. •..•«» so ia to be »t a turni.'ig polat in the history of btonie «3n-jriyt wh«n vt» med to -dve nore CDAsid^mtion to th» tot»l imp«iet an the savirojiaeiat, wiich its so important for th-s ruturn of out o«j-mtry» purely iss need elaotrioity smd aauelear B ew«Bi to bfi the u.ie?wr, but thnr^ u.ro -flays th»t c^jr air f«»d w\t-ar oun be protected sad xvo n«n»d to 9R^»i»i8o this to th© fNllwat ia devels^jiHg this oar osarirorwjntal or i s^a wo b«gia.d«^ fco foro« us to a ;aoro r«»tlG«ui ii» tho n»r future &a Sipj.>roaoh to the resional, aatir«ial 'ad Q intermti->r;sl pjManing of pO"«r pl'yst siting thut will ooasidor bftsfe will iicluda eavlrmMasitital effects such a than*.! «C'£«ets oa r s?y3ttjns, fair pollution problems BS det«rmi"ic<} by reci!>-ig-l itl :s fxod populati.'M daasities, thatlo.;s &ad ja^ay othor factors that ar« ncrt now ooiitrRl oon» 'se in the aiti'v; of poiior plants, aot to ;«»jntiai the plsuitd::^ of raore ir,^;jimttiv© tn^rfy syat«ns • . . » Local th«riafil effects ar«i a nueh <;ror.J;»r ~>robl9;i «ixl arr- alroiidy noWc^blo, -e will havo to Disperse the hoat pro^.'ueo! -»orH eJ'r^fiilly, Curfcaial,; if in are coinj; to uae our energy to continue to hoawfit {!au» »a3 not harm hi» or his anvirtajwoat, we will h&vo t;> / ivc fw grodtor oo.mideratlon to th» wiisag«JKont of whftt le now our -?»ste lios-t. I boll >w tMs «r-a bo d-»i« by better slta planning, funti Tdth th» pro^r us® of now »ad olijig tf9chnolof;i«o, such as ooo'i-ig toworo - of bot;i th> wot und dry ty - hol<)i ^ po/-M3a, oanals, c«d other aotnotis." So - 1 fe^)9/ n is r^sRiasd an July :ilst. I hfjpe to bo pr»"-«nt -oki vvnt to tii^nk v y for ,yo-r o?'rort8 in t/-.!a ar.ttor, fta«l for yc^u* ------- Copies to - Secretary he ear Ur, #ranois T» myo Senator idmurd amide Oov, '«aa» G. adl liken Senator Philip »rt Michigan jpt«, of Natural Useources secretary waiter J. liiekel Carl L. Kloin Donald C, Cook Br, Glenn aeaborg July 9, 1970 Col, Jaraee T Ifoite, Jr. Amy Corps of Ssfceineers, ?, 0. BOX 1027 Detroit, Mich. 48231 Dear Col, Whlt«t !st week my husband And X visited the nor completed inf orafttion end Visitor e' Center at th« Donald C, Cock Nuclear flwit, Brtdg»m, Michigan, There X learned you havw not yet granted the permits for the proposed temporary harbor, or for the installation of the pipes for the "cooling qyeteW, You oan believe X HAS very thankful to le&rn this fact. &eently 1 have attended several hearings which have been jaoat in tore sting, -jjd which X believe represent a turning poiat ir, the environmental nrot«o> tlon story, which will influence what is to b* dona in the future to stop pollution tu all its forma* Fir at * the I*ke MiohJ^n 'nforoenent Conference, held in Chicago on Jfey 7th, established tho fact that th» i'epartraent of the Interior thought it advis- able to set a new standard in rogard to tharraftl pollution, as followoi "The isaat« heat chall b» added to the waters of Lake Michigan, Xa no oireaat trill heat disoharges b poraittod to ejco»«d 1 degree F* over aabiant at tho point of discharge, This Trtll preolude th» ae«d for mixing semes" X undsratiand that the four states border- iag on Lake Michigan are now eoneideriag this net? standard, to put it oa a working basis, Second • the abating held ia Balaoasoo, tiiohig&n on Jttne 23, 24 and 25, in \-zhlcJt the ^Socdo aorgy Coenisai >n oaoduetod & hearing In regard to grant<» lag a prorisi >oal oporating license to the Consumers Power Company for the opening of Its BOW ooopletad falisadas ftoolear Pl^at, Four eaviroi^wntal groups, joitied by the sierra Glob, together with aersral lasers i^to gaim their sendees vithoat pay, brwght ia enough evldanoe that Mr 'jam Jeasoh of the ^tonio Safety and Licensing Board adjoined the tasotiag after three days of testinooy, sineo he beoarae co-nrl^ced there were too nany issues to be resolved, requiriisf, furthnr InforavblJa on all types of possible pollution connected with the operation of the plant* Therefore ho called for & reoess, without issuing &ny permit, askine that further data be presontod by all parties involved - the hoarlng then to be reconvened oa July 21st, The deciding factor in all this, it se4nat«v«^r the final outoos-« of this Atonic .nor^y Coanission hearing is, it will also be pertinent to the Done Id C, (took Plant, and we wot to be sure that the necessary changes in their plans are considered notr* Just this morning ia the news report, e learned that president Hlxon has organised a new Federal SBvlronmantal Protection Agency, that -will hnve coo- plete charge of all Hatters pertaining to the protection of the enviromant. With all these new agencies and laws beinf, sot up, it eeoas to us that the Ansy Corps of 'Acineere should not grant any permits to the Donald C Cook Pleat at the present; tisw, awaiting the new standards that will inevitably be set to govern the development of nuclear energy. You sorely wo-;ld be doing the Indiana and Michigan hleotric Coop&ny a real ser- vice cy delaying the granting of these per nit a, so that they will aUoB no costly nistokes that will later have to be rectified. Wli do hope you will add the Aray Corps of engineers to the list of organisations who are now actively concerned in all fonts of pollution - and assure you •ns will greatly qpprooiate your efforts in this regard. Sincerely, ------- Copies to - Senator Philip A. Hart Michigan %tor Resources Commiseioi. Mr, Donald C. Cook, Pres. fan. Power Co, Col. James T. White , Army Corps July 9, 1970 GOT. 'to. G, Mil liken, State of Michigan, Lansing, Mioh. 48926 ">ar Gov. Millikent Ifey I preface my remarks by saying that for the past thirty-three years we have been spending our summers in Michigan . and have come to feel that it ranks above most any state in the union for sheer beauty and enjoyable features. We have adopted it as our favorite place to be - and in the very near future hope to make it our permanent home* Heedless to say, it is the big lake itself that is the most appealing aspect of our lor* for Michigan and we are very rauoh disturbed by what has been going on in recent months to undermine this moot ealient and important natural resource* Ju.rt two wsaks ago I attended a three day hearing at Kalaraaeoo, in which the Consumers power Company was seeking a license to operate its now completed mlisades Nuclear Plant, Zt was a most interesting and surprising meeting in the fact that the Atomic Energy Commission completely reversed its thoughts that it -was not concerned with the thermal pollution that would result in the heated water to be introduced into the Lake at 28 degrees P. As you are aware, I am sure, the meeting was adjourned, without the granting of the permit, in order that more avidonce and factul material be produced by all parties concerned - to be reconvened on July 21 et. There is no way to predict what the outcome will be - but at least we conservationists feel there is hope} Now - what I am moat concerned about is that during this moating the fact wae constantly brought out that the state of Michigan has set no standards in regard to Lake Michigan Your attorney general (or it might have been someone who represented him) gave evidence to this fact and could promise nothing in the way of future regulations* This is hard to believe in the face of the fact of how important the Lake is to the entire state in ways that wot Id take pages to enumerate. Via cannot understand the reason for this - and do hope that in the near future steps will be taken to correct the matter - which is the reason I am calling it to your attention* I am sure you are aware of the importance of this matter, when the Department of the Interior proposad t. limit of no more than one degree rise at the outfall of each plant. As I understand it* this propos&l must be acted upon by a conference of the four states involved. Hay v* say, we are hopeful that the state of Michigan will fulfill its obligation in this matter, setting a state standard as nearly in accordance with this propo- sal as is pfaotio&lly possible. If this happens, our confidence in the leadership of this glorious state will be renewed and intensified* May I suggest that before you and your colleagues come to any definite conclusion that you look carefully into the regulations set forth in two acts passed by Congress since April 1, 1970 - both the National Environmental Policy and the Wter Quality Act, It was facts brought out in regard to these two recent Congressional acts that caused the Atomic Energy Conmlssion Licensing Board to look further into the matters involved and to continue the abovo .mentioned hearing at a later date* The Palisades Plant was designed and built, meeting the standards (or lack of standards) - and now it is ready to begin operations - and so far cannot obtain the license to do so. It surely is not fair to the Consumers Power Company or to the Indiana & Michigan Power Company to plan their facilities under conditions like this. Our sumitwr home is just a mile south of tho Donald C. Cook Nuclear Plant under construction. They at the present time are endeavoring to get a permit to introduce heated vt&t&r into the Lake at 21 degrees P., and •".£ far as I know the Army Corps of Engineers have not as yet issued the license, What must be hold it up is the uncertainty as to the laws of the state of Michigan, 1-0 vdll ^ealy appreciate your efforts to rectify this situation, keeping in mind that nothing should be permitted that would in any way cause the deterioration of Lake Michigan. Sincerely ------- 14, 1070 Hr» Dem 3d C. Coda, Pro aidant, •fiaoriofta !il@etrlo power Cor^jfiay, Iae«, 2 Broodisay, Hew York, 1«Y, lOOQ-i Dear ISr. Cooki Ifc tea bean soae time ainoe \» hssve been if} eaetnunioafeion. So sa»fe hag happened in just the past few weeks - and thore Is so EJEWA to talk about, 1 knew or0 to begin, Since you hwe b«sa kSnd enough to giro attention to letters to yo>», 1 am again taking the opportunity to talk with you about first, I tjonltl like to toll you about the pl««aitro t» fed on s reocsat r&Jay of beiar: guests of the Indiana and MiehlfWj i^ver Congmny at your recently atoned Cook 'tableo? Crater, Kr. Pruolasffiiller sent all of us Sa the aroa a letter oi JL tioo a«J M-ay todt atl?nnte/;o of the opportuaivy to l«an» what is boiii^ doas ^«Jd of tho progress thp.t heta bean a&de. The Center surely is aw aro<oe-iisrsl gats, uafl tho l*na» aoaplng is b««utiful --JKI so 4ppronriut« to the OT$!tnt ot i'-aliaaaeo P&rk, Two moat tmoxp^ct'X? rteTBlojnonts hnvs cons out of these (1) The propoaal that "in no erent tdll hf«t tfi0cjj.r§os be to 9-XSG9& 1 dsgr3« F, rise over asibiont at the point of disohftf ge, thus precludlr'K need for alxlng «9o»''» • this beiag propoaed by ti» Bepartrneafc of tSto interior, AS I under cfearstl it, the ftair statoe bordering on lutea Miohigan ore now to the process of ew&luofei&ij tl\ia proposal In the hojw of arriving at a worJaable solatii,n, 1« dstemlning jusS vAat hiss safe, porsisiagabla tessgjeratur ahould be for water returned to the? fhls -sdll in oil probability tftk® R,t lo^st tfljt to nine nusjths to aoooaallah, So - huvr to «ait to SB© whut oorasg of (2} Tho a0otia^ at Kalomaaoo, oo£id«otad by a .:;o4^rfl o.? tfoe taaie t, in regard to thfj grtuit'ng of a liconee to op-Tat© to the Congisaers i£r «r for its now ocrapleted plaint at faliaadea - prodtwxx a moot aaaapeetod txtaujt - a complete rsvcreal of a sfciiatl"tho .Atonic '-acrcy ConRlaaiiin has t«4sea la the gnot, AS t«Rs sfcatfld by tJwt Board wipwatgdly at t:« opoaiag of the meeting it oae act otaioeraoij with the probl«3 of "'tharaal pollution'1 - but at the end of tiro© dayo a reoesa \iaa oallod so that further srlrionoe ootild be brought in by ail parties oc.'soeriio^, I ea onolosing a oow«sap«rr report -wtfdoh covors fcfk> throo day hearrLig -mito adeqnatoly« but wish to aay furtbar, that tho latter who gpvo bis oervieas without ohairge, pros««i-,Gd his oese for the esnaarrotioa Sfs£>« in a brilliant manor, les^i.iG no doubts thut tte racozatly passed Congressional Acts (both Sho -wriromonrtal Art anfl the ktor ^ii-lity Act) a ooajjl:-te review of Btanelards thnt hsw» boon f®lt adot^uate Ln the past, AJ-d so, ae sfcatoS above, tho haRring ^as recessed after three days, to 00 reooiWsjaiod CM July I ho;>e to be present at ttot tine, With the above la mind, yfca oan toMgl-ie ho-,? aurpris-^ %afl TW all «re to learn that th» Angy Corps of an^iaews just within the aasfc week ma granted tho t"X> panaits loh i««pe boinc oo:ite8to<< by rarity grow^a aw? iixlivlduftle !.•« this area . In i-Js® face of th* fact that so wuoh is developi:is &!»>?,, tsio lino Just at tMs It aeeras to en thi« is wost shorU-oi^hted at a tins vjh>?n ncn7 ofcf -.^fiJTc' s &re in the ------- - 2 . process of being set * aad before all the evidence it in, For* surely, i&at happen* at the aeettng la Ealaaajjoo aext mek all! apply to the Donald C. Cook Plant as well, A* I an sure you are aware, president Utxon le at present setting up a aw InnriroasMotal Protect Icn Agency, dravrlng the mt.Jor eleraonte of pollution fighting agencies under one unfcrella, for a concerted battle to clean up the nation' 9 air and water, Sorely this aew a^eacy will bo above the Anqr Corps. if it is to be effective at all and at last the long history of horrible instances of envlranaozital deterioration, which has rightfully bean pluoed At tha doorstep of the Corps, will be brought to an end. 2 ftj* asking that you give consideration to the copies of letters X have written to various concerned people - especially to the letter to Hr, tea Jeneoh, la nhfteh I how> quoted frca a roeeat speech by Or* Glenn Seaborg, which bringe out th» fast that be too is baooatne «mre that new standards i»v« to be set, as fppiied to atonic energy, to protest the enviroas»nt« Then •> there is the article about new plans to u9 the hot water of Suolear Plants * a study being eoadooted at the Oak Kidge flational l«tbore.tary * t whioh show that new and oongtructire mays are being earisioas4 for the use of «mat is now "wast,® heat1** X know you do feel that there trill be ao ham to the take by adding heated water. But from all the eridttwe I htvre heard* there is «wmh fooling «ad knowledge to the ooatrary. The Open Unds Project (entirely funded by oonoerasd buainass aea and individual aitisens) begpn in a siall «ay, being interested ia preserving the eaviroaoent in the Ghioago area, KM now, just irtthia the last few troek's, extending their aotivitiu* and o'MCernfl to the satire Lake Michigan area, including all four states bordering on its shores, «o that with this larger organization they oaa becows more effective ia their efforts* they are t»ry «wh oonoerned with the thenaal pollution aad are putting all their efforts and wiantlfio toowledgs to work to stop it. As you aight r«iaeaA>er, m haye spent over thirty euoraers on the late in this area (Just & Mile south of the Cook Plant) sad I have seen the iafee constantly deteriorate, '** now hnw algae most of the tine * ss-wthinc t^t ttas onJmown a few years ago - all due to the aisttae of the l^e» by industries ^ad isunicipeJLiti@s over a long period of tins* So, the adding of "heated wator" is <& real danger* especially a» it is ridded to tho pollution that already ia present in leJco Miohi^o* Dr» Ayros hiaeolf admitted at the open hearing in Bridgpitt this spring that there would be algae in the immediate vicinity of the Pl&nt and whan pressed for <a anewor as to hotr far, as said it wiltf probabl;; cover & adle or two eftoh T»y. This is terrifying to us who are within that vicinity, but also for w^ny others mho coma to the beaches for relaxation and reoroation, Ia the past two sunasrs ne havw had days wh0a the algae «ag so severe us had to stay eaay from the lake until the condition iiaproved .« would read ia tie paper - ^Donuld C. Cook, president of /werioaa For Company, has node the decision to ------- • 8 - \|»~farther that «A.th all that has been happening in the past few wok* * all the reeest f ladlnge anA rrriead theorise that has been of concern in high place** from President Nixon on daw through the various bureaus ftnd ocnaisaions ia the goveraasnt - you will proceed aoro tloety end with aore thought in 11 thcdt is being pltMtasd for the Donald C, Cook Plant X do hope that sone tin* tie Right aeet* As X told you in a previous letter, X had the pleasure of nesting several of your toy sen from the Hew York sjrea, «xan they were present at the publis hearing at Brldg«a» this spring - and so &» hoping that in sosao future visit in our area, it ndght be ny privilege to meet end talk with you You are cordially invited to be a gn^st in our hotae in Oanewoodl, on the l ------- An article from "The Rational Enquirer* 1BW PLOT WILL USE HOT WATER WASTE CF NUCLEAR PLANTS TO HEAT AND coca. CITIES Instead of polluting lakes and streams and klll& g fish by the thousands as it does today, the hot water expelled from nuclear power plants could be of vast benefit to nankind, a noted atomic eeientict says* It oeuld be used to heat and eool entire cities, maintain huge greenhouses for food crops, and even help solve other pollution problems such as waste disposal. This is the picture painted by Sanu&l E. Beall, head of the Nuclear Reactor Division at Oak Ridge national laboratory in Oak Ridge* lean, Beall says much of the energy generated by atomic reactors is lost in the water used for cooling then. By utilising this wasted power, he told The Qdqulrer, industry eould turn a potential environmental ft aaster into a blessing* With this in mind, he noted, a new division of Beologiaal Sciences has been set up at the Oak Ridge National Laboratory to search for ways to turn the liabilities ef nuclear energy into assets* "A large eity could be heated and cooled with the throw-away heat from nuclear plants, and it could be done more cheaply than with electricity", Beall said, B» explained that the hot water could be piped into the city and used to operate heating and refrigeration equipment* The hot water could also be used to heat giant greenhouses, thus creating additional food supplies stt to feed entire cities, Beall suggested* "With a constant flow of hot water, temperatures and humidities could be regulated in greenhouses to greatly increase the productivity of existing acreage* By using the land All year round for three separate crops, one acre of land under such a greenhouse could produce up to 600,000 Ibs. of tomatoes, for example - or 10 times ae much as an average outdoor acre." The otherwise wasted heat from nuclear reactors eould also be used to evaporate waste water in sewers, Beall said. Then the purified water produced by the evaporation eould be recycled into water treatment plants for human consumption - without costly purification procedures* A team of 60 scientists, headed by Dr. Stanley Auerbaoh, will work in the now Ecological Sciences Division at the Oak Ridge National Laboratory. Their findings will be used in planning all types of industries in order to provide maximum benefits with a T^M""* of environmental pollution* ------- H J DUNSMORE DIRECTOR-ENVIRONMENTAL CONTROL October 26, 1970 Mr. Murray Stein Conference Chairman Federal Water Pollution Control Administration Washington, D. C. 20242 Dear Mr. Stein: Third Session - Federal Conference on Lake Michigan and its Tributary Basin United States Steel Corporation wishes to have the following statement included in the official record of the Workshops on Lake Michigan held in Chicago, Illinois, on September 28 - October 2, 1970: Three plants of United States Steel Corporation, namely, South Works , Gary and Waukegan Works , are located on the shores of Lake Michigan and would be directly affected by standards limiting temperature in the waste water discharges from these plants. Although the temperature and volume of these discharges are substantially lower than those of the power industry, a requirement of recirculation or other closed system method to control heat would present substantial problems to United States Steel Corporation as well as , we expect, to all other industry. The general tenor of the scientific testimony at the Conference indicated the lack of substantial knowledge of the present and future effects of thermal discharges to Lake Michigan, but that significant study programs on the question are in progress. In light of this we recommend maintaining the existing standards until such time as these studies and others demonstrate the nature and extent of needed change, if any. Very truly yours, HJDrujw ------- AMERICAN ELECTRIC POWER Service Corporation 2 Broadway, New York, N. Y. 10004 (212) 422-4800 October 2?, 1970 To The Conferees The Lake Michigan Enforcement Conference Mr. Murray Stein, Chairman Mr. David Currie Mr. Thomas Frangos Dr. F. T. Mayo Mr. Perry Miller Mr. Ralph Purdy Gentlemen: At the Workshop Session of the Lake Michigan Enforcement Conference on September 28 - October 2, there was some discussion of the thermal bar. The "White Paper", Physical and Ecological Effects of Waste Heat on Lake Michigan, based much of its argument on the occurrence of substantial, long-period build-up of temperature and of chemical concentrations behind a barrier at the "thermal bar" that prevented mixing. Attached is a discussion of this concept prepared by Dr. John C. Ayers. TAM/fkr (attachment) Very truly yours, T. A. Miskimen ------- Comments on the Thermal Bar as a Barrier to Mixing John C. Ayers The concept that the thermal bar is a real physical barrier to horizontal transport and mixing appears to have had its origin in misinterpretation or in misapplication of the conclusions in the papers of Rodgers (1965, 1966, 1968). As I read these background papers I find Rodgers to be writing very cautiously; the strongest statement that I find in these papers is in his 1966 paper where he says on p. 371: "In the case of Lake Ontario there appears to be some validity to the concept of the thermal bar as a barrier." It should be noted that the wording is: 'appears to be some validity'; this is no statement that the thermal bar is a barrier. The first bald statement that the thermal bar is a barrier to horizontal mixing and transport is in the' publication "Lake Currents" (Lake Michigan Basin) by the FWPCA, Great Lakes Region, Chicago, Illinois, November 1967. In this publication there is a strange drift from a sensible discussion of the annual temperature regime of Lake Michigan on pages 19 through 21 (in which it is pointed out that in spring the thermal bar as described by Rodgers may develop), to a firm conclusion on p. 353 which says: "Thermal barrier conditions during the fall, winter, and spring period limit the outward extent of the effective mixing volume. This factor appears to be responsible for unusual solids build- up in the nearshore waters during this period." It appears that the latter conclusion has been picked up by the USBCF in the preparation of their "White Paper" and that it has been the basis for their definition of an inshore zone that does not mix with the rest of the lake. In view of the FWPCA's conclusion that unusual solids build-ups occur in the nearshore waters in fall, winter, and spring, it is proper to test their ------- -2- hypothesis by examining available independent data for evidence of unusual solids build-ups. The suitable long-term data available are those of the water- treatment plants on the perimeter of Lake Michigan. These plants draw their water from the very same nearshore waters in which FWPCA found or postulated unusual solids build-ups. If the thermal barrier conditions in fall, winter, and spring do limit outward mixing, the records of the water-treatment plants should show higher levels of "solids" in those seasons. Indeed, if the thermal barrier condition is continuous throughout the fall, winter, and spring seasons (as the FWPCA implies) the record of "solids" in the nearshore waters should begin to rise in fall, continue to rise in winter, and reach a maximum sometime in spring before "spring storms destroy the thermal bar." I have examined the available records of longer-term conservative (not influenced by biological activity) "solids" at Michigan City, Indiana; at Gary, Indiana; at Milwaukee, Wisconsin, The results are presented as annual graphs of the available "solids" parameters in Figures 1 through 4. Figure 1 presents the results of samplings by the State of Indiana for specific conductivity a"t the Michigan City water plant for the years 1957-1967 inclusive. There is a small rise in specific conductivity in the months March through May which may or may not be significant, but certainly there is no sub- stantial rise in this "solid" beginning in fall, continuing through the winter, and culminating in a maximum in spring. Figure 2 gives the levels of chlorides (as chlorine) in the Michigan City intake records for the years 1957-1967 inclusive. The graph shows no difference in chlorine in the nearshore water from year's beginning to year's end. That the contribution of chlorine from the early-spring melt-off of road salt is not detected by the local water plant indicates that there was substantial escapage ------- -3- to the open lake and that the spring thermal bar at Michigan City was not operating as a collector of pollutants. Figure 3 shows the annual distribution of total dissolved solids at Gary, Indiana, for the period October 1959-September 1962 inclusive. Levels of IDS in January, February, and March are slightly higher than for the rest of the year, but there is no evidence of a rise beginning in the fall, continuing through the winter, and culminating in a maximum in spring. Figure 4 depicts the year-round condition of total dissolved solids at the Milwaukee, Wisconsin, water plant from August 1960 through September 1962. Here the data show no change from year's beginning to year's end. There is no evidence of a collection of "solids" behind a thermal barrier in any part of the year. In summary, the independent data available with which to test the FWPCA hypothesis that thermal barrier conditions in fall, winter, and spring collect unusual levels of "solids", do not support the FWPCA hypothesis. References Rodgers, G. K. 1965. The thermal bar in the Laurentian Great Lakes, pp. 358-363 in Proc. 8th Conf. on Great Lakes Research. Univ. of Michigan, Ann Arbor. Rodgers, G. K. 1966. The thermal bar in Lake Ontario, spring 1965 and winter 1965-66. pp. 369-374 in Proc. 9th Conf. on Great Lakes Research. Univ. of Michigan, Ann Arbor. Rodgers, G. K. 1968. Heat advection within Lake Ontario in spring and surface water transparency associated with the thermal bar. pp. 480-486 in Proc. llth Conf. on Great Lakes Research. Internat. Assoc. Great Lakes Res. Ann Arbor, Michigan. ------- SPECIFIC CONDUCTIVITY (^mhos/cm) o o CO o o o o o o S o ,® . •% • • . :• • % ^ © 3 25 3 ° - H i-" >-< se- en _i M ' • •• • • .. .1. ------- ••©.' •;• 4 •' -.5- • • • • Q w £ p 55-" • i.: !H 1 in o m o ------- 8 So3 ^ r o TDS (mg/t) o o to o o w g> 03 to o> to ------- TDS (mg/4) o o to o o o o Co H M «o S CQ a o w f • • •• • •• • • • © ------- State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES L. P. Voigt Secretary November k} 1970 MA.OISON, WISCONSIN 53701 Mr. Murray Stein Assistant Commissioner for Enforcement Federal Water Quality Administration Department of the Interior Washington, D. C. 20212 Dear Murray: Attached is a copy of a statement from Senator Proxmire which he wishes to have entered into the record of the Thermal Pollution Workshop of the Lake Michigan Enforcement Conference. Could you take care of this, please? Very truly yours, D. J. Mackie Assistant Secretary DJM:dgb Attach. ------- . ' i, ,',, V. X , CHAIRMAN i--Q._i iG, MO. u.^ I G. .'.CC^..t_Aw, PA. UIA,- i>. Wi-.N/ L-,. N.J. J. cROC.C J3, Ti-.vJS. IJL, --• C. CO.N.'.c.LL, JR., N.Y. HIO EXECUTJVC D,fi£CTO« JOINT ECONOMIC (CREATED PURSUANT TO sec. sU) o;-- PUSLJC LAW ac, TSTH CONGRESS) WASHINGTON, D.c. 20510 JOHN jiW- s,yi/V', AUA. J. VV. Klju'-rtlGHT, AKK. HcHMAN E. TALMAOGL, GA. STUART SYMINGTON, MO. ADRAHAM IVlJllCOrF, CONN. JACOB X. JAVITS, N.V. JrtCK MILLAR, IOWA LEN B, JORDAN, IDAHO CHARLES H. PERCY. ILL.. JAMES W. KNOWLES, DIRECTOR OF RESEARCH October 23, 1970 , L. P. Voigc, Secretary P.O. Box 4-5 Wisconsin 53 Znclosed you v<-lll Tina my stater,i3n'i prepared for the record, of the Lcike i.llcn:'.3'an Pollution Conferance. The subject of uhe statement, as you know, is ther.aal pollution and i;o r.ach for your cooperation in this ratter. ------- Statement by Senator William Proxmire WASTE HEAT AND LAKE MICHIGAN Waste heat is rapidly becoming one of this nation's most serious sources of water pollution. In order to solve the problems associated with waste heat, we must fully understand its causes, effects and controls. Tremendous amounts of water are used each year by industries for cooling purposes. In fact, according to the Federal Water Quality Administration (FWQA), almost one-half of all water used in the United States is utilized for cooling and condensing by the power and manufacturing industries. In I$6k, this amounted to about 50 trillion gallons. How Thermal Pollution Can Affect Lake Michigan The potential for serious ecological damage to our nation's water resources as a result of the discharge of industrial waste heat is readily- apparent when we examine Lake Michigan. Although more research is needed on the ecological effects of waste heat, the evidence gathered to date substantially demonstrates the adverse effects of thermal pollution. Let me describe two of these effects in relation to Lake Michigan. First, waste heat can speed eutrophication — the process by which a lake chokes itself to death. The rate of eutrophication is controlled primarily by nutrient supply and water temperature. In Lake Michigan, indica- tions are that nutrients in the inshore waters are approaching levels commonly found in the central basin of Lake Erie. Lake Michigan inshore waters receive a substantial and increasing load of nutrients in the form of nitrogen, ------- -2- phosphorus, and other fertilizing agents from domestic effluents and agricultural run-off. If nutrients are not sufficiently controlled, the inshore waters of Lake Michigan will attain conditions of algae pro- duction similar to those in Lake Erie. When these conditions are reached, temperature becomes a very important factor. HLue-green algae, which are especially responsive to higher temperatures, will increase in direct proportion to temperature increases. The process of eutrophication will be well on its way. Lake Michigan will begin to choke itself to death. Second, evidence gathered to date also demonstrates the adverse effects of thermal pollution on the fish life of the lake. The role of temperature is an important one in the growth, survival and abundance of fish in any water environment. All available information indicates that each fish has specific thermal tolerances. These thermal tolerances vary from life stage to life stage. When the limits are exceeded the organism functions at reduced efficiency and may ultimately die. As the U.S. Pish and Wildlife Service has pointed out, the timing of natural events is essential for the perpetuation of Lake Michigan coldwater aquatic life. Any waste heat influence which would interfere with this natural timing places the survival of this aquatic life in jeopardy. Evidence indicates that only slightly elevated temperatures may be critical in the life history stages of Lake Michigan species. Power Needs and Thermal Pollution Each year this nation's power needs have increased. The public has demanded greater and greater amounts of electric power. And, as a result, power industries have been called on to produce the needed quantities of electricity. ------- -3- The increasing demands for power over the past decade has meant increasing amounts of waste heat to be disposed of. Thermal pollution has been a direct result, then, of the public's demand for greater amounts of electric power. In view of the fact that the electric power industry accounts for about 80 percent of all cooling water used in this country, the best single index of thermal pollution potential lies in projecting future power production. POWER PRODUCTION The demand for power has increased steadily since the turn of the century. For the past 30 years, power generation has increased at a rate of 7.2 percent annually, virtually doubling every 10 years. This has necessitated a doubling of electric power facilities each decade. This trend is expected to continue, and possibly accelerate, through 2000. The following table prepared by the FWQA indicates the amounts of electrical power used in certain past years as well as projected national requirements through 1985: U.S. Electric Power — Past Use, Future Requirements Year Billion KWH 1912 11.6 I960 753 1965 1,060 1970 1,503 1975 2,022 1980 2,75^ 1985 3,639 Power is usually generated by hydro- or steam-electric plants, with the latter process requiring cooling water for waste heat removal. ------- There are few sites remaining today for hydro-electric stations, so the power industry must depend more and more on thermal power generation to meet future needs. Presently, thermal plants produce approximately 80 percent of the electricity in the United States. Predictions indicate this figure may reach 92 percent by the year 2000, when two-thirds of the plants may operate on nuclear fuel. Thus, thermal plants will continue to gain a larger portion of a steadily increasing market for power. Waste heat production will increase proportionally, which in turn reflects the increase in waste heat disposal that we must accomodate. The waste heat output from manufacturing industries, such as the chemical, petroleum and paper industries, will also increase in the coming years. The cooling facility needs of these industries are expected to increase at a ^.5 percent annual rate, compared to the 72 percent annual increase expected by the power industry. Lake Michigan Power Production As with the rest of the nation, power demands have increased in the Lake Michigan area. In fact, it is predicted that more power facilities will be installed in the Northeast and Midwest in future years than in any other section of the United States. Nowhere are these plans for expansion more apparent than on Lake Michigan. And, as a result, waste heat effluents from the power industries along Lake Michigan will increase. According to a study recently completed by the Department of Interior, the doubling of power capacity each decade means that the Lake Michigan megawatt capacity will increase at a geometric rate. Cooling water require- ments will also increase at a similar rate (almost fourteenfold). Heat ------- -5- addition from steel and municipal sources is expected to increase by 63 percent by the year 2000. In total, it is estimated that waste heat addition to Lake Michigan from these sources will increase from 10 billion Btu's in 1968 to about ^31 Btu's in 2000. Thus, at the predicted rate of increase, the amount of waste heat dumped into Lake Michigan by 2000 will be 10 times larger than it is today. In light of the environmental affects of thermal pollution which I mentioned earlier, it is obvious something must be done to control the massive amounts of waste heat that are predicted for the future. Waste Heat Limitations In its first annual report, issued last August, the President's Council on Environmental Quality stated: A strong and consistent Federal policy should be developed to control thermal pollution. Criteria should be upgraded to assure prompt and successful negotiations with the States on water quality limits from thermal pollution... I fully support this recommendation by the Council. It is in the public interest to upgrade water quality standards now. If we wait too long, correcting the ecological damage caused by thermal pollution may be extremely difficult, if not impossible. According to the FW^A, the adoption of alternative cooling systems to control heat waste discharges would be economically feasible. The increased costs of the monthly bill associated with adopting alterna- tive cooling systems, based upon an average family electric bill of $9«^ a month, would be: ------- -6- wet mechanical draft tower ..... wet natural draft tower cooling pond spray canals dry mechanical draft tower dry natural draft tower 9^ Conclusion Waste heat discharges can be harmful. It is within our power to control these discharges. And it is economically feasible for us to do so. I hope that the federal government, working in cooperation with the states, can act on this without further delay. U. S. GOVERNMENT PRINTING OFFICE : 1971 O - 422-409 (Vol. 5) -------


 PROCEEDINGS
                                    THIRD SESSION
                                    RECONVENED IN
                                    WORKSHOP SESSIONS
                                    September 28, 29, 3O,
                                    October 1,2, 197O.
                                    Chicago, Illinois
                                            Vol. 5,
 CONFERENCE
    Pollution of Lake Michigan
    and Its Tributary Basin
U.S. DEPARTMENT OF THE INTERIOR . . . FEDERAL WATER QUALITY ADMINISTRATION

-------
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 V
                          Bal Tabarin Room
                           Sherman House
                         Chicago, Illinois
                          October 2,  1970

-------
                                                       11






               CONTENTS



                                                      Page




Telegrams and Letters (read by Murray Stein):   1720  -  1726




   Pearl L. Pohl                                      1720




   Robert Q. Kuehn                                    1720



   Mrs. Ralph G. Dunlap                               1722




   George Graff                                       1724



   John Chascsa                                       1726




Thomas E. Dustin                                      1723



Mrs. J. F. Voita                                      1760




Eileen L. Johnston                                    1761



Frank Pierson                                         1769




Arthur Pancoe                                         1775



Mrs. Lee Botts                                        1795



Lowell Gomes                                          1314



Edith McKee                                           1&L9



Hon. Abner J. Mikva



William J. Scott



John E. Bardach                                       l£62




Hon. Robert E. Mann                                   1895



Joseph T. Sobota, M. D.                               1923



William S. Singer                                     1945



Hon. Philip A. Hart (read by Murray Stein)            1950




Ted F. Miller                                         1954



Mrs. Louise Erickson                                  1957



Ron McCandlis                                         1962

-------
                                                      iii
CONTENTS, Continued

Dana Schindler                                        1966

Raynor F. Sturgis, Jr.                                2024

Herbert P. Read                                       2023

Mrs. Robert A. Barber                                 203#

Mrs. Shirley Gruen                                    2039

Mrs. Mary Helen Dunlop                                2042

George Brown (presented by Mary Helen Dunlop)         2043

Clyde Mathews                                         2047

Mrs. Miriam G. Dahl                                   2049

Mrs. Donald Trump                                     2054

Russell G. Hill                                       206?

John F. Wilson                                        2076

Carole Magnus                                         212#

Mrs. Edgar Wilkinson                                  2129

Mrs. Catherine T. Quigg                               2130

Hon. Gaylord Nelson                                   2132

Vance Van Laanen                                      2133

Ted Mac Donald                                        2151

Sol Burstein                                          2159

John C. Berghoff                                      2160

Mary Alice McWhinnie                                  2164

Mrs. Sylvia Troy                                      2247

Seymour AItman                                        2248

Mrs. L. W. Bieker                                     2250

Mrs. Robert McKimpton                                 2251

Andrew J. 0'Conor                                     2261

-------
                                                        iy
CONTENTS, Continued

John Chascsa                                          2289

Harold B. Olin                                        2298

A. J. Boehm                                           2304

Mrs. Paul Kaefer                                      2305

Mrs. Robert Herlocker                                 2306

James Sloss                                           2303
                                                      2356

Michael R. Rouse                                      2309

Mrs. Maynard J. Seidraon                               2310
                                                      2357

Lucy M. Barr                                          2311

Aaron S. Wolff                                        2312

Closing Remarks - Murray Stein                        2313



Documents Received Following Conference:

Petition, Citizens of Lansing, Michigan               2324

Mrs. Richard Schnadig                                 2325

W. D. Mohr                                            2326

Adlai E. Stevenson III                                2329

Grace Marie Knapp                                     2330

Gaylord Nelson                                        2333

Michigan State Chamber of Commerce                    2334

F. Scammon Barry                                      2336

E. M. Davey                                           2337

Robert Dover                                          233#

Bradley M. Glass                                      2339

Ted Falls                                             2345

-------
CONTENTS, Continued



F. A. Miskimen                                        2350



Mrs. Maxwell McCrohon                                 2353



Mrs. Dan Harper                                       2354



Hon. Robert McClory                                   2355

-------
                                                        VI






          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 and the



Randolph Room of the Sherman House, Chicago,  Illinois, on




Friday, October 2, 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, B.C.








          CONFEREES:




          CLARENCE W. KLASSEN, Director, Illinois



          Environmental Protection Agency, Springfield,



          Illinois.





          PERRY E. MILLER, Assistant Director, Stream



          Pollution Control Board, Indiana State Board



          of Health, Indianapolis, Indiana.








          ALTERNATE CONFEREES:





          DAVID P. CURRIE, Chairman, Illinois Pollution



          Control Board, Chicago, Illinois.

-------
                                                         vii




ALTERNATE CONFEREES, Continued:





          JACOB D. DUMELLE, Member,  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.





          R. J. SCHNEIDER, Deputy Regional Director,




          Federal Water Quality Administration,  U.S.




          Department of Interior, Chicago, Illinois.





          ROBERT P. HARTLEY, Director,  Office of



          Enforcement and Cooperative Programs,  Federal



          Water Quality Administration, U.S. Department



          of Interior, Chicago, Illinois.








          PARTICIPANTS:



          Thomas E. Dustin, Executive Secretary,  Indiana



Division, Izaak Walton League of America, Fort Wayne,



Indiana.



          A. Joseph Dowd, Assistant  General  Counsel,



American Electric Power Service Corporation, Two  Broadway,




New York, New York.

-------
                                                       viii

PARTICIPANTS, Continued:

           0. K. Petersen, Senior Attorney,  Consumers Power
Company, Jackson, Michigan.
           Mrs. J. F. Voita, Oak Park, Illinois.
           Eileen L0 Johnston, Wilmette, Illinois.
           Frank Pierson, Spokesman, Campaign Against
Pollution, Chicago, Illinois.
           Arthur Pancoe, SAVE, Campaign Against Pollution,
Glencoe, Illinois.
           Mrso Lee Botts, Open Lands Project, Chicago,
Illinois.
           Lowell Gomes, Senior Associate, Theodore S.
Leviton & Associates, Chicago, Illinois.
           Edith M. McKee, Chief Geologist,  Theodore S.
Leviton & Associates, Chicago, Illinois.
           The Honorable Abner J. Mikva, u. S. House of
Representatives, Washington, D,C.

           William J. Scott, Attorney General, State of
Illinois, Springfield, Illinois.
           John E. Bardach, Professor of Natural Resources,
University of Michigan, Ann Arbor, Michigan.
           Jack Hipke, Wisconsin Power and Light Company,
Madison, Wisconsin0
           David Do Comey, Campaign Against Environmental
Violence, Chicago, Illinois.

-------
                                                         IX
PARTICIPANTS, Continued:





          H. R. Thoke, Wisconsin Southeast Chapter of



Trout Unlimited.



          The Honorable Robert E. Mann, Chairman, Lake



Michigan and Adjoining Land Study Commission, Chicago,



Illinois.



          Joseph T. Sobota, M.D., President, TEMP,



Kalamaaoo, Michigan.



          William S. Singer, Alderman, 43rd Ward, Chicago,



Illinois.



          The Honorable Philip A. Hart, U. S. Senate,



Washington, B.C.



          Ted F. Miller, Chairman, Elk River Drainage



Basin Council, Elk Rapids, Michigan.



          Mrs. Louise Erickson, Chairman, Racine Committee



for the Natural Environment, Racine, Wisconsin.



          Ron McCandlis, President,  Pro-Tern, Michigan



Steelhead and Salmon Fishermen's Association, Kalamazoo,



Michigan.



          Miss Dana Schindler, Manistee County Anti-



Pollution Organization, Manistee, Michigan.



          Raymond F. Sturgis, Jr., Director, Illinois



Department of General Services, Springfield, Illinois.



          Herbert P. Read, State Director, Indiana



Division, Izaak Walton League of America, Chesterton,



Indiana.

-------
PARTICIPANTS, Continued:





          Mrs. Robert A. Barber, Deerfield,  Illinois.




          Mrs. Shirley Gruen, Wisconsin Federation of




Women's Clubs, Glendale, Wisconsin.



          Mrs. Mary Helen Dunlop, Evanston,  Illinois.




          George Brown, Committee on Lake Michigan



Pollution, Wilmette, Illinois (presented by Mary Helen



Dunlop).




          Clyde Mathews, Community Action to Reverse



Pollution, Gary, Indiana.




          Mrs. Miriam G. Dahl, Izaak Walton League,



Wisconsin State Division, Milwaukee, Wisconsin.



          Mrs. Donald Trump, Chairman, Environmental




Quality, League of Women Voters of Indiana,  Valparaiso,



Indiana.



          Russell G. Hill, Executive Secretary, State



Soil Conservation Committee, Lansing, Michigan.



          John F. Wilson, Director, Wisconsin Ecological



Society, Green Bay, Wisconsin.



          Miss Carole Magnus, Secretary, Manistee County



Anti-Pollution Organization, Manistee, Michigan.



          Mrs. Edgar Wilkinson, Society Against Violation




to the Environment, Highland Park, Illinois.



          Mrs. Catherine T. Quigg, Barrington, Illinois.

-------
                                                        XI
PARTICIPANTS, Continued:




          Vance Van Laanen, President, Wisconsin




Resources Conservation Council, Green Bay, Wisconsin.



          Ted MacDonald, West Lafayette, Indiana.



          John C. Berghoff, Associate General Counsel,




Swift & Company, Chicago, Illinois.




          Sol Burstein, Senior Vice President, Wisconsin



Electric Power Company, Milwaukee, Wisconsin.



          Mary Alice McWhinnie, Professor, Department



of Biological Sciences, DePaul University, Chicago,



Illinois.




          Ted Falls, President, Porter County Chapter,




Izaak Walton League, Wheeler, Indiana.



          Seymour Altman, Commissioner, Highland Park



Environmental Control Commission, Chicago, Illinois.



          Mrs. L. W. Bieker, Division Board, Indiana



Division, American Association of University Women,



Munster, Indiana.



          Mrs. Robert McKimpton, Independent Citizens'



Water Pollution Research, Ind., Hammond, Indiana.



          Sylvia Troy» President, Save the Dunes Council,



Munster, Indiana.



          Andrew J. 0'Conor, Attorney, of the firm of



Berry and 0'Conor, Ottawa, Illinois.



          John D. Harper, Director, Environmental




Parameters Research Organization, Chicago, Illinois.

-------
                                                     xii




 PARTICIPANTS, Continued:





          Harold B.  Olin,  AIA,  Member,  Board of Directors,




Lake Michigan Region Planning Council,  Chicago,  Illinois.



          A. J, Boehra,  American Fishing Tackle  Manufac-




turers Association,  Chicago,  Illinois.




          Mrs. Paul Kaefer, Citizen,  Northbrook,  Illinois.




          Mrs. Robert Herlocker, Calumet Area Branch,




American Association of University Women, Munster,  Indiana,



          James Sloss,  Glencoe, Illinois.



          Michael R. Rouse, Waukegan, Illinois.




          Mrs. Maynard J.  Seidmon, Glencoe,  Illinois.



          Lucy M. Barr, Highland Park,  Illinois.




          Aaron S. Wolff,  Chicago, Illinois.



          Michael Sheldrick,  McGraw-Hill Publications.



          Mrs. Richards Schnadig, Action Acommittee,



League of Women Voters, Glencoe, Illinois.



          D. W. Mohr, P.E., Benton Harbor, Michigan.



          Grace Marie Knapp,  Mequon,  Wisconsin.



          The Honorable Gaylord Nelson, U. 3. Senate,



Washington, B.C.




          F. Scammon Barry, Glenview, Illinois.




          E. M. Davey.



          Robert Dover, Wilmette, Illinois.



          Bradley M. Glass, Attorney, Chicago,  Illinois.



          T. A. Meskimen,  Senior Engineer, American




Electric Power Service Corporation, New York, New York.

-------
                                                      Xlll
PARTICIPANTS, Continued:




          Mrs. Maxwell McCrohon,  Crete,  Illinois.



          Mrs. Dan Harper,  Crete,  Illinois.



          The Honorable Robert McClory,  U.  S.  House



of Representatives, Washington, D.C,

-------
                                                      1720
                       Murray Stein

                   PROCEEDINGS
          MR. STEIN:  Let's reconvene.

          We have several telegrams here,

          "We believe in the present environmental crisis.

We must not court further disaster by allowing any industry

to return heated water to Lake Michigan, until it is

precisely determined what effects added heat will have on

the multiple uses for which water is used.  A 3 percent

increase in cost of electrical production is negligible

in -solution of grave problems of water quality with which

we are now faced."  La Budde Memorial Chapter (Women)

Izaak Walton League of America, Pearl L. Pohl, President,

Milwaukee, Wisconsin.

          I didn't know they had female chapters.  I am a

member-at-large of the Izaak Walton League.  I think I am

going to affiliate with one of those.

          "The Milwaukee Chapter of the Izaak Walton

League of America strongly recommends that the water

temperature from water coolants used in nuclear powerplants

discharged into Lake Michigan be the same temperature as

that of the intake.  Temperature extremes that vary widely

from the norm as yet have not been fully investigated as

to their effect.  They could prove to be very detrimental

to all aquatic life.  Therefore, until sufficient research

-------
                                                      1721






                      Murray Stein




is available concerning the effect of the temperature



variation of the Great Lakes waters, future nuclear power-



plants should be required to maintain the present tempera-



ture level."  Robert 0. Kuehn, President, Milwaukee Chapter



of the Izaak Walton League.



          "I strongly support your efforts to establish



strict and enforceable thermal pollution standards to



protect the aquatic and shoreline ecology of Lake Michigan.



We must not let Lake Michigan become another Lake Erie.



          "I endorse the United States Department of



Interior   proposal to limit thermal discharges to a



maximum of one degree Fahrenheit higher than the natural



lake temperature.



          "We must avoid irreparable damage to the ecology



of the lake.  Significantly raising water temperatures



will not only kill some of the lake's fish but accelerate



the growth of undesirable bacteria.



          "Power companies can construct cooling towers



to avert the warm-water problem.  Toledo Edison Electric



Company plans to build a cooling tower for its powerplant



on Lake Erie.  The cost of such towers is small compared



with the cost to our environment if Michigan becomes a



dead lake.



          "I commend the pioneering efforts of citizens'

-------
                                                      1722





                      Murray Stein




groups such as yours in acting in the face of substantial



opposition to protect Michigan's environmental heritage,



I have asked Ralph Purdy to give serious consideration



to your views."  This is also from Senator Sander Levin.



          Then, here is a letter saying:  "I wish to urge



as strongly as possible the adoption by the Four-State



Conference on Lake Michigan of the strictest standard



under consideration for control of thermal pollution in



Lake Michigan:  a maximum of fone degree Fahrenheit rise



over ambient at the point of discharge.'



          "It is absolutely essential, if we are to pre-



serve Lake Michigan, to take the long view; in this case,



to take into consideration the long-range and cumulative



effects of returning heated water to the lake.  Let us



not use Lake Michigan to death.  Too often, we have said,



'We have no alternative;1 or 'It's too expensive;' or 'We



can take care of that problem later, when it arises;' and



consequently we have found irreversible damage has been



done by our lack of thoughtful care and caution — by our



negligence.



          "Something can be done now to prevent thermal



pollution of Lake Michigan;  The conference can adopt



the strictest standard proposed by the Department of the



Interior.  Please use your influence to that end."

-------
                                                     1723





                      Murray Stein




          That is from Mary Helen Dunlop of 2246 Orrington



Avenue, Evanston, Illinois.



          And we do have some longer letters and statements



and with the conference's approval I would like to put



them in the record as if read and I would pass these to



the conferees and they can read these,  and without objec-



tion they will be entered into the record as if read.



          (The letters above referred to follow in their



entirety.)

-------
                                                                         1724
                   HIGAN STATE: CHAMBER of COMMERCE:
                     215 S. Washington Ave., Lansing, Michigan 48933 • Phone 517/482-0657
           otfic.s                                    September 28,  1970
Mr.  Murry Stein,  Conference Chairman
Thermal Pollution Workshop
Sherman House
100 West Randolph Street
Chicago, Illinois

Dear Mr. Stein:

Enclosed you will find a copy of the Michigan State Chamber of Commerce's
Policy on Thermal Effects which was adopted by our Board of Directors
on January 21, 1970.

Please enter this into the proceedings of the Department of Interior's Thermal
Pollution Workshop currently underway in Chicago.

Sincerely,     /n   .
George P.  Graff,
Manager, Natural Resources

GPG/sk

Enclosure

cc: Francis T.  Mayo
    Ralph  Purdy

-------
                                                                                1725
          MICHIGAN STATE CHAMBER POLICY ON THERMAL EFFECTS
       The Michigan State Chamber of Commerce has long recognized the need to
protect and enhance the quality of the environment in the State of Michigan.  Cooperative
efforts of both the public  and private sectors are necessary to effectively promote this
objective.


       The Waters of the State of Michigan are an important  segment of the environ-
ment and should be so respected.  The potential effects  of thermal discharges to these
waters are not fully understood.  However, it is known that in some instances these
effects are detrimental to legitimate uses, while in other instances they are beneficial^
       Recognizing that there are many needs and objectives in society, and. that they
cannot all be satisfied in their entirety, the State Chamber strongly recommends that
the Michigan Water Management Program,  with particular reference to thermal effects,
be guided by the following principles:


       1.  That no single set of regulations  is adaptable to all situations.

       2.  That the management program provide for beneficial water uses, with joint
consideration of alternative costs to society and the objective of preserving environmen-
tal quality.

       3.  That water quality standards regarding thermal effects adopted by the State
are consistent with the water use management program which recognizes the needs of
our society and further that Michigan industry will comply with all  state standards.

       4.  That any use which has potential of causing significant environmental effects
be carefully monitored to determine the extent of any effects and the possible need for
corrective action.

       5.  That prompt corrective action be taken whenever effects detrimental to
legitimate uses are detected.

       6,  That thermal effects research be promoted in an effort to obtain sound data
from which intelligent judgments  can be based regarding thermal discharges.
       The State Chamber commends the responsible State agency's accomplishments
in the area of water quality control and pledges its continuing support and coopera-
tion in efforts to provide an improved environment and high quality water in the State
of Michigan.

-------
                                                                               1 T2 f\
                  lafee  Crie  Cleanup  Committee

                                        ,  Jtttcfjigan

JOHN CHASCSA                                                             C. W. (TED) HOFFMAN
   Fmident                                                                  Vice President
MRS. IRENE FINCK                                                            LAWRENCE LEIBOLD
   Secretory                                                                   Treasurer
                                                    September  28,  1970


       Lake Michigan Enforcement Conference
       Sherman House
       100 West Randolph Street
       Chicago, Illinois

       Attention:   Chairman,  Murray  Stein,  Chief  Enforcement Officer
                   Interior's Federal  Water Duality  Administration

       Dear Mr. Stein:

       It  is indeed encouraging to learn  that all  types of Pollution are being
       investigated by  your Committee.

       We  have, on many occasions, heard  that one  type of waste after another
       is  responsible for the condition of  our Lakes, Rivers and streams.  In
       some instances we have condemned the use of our waters as dumping
       grounds  or  hiding places for  unwanted waste sewage, refuse  and hot water
       from large  Industries.   However, it  took our  President, Richard M. Nixon
       to  open  our eyes to the  serious dangers involved in permitting Thermal
       Pollution to further complicate our  Environmental problems.  So, if
       Biscayne Bay can Become  a  living mass of Algae interspersed with dead
       and dying marine and bird  life, this could and would create a very
       nauseating  stench in the area,  (which by the  way is the location of
       our Southern White House,  it  isn't used much, but it is there.)  You
       can imagine what could happen to Lake Michigan, Lake Erie or for that
       matter any  of our inland Lakes.  Lake Michigan is the most vulnerable
       though,  and then Lake  Erie.

       Lake Michigan from Muskegon to Gary,  Indiana, and then on to Chicago
       is  (as you  know)  the natural pocket with no place for the water to flow.
       This area has for many years  received all sorts of waste, it has been
       the cause of many illnesses,  much  fish and wild fowl mortality, and
       could become a hot bed of  more of  the same, if permission to use Lake
       Michigan were granted  to cool industrial or municipal hot water.

       Why must the general Public have to  accept the loss of the use of a
       Public Lake,  Stream or River, and  be  expected to pick up the tab for
       cleaning up the  mess when  it  becomes  too unbearable?

       There are,  as you have pointed out,  many ways to cool and purify water
       and there are some that  have  not even been considered.

-------
                                                                       1727
page  2
Mr. h. Stein
Sept. 28, 1970
Perhaps the state of Michigan's Fisheries Department are expecting to
use the warmer water to escalate the growth of the Coho that is being
planted by them, or perhaps this is a good way to get a ready cooked
meal.

Seriously, the Lake Erie Cleanup Committee supports your stand on pro-
hibiting the use of our Lakes as a depository of Thermal Pollution, or
any other form.

Knowing the area around Ludington,  I would suggest that these combined
systems be used - such as an inland cooling Pond with spray and return
canals for re-use in the plant or into the Lake.

Due to unforseen circumstances I am unable to attend this conference,
but would like to take this opportunity to voice the opinion of the
Lake Erie Cleanup Committee, and the Monroe County Rod and Gun Club ,
and to thank you for this presentation.

For a better Environmental tomorrow,  I remain.
                                             Sincerely,
                                            'John Chascsa, President
                                             Lake Erie Cleanup Committee, Inc.
cc:   Conferees:   Illinois Environmental Protection Agency!
                   Wisconsin Department of Natural Resources,
                   Indiana Stream Pollution Control Board,
                   Michigan Water Resources Commission

-------
                                                      1728
                      T.  E.  Dustin




          MR. STEIN:  Now, I would like to,  if we can,




try to have the people who are making presentations here




be as brief as possible,   I know this is a public day;  I




also know that almost all of you — if not all of you —




are here on your own time and volunteering your time for




this.  We have many, many speakers scheduled and I would




ask you to be as brief as possible.  If you have longer



statements, we will be glad to put them in the record




and when I ask for questions this will include the panel



as well as the floor.




          May we have Tom Dustin first, please?








          STATEMENT OF THOMAS E. DUSTIN, EXECUTIVE




          SECRETARY, INDIANA DIVISION, IZAAK WALTON



          LEAGUE OF AMERICA, FORT WAYNE, INDIANA








          MR. DUSTIN:  Thank you, Mr. Chairman, and



ladies and gentlemen of the Lake Michigan Enforcement




Conference.   My name is Thomas E. Dustin, and I appear




as the executive secretary of the Indiana Division, Izaak



Walton League of America.  Our organization includes 5,300



members in 1+6 chapters in the State of Indiana, distributed




from the Ohio River literally to the shores of Lake




Michigan.  Our interest and concern are directed to all

-------
                                                      1729





                      T. E. Dustin



phases of the natural environment, man's relationship to



that environment, and the interdependencies of all living




organisms with it,



          Our history of direct interest in the Lake



Michigan environmental unit needs little preamble.



          We have been reading and hearing the press



releases which have emanated from this conference since



its convening September 2&; and they are remarkably



similar to those of previous sessions — particularly



those coming from industrial spokesmen.  We know the



Chairman of this conference has heard it all before, too.



To hear the polluters tell it, you would think they were



all milkmaids distributing effluents as pure as the



driven snow.  Yet Lake Michigan continues on its path to



polluted uselessness.



          But in the rhetoric, denials, assertions, and



carefully couched semi-scientific testimony that have



been offered, the essential questions have become obscured:



          1)  Are we, as a society, really serious about



our intent to save and restore Lake Michigan?  If we are



— and the Izaak Walton League answers with an unqualified



"yes" to this question — then it is perfectly obvious



that we will not only have to halt the increased pollution



of the lake, but must roll back the sources which have

-------
                                                     1730






                      T. E. Dustin




come into existence through most of this century.




          Second —




          2)  Are we all prepared to join together in a




mighty and sustained program of active achievement, and




to share among us the cost of doing it?  Again, the Izaak




Walton League's response is an unqualified "yes,"   Third —




          3)  Are we wise enough and perceptive enough to




understand the highest and most productive purposes of Lake



Michigan, and to grasp its significance in terms of all the




values and dimensions, both tangible and intangible, that




it holds for man, and for all of the other organisms which




form its community?  Again, we say that our species has




this capacity for understanding, though because we have



been lazy and have pursued more superficial goals, our



general record has been one environmental atrocity after



another.



          We are not here to attack devils because we



recognize that all men, institutions, and corporations are




bound together in a common web of ideas, trade, and inter-




change of energies of one description or another.




          But I will say that I hope the defense of thermal



pollution reported in our local Fort Wayne newspapers, on




the part of Indiana and Michigan Electric Company, is not



a mirror image of our society's state of conscience and

-------
                                                    1731
                                                    1732

                                                    1733
                      T. E. Dustin                  1734

                                                    1735
environmental awareness.


          I want it fully understood that the Izaak Walton


League supports without qualification the proposal by the


Department of the Interior that thermal discharges be


limited to not more than 1 degree Fahrenheit above the


natural ambient temperature of Lake Michigan,  This


principle has been thoroughly reviewed by all of the


policy-making bodies of our group, and by all of our


membership.  Moreover, we see the 1 degree Fahrenheit


recommendation as a minimum goal to achieve; we support


the effluent standards for all forms of unnatural dis-


charges.


          From all of the press reports and all of the


testimony we have seen regarding the effects of thermal


discharge on Lake Michigan, we observe that the utilities


— including Indiana and Michigan Electric Company and


Northern Indiana Public Service Company — have created


a phalanx essentially around the person of one zoologist


whom they have hired to justify the increased dishcarge


of waste heat to Lake Michigan.


          But even if Professor J. C. Ayers is right in


some of his assumptions — and there is persuasive


testimony to indicate he doesn't know what he is talking


about — he stops far short of responding to far larger

-------
                                                      1736
                      T. E. Dustin



questions.  Much of whatever genuine field studies he under-



took were at the Charlevoix Big Rock installation of some



55 megawatts capacity — almost irrelevant to the draconian



questions we face here.



          In describing the miniscule hot water plume



there, he acknowledges that organisms that may be exposed



to it have other environmental choices, since that plant



operates in a comparative thermal vacuum, uncomplicated by



other sources of heat.



          Professor Ayers explains that most oxygen recharg-



ing of the lake takes place in winter, when the warmed



epilimnion disappears, and lake temperature is relatively



uniform.  He makes no effort whatever to explain what happens



when a warm surface condition is perpetuated, and when there



are so many sources as to influence a significant portion



of all shallow water environments.



          No one, not even Professor Ayers, can estimate



the effects over the next 30 years as the amount of waste



heat rises from a mere 30 billion B.t.u.'s an hour to over



400 billiono  But it will hardly be a biological health



spa.



          Few, if any, competent aquatic biologists have



stood forward to endorse his whitewash of thermal pollution



for his clients.  And a great many of them fully recognize

-------
                                                       1737





                       To E. Dustin



the detrimental effects.  For the record, I have thoroughly



read the Interior Departments September 1970 publication,



"Physical and Ecological Effects of Waste Heat on Lake



Michigan,11 and find it wholly consistent with every principle



we support, and consistent with the concerns of qualified



limnologists and other biologists whose opinions we have




sought.



          One such authority is Dr. John S. Bardach, of



the University of Michigan, whose testimony in connection



with NIPSCO's Michigan City construction application we



have.  If that statement has not yet been made part of the



record of this conference, we request that this be done, and



will provide a copy for you on request.  It is at very least



as competent as the views of Dr. Ayers and much more



independent.  (See  Pp.  1737a-1737o)



          But there is another essential question here.



Spokesmen for the utilities have laid down a challenge to



prove that thermal pollution is injurious.  I would state



to you that it is this very formula which has necessitated



this conference today, and those before it.  All of those



who have preceded us as Lake Michigan polluters have made



the same case, asking that positive proof of damage be



made before the event.



          I submit to you that this ploy has precisely the

-------
                                                            1737a
          Resume of Statement for the Record by


                  JOHN £. BARDACH, Ph.D

      At a Vublic Hearing at Michigeu City, Indiana
                   September 11, 1970
                         Before

                 COL. WILLIAM G. STEWART

                    District Engineer
          Chicago District, Corps of Engineers
                 Department of the Army

                    In the Matter of

         NORTHERN INDIANA PUBLIC SERVICE COMPANY

Application to Construct Intake and Discharge Facilities
       In Lake Michigan at Michigan City, Indiana
Colonel Stewart, Ladies and Gentlemen:

      My name is John S. Bardach and I reside in Ypsilanti,
Michigan.  By profession I am an aquatic ecologist with more
than 20 years of teaching and research experience.

      I am currently a full professor in the Department of
Wild Life and Fisheries in the School of Natural Resources and
a full professor of Zoology in the Department of Literature,
Science and the Arts at the University of Michigan in Ann
Arbor, Michigan.  I was born on March 6, 1915 in Vienna, Austria
and I became a naturalized American in 1953.  I was graduated
from the Real-gymnasium in Vienna, Austria in 1933.  I then
attended the University of Berlin, Germany, for two years and
thereafter Queens University, Kingston, Ontario, where I
received a Bachelor of Arts Degree in 1946.  I received a
Master of Science degree in 1948 and a Doctor of Philosophy
degree in 1949, both from the University of Wisconsin.

      My present teaching duties at the University of Michigan
include a course in Functional Ichthyology concerning itself
with anatomy, physiology and behavior of fishes, and the
supervision of graduate students on physiology, ecology and

-------
                                                              1737b
behavior of aquatic organisms.  Moreover, I am involved in
teaching Natural Resources Ecology, a course dealing with
man's influence on and management of his natural environment.

      My research and publications over the last 20 years
have dealt -,~ith the entire range of ny expertise and partic-
ularly the physiology of aquatic organisms and the reactions
of aquatic organisms to man-made and man-induced changes
in lakes, streams and seas.

      The following statements comprise my opinion based
upon my 20 years of experience, teaching and research in my
area of expertise.

      Based upon my experience I have a scientific concern
about the added heat load to the shore waters of Lake Michigan
which would occur if electrical generating plants of the
type of Michigan City were to discharge into the lake the
waste heat in their cooling water in an unabated fashion.

      My opinion that heat loading of the shore waters of
Lake Michigan would contribute, in a long range fashion, to
the deterioration of its ecology is predicated on two grounds:

      1.  Present knowledge of hydrographic and meteoro-
logical parameters is insufficient to make proper prognosis
of the cumulative ecological effects of several electrical
generating plants which would emit heated effluents into the
lake.  Only substantial further research will furnish the basis
  Attached hereto as Exhibit A is a summary of my research
  experience from 1946 to the present.  Attached hereto
  as Exhibit B is a list of my professional experience and
  honors.  Attached hereto as Exhibit C is a list of publi-
  cations which I have prepared or of which I have partici-
  pated in the preparation.

  I hold the following memberships in professional societies

       AAAS  (1959); Corporation Member, Bermuda
       Biological Station for Research  (1956); Int.
       Soc. Theor. Appl. Limnology (1960); American
       Institute Fish Res. Biol.  (1962); American
       Soc. Zool.  (1949); Amer. Soc. Limnology &
       Oceanography  (1951); Ecol. Soc. Amer. (1958);
       Amer. Fish. Soc. (1954); Sigma Xi  (1949); Fellow,
       International Academy of Zoology  (1960); Amer.
       Soc. Ichth. and Herp.  (1958); N. Y. Acad. Sci.
       (1966).
                           -2-

-------
                                                             1737c
for judgment whether thermal changes will have moderate or
pronounced effects and whether these will be more or less
gradual.  Experience with other man-induced environmental
changes (deforestation and resultant stream warming, for
instance)  that affected complex aquatic ecological systems
make one cc fident in predicting the. there will be changes,
many of them not beneficial.  I agree with the statement
of David Ehrenfeld in "Biological Conservation/1 Holt,
Rinehart and Winston, Inc. 1970 that,

          "Chances in water temperature affect both the
           activity and energy requirements of aquatic
           organisms.  Oxygen requirements also change.
           If the temperature rises, oxygen consumption
           increases but oxygen solubility in water
           declines.  Many organisms have a narrow range
           of temperature tolerance.  At some point
           lethal temperature is reached; this varies
           according to the rate of change of temperature,
           species of animal or plant and physiological
           condition of the individual.  Since a rise
           of 10° C. is sufficient to double the rate of
           many chemical reactions, it can readily be
           understood why even a small amount of thermal
           pollution is sufficient to disrupt the
           organization of aquatic communities.  Thermal
           pollution also damages ecosystems indirectly.
           Most important, it aggravates the effects of
           poisons and accelerates deoxygenation processes."

      One electrical generating plant will have some adverse
effect and several of them would exacerbate conditions in a more
than additive manner, due to the prevailing hydrographic con-
ditions set forth below.

      Some scientists believe that heated water remains on the
surface and quickly loses heat to the atmosphere rather than
to the water.  However, present knowledge of water-air heat
exchange and heat exchange between water masses in the regions
of Lake Michigan to be affected is incomplete as there is not
available information on all possible weather conditions
such as patterns along the shore under which these exchanges
would take place.  Nevertheless, and especially if there are
a dozen electrical generating plants along the shoreline and if
the current? flow along this shore a  they are indicated to c":>,
long term adverse effects of heating the shallow water are
likely to occur and eutrophication is likely to be accelerated.

      Some of the likely changes to be enumerated below are not
solely or not even predominantly caused by temperature increases


                           -3-

-------
                                                              1737d
but a temperature rise contributes to them; others are
directly related to temperature rises.  Like many biological
phenomena they proceed slowly at1 first, soon to increase in
geometric proportion and to become ever more difficult if not
impossible to reverse.

      (2)  It is my opinion that even the incomplete knowledge
about Lake Michigan which we now possess/ coupled with general
experience of ecological phenomena permit certain scientific
conclusions and opinions, as set forth below, and that make the
occurrence of long term deleterious effects of heat loading of
Lake Michigan's shore waters highly probable indeed.  I am
particularly concerned, about the following long range effects,
covering two or more decades, of heated effluents from several
electrical generating plants being voided into Lake Michigan:

           (a)  An increase in the rate of eutrophication
                of the shore waters.

           (b)  A worsening of conditions favorable for, if
                not a Iphreat to, the survival of a very
                valuable and unique fish fauna.
                      t
           (c)  A change in conditions so as to favor less
                desirable fish species such as carp and
                alew-ife.
                      •V
      Discharges from electrical generating plants will cause
Lake Michigan shore wafers to be threatened by increasing
eutrophication.  The cooling water discharges enter and are
restricted to coastal waters, out to but a few miles from the
shore.  These lake areas also receive a substantial and
increasing load of nutrients in the form of nitrogen and
phosphorus compounds from domestic effluents and from agricultural
runoff and, according to our present knowledge, the water in them
does not mix substanti-ally with the water in the lake at large
during the fall, winter and spring; during the summer more mixing
occurs but even then it is not continuous.  Consequently
fertilizing effects first and foremost occur in near-shore waters,
proceeding faster at higher than at lower temperatures.

      It is my opinion.; that the shore regions of Lake Michigan
contain relatively discrete water masses which do not mix with
the waters of Lake Michigan during the year at large.  This
opinion is hased upon my experience ;. s well as upon a recent
report of the Federal Water Pollution Control Administration,
Great Lakes Region, phicago, Illinois, entitled "Lake Currents"
(Lake Michigan Basin),.November 1967.
                           -4-

-------
                                                              1737e
                "Temperature records taken during the winter
           of 1961 through the summer of 1964 indicate that
           the following conditions occur ... The existence
           of thermoclines and thermal barriers during
           extended periods of the year greatly reduce mixing
           of the shallower shore w.'iiers and the waters of
           the hypolimnion with the main body of the lake.
           Such conditions promote the build-up of persistent
           pollutants discharged into isolated waters.
           Because of the prolonged periods  during which
           such conditions can continue such build-ups can
           impair the uses of the water adjacent to the
           discharge points."  Id. at p. 233.

                "Thermal barrier conditions  during the fall,
           winter and spring limit the outward extent of
           effective mixing volume ... The late spring storms
           and lake overturn break up the zonation due to the
           thermal bar and create conditions for effective
           mixing with the lake proper.  However, during the
           summer when the thermal bar no longer exists,
           similar build-up occurs.  Boundary effects,
           friction and the Southern gyre are probably
           responsible for the lateral transfer of water along
           the shore."  Id. at p. 353.

                "In general the shore currents move northward
           on both sides of the lake, except for periods
           during the late fall, winter and  early spring....
           Average current speeds on the western side of the
           lake range from 5 to 10 cm/sec, while those on the
           eastern side range from 12 to 14  cm/sec.... Inshore
           and offshore currents are quite separate from one
           another."  Id. at p. 179.

      Indicators of the changes generally subsumed under the
term "eutrophication," and even now noticeable along certain
portions of the shores of lower Lake Michigan, are the prevalence
of algae, plankton and bottom organisms and  eventually of fish
tolerant of, by virtue of their evolution, and therefore adapted
to warm oxygen-poor turbid water instead of  those adapted to
cool clear oxygen-rich water.  The latter conditions were those
of the Lake Michigan's geologic history and  the organisms that
evolved in the Lake, or in lakes like it, are therefore
genetically fitted to them rather thin to new man-induced one~.
The biology of these fish and organisms do not permit rapid
adaptation to man-induced changes.

      Specific indicators of eutrophication  are: blooms of


                           -5-

-------
                                                              1737f
bluegreen algae, the colonization of suitable substrates by
the profusely growing green alga'Cladophora the filaments
which have known nuisance value.1  If effluents from electrical
generating plants generate stationary warm water masses for
variable periods of time it is likely that point heat sources
will accelerate localized conditions of chemical and organic
pollution and that commercially valuable cold water fishes
will disappear and be replaced by carp, suckers, alewifes and
the like.  Each of these factors singly, but more so in
aggregate, decrease the value of shore property as well as
certain recreational opportunities.

      The biological changes are gradual and cannot be properly
ascertained by a one, two or even three year study following
a local change such as a newly installed heated water discharge
like Michigan City Generating Station as overall climatic
fluctuations may mask their effects.  However, the biological
changes gain momentum once they have begun unless the
conditions favoring them are reversed.

      The deterioration of Lakes Erie and Ontario since, the
turn of the century provides reliable and relevant analogies
to the danger Lake Michigan faces from heated water.  The average
water temperature of Lake Erie has risen by 2° F. since 1920,
due to heat loading, even without massive spot heat inputs such
as occur through electrical generating plants, and due to
alterations in land use.  Such a rise is tantamount to displacing
the entire lake to a location 50 miles to the South.  Small as
the temperature change is, it is considered a contributory factor
to the disappearance from Lake Erie of the Lake Herring, formerly
the most abundant and valuable species in the Lake.  It also
favored the growth of undesirable algae in Lake Erie.  Such
changes in Lake Michigan as are presently being observed suggest
that a comparable deterioration process may be already under way
in Lake Michigan.

      The Great Lakes, but especially Lakes Michigan, Huron and
Superior are the home of a unique, c^Trnercially valuable species
complex of fishes, i.e., the trout and salmon, related whitefishes
and the lake trout.  The numerically most abundant and commercially
and recreationally most valuable among them spawn in in-shore
or near-shore waters.

      Experiments and observations at the Great Lakes Fishery
Laboratory rf the Department of Inte: ior have shown them to b 2
very sensitive to increases in water temperature, especially
during their larval and juvenile periods.  Their eggs are deposited
on the bottom and their larvae must rise to the surface to gulp
air for initiating the filling of their swimbladders.  Without
this one gulp they can never adjust their buoyancy.  At that  time


                           -6-

-------
                                                             1737g
they are but an inch or so in length and even if they sensed
deleterious surface temperature, they are instinctively driven
to the top where they will not be able to avoid warm water
than could kill them.  Such kills might be sporadic but could
increase in frequency as patches of heated water multiply
with severcT. instead of one or two electrical generating plants
voiding heated water.  The kills might also not be noticed
due to the small size and semitransparent nature of the fish
larvae.  Given such conditions, the effects of the kills would
become apparent through a gradual irreversible reduction in
the number of adult fish and eventually likely lead to the
complete disappearance from Lake Michigan of a yet unpredictable
number of their species.

      It is ironic, in this context, that millions of dollars
were and are spent to save these same species from the deprada-
tions of the sea lamprey and to rehabilitate them to their
former abundance when the danger to them may now be shifted to
thermal loading of the Lake from electrical generating plants.
The main difference between the two dangers is that lamprey
control necessitated costly research before it could be
implemented while the method of heat abatement of cooling waters
is well within technological research today.

      The Pacific Salmon, recently introduced into Lake Michigan
is in far less direct danger from thermal change than the
species native to the Lake, inasmuch as the numbers of the
former will be replenished by artificial propagation.  Only
where spawning streams or shore areas near them become heated
may direct temperature effects threaten some of their numbers.

      While zones of heated water near the shore may not harm
the salmon directly, they adversely affect the fishes' recreational
potential.  State of Michigan biologists believe that warm water
near the shore such as prevailed due to climatic conditions
in 1968 and 1969 kept the fish away from the shore and therefore
out of the reach of the sport fishermen's craft.  Heat loading
of shore waters could well make these conditions that are
adverse to recreational salmon fishing a much more permanent
occurrence.

      Some salmon which have established spawning runs in Lake
Michigan streams will enter the shore waters near them on an
instinct driven journey to their spawning grounds.  It has been
the experience of Michigan fishermen that they are far less
likely to strike the fisherman's lure in warm than in cold water.

      Alewives and other undesirable fish species will be
favored through lake temperature increases.  Alewives are shore
spawning warm water fishes which have entered the Great Lakes


                           -7-

-------
                                                             1737h
inadvertently, through a man-made channel.   In Lake Michigan
they live at the lower edge of their temperature range
and are very vulnerable to such cooling as  occurs occasionally.
If warm water becomes available to them they seek it out,
entering into existing heated effluents in  great numbers.  A
warming of shore waters is likely tc favor  them as are large
streams of warm water from electrical generating plants likely
to attract them.  They are, however, also delicate fish, prone
to mass mortalities.  Temperature conditions favoring their
numbers could well be accompanied by far greater die-offs
than have been experienced until now.  Clean-up operations of
millions of alewives are indeed costly to society.  Over a
twenty-year period their cost may well reach a significant
portion of that involved in installing, initially, cooling
devices for the effluents of electrical generating plants.  If
ancillary losses in the tourist industry were to be included,
the total loss may well equal or exceed the costs of
installing cooling devices.  In 1967 such total direct and
indirect losses due to alewife die-off was  estimated at 50
million dollars on the State of Michigan shoreline alone.

      I am aware that there well could be possible beneficial
consequences of heated electrical generating plant effluents,
especially in the first few years of a plant's operation, before
the deleterious effects mentioned here would have time to build
up.  Pishing may improve in or near the effluent cones due to
the attraction by the warm water of certain shore fishes such
as perch, bass, pike and bluegill.  These same water areas may,
incidentally, also afford ice free fishing lagoons in the winter.
V7ater might become warmer in certain places and make them more
attractive for swimming, and in the same places the swimming
season might be prolonged, at least before the build-up of
algae detracts from water contact sports.  These beneficial
consequences, given continued eutrophication influences from
other sources will almost certainly be replaced over the years
with eutrophication, disappearance of native fishes and alewife
nuisance.  Any assumed beneficial effects would represent a
poor interest indeed on a continuously devaluating large
environmental capital.  Cooling devices for the effluents  snould
be installed on all present and future electrical generating
plants discharging heated water into Lake Michigan to prevent
them from contributing to the devaluation of this capital.  Later
alleviation of thermal loading through subsequent modification
of existing plants could well be more costly not only to the
power industry, but, by virtue of the nature and time course of
the changes indicated, it would also put an ever increasing
economic burden on society at large.
                           -8-

-------
                                                                     17371
Research Experience

     Sensory physiology, especially cheuical and temperature senses
of fishes:
1968-'  pilot study of effects of thermal pollution on behavior of
     bullheads.
1957-1958:  Chemical senses in communication and social behavior of
     fishes.
1957:  Electro-olfactograms of tuna (unpublished) Cheraosensory
     orientation of tuna (unpublished)
1963-1966:  Research with chemical and mechanical senses of fishes
     in relation to behavior.
1961-1963:  Research with time-coordinated behavior and learning of
     fishes (see Biographical sketch and Publications)
1961:  Sabbatical Leave, study of fish physiology and  behavior  v?ith
     Prof. Sven Dijkgraff and G,  P.  Baerends of Universities of
     Utrecht and Groeningen, Holland,  respectively.  Holder of  OEEC
     Senior Visiting Scientist Stipend.
1953-1957:  Research on temperature and  tactile senses of fishes,
     Resoarch and Behavior of Reef Fishes.
1946-1953:  Graduate Studies, Madison, Wisconsin,  under Professor
     A.D. Hasler on ecology and physiology of fishes,  teaching
     assignment at then Iowa State Teachers College  and student
     research supervision (University  of Iowa graduate students)
     and ov?n research on limnology and ecology at Iowa Lakeside
     Laboratory.
                          EXHIBIT A

-------
                                                                  1737J
professional Experience and Honors

Re-introduced instruction and research in Limnology,  Iowa Lakeside
     Laboratory, 1950-1953.
Director, Bermuda Government Fisheries Research Program,  part-time,
     1954-1958.
Fisheries Advisor, Government of Cambodia, on leave of absence from
     University with AID, 1953-59.
Senior Visiting Fellow in Science, O.E.E.C., at University of Utrecht
     and Groningen, Holland, study of comparative physiology and
     behavior, 1961.
Behavior and ecology of reef fishes, senior investigator  (NSF),  1955-57.
Bermuda government - fisheries research program, program  director
     (government of Bermuda), 1955-56.
Temperature oensc of fishes, senior investigator (Horace  H.  Rackham
     School of Graduate Studies), 1956-50.
Investigations of sensory structures in skin of fishes, senior
     investigator (Horace H. Rackhatn School of Graduate Studies),
     1958-62.
Time-coordinated behavior of fishes, senior investigator  (NSF)
     1962-63.
Extra-enteral food uptake by fishes, senior investigator  (Michigan
     Memorial-phoenix Project).
Time sense of fishes, senior investigator (NSF) 1961-62.
Coloration of Reef Fishes (Horace H. Rackham School of Graduate
     Studies) 1965.
Skin senses of fishes, principal investigator (PHS Grant  No. NB-
     04687-01-05) (1953-1958).
Chemical Senses of Fishes, principal investigator (NIII,  INDB Grant
     04687-06-09)  1968-1971.
Research and Fact finding on World Status of Aquaculture  for National
     Council on Marine Resources and Engineering Development,  1967.
Participation National Academy of Sciences organized  International
     workshops:  Oceanography and Fisheries Manila,  1967,  Food,
     Djakarta, 1968.
Consultant to Econ. Comra. Asia and Fa^ taut, U.N. Bangkok;  also  to
     Asst. Adminiscrator for Far East U.S. AID/ Department of State,
     Washington, D.C. and short terra State and Federal Assignments
     dealing with physiology of aquatic organisms in  relation to
     water quality control.
Fellow American Association for the Advancement of Science (1963)
President and Co-founder:  Michigan Asoociation for Conservation
     Ecologists (1964)
Member Pacific Science Board, U.S. National Academy of Sciences  (1957)
Distinguished Faculty Achievement Award, The University of Michigan 1957,
                        EXHIBIT  B

-------
                                                        1737k

BIBLIOGRAPHY  - PROFESSOR JOHN E. BARDACH
A biological survey of Lake Opinlcon.  Curran, H.V/., J.E.
Bardach, R. Bowman, and H. Lawler.  Queen's University
Biol. Sta. Rep., Kingston, Opt., 48 p. 1947.

A preopercular tag for perch.  Bardach, J.E., and E.D
LeCren.. Copeia, 1948 (3): 222-£24

Daily migrations of perch in Lake hendota, V/isconsln.
Hasler, A.D., and J.E. Bardach. "jour  V.'ildl. hgt. Vol.13,
No 1: 40-51,
Lake Hendota Perch Teach School.  Bardach, J.E.  V/isconsin
Conserv. Bull., July 1949, pp. 11-12.

Do fish have a color vision?  Bardach, J.E.  Bios. 21(4):
273-275, 1950.

hicrophotography without a camera.  Bardach, J.E.  Sci.
News, Iowa Acad. Sci. 18(3): 7, 1950.

Changes in the yellow perch population of Lake hendota,
V/isconsin, 1916-1948.  Bardach, J.E.  Ecol . 1951, 32(4):
719-728.

Preliminary report on the distribution of bottom organisms
in West Lake Okojoji, Iowa.  Bardach, J.E., J. Morrill,
and F . Gambony , 9 p . , 1951 .

A demonstration of the effects of water density.  Bardach,
J.E.  Turtox News, 31(11): 208, 1953.

Harvest and products.  Lagler, K.F., and J.E. Bardach (in)
Fish and fishing in recreation and commerce.  Ann Arbor,
Univ. Mich. Extension Service 14 p., 1954.

Coastal streams.  Lagler, K.F., and J.E. Bardach.  (In)
Fish and fishing in recreation and commerce.  Ann Arbor,
Univ. hicn. Extension Service, 14 p., 1954.

Continental shelf and banks.  Lagler, K.F., and J.E.  Bardach.
(In) Fish and fishing in recreation and commerce.  Ann Arbor,
Univ. hich. Extension Service, 8 p., 1954.

Conservation.  Lagler, K.F., and J.E. Bardach.  (In)  Fish
and fishing in recreation and commerce.  Ann Arbor, Univ.
hich. Extension Serv., 25 p., 1954.
                EXHIBIT C - page 1

-------
                                                        1737-1

                           2.


The high seas.  Lagler, K.F., and J.E. Bardach.   (In)  Fish
and fishing in recreation and commerce.  Ann Arbor ,  Univ.
Mich. Extension Serv., 10 p.,. 1954.

Plankton Crustacea from the Thelon v;atershed.  Bardach,  J.E.
Can. Piel-i Nat., 68 (2): 4? -52, 1J54 .

Effects of the wind on water movements in Lake West Okojoji,
Iowa.  Bardach, J.E.  Proc. Iowa Acad  . Sci., 6l:  450-4 57,
1954.

(Review of) The western end of Lake Erie and its  ecology.
 by D.H. Langlois), Bardach, J.E.  Sci. Mon. 80 (l): 59-
(Review of) Etude experimental du determinisme de la
regeneration des nageoires  chez les poissons teleosteens.
(by J. Buser-Lahaye) .  Bardach, J.E.  Progr. Fish. -Cult.
16 (4): 188-191,
Certain biological effects of theraocline shifts.  Bardach,
J.E.  Hydrobiologia, 7 (4): 309-324, 1955-
The opercular bone of the yellow perch, Perca_ flavescens,
as a tool for age and growth studies.  Bardach, J.E.
Copeia, 1955 (2): 107-109-

(Review of) Fischkrankenheiten (by W. Schaeperclaus) .
Bardach, J.E.  Copeia, 1955 (2)  155-

Bermuda Fisheries Research Program, Progress Report # 1,
Sutcliffe, V/.B., Jr., and J.E. Bardach, Bermuda Govt .
Publ., Hamilton, Bermuda, 14 p., mimeo, 1955.

Bermuda Fisheries Research Program, Progress Report #2.
Bardachj J .E . , and L.S. Mow bray .  Bermuda Govt. Publ.,
Hamilton, Bermuda, 94 p., 1955-

(Review of) Margins of the Sea (by M. Burton).  Bardach, J.E.
Sci. Mon., 80 (6): 383-384, 1955-

The sensitivity of the goldfish (Carassius auratus L.) to
point heat stimulation.  Bardach, J.E.  Amer. Nat. 90
(854): 3^9-317, 1956.

(Review of) World Sea Fisheries (by R. Morgan).     -dach,
J.E.  Science, 124 (3231): 1085-1086, 1956.

Field and laboratory observations on the growth of some
Bermuda reef fishes.  Bardach, J.E., and D.W  Menzel .
Proc. 9th Gulf Caribb. Fish Inst., (1956), pp. 106-112.

                 EXHIBIT C - page 2

-------
                                                         1737m
Bermuda Saga.  Bardach, J.E.  (In Michigan Rorecter by Staff
and students of the School of Natural Resources).  Univ.
Mich. pp. 71-73, 1956.                      "

The senses of fishes.  Bardach, J.E. Bermuda Fish. Quarterly,
1(2): 6,  1956.

Marine Fisheries and Fish Culture in the Caribbean.  Bardach,
J.E.  Proc. Gulf and Carlb. Fish. Inst., pp.; 132-137, 1957-

(Review of) The Galathea deep sea expedition 1950-1952, (by
A.F. Bruun et al.) .  Bardach, J.E.  Sci. Mow.  84 (6): 322-
323, 1957.                                  ;.  •

Behavior, sexual dichromatism, and species oT parrot fishes.
Winn, H.E., and J. E.'- Bardach.  Science, 125 (3253): 885-
886, 1957-

The temperature sensitivity of some American freshwater fishes
Bardach,  J.E., andR.G. BJorklund.  Aiaer. Nalt.. 91 (859): 233-
251, 1957-                                  ;.

Bermuda Fisheries Research Program, Final Report.  Bardach,
J.E., with L. Smith and D.W. Henzel.  59 p., 1958.

Bermuda affair.  Bardach, J.E. (in Michigan Forester by
staff and students of the School of Natural Resources).
Univ. Mich. pp. 7^-75, 1953.

The production of Exopthalmos by Androgens in two species of
teleost fish.  Matty, A.J., D. Menzel and J^E. Bardach.
J. Endoc., 1958, 17, 31-4-318.

On the movements of certain Bermuda reef fishes.   Bardach,
J.E.  Ecol. 39 (1):139-146, 1958.

The role  of the senses in the feeding of the nocturnal reef
predators Gymnothorax raorij^a and G_,  vlcinus.".   Bardach, J.E.,
H.E. Winn, ancTZTW. Menzel.  Copeia,  1959 f2) =133-139.

The summer standing crop of fish on a shallow Bermuda reef.
Bardach,  J.E.  Limn, and Ocean.  Vol. IV., No. 1: 77-85,
1959-

Different4al food selection by mo^ay eels and a possible
of the mucous envelope of parrot fishes in reduction of
predation.  Winn,  H.E., and J.E. Bardach.  Ecol.  Vol. 40,
(2): 296-298, 1959-

Report on fisheries in Cambodia.  Bardach, J.E.  Ag. Div.
USOM Cambodia, 58 p., miraeo., 1959.

                   EXHIBIT C - page 3

-------
                                                          1737n
Etude sur la peche au Carabodce .  Bardach, J E.  1959,
Serv. Eaux et Forets , Phnom Penh, Cambodia, 80 p. tairaeo.

(Review of) The Open Sea: Its' Natural History (Sir Alister
Hardy).  Bardach, J.E.  Scl.  130(3384): 12^7, 1959-

Some acpucts of the comparative Liology of parrot fishes
at Bortr.uda.  Winn, H.E., and  J.E. Bardach.  Zool . 45(1),
I960, 29-34.

On the transport of calcareous fragments by reef fishes.
Bardach, J.E,  Science 133(3446): 98-99,
On touch receptors in fishes with special reference to the
mo ray eels ( Gymnot hor ax yicinuG and G. morin^a) .  Eardach,
J.E., and L.A. Lo3v;snthai .  Copeia, ~l"96l, (T) , ^2
The sensory function of modified fins of some marine fishes.
Bardach, J.E., and J. Case.  Am. Zool. 2(^4): 76, 1962.

Time -coordinated pref ceding activity in fish.  Davis, R.E.,
and J.E. Bardach.  An. Behav. 13(1): 154-162, 1965.

Sensory capabilities of the modified fins of squirrel hake
(Urophycis chusg) and searobins ( Pr3.onptu_n carollnus and
L- gvo-i.ans) .  Bardach, J.E. and J.Case. Copeia 2, 19^-206,1965,

Detergents: Effects on the chemical senses of the fish
Ictalurua natalis (le Sueur) .  Eardach, J.E., M. Fujiya
and A. Holl.  Science, 1^8 (3577): 1605-1607, 1965.

A comparison betv.'een the external taste sense of marine and
freshv/ater fishes.  Fujiya, M., and J.E. Bardach.  Bull.
Jap. Soc. Fish., 32(1): ^5-56, 1966.

Tolerance to temperature extremes: Animals. Part IV: Fishes.
Bardach, J.E., J.J. Bernstein, J.S. Hart and J.R. Brett.
Environmental Biology-, Biological Handbooks compiled ar/1
edited by P.L. Altiaan and D.S. Dittmer, Federation of
American Societies for Experimental Biology, Bsthesda,Md. ,
1966, pp. 73-80.

The chemical senses and food intake in the lov.'er vertebrates.
Bardach, J.E.  Symp . on Mutr , and the Chem. Senses, Cornell
Univ., 1^66.  Johns Hopkins University Press, Baltimore, '**d.,
1967, pp. 19
Investigations of external cheraoreceptors of fishes.  Bardach,
J.E., M. Fujiya and A. Holl.  Proc . 2nd Intern. Symp. on
Olf action and Taste, Pergamon Press, N.Y., 1967, pp. 6^7-655.


                   EXHIBIT C - page k

-------
                                                                     1737o

                                 5.

A new laboratory method for  tracking aquatic animals.
Bardach, J.E,, G. Johnson and J.ll. Todd.  Med. Biol. Illustr.,
1957, XVII  (2):  103-111.

Orientation by taote in fish of  the genus Ictalur_u_s_. Bardach,
J.E., J.H. Todd and R. Crickner.  Science, 155(3757): 1276-
1278, 1967

There Is Poetry in Science. Bardach, J.E., and Alice Bloch.
Mich. Quart. Rev. VI(2), April,  1967, 107-108.

Chemical communication in social behavior of a fish, the
yellow bullhead (Ic. talurus nata1 is). Todd, J.H., J.  Atema
and J.E. Bardach.  Science 158(3S01): 672-673, 1967.

Bardach, J. and J, Todd, Chemical Cormmnication in Fishes, jLn_
Advances in Chetnoreception, Appleton Century Crofts, Mew York,
in Press

Bardach, J.E., Taste in Fishes,  in_ Handb. of Sensory Physiology,
Jul. Springer Verl. Berlin, Heidelberg, Nex* York. L. Beidler ed.
in preparation

Bardach, J., and J. Todd. Chemische Verstaendigung bei Fischen.
UMSCHAU in Wissenschaft imd Tcchnik, Frankfurt a.M., in press.

Bardach, J.E., G. H. Johnson, and J.H. Todd.  Orientation by
Bulk Messenger Sensors in Aquatic Vertebrates.  Presented at
Second Conference on Planetology and Space Mission Planning.
Ann. New York. Acad. Sci., in press.
BOOKS

ICHTHYOLOGY, K.F. Lagler, J.E. Bardach and R.R. Miller,  John
Wiley and Sons Inc. 545 pp., 1962.

DOWNSTREAM, A Natural History of the River.  John Bardach,
Harper ant5 Row, N.Y., 278 pp., 1964.

HARVEST OF THE SEA, A Scientist Looks at the Oceans - Their
Past, Promises and Prospects.  John Bardach, Harper and  Row,
N.Y., 301 pp. 1968.
                    EXHIBIT C  - page  5

-------
                                                       1733





                      T. E. Dustin



same validity as a demand that you prove a war yet unfought



will kill people.



          I challenge them to look for themselves at Lake



Michigan and tell us that pollution does not kill.



          Why should the burden of positive proof rest on



our shoulders?  It is because we have always carried that



burden that Lake Michigan is in its deteriorating condition



now.



          It is time those who would use our waters for



septic tanks and stewpots prove their actions will be



harmless.



          They cannot make that case; and it will take more



than one hired biologist to make it for them.



          Is it not time — is there not already enough



in our abominable environmental history on Lake Michigan —



to at last stand firm and say "enough"?



          Let us turn back the destruction of Lake Michigan



before the fact.  Once it is a fait accompli, it becomes



just another mistake of the past that we must live with



indefinitely, if we will be able to live with it at all.



Both the Federal and State Governments should by now have



seen enough of the fait accompli here not to want any more



of it.



          We recognize that every special group of polluters

-------
                                                        1739






                      T. E. Dustin




does its own thing when appearing before these conferences*



The steel mills gave you their routine, and the chemical



companies, the refineries, the harbor interest, the Corps



of Engineers, and now the utilities, each in turn, as their



own environmentally irresponsible status quo comes under



test.  But just look at Lake Michigan and where it is going.



          It seems evident — and the Izaak Walton League



has been a participant in all of these matters — that



unless we s-ee and understand Lake Michigan in a larger per-



spective, we will be permanently committed to these cat-and-



dog squabbles as each new kind of defecation in the lake



comes to light.  And as long as we are committed to unlimited



growth, unlimited production, unlimited consumption,



unlimited population, unlimited power, and unlimited profits



and material things of all kind, there will be little hope



that our greatest efforts can save this lake or anything



else that cannot be priced in dollars.



          It seems the utilities are committed to just such



a course.  They will come before you with the statement that



power capacity must double every 10 years to meet the




"demand."  It is a vicious circle.



          There is something fundamentally defective in



our way of doing things in the environment.  We have always



operated our industrial systems open-endedly, scratching from

-------
                                                       1740






                      T. E* Dustin



the earth what we could use, and indiscriminately spewing



out what was not profitable to convert.  We are long past



the point that this stone age attitude should have changed.



But it must change, and we must all be part of that change.



We will have to learn how to create closed systems, includ-



ing retention and conversion of waste heat.



          We recognize Lake Michigan and its general



environment as a unit, not separable nor dissectable as



a pie, whose parts are doled out to the most ravenous



appetites.  It is our position the whole of it is'weakened



when one part is assaulted.



          It is a total resource of incalculable value to



all of the people in its watershed and far beyond that. If



we justify its impairment at one location, then it is diffi-



cult to defend at other places.



          Above all, the Lake Michigan environmental unit



should be a public trust, and no one should have the right



to impair it; everyone should have the responsibility to



restore and preserve it.  The cost of failure to accept and



act upon this principle will be infinitely greater than the



alternatives; and we will be committed to an endless series



of futile conferences mainly because we have not defined



and made clear that the legitimate uses of Lake Michigan



simply exclude using it as a dump for waste heat, chemicals,

-------
                                                    17U





                      T. E. Dustin



harbor dredgings, and all of the other spewtum of our



society.  No well-considered Lake Michigan policy could



possibly include such uses.



          Instead of adopting a general Lake Michigan policy,



we are continuing to be confused by smokescreen rationale



which create the aura of acceptability for further destruction



of this lake.  In recognition of this perpetual problem, the



Indiana Division of the Izaak Walton League has adopted a



10-point proposed policy for Lake Michigan.  We do not



pretend that it is the last word or that it is ultimate in



quality.  But it is a start.  Most important, it treats



Lake Michigan as an environmental unit; and we believe the



lake must eventually be seen in that light, and not as a



carcass from which chunks can be torn off at will by any



interest that wants a piece — such as the utilities now



propose, and the steel mills before them.



          Proposed Policy Position



          1)  Prohibitions of any more landfills or altera-



tions of the natural shorelines, coupled with a total



evaluation of the social, economic and ecological qualities



of Lake Michigan.



          2)  Acquisition of an environmental easement along



all undeveloped portions of Lake Michigan shoreline, pending



results of the total evaluation, at which time decisions



should be made as to what portions of the easement should

-------
                                                      1742






                      T. E. Dustin




become permanent, and what should be expanded in the public



interest and for environmental protection.




          3)  Establishment of total effluent standards for




all discharges to Lake Michigan including the 1 degree




Fahrenheit above ambient proposed by the Department of the




Interior,,



          4)  A strict constructionist establishment and



interpretation of a  nan degradation policy for both water




and air discharges in the lake context.




          5)  A no-discharge policy for all commercial and




industrial shipping, including on-board surveillance and




enforcement by trained interstate or Coast Guard agents,




together with complete environmental control systems and



design for all such vessels using Lake Michigan.



          6)  Prohibition of any dumping dredged materials



from harbors, ship canals, industrial wastes or slags, and



similar materials into any waters of Lake Michigan or its



drainage basin.



          7)  Special Federal and State appropriations




earmarked for sewage treatment systems in the Lake Michigan



Basin, planned for maximum cost effectiveness along lines




proposed in 1969 by the U. S. General Accounting Office.




          &)  A total prohibition of all persistent




pesticides in the Lake Michigan Basin.

-------
                                                       1743






                      T* E. Dustin



          9)  A general "inland development policy" which




would prevent further visual, physical or ecological




intrusion on Lake Michigan.




          10)  A firm policy with respect to all Lake




Michigan ports which would require nonpolluting handling




of all shipboard wastes and residues, and environmentally




designed and operated fueling, servicing and cargo trans-




ferring procedures.




          Until we are all ready to proceed with a compre-




hensive policy at both the Federal and four-State levels,




and until we are ready to enforce it, we see little hope




of saving the Lake Michigan environmental unit.  As long




as there are holes and vagueness in our position, they



will be exploited.




          On the other hand, if a policy can be firmly



established, the kind of brush fire we are fighting today



will be diminished if not extinguished.  The utilities



will, as they should, build away from these shorelines and



include all environmental factors within integrated and




closed systemso  They are perfectly able to do this,  or



would be able to do it, when the answer to doing it in and




on the lake is simply a flat "no,"




          In closing, in the record is a letter of September



16 by Senator Vance Hartke of Indiana, which was submitted

-------
                                                       1744






                      T. E. Dustin




in the context of the Michigan City hearing on the NIPSGO



application,,  We wish that to become a part of the record as



it is especially germane, and I will turn in to you a copy



of the statement prepared by the student Alpha Chapter of



the Izaak Walton League of Fort Wayne, which is the first



student chapter of the Izaak Walton League.  We will submit



that for the record.



          MR. STEIN:  We will be glad to receive that



information for the record.



          (The documents above referred to follow in their



entirety.)

-------
 ,|sf. fc, •. - ,.,-; , ><'..:,<•'.;:,;.'•*$"<*••

l'£olQtt«l William Stewart
                                        ecHMMrrrce ON COMMON*
                                        WASHINGTON, D.C. 20510
                                           .September
           Army Corps' of Engineers"
       Imrk Street \.\ •.;.    •   '
       hicago,
    i'Dear Colonel Stewart:
               •
              Indications from a great many Indiana residents, especially -
           northwest region of the state,  provide evidence of the interest
   7* I felt would be shown at the Michigan City hearing which J requested
     that you hold, regarding an application by the Northern Indiana Public
            5 Company to construct a flume and to discharge heated water :
       Lake Michigan,
           r  i» me interest of not biasing the hearing, J have withheld my
           until its conclusion and now desire to have the following included
    ftn the record of the proceedings,'             ,       •  .

             I oppose the granting of this  permit and urge  the Corps of
     ISagitteers to encourage the applicant  to consider inland sites for con-
     struction of any; increased generating capacity that may be needed,   ^>
        opposition to. granting of the permit is based upon the following:
             I,) While there are conflicting views on the effect of
             »  it seems clear that introduction of heat to the Water of Lake
              can have nothing but a deteriorating effect. Studies which
              > minimize the effect of thermal pollution appear superficial*
        tittle to'consider long-term adverse effects,  and  fail,Id take into.  '/.^
            th.e"'*pro life ration of thermal sources  which are  already ,costtr,i« f
           to the degradation of the lake,

             2,} The construction of a huge power plant and,*a
      .schaffe staclc'immediately adjacent to^the edge,of
•*?„
  P|<|itroposeclf will create a major visual'intrusion
           National Lalceshore on the west and tower
      ecreational harbors and facilities lying. imrn.edfintct.y,

-------
i^CJolonel Stewart •       '       -2-    '          September 1&,;>19?Q
        "- '-'3») State-of-the-art control of sulphur oxide discharges " .   '"/•-,;
      .utility plants is highly unsatisfactory, and, indeed,' such controls- '.' ' -
 for existing power plants along Lake Michigan seem virtually non-
V';existent,'; Control of particulate emission is almost equally unsatis-  -  ; .''
•^.factory; complaints have been lodged by many interests along the       ;•"
"X&ke Michigan shore, indicating unacceptable flyash fallout ami great   ;
'i;eo8t"wt removing  it and  restoring finishes to such objects as homes     , '*-
r;tod pleasure boats.  There is no acceptable assurance that an additional '
y"power plant at the proposed location will reduce this costly form of
:;f pollution,       .         .            ,                           .       :'l;-

*!;";„   "   '4») Construction of the plant would be accompanied by huge
,-::>eoal and combustion products storage areas,  inevitably creating an
:'fyesore,  destroying the beauty of the shore areas and quite probably '  \ •
.adding to existing pollution problems of both air and water, as well as
/Increasing local noise background,

-si ' .. ,   '; ' 5,) Considerable  erosion lias-taken place along the Lake Michigan
'"shoreline, most notably in  the Beverly Shores area,  and this appears to'
;/:t»e traceable to landfills at  Michigan City, which interfere with the normal
.."littoral flows along  the shore and to  the considerable discharge- of hundreds
fj.of thousands of gallons of cooling water per minute from the existing flume.

",f'-!'"  ,     6» ) Jn spite of plans to prevent or minimize-chemical pollution
/aspects from power plants,  nutrients and heat appear to be contributing
 to accelerated  growth of algae and to the continued degradation of water
"quality which is occurring in Lake Michigan.   For decades. Colonel
.Stewart* our society has been at Russian roulette with our  water  resources,
 Almost universally in the past, we have  given  ourselves the^benefit of the
•''doubt in deciding whether to use our shorelines and  great bodies and
-''streams of water  as recepticles for  wastes and other unwanted by-products
,jof production processes.

:f'v- ' . /. ''- The results of this policy have ruined much of our rivers and
''streams, has polluted our Great LaKes  to a point approaching uselessness .
 .for recreation, commercial and sport fisheries, and for many oilier
^legitimate needs which are clearly in the public interest.

       r  While we have enacted far-reaching legislation, which if fully   •
;implemented should begin to reverse- the destruction of  our waters,
•'Including Lake Michigan, the fact is that this  body of water is now in ,  ; :•
 worse condition than it was five years ago.  In. my opinion,  this is      . -
 traceable to the fact that new abatement facilities are slow in coming,

-------
         Stewart ,              - 3 -              September 16, 1970
    not planned for maximum effectiveness, niul are offset by new
 sources of pollution, which arc being permitted.   This is intolerable.

         Even, now the  areaa of Lake Michigan that arc still usable
 for millions of bathers and other water recreationists are maintained  . -
 that way only through heavy use of chlorine and other disinfectants,
 •tich $S are  used at the Indiana Dunes State Park by the Department of
.Natural Resources,

*...'  •.• .  It is not at all alarmist to anticipate that  the next significant
 increase in environmental pollution could well rodurc  thesc-waters
 below the quality of safety and aesthetic acceptability.

' "•'  '  -,:   to the present situation I have also become aware of the
Distressing fact  that the company has already constructed major parts
jof ,a discha rge flume required by the proposed new plant.  Apparently,
,1t$u.9 has been done in anticipation of routine approval of the permit
 application,  lam sure the Corps  of Engineers is  sincere in its intent
'.fcO give full consideration  to the provisions of the National Environmental
'^Policy Act of 1970, and is in no way a party to any pre-liearinn conrlu-  :
       r informal understandings.                                      :
                                                      '
                                               ,
         Let me observe that throughout much of our environmental
         it has been the burden of )ho>;e concerned with pollution to
             conclusively that a proponed aeiKity will  be harmful to
    environment. I believi: this priiu'iple ha ,s outlived  its unefulixess,
Jtf it ever had any.  It should be the burden of those interests which
'proposed the- activity to demonstrate conclusively that  no harm will
result from it.
 L  > £-
         The evidence and data available with respect to the type of
activity proposed by the Northern Indiana Public Company leads me
to the conclusion that the company cannot mn°he that case, and that very
great damage will in fact be caused  to all of the environmental qualities
cited'.in your notice of the September 10th lu-aring,  jf this plant is per-
mitted to be built at the proposed location.

*';t ".   " .  Therefore, the permit application  should  be rejected,  and the
company should be encouraged to locale inland.  ,Sueh a facility  should
encompass within its site;  all  systems needed for an*  pollution  control;

-------
 ;*;..,  .  r>  -     •;%              '•>                -     -     - -             •  -1748
i-    ' «    % *'      '••"",           -  " .r  „ >




Colonel Stewart  _            _.  -_4 -       ,        September 16,  3970
Cooling pottds or other techniques', to prevent thermal pollution of

           ''"     waters';" carefully 'planned fuel storage areas;
  d a "detailed plari'for non- polluting disposal of combustion residues.


                 '               '''.-•'•

           ''     ^            ' '"• "-.' '•   /Sincerely,
      ;'.  --->  -     ••             ' .'-•„.      Vance Hartke

 juj:-   1" "'"* ;       *            ., -f.-•",";     United States Senator
i. '  ••
    ?»

    t

-------
                                                                             1749
Lake Michigan Enforcement Confernece Workshop
c/o The Sherman House
100 West Randolph Street
Chicago, 11 Iinois

Attention:   Mr. Murray Stein, Chairman
            (Federal Water Quality Administration)
     We are an organization of college students who are formally associated
with the Izzak Walton League of Americans.  Some of us arranged and organized,
and all of us participated in the Earth Day seminars presented at the Fort
Wayne Regional Campus of Indiana-Purdue Universities last April.  The seminars
were conducted by various University faculty members, and by members of the
Fort Wayne community, including Mayor Harold Zeis and state and federal
officials.  They were we 11-attended, from 9:00 a.m. to 10:00 p.m., by students
from local high schools, and from the several colleges and universities in
the city, as well as by other interested persons from the Fort Wayne area.

     As you may know, regional universities such as ours, are largely attended
by people who'are working to pay all or most of their own way through school.
Some are married, with families, some are veterans; virtually all are concerned
with information and education, before demonstration.

     In an effort to prevent our concern for the environment from ending with
Earth Day, this group met to find ways of continuing our interest, and of
taking an active part in changing unfavorable conditions.  In the end, it
was decided to affiliate with the Izzak Walton League (as Its first campus
chapter) becuase we believe our efforts can carry further through cooperation
with a respected organization whose resources of various kinds far exceed
those a smalI  group can muster.

     While our commitments prevent us from attending the conference, we
would like our views to be known and heard.

                                      I

     We heartily commend the three Interior Department agencies for the
responsible and forthright statements issued in their report "Physical and
Ecological Effects of Waste Heat on Lake Michigan."

     It seems unnecessary for us to point out what many at the conference
have undoubtedly discussed in detail:  the incalculable resource—economic,
recreational,  biological,  climatological, aesthetic, spiritual—which lakes
represent.

     Many avenues of investigation suggest that there is no evidence showing
the effects to be deleterious to disastrous, and extremely difficult (if
not impossible) to counteract.

     The conclusion is inescapable that preventive medicine is imperative,
not only in terms of effectiveness, but also because corrective measures
are unquestionably even more costly.

-------
                                                                       (2)
                                                                              1750
     We therefore support the view that recommends no increase in temperature
of the waters of Lake Micigan.

                                       It

     We also strongly support the search,  by government and industry,
for better ways of dealing with all industrial  and metropolitan wastes,
including the thermal waste discussed in the report "Feasibility of Alterna-
tive Means of Cooling for Thermal Power Plants Near Lake Michigan."

     We encourage federal agencies to support actively those methods which
promise the least damage, in any way, to the environment.

     While it is to be anticipated that objections to such proposals
will be raised on the basis of costs, let it be noted that cost considerations
do not, in the end, harm a company or industry as much as they harm the consumer.
It is he who ultimately pays.  Ironically, this is true whether it be in
terms of higher costs for services, or in terms of a devaluated earth.

     We, as present and future residents of the Fort Wayne area	a community
which depends primari ly for power on the Indiana and Michigan Electric
Company—wish the Conference to know that we are not only willing to pay
more for power, but insist that we must, in order to bear our rightful
share of the responsibility for preventing further deterioration of Lake
Michigan

     And, we strongly recommend that effective controls be instituted
by industry and the government for the prevention of yet another pollutant
being introduced into this lake.

                                     Ill

     We recognize that most of the ill effects of an industrialized
society were not realized or even imagined only a few decades ago.  Many
practices which were acceptable  in a sparsely-populated world have become
intolerable in a crowded one.

     We do not blame the past.   It is one of the characteristics of
mankind to be more gifted at hindsight than at foresight.

     We do blame the present for remaining, in such large measure, insenstive
or callous to the dangers of our present situation.

     We recommend that those  in authority, in whatever sector of the nation's
activity, work for a speedy discontinuance of all current practices contributing
to the eutrophication of Lake Michigan, and that all possible measures to
be taken to reverse the process.

     We heartily support the ten-point policy position of the Indiana Division,
Izzak Walton League (enclosed)

-------
                                                            (3,            1751
     Reclaiming and maintaining a healthy world is  going to be expensive.
It must inevitably cause changes in  our present patterns of living.   But
it is no longer a debatable Issue:   the only  alternative to making changes
is planet-wide disaster.

     We accept the price.    We urge  you to do so, too.
                                       Alpha  Chapter
                                       Izzak  Walton  League
                                       Indiana-Purdue  Regional  University
                                       Fort Wayne,  Indiana   46807
                                       2101 Coliseum Blvd.  East.

-------
                                                                            1752
(I)  Prohibitions of any more landfills or alterations of the natural  shorelines,
coupled with a total evaluation of the social, economic and ecological qualities
of Lake Michigan;

(2)  Acquisition of an environmental easement along all undeveloped portions of
Lake Michigan shoreline, pending results of the total evaluation, at which time
decisions should be made as to what portions of the easement should become perma-
nent, and what should be expanded in the public interest and for environmental
p rotect i on;

(3)  Establishment of t<->tal effluents standards for ALL discharges to Lake
Michigan including the 1 °F above ambient proposed by the Department of the Interior;

(4)  A strict construct?onist establishment and interpretation of a non-
degredation policy for both water and air discharges in the lake context;

(5)  A no-discharge policy for all commercial and industrial shipping, including
on-board surveillance and enforcement by trained interstate or Coast Guard
agents, together with complete environmental control systems and design for
all such vessels using Lake Michigan;

(6)  Prohibition of any dumping dredged materials from harbors, ship canals,
industrial wastes or slags, and similar materials into any waters of Lake
Michigan or its drainage basin;

(7)  Special Federal and State appropriations earmarked for sewage treatment
systems in the Lake Michigan basin, planned for maximum cost effectiveness
along lines proposed in 1969 by the U.S. General Accounting Office.

(8)  A total prohibition of all persistent pesticides  in the Lake Michigan
basin;

(9)  A general "inland development policy" which would prevent further visual,
physical  or ecological intrusion on Lake Michigan;

(10) A firm policy with respect to all Lake Michigan ports which would
require non-polluting handling of all shipboard wastes and residues, and
environmentally designed and operated fueling, servicing and cargo transferring
procedures.

-------
                                                    1753





                      To E. Dustin



          MR, STEIN:  Any comments or questions?



          If not, thank, you again,



          MR, DOWD:  Mr, Dustin, I am Joseph Dowd.  1 am



counsel for Indiana and Michigan Electric Company,



          In your statement, you refer only to the work of



Dr, Ayers,  Are you aware of the testimony or the substance



of the testimony that has been presented here this week



by Doctors Pritchard, Lee, Dr, Robertson, Dr, Raney, and



Dr. Pipes?



          MR, DUSTIN:  I would say that Dr, Ayers, according



to the press release, seems to be the only one willing to



be quoted.  At least he is the only one quoted in the Fort



Wayne press as far as we could see.



          Are you aware of the testimony of Dr» Bardach?



          MR. DOWD:  Yes.



          MR. DUSTIN:  We hoped that he would be here to



handle this thing.



          I would like to make a comment.  I think it is



inappropriate, sir, that we should be willing to gamble



the life of Lake Michigan on the say-so of the few men



that you retained to provide these responses.  There are



certainly essential facts associated with thermal pollu-



tion.  I think that cannot be denied.  Reduced contents



of oxygen, for example; stimulation of algal growth.

-------
                                                      1754






                      T. E. Dustin




These matters are not of bathtub origin, as Dr. Ayers




would like us to believe.




          There is a great deal of testimony also to




indicate that Dr. Ayers is wrong in the idea that most




of the heat is dissipated to the atmosphere.  It is, in




fact, mixed with the cooler water.  The Department of




Interior   people have suggested that possibility.




          Do you have anything else?



          MR. DOWD:  Would it be correct to say that you




are not aware of the testimony of the scientific' witnesses



presented by Commonwealth Edison during the week?




          MR. DUSTIN:  We are familiar with some of the




depositions that have been filed in the Commonwealth Edison



matter, however not in the direct context of this hearing.



          However, I have read Dr. Ayers1 complete testi-



mony with respect .to the Donald C. Cook plant at Bridgman



which is essentially the testimony that NIPSCO is relying



upon at the Michigan City plant.




          Dr. Ayers and his associates, as far as we know,




failed to deal with the cumulative effects of thermal




pollution in this area, nor with the views of other




biologists that the inshore waters are  biologically



essential for the life and health of Lake Michigan and its




source waters that would be most severely affected by

-------
                                                      1755
                      T. E. Dustin



thermal pollution, not only from the $0 percent of the




thermal pollution for which your particular industry is




responsible  but from all other sources, too.  There are




many sources of thermal pollution here in Lake Michigan and,




of course, none but a few particular plants in Indiana are




so involved.




          MR. DOWD:  Thank you, Mr. Dustin.




          MR, DUSTIN:  You are more than welcome.



          MR. STEIN:  Anything else?




          MR, FETTEROLF:  Yes.  I would like to ask Mr.




Dustin a question.




          In your testimony, sir, you referred twice to




problems with dissolved oxygen and algae in relation to



heated discharges.




          Could you elaborate on that a little bit?



          MR, DUSTIN:  Yes.  I believe that Dr. Donald



Mount of the Federal Water Quality Lab at Duluth has



indicated a very substantial shift from healthy diatom



food cells toward the green and the blue-green algae as




temperature shifts as little as 4 or 5 degrees upward.  I




have forgotten the exact range, but something like from




&2 to $6 degrees, or something like that.  It is a very




strange shift in the distribution of the different types




of algae that would be found in water.  It is a simple

-------
                                                     1756






                      T. E. Dustin



question of physics.  I don't think — if you would like



me to get into this, I am not a physicist guy, you under-



stand — that warm water simply will not dissolve as much



oxygen as cold water.  I don't think that is subject to



controversy.



          MR. FETTEROLF:  But you don't have any evidence



that this is observed in lakes that have received heated



discharges, have you?



          MR. DUSTIN:  We, of course, have to rely to some



extent on biological experts for whom we have respect and



who have no reason to be influenced by other sources.  Some



of these matters have been discussed for me by Dr. William



Eberly of Manchester College, who is one of this country's



leading limnologists, and I am sure that if you wish I



can obtain from him a written statement.  He has done some



of his postgraduate work at Uppsala University in Sweden,



which to my understanding is the outstanding limnology



institute of the world.  If you would like me to, I am



sure we can provide this for the record.



          MR. FETTEROLF:  I am sure the conferees would



be delighted to see it.



          MR. DUSTIN:  In that case, we shall provide it.



          MRo STEIN:  Mr. Petersen.



          MR. PETERSEN:  My name is 0. K. Petersen.  I am

-------
                                                     1757





                      T. E. Dustin




an attorney for Consumers Power Company and I have one or



two short questions.



          It was my understanding that Dr. Bardach may



be here today to testify.



          MR. DUSTIN:  We hope so.



          MR. PETERSEN:  Is it merely your hope or do you



have reason to believe that he will be here?



          MR. DUSTIN:  No, I have no information that he



will be here.



          MR. STEIN:  He is listed as one of the people



who want to speak.



          MR. PETERSEN:  Thank you.



          You spoke of the Department of Interior — I



take it you are speaking of this report — the so-called



"white paper" — when you talked of the Department of



Interior report.



          MR. DUSTIN:  The gentleman was referring to



Interior's "white paper" on Lake Michigan, and I was



countering with the discussion of a "white paper" produced by



NIPSCO which is far less meaningful than this one.



          MR. PETERSEN:  Do your sources agree entirely



with the material set forth in this "white paper" as



written?



          MR, DUSTIN:  Well, I — let me put it this way:

-------
                                                      17 53





                      T. E. Dustin




We have only had that document for about 2 or 3 weeks,



give or take a little.  We haven't had the opportunity to



review this with the entirety of the Academy of Science.



But if that is another desire of the conference, I am



sure we can provide an analysis.  We happen to have in



Indiana a professional resource chapter.  Credentials



for membership in that chapter are Ph.D. in one or more of



the life sciences.  We have forty members in that chapter.



We would be pleased to present an analysis of the



Department of Interior's recommendations.



          MR. PETERSEN:  I am merely trying to ascertain



your positions, not what you are wanting to do in the



future, the basis for your precept.



          MR. DUSTIN:  If the record is open for 30 days



I am sure we can do that.



          MR. PETERSEN:  The basis for your precept is,



in part, this "white paper" as written, as I understand



it.



          MR. DUSTIN:  Yes, sir.



          MR. PETERSEN:  And the material as to heat



and the inshore zone and the retention of heat therein



and in the waters of Lake Michigan is part of your theory.



          MR. DUSTIN:  Yes, and I wouldn't want to quote



Dr. Bardach.  I think we will let him speak for himself

-------
                                                     1759






                      T. E. Dustin



on it.



          MR. PETERSEN:  Thank you.  I have no further



questions at this time.



          MR. STEIN:  Are there any other questions?  If



noti thank you, Mr. Dustin.



          MR. DUSTIN:  Thank you.



          MR. STEIN:  Let me announce the schedule.  The



way it looks, it is going to be a long, long day.  We



have to give up this room at 6:00 o'clock, I understand, for



a dinner scheduled here.  The only breaks we are going to



take will be dictated by Mrs. Hall.  We may work right



through.  The conferees may eat lunch at their desks.  I



realize it is very important for us to get this public



testimony.  I also know, as I have in the past, in making



these pleas or suggestions that you summarize what you



are going to say, that it is very difficult for people



who are not professionals to summarize, and they feel



that they have to read exactly what is in their paper,



but I ask you all to cooperate so we can get through at



a reasonable hour.



          Again, I want to emphasize everyone is going to



be heard, and we are going to give everyone an opportunity



to present his   views.



          May we have Mrs. J. F. Voita who has a statement

-------
                                                    1760






                    Mrs. J. F. Voita



of Senator Ralph Smith.








          STATEMENT OF MRS, J. F0 VOITA,




                OAK PARK, ILLINOIS








          MRS. VOITA:  I would like to speak for myself



because I am teriffically interested in Lake Michigan,




but the speech that was just made, of which I only heard



a part, gives probably all of my feelings and I hope that



a great deal of consideration will be given to it.



I think that the fact that all of these wonderful organi-




zations are working toward saving Lake Michigan is proof



of how important it is.  I know that Senator Percy




is doing a tremendous job also.



          It seems to me that it is very foolish on the



part of power companies to talk about the cost of doing



it some other way, the right way.  When you think of



what the cost will be to save or to do somthing about




Lake Michigan after we have ruined it, there is no com-




parison as far as I am concerned.




          I wrote a letter to four people from Illinois.



One of them was Senator Smith.  And I was very much sur-




prised and pleased this morning before I came to have a



call from Washington, D. C., saying that he was very sorry

-------
                                                     1761






                     Eileen L. Johnston



that he could not be present but he wanted this statement




read.  This is it:  "I am a co-sponsor of President




Nixon's legislation to prevent pollution of the Great




Lakes.  A clean Lake Michigan is an important factor in




the maintenance of a healthy, vital economic climate in




the State of Illinois.  This goal can be accomplish ^d by




strict enforcement of anti-pollution regulations.  We




must have complete adequate safeguards to control pollution



and other detrimental ecological effects of our Great




Lakes."  Senator Ralph Smith.




          MR. STEIN:  Thank you.




          Are there any comments or questions?  If not,




thank you very much, Mrs. Voita.



          May we have Eileen L. Johnston?








          STATEMENT OF EILEEN L. JOHNSTON,



               WILMETTE, ILLINOIS








          MS. JOHNSTON:  My name is Eileen L. Johnston



and my home is in Wilmette, Illinois.




          Mr, Stein and conferees, thank you for the




privilege of speaking before you.




          The other day, Mr. Vaughn, engineer of water




purification, city of Chicago, said that he was looking

-------
                                                       1762






                      Eileen L» Johnston



forward to my presentation.  At that point I didn't know



whether I was going to say anything, but I thought if he



wanted me to, I would do so, so here I am.



           It is going to be a sad day in Chicago when Mr.



Vaughn retires.  He has been a dedicated man.  And, Mr.



Stein, speaking of retiring, I think it would be very



nice if you and the conferees could send a little message



to Mr. Blucher Poole telling him how much we are going



to miss him at this table.



           MR. STEIN:  I miss him already,



           MRS. JOHNSTON:  I do, too.  I miss that Hoosier



humor and twang.



           MR. STEIN:  You have to recognize that no one



misses him more than I do.  I have worked with Mr. Poole



for the past 25 years.



           MRS. JOHNSTON:  I realize that.



           Well, I believe that I am one of the hysterical



people that Dr. Raney was referring to the other day.



I have been on the environmental beat for sometime  now



and aim thoroughly convinced that man had better take some



drastic actions to restore his environment.



           May I have the privilege of introducing to the



Illinois people — Mr. Stein,"may I have the privilege



of introducing to the Illinois people, who may not

-------
                                                     1763
                    Eileen L. Johnston



realize that Mr. Currie is the chairman of our new




Pollution Control Board, sitting immediately to my right?




          MR. CURRIE:  Thank you.




          MIS. JOHNSTON:  In 196£ I made a statement before




this conference and stated:  "We must restore all of Lake




Michigan to pure water including its tributaries.  This




wonderful lake is actually one big well for the use of the




people of four States and it should be treated as such.




Who would throw sewage, chemicals, oil, heat, pesticides



down the well and expect to survive?



          "No individual, Federal installation, State




installation, municipality, or industry has the right to




put anything into our source of water — the lake.  Lake



Michigan is not the four-State dump for municipal and




industrial wastes, pesticides, thermal pollution, boat



wastes.  Let's clean up this big well, then keep it that



way.  We are making progress with legislation.  With



proper enforcement and continued research we should be



able to do the job.




          "The public needs education.  We need a new




value put on our most valuable resource throughout the




Nation.  It is going to cost us money for pure water.



Let's face it and go to work."




          An article by Harlan Draeger in the Chicago

-------
                                                      1764





                     Eileen L. Johnston



Daily News of August 3» 1970, quoting Mr. Mayo,  Mr. Dumelle,



and Mr. Miller shows clearly that we are not making progress



in the lake cleanup despite efforts of industry.  Are we



wise to even consider putting more heat into the lake?  Mr.



Stein, are you able at this time to give us an approximate



date for a reconvening of the Calumet Enforcement Conference?



It is long overdue,  Mr. Stein?



          MR. STEIN:  Yes, Mrs. Johnston.  I note you have



attended these things and know how they work and, again,



you know I am the Chairman of the conference and the



representative of the Secretary.  The Secretary of the



Interior directs the reconvening and the calling of these



conferences.  Very often he asks me to call them in my



delegated authority, but I do think that we will be in



touch with the other States and make a recommendation to



the Secretary of the Interior on that»



          I have no statement now on the reconvening of



the conference.  We have two things to consider:  1) We



have special problems such as this thermal problem; and



2) all of these States have busy programs, and part of



the counter-program is that we just have to keep the



conferences down so they can do their work.  Just prepar-



ing for these conferences takes a tremendous amount of



staff work on the part of the State agencies and everyone

-------
                                                      1765





                     Eileen L. Johnston



else.  We try to hold them as frequently as we think they



will do the most good, but we will take that up with the



States, and I think we can give you a judgment on that



after I have checked with the people back at the ranch in



Washington, and we will do so.



          MRS. JOHNSTON:  I urge other citizens to do so



because the last time this was — this was in August of



1969 and things are not very good down in that part of



the lake.



          It was pointed out by this study fco Mr. Dumelle



and Mr. Mayo brought it out.



          My position has not changed one bit from 196$,



so you see I do endorse the Department of the Interior



position of September 19700  It was a teriffic meeting



and I think, Mr. Stein, it might be very worthwhile to



have the highlights of that meeting published so that



people can obtain it.



          I have toured the Ann Arbor laboratory and I



have observed experiments going on over there, talked



with the research men, and heard them speak at confer-



ences on research.



          Mr. Frangos, I have a question for you.  Last



spring I toured the Jones Island Treatment Plant in



Milwaukee, and the superintendent told me they would be

-------
                                                      1766
                     Eileen L, Johnston



chlorinating the effluent by the end of the year.  Now,




this is October.  Do you know what progress has been made?




In view of the big discussion that took place at Milwaukee,




I feel it should be brought up at this time.




          MR. FRANGOS:   Well, the superintendent has been




telling me — and we didn't understand that as a commitment




legally to our agency,  Mrs. Johnston — but they are




proceeding along the timetable that we have established




in the State of Wisconsin0  They are not chlorinating as



of this date nor will they be chlorinating this fall.




Their schedule is for next fall.




          MRS. JOHNSTON:  The superintendent should not




have told me that they were going to be chlorinating by




the end of the year if that is the case.



          I urge a speedup of the phosphate deadline in



sewage treatment effluent.  We have the technology.  In



fact it is being applied in Milwaukee.  Both Mr. Vaughn's



and Mr. Dumelle's papers bring out the urgency of




immediate action.



          We must keep in mind we are talking about a



very sick lake full of lead, mercury, oil, radioactive




wastes, arsenic, pesticides, nitrates, phosphates, heat,




and we just don't know the whole story.  The ill effects



of any one of the pollutants might be so harmful, but

-------
                                                      176?






                     Eileen L. Johnston



the synergistic effect may be so ominous,



          I respect Commonwealth Edison for their study



plan and for the caliber of the research men who testified



for them.  Certainly no man has studied Lake Michigan more



than Dr. John Ayers, and I have always had great respect



for D:f. Ayers,  They do have problems that are difficult



but that can be solved.  This, of course, applies to the



other power companies around the lake.  The public will,



I am sure, be willing to carry its fair share of the cost



of alternate methods to once-through cooling when it is



made fully aware of the alternative.



          I realize the outcome of this conference will be



based on the judgment of extremely competent  men.  I



have all of the faith in the world in you conferees.  I



just hope you will remember the small voice of the citizens



in your deliberations, and there is one other thing I



would like to mention, please, Mr, Stein.  A lot has been



said about the heat input from other industries other than



power, and when we toured U. S, Steel down in Gary —



remember, Mr. Stein — in, I think, it was 1968 — that



brand new facility — I was really shocked and amazed



when I asked the man the temperature of the effluent and



it was 11 degrees warmer than the input.



          MR. STEIN:  Thank you.  Are there any questions?

-------
                                                  1768






                     Eileen L. Johnston



          You know, Mrs<> Johnston, I was surprised it was



that low considering what they ran that water through,



          MRS. JOHNSTON:  Really?



          MR. STEIN:  Sure.  You saw the heat of that



steel.



          MRS. JOHNSTON:  Oh, yes.



          MR. STEIN:  And what they subjected it to.



          MS. JOHNSTON:  But when you think of all of the



industries down at that end of the lake, and Mr. Morton



or Mr. Schneider at the Lake Erie Conference, wasn't there



some discussion in the auditorium on the future industry



building down there for awhile?



          MR. STEIN:  Well, I didn't hear that.  Again —



and you know you raise a question here and a lot of people



have talked about this — let me make one thing clear:  I



don't think that people either in the State water pollution



control agencies or the Federal water pollution control



agencies have any authority over land utilization and I



am not sure you people would want us to have thato  The



land utilization has traditionally been a local responsi-



bility.  Usually the States control it, certainly not the



Federal Government, except when you are dealing with the



Federal lands, of course, but with non-Federal lands we



don't.

-------
                                                    1769






                    Fo Pierson



          The point is, however, once a decision is made



by the local people of land utilization, we do have the



powers to assure that the environment is protected, and



this must be borne in mind *     I think when people talk



to us about putting a moratorium on sites or on uses,  I am



not sure they recognize 1) the limits of their authority



or 2) the implications of that kind of request, to put the



Federal Government in that type of business.  I am not



sure you would like to live under that sort of Government



in this country,



          MRS. JOHNSTON:  Thank you.



          MR. STEIN:  Thank you.



          Frank Pierson,








          STATEMENT OF FRANK PIERSON, SPOKESMAN,



          CAMPAIGN AGAINST POLLUTION, CHICAGO,



                         ILLINOIS








          MR. PIERSON:  My name is Frank Pierson,  I am



representing the Campaign Against Pollution here not so



much as a technician, but as a concerned citizen, conveyor



of peoples' sentiments, and so on.




          We just turned in a copy of our formal technical



testimony and I won't trouble you with it here.  I am here

-------
                                                      1770





                      F. Pierson



to stress a single point and to ask some extremely simple



questions•



          The problem of thermal pollution has been discussed



throughout Chicago and the suburbs.  The people of Chicago



and the suburbs, the thousands of us who constitute the



campaign against pollution and other sympathisers have come



to the following conclusions which we feel is the only



human conclusion:  There must be no discharges of heat into



the lake by a power company.  We won't tolerate those dis-



charges.  And when I say this, I am talking about some very



worked up, very adamant people.



          We pledge ourselves to be unrelenting in the



fight against heat discharges of any magnitude by the power



companies.  We insist that these companies must employ



closed cooling systems and that people won't be fooled by



phony demonstration projects designed to conceal the fact



that those projects propose a thermal pollution threat.



          So we ask you gentlemen for a favorable answer



and we hope that it will come soon.  The longer you wait,



the more certain we become that you are dickering behind



our backs with big corporations, and we are positive



that you have the interest of big money and not the people



at heart.



          That concludes what I would like to say.

-------
                                                     1771
                      F. Pierson



          I would like to ask Chairman Stein a question,



and that is when he expects this body will make a decision



concerning the matters that are being discussed today.



          MR. STEIN:  Well, a lot of people have contributed



many attributes to me which I don't have, and I appreciate



being given the wonderful clairvoyance, but I can't



predict that.



          We have a group of five conferees, all independent



thinkers.  We have had some very complicated information



presented before us.  We are not completed yet,     I think



if you want to wait until the wee hours of this morning



or tomorrow,,! will be able to give you a better judgment



when this is complete and I have consulted with the other



conferees.



          MR. PIERSON:  Well, may I ask this:  Can you



say that you will have a decision by the end of October?



          MR. STEIN:  Any decision that we have will



depend on actions of many people other than myself.  I can't



speak for them.  I will try to get a decision as rapidly as



I can.  From my personal point of view, I would hope that



the conferees would be able to come up with a determination



within a couple of weeks..,     I haven't spoken to them and



I have no notion of what they want to do.  This is, again



— and you are asking the kind of question that people ask

-------
                                                    1772






                      F. Pierson



about timetables in enforcement cases and when things are



going to be done.  But this depends on the determination



of third, fourth, fifth parties, and one person doesn't



handle all of the strings and is not able to make all of



these judgmentso  I think my function here is to hold



everyone's nose to the grindstone to be sure that there



are no dilatory tactics used and we arrive at the decision



as rapidly as is humanly possible.



          MR. PIERSON:  Could I tell .my people, then, that



we could expect a decision — at least a recommendation —



from this body within, say, 2 weeks?



          MR. STEIN:  You can tell your people that but



please don't tell them I said it.



          MR. PIERSON:  Let me ask one more question:



Will this body be meeting with industry before a decision



is made other than in this hearing here?



          MR. STEIN:  I don't think the body will meet



with industry.     Let me make another thing clear:  As



a public official, and I guess maybe the others, I have



an open door in my office, and whether you or a citizen



group, industry, or anyone wants to come up and see me,



they are always welcome.  I don't know that anyone wants



to come up, but I don't feel as an official we can close



the door to anyone,       I think it ±e fairly clear on

-------
                                                     1773
                      F. Pierson



our record that when we meet in a body with people who



have an interest in pollution control, we do this in a



public manner <,  I have said this again and again.  We are



a public agency doing the public business in a public



manner.     J£ you think that the implication is there are



going to be any private meetings, large meetings that no



one knows about, the answer is no.



          MR, PIERSON:  Would you do us this favor then?



If and when some of the power companies would like to get



together with you, would you invite us to those occasions



so that we can present the citizens' viewpoint?



          MR. STEIN:  Well, again, we don't operate, in a



sense, that way, and I have talked about this many, many



times.  If you want to meet with me, I am not sure I will



invite the power companies or anyone of that kind,



          I think, an essence of our society — and 1 know



your group has been here before and I have put this out



before — an essence of our society is a right of privacy.



Privacy doesn't mean secrecy, and we respect that right



of privacy of every citizen as a basic constitutional



right.  And if I want to have a private meeting with my



wife or my children,, I don't think that anyone has a right



to ask to come in^.     I think if any one of the group here



wants to come into my office or anyone else's office or

-------
                                                     1774
                       F. Pierson



just meet on a personal or other basis, we will have that



meeting.  I will assure you one thing,  I am sure the



other people here do this.   Nothing I do officially is



governed by confidentiality or secrecy.  Every public



operation we have will be fully disclosed.



          MR. PIERSON:  I would like to say that I think



this is a public issue and not a private one of the sort



you referred to, and I think that the people should be



represented at even the small gatherings where decisions



might, in fact, be made without our knowing it.



          I presume that this wouldn't be a situation in



which you are trying to conceal some sort of negotiation.



          MR. STElN:  No decision is going to be made



without your knowing it or anyone's knowing it.  But,



by the same token, in the ordinary conduct of any public



business I may have between, oh, I don't know maybe 10 or 15



people in the course of a day coming into my office on



special pollution problems, a lot of them spend considerable



time and expense in coming to Washington to see a public



official.  Before they could get past that phalanx of



secretaries in my outside office, if I had to tell each



one of them that before I could see them, I would have



to notify someone else who might have a

-------
                                                       1775






                      A. Pancoe




remote interest in what they were concerned with so they all




could go to the meeting, I think we would have a sorry




kettle of fish.  We just don't do business this way, and I




think you have to recognize we are operating within our




society.




          Sir, I have got one more thing to say:  If you




don't have confidence in your public officials and if you



don't think that we are going to represent the public



interest in all our dealings with whoever we deal with in



the best way, public or private, then it is up to the




people to get rid of us.  But we have to have that mutual




faith and confidence if we are going to do business.




          MR. PIERSON:  We think you represent us but we



would just like to help you out a little bit.




          MR0 STEIN:  We appreciate it.  Thank you.



          May we have Arthur Pancoe?








          STATEMENT OF ARTHUR PANCOE, SAVE -



          CAMPAIGN AGAINST POLLUTION, GLENCOE,



                         ILLINOIS








          MR. PANCOE:  I want to thank you gentlemen for



the opportunity to testify„  My name is Arthur Pancoe, a




resident of Glencoe, Illinois.  I am here as a scientific

-------
                                                       1776





                      A. Pancoe



director of SAVE and also Campaign Against Pollution,



          I have a graduate degree from Northwestern,



and Master's from Northwestern University, and I expect to



discuss this problem from a slightly different point of



view.



          The use of Lake Michigan for thermal discharge



from nuclear plants constitutes only a temporary home for



the heat.  When considering the possible damage from this



discharge and realizing that the heat will in turn be dis-



persed into the atmosphere in a relatively short time, the



question arises:  Why not emit the heat to the atmosphere



originally via cooling towers?  Taking into account seasonal,



and shorter range temperature variations, the heat will



remain in the lake approximately 10 days on the average,



(Ref, 1)  It seems ludicrous to take a chance with the



quality of the lake under such circumstances.  The total



consequences of depositing large amounts of heat in the



lake cannot now be determined accurately.  The probabilities



indicate that if damage does occur, it will not be apparent



until years or even decades in the future.  And should



danger signs occur from the heat, could the plants in



existence even be reoriented?



          The St, Louis-based Committee for Environmental



Information in March 1970 estimated that "In the year 2000

-------
                                                        1777





                      A. Pancoe



if power consumption continues to increase and there is no



corresponding increase in overall efficiency powerplants of



all kinds will dispose of roughly enough waste heat to raise



by 20 degrees the total volume of water which runs over the



surface of the entire United States."  The committee had



more dire conclusions with regard to carbon dioxide and



radiation contamination that will result from such plants.



But these problems are not pertinent to the subject being



considered.



          There are some calculable parameters that can be



of use in judging whether a risk can occur in certain areas.



It can be roughly determined that the heat input to the lake



from all plants by 1990 would be less than 1 percent of that



supplied by the sun on a clear early summer day.  (Ref. 2)



This figure on a superficial basis appears to make the



entire question of thermal pollution moot0  However, if we



are sagacious about this figure and if additional aspects



of man-created heat are taken into account, our complacency



will soon disappear.



          First, unlike the sun, the plants will supply



heat to the lake continuously, with no interruptions by



either darkness, cloud cover, haze, cold days, or cold



seasons of the year.  Also the heat will be injected



entirely into the inshore portion of the lake at depths

-------
                                                        1773






                      A. Pancoe




of less than  10 meters and into an area representing less




than 8 percent of the lake's surface.  Under these more




concentrated conditions the input in the area affected




will represent approximately 10 percent of the solar




generation again on a clear summer day.  (Ref. 3}  It is now




important to discuss a process by which this heat in the




shore areas will be concentrated, perhaps dangerously, in




the spring of the year.




          During this time a phenomenon occurs which is not




unusual in lakes but particularly prevalent at times in




Lake Michigan.  This is a condition in which a thermal bar




of water (i.e.,  water at its maximum density 4 degrees




centigrade) is established offshore forming a barrier which



allows little horizontal mixing between inshore and the much



larger offshore volume of water.  This condition can last



days or even weeks.-  The heat which is already concentrated



in the inshore area will be trapped and will spread out in



a thermal plume traveling great distances along the shore.




As spring proceeds and the bar moves farther offshore,




usually sometime  in June, the thermal mixing of the lake




will return to normal.  However, with regard to possible




biological harm, uhis intense inshore concentration of heat




occurs at precisely the most sensitive time of the year.




(Ref. 4)

-------
                                                      1779





                      A. Pancoe



          J. J. Resia of the Department of Biological



Sciences, Northwestern University, formulated a detailed



description of the danger to the fish population from



this phenomenon,  (Ref. 5)  I have attached herewith a



detail of his statement.



          Another problem that bears consideration is



possible fish kills resulting from upwellings about



thermal plumes.  Such kills have already been documented



with regard to fossil plants.  (Consumers Power, Port



Sheldon, August 29, 1968)  As discussed by Resia, fish



population will be attracted to the areas of heated dis-



charge .



          It is well established that the greatest danger



to a fish population about a plume exists from temperature



drops occurring from a sudden upwelling of cold bottom water<



Therefore, the critical upper limit of discharge is governed



by this factor and not the upper lethal temperature of a



given species.  The maximum acclimation temperatures for



the game fish in Lake Michigan make it doubtful if any



major heat discharge does not involve a risk.  (Ref. 5)



These allowable acclimation temperatures are well, below



proposed discharge temperatures of the plants„  But, more



startling the recommended maximum discharge temperatures



are below natural maximum monthly surface temperatures.

-------
                                                       1780
                      A. Pancoe



(Ref. 6)  Thus, safety to the fish population, from even the



proposed strong 1-degree limitation above ambient now being



considered, is negated.



          More important than ambient standards is whether



any major heat discharges should be allowed.  As described



earlier, large amounts of heat are continually added in the



spring of the year to a rather limited volume of water.  Even



though this is accomplished by diluting the heat in large



volumes of water, the increase in lake temperature inshore



will be precisely the same as if the heat were added at a



more severe temperature originally.



          At this point, I wish to digress.  It is my con-



tention that the various standards being suggested for dis-



charge into the lake all provide precisely the same safety to



the lake:  none at all.  I want to strongly emphasize this



point if no other point in my statement.  The public, in



my opinion, is being misled, and I certainly do not think,



in the case of this board, purposely, by the 1-degree stan-



dard into believing the lake is protected.  I do not



think the public has been fully cognizant of the fact that



the main free ride is given by the lake itselfo  There is



roughly a 15- to 25-degree temperature change between the



water at the point of intake and the outfall point during 10



months of the year.  I want to strongly emphasize this

-------
                                                      1781





                      A. Pancoe



point,  I think the 1-degree, again — not intentially by



this board — is a coverup.  If I were the power company, I



could live within this 1-degree temperature standard very



easily and accomplish the exact same damage, if there be



damage to the lake.



          As I pointed out earlier, I do not think that it



is even fair to put the power companies to the expense of



going through various contortions to live within this



standard.  The question is:  Will the heat harm the lake?



          Now, I want to make a little statement here about



scientists, and this will cover all sides of the question.



          MR. STEIN:  Mr. Pancoe, when we put you on, you



indicated you would take 10 minutes.  Are you going to



adhere to that?



          MR. PANCOE:  I am going to end with the statement



on this one point, because I think it is the only point I



have to add to the discussion.  I don't think any scientist



either for or against this heat discharge can honestly say



that it either will or will not harm the lake.



          Einstein in his later years  said that his



present theories of relativity are more than likely nearer



to a correct prediction than the former Newtonian laws,



but that his laws will then be improved upon as time goes



by  by other scientists.

-------
                      A, Pancoe



           Thus, when any scientist says that he unequivo-



cally can state that there will be no damage to lakes from



heated discharges, I think this man is possibly dishonest.



I likewise feel that anyone who says that heated discharges



will definitely harm the lake is equally dishonest.



           With this in mind, I think that the real



question here is:  We do not know.



           And with this, I want to close by stating that



I don't think that the heat should go into the lake.  It



can go just as easily under less stringent standards as



under the previous 5-degree standards.



           I don't think the harm comes from the temperature



the water is put in, but from the cumulative effect and



the total number of B.t.u.'s put into the lake will be



precisely the same in either case.



           Thank you.



           MR. STEIN-:  Did I understand you, Mr. Pancoe?



           Your proposal is that power companies or



industrial plants not be permitted to put any heated



water into the lake.  Is that correct?



           MR. PANGOE:  That is my proposal.



           Either the power companies should be allowed



to put the heat in or not allowed to put it in, and I



think I could show them if no one else could how to put

-------
                                                      1733
                      A, Pancoe



the heat in under the 1-degree standard.



           MR. STEIN:  Are there any other comments or



questions?



           If not, thank you very much,  Mr. Pancoe.



           MR. PANCOE:  Thank you.



           (Mr. Pancoe*s presentation follows in its



entirety.)

-------
r   /    I      i   ^
I	X  [	j  I	j   \^
             SOCIETY

   AGAINST VIOLENCE          _   ^     ^v          ^   NORTH  SHORE AFFILIATE

              TO THE   ""  
-------
                                                                                 1785
             SOCIETY

   AGAINST VIOLENCE

              TO THE

        ENVIRONMENT

               BOX 84

GLENCOE, ILLINOIS 60022
 *%&§&?*?
                                                    PAGE 2

    During this time a phenomenon occurs which is not unusual in
lakes but particularly prevalent at times in Lake Michigan.  This
is a condition in which a thermal bar of water, (i. e.  water at its
maximum density 4°C.) is established offshore forming a barrier
which allows little horizontal mixing between inshore and the much
larger offshore volume of water.  This condition can last days or
even weeks.  The heat which is already concentrated in the in-
shore area  will be trapped and will spread out in a thermal plume
traveling great distances along the shore.  As spring proceeds and
the bar moves further offshore, usually some time in June,  the
thermal mixing of the lake will return to normal. However, with
regard to possible biological harm, this intense inshore concentra-
tion of heat occurs at precisely the most sensitive time of the year.
(ref. 4)
    J. J. Resia of the Department of Biological Sciences North-
western University, formulated a detailed description of the danger
to the fish population from this phenomenon,  (ref. 5)
    Another problem  that bears consideration is possible  fish
kills resulting from upwellings about thermal plumes.  Such kills
have already been documented  with regard to fossil plants.
(Consummers Power Port Sheldon, Aug. 29, 1968).   As discussed
by Resia, fish population will be attracted to the areas of heated
discharge.
    It is well established that the greatest danger to a fish population
about a  plume exists from temperature drops occuring from a
sudden upwelling of cold bottom water.  Therefore the critical upper
limit of discharge is governed  by  this factor and not the upper
lethal temperature of a given species.  The  maximum acclimation
temperatures for the game fish in Lake Michigan make it doubtful
if any major heat discharge does not involve a risk. (ref.  5)  These
allowable acclimation temperatures are well below proposed
discharge temperatures of the  plants.  But,  more startling the
recommended maximum discharge temperatures are below natural
maximum monthly surface temperatures,  (ref. 6) Thus,  safety
to the fish population, from even the proposed strong 1° limitation
above ambient now being considered, is negated.
    More important than ambient standards, is whether any major
heat discharges should be allowed.  As discribed earlier,  large
amounts of heat are  continually added in the  spring of the year to
a rather limited volume of water.  Even though this is accomplished
by diluting the hept in large volumes  of water, the increase in lake
temperature inshore will be precisely the  same as if the heat were
added at a more severe temperature  originally.
    Another field of concern is the effect on alge growth,  (blue-
green) resulting from removing large volumes of nutrient,  enriched
water from  the hypolimuion (the cold bottom layer), warming the
water, returning it to epilimnion (the warmer top layer), and thus
-------
                                                           1786
            SOCIETY

   AGAINST VIOLENCE

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       ENVIRONMENT

              BOX 84

GLENCOE, ILLINOIS 60022
'<&

                                                       PAGE 3
 increasing the growing season in the surface waters.  Additional
 secondary effects possibilities are depletion of oxygen in the bottom
 waters in summer, changes in species composition, numerical
 relationships in lake  plants, and animal populations, (ref.  7)
 Clarence A.  Carlson of Cornell in a paper entitled "Ecological
 Impact of Nuclear - fueled Power Plants" states many other con-
 siderations not mentioned.
      a)  Due to inefficiency of nuclear plants 60% more waste height
         is released to cooling water per K. W.  than fossil - fueled
         plant causing great extremes of conditions via vie fossil
         plants.
      b)  Temperature is important to aquatic organisms  as  a lethal,
         directive, and controlling factor.
      c)  Increase in temperature will increase  the rate of metabolism
         and oxygen consumption in aquatic organisms while con-
         currently decreasing the oxygen - dissoling capacity of the
         water.
      d)  Increased temperature generally stimulates growth of taste
         and odor producing organisms.
      e)  formation of  sludge gas
      f) multiplication of saprophytic bacteria and fungi
      g)  consumption  of oxygen by putrefactive  processes
      h)  warming of water likely to increase  suseptibility of fish to
         certain disease organisms and metabolic poisons.
      He also  states that less than  5% of the 1900 fish species found
 in U. S. have been studied with respect to temperature response.
      The Fishery Resource Management paper "Some Adverse
 Effects of Thermal Pollution of Aquatic Ecosystems" suggests
 other dangers from thermal discharge,  (ref. 8)
      Since means of disposing of the heat directly into the atmosphere.
 are available why take  any risk with the lake?
                                        Arthur Pancoe
                                        Scientific Director of SAVE
  References
  1,2,3, - C. H.  Mortimer,  Director,  Center for Great Lakes Studies
          Zion, 111.  May 2,  1970
  4,5,6,  - See attached
  7   -   Alfred W. Eippen, July 3, 1970, American Society for
          Advancement of Science
  8   -   See attached
-------
 Table  3.  Recommended  seasonal maximum temperatures for spasming and'
          depths  at vhich  spawning has occur'red in Lake Michigan
    Specie
                         Season
                        Depth (ft. 1  T^mp^rj^u£e_(^F)_
Lake Trout

.Lake Herring

Lake White Pish

Yellow Perch



Channel Catfish

Coho Salmon
Oct. - April

Nov. - April

Nov. - April

April - May

Jan. - March

May - June

Fall
                                                 10
                                                                 Streams
I/  Keller, M., 19^9«  Personal communication.
£/  Kpelz, 1929.
3/  Wells, L. , 19o9-  Personal coEraunication.
J/  Wells, 1968.
5/  Embody, 193!*.
6/  Unpublished data, BCF, Ann Arbor, Michigan.
7/  Price, 19^0.
o/  Unpublished data, 1IWQL, Duluth, Minnesota.
2/  Sneed, K.  Personal communication.
-------
    Ref.  5

             SOCIETY

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        ENVIRONMENT

               BOX 84

GLENCOE, ILLINOIS 60022
                                                          1733
    "One thing which definitely is not needed in the current debates
over effects of waste heat from nuclear power plants on Lake
Michigan is another biologist who takes the position of an advocate.
I therefore must preface my following remarks with a.brief bit
of philosophy.
    With few significant exceptions,  predictions of resultant harm
to the Lake's biota are honestly debatable.  When specialists in
pertinent fields  disagree, the issues become quite clouded and
confusing to the  public.  The clouds part a bit,  though, if the
layman keeps two  things in mind.
    First, the empirical, inductive method to which modern
science is wedded never "proves" or disproves" anything.  No
matter how dogmatically some scientific "truths" often are taught,
it must be remembered that at the philosophical foundation of
scientific method is a rule which says that the most an investigator
can hope to accomplish by his experimental results and interpre-
tations is to cause one hypothesis or another to seem  more or less
likely to be true.  Hence, competent scientists, honestly attempting
to be objective,  can and often do disagree..
    This brings us to the second point.  The current environmental
quality crusades in general and the nuclear power plant controver-
sies in particular  have seen too many scientists showing too little
regard for objectivity.  Abuses of this nature seem to come from
both sides of almost every confrontation.  It can be maddening
for a scientist to try to refute a less idealistic  oponent's "absolute
certainties" with wishy-washy "it appears thats" and "the data
suggest thats. "  Nevertheless, scientists and engineers who my-
opically pander  either to their employers' vested interests on the
one hand or to crowd response on the other do service to no one
and, I fear, are going to learn that in the long run,  their credibility
and that of their profession is as fragile as it is valuable.
    Granted the above, I would like to describe a problem  which I
feel has  not yet  been given any real  attention by those about to decide
what can and can not be done with waste heat in Lake Michigan.
    In the temperate latitudes in which we live, organisms are
forced to adjust their life cycles to the rigors  of changing seasons.
Mother Nature has been very fussy about compliance, and those
species which failed to synchronize  became evolutionary drop-outs.
One well-known environmental cue that is  widely used by plants
and animals as a season-indicator is photoperiod, the changing
length of the day.  Thus, many birds,"for  exampie, are  "told
when tUeir gonads should ripen, when they should mate,  and when they
should fatten up and migrate  by the lengthening or  shortening day-
light hours.
    For terrestrial organisms, as well as for  those which are
found in rivers and streams (lotic environments), photoperiod
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c5Cffl
                                                                            PAGE 2
GLENCOE, ILLINOIS 60022
                         is a cue far more trustworthy than temperature.  For the biota of
                         lakes and ponds (lentic environments), however,  seasonal temper-
                         ature changes usually are pretty consistent (especially in large
                         lakes), and it is well-known that for many lentic  species (notably,
                         fishes), water temperature plays the principal role in seasonal
                         synchronization.
                             Since the effects of thermal discharges, present and proposed,
                         on the overall  temperatures of Lake Michigan can be considered
                         insignificant (which, possibly,  is why Commonwealth Edison
                         spokesmen have mentioned them so often), and since the plumes
                         of heated water will be small in relation to total  Lake area,  it is
                         not immediately evident that a  significant proportion of any popu-
                         lation in the Lake could be affected adversely.
                             There is more to the story, however.  In the first place, the
                         littoral   (nearshore) areas of any large body of water are by far
                         Ihe most biologically important.  In these littoral areas, Nature
                         provides light and nutrients in  relative abundance, and productivity
                         is high.  Since populations always produce more  offspring than
                         the environment can support, and  since the principal limiting
                         factor in the  survival of offspring  of most aquatic animals is
                         food availability, natural selection has "taught" the great majority
                         of species to reproduce in littoral waters.  Thus, these near-
                         shore areas, into which the nuclear plant effluents are to be
                         directed,  see a lot more biological traffic than comparable off-
                         shore areas.  Included in this relatively congested situation  are
                         those fishes which are spawning, those which have been spawned,
                         and those  predators desirous of eating spawner or spawnee.
                             We understand, then, that biomass is relatively large in the
                         general vicinity of the proposed heated effluents,  but the story
                         goes further.  Most animals have  preferred temperatures.   This
                         means that their activity is less at one temperature  than at any
                         other. In fishes, for example,  an individual's preferred tempera-
                         ture  depends on such factors as species, previous thermal history,
                         age,  physiological state, time  of day and year, and many other things,
                         known and unknown, but it may be generalized that if a group of
                         similar fish are placed in a thermal gradient, they will tend  to
                         congregate at their preferz'ed ternperature in a sore of "gapers'
                         block" effect.
                             I have heard the advocates of  "thermal enrichment" speak
                         enthusiastically of fishing "hot spots" produced by power plant
                         discharges.  Such  phenomena are  produced when ambient water
                         temperatures are below the preferred temperature of fish in the
                         general vicinity of a heated plume.  When the fish congregate at
                         their  preferred temperature in the gradient caused by the plume,
                         a fisherman's bonanza results.
                             But there may  be a catch to this.  I have already discussed
                         why fishes tend to be in the general vicinity of the thermal plumes,
                         and how they can tend to move  to positions in the plumes where
                         temperatures are above ambient.  Such situations already exist
-------
                                                                                 1790
             SOCIETY

   AGAINST VIOLENCE
       ENVIRONMENT

               BOX 84

GLENCOE, ILLINOIS 60022
         •'AtVv * V* * "t-V  ^LW*'*
TO THE Jt^-V&fV'*  *%^'
        CLxLJ  LJ   W
                                                            PAGE 3
                         on small scale in Lake Michigan.  But if to these  considerations
                         we add the proposals for a growing number of large discharges
                         from nuclear plants, we must conclude that greater percentages
                         of the Lake's fish populations would be  spending greater amounts
                         of time at temperatures above  ambient.
                              Besides having other, more well-known, physiological effects,
                         water temperature  (as mentioned previously) is the principal
                         seasonal timer for  many species of fish. In effect, progressive
                         changes in the ambient temperature of the Lake "tell" a fish
                         when to begin and complete gonadal development,  when to feed,when
                         to migrate, and when  to spawn.  Thus,  each  species of fish is
                         influenced to perform  some or all of these activities at a time of
                         the year most advantageous for survival of the population.  It
                         must be noted that  the physical characteristics  of the season are
                         not the only reasons why timing is important.  Spawning, for ex-
                         ample, must be performed simultaneously by the  greatest possible
                         proportion of the population, for maximum efficiency, and the lar-
                         vae  must latch in synchrony  with the often ephemeral availability
                         of important food species (which also are influencpd by tempera-
                         ture).
                              Add to all of these considerations the complex, seasonally-
                         variable food-web interactions in the Lake, and one begins to
                         understand the validity of questions  raised about fishes spending
                         time in the proposed "hot spots" rather  than in  waters of ambient
                         temperatures.   The temperature a fish "likes"  bears no necessary
                         resemblance to the temperature that is good for survival of its
                         population.
                              I have heard attempts by some to defend calefaction on the
                         grounds that elevated  temperatures  have no adverse effects on
                         certain aquatic animals from arctic or tropical latitudes.  I have
                         also heard it mentioned that  in certain fish culture practices,
                         people spend money to heat ponds to increase yield. In answer
                         to the latter, it should be noted that such people also have to feed
                         the fish in those cultures.  Cultures  are not ecosystems.  AricTTn~
                         answer to both, we need only keep in mind that  we are concerned
                         with temperate latitude fishes trying to stay alive and obtain food
                         in a tempeKate latitude lake.
                              Finally, I wish that discussions  of ecological effects of waste
                         heat could rise above  naive considerations of what is lethal to
                         adult fishes.  There's more  than one way to skin a population,
                         and  knocking out reproduction  sounds to me as though it might be
                         fairly effective. "
                                                          J.  J. Resia
                                                          Department of Biological Sciences
                                                          Northwestern University
-------
                                                                   1791
 Table  2.   Lethal  temperatures for some Lake Michigan fishes.
STDCCICS Acclimation Temperature ' (°

Channel Catfish-



Lake Herring—



V
Lake Trout-'


Coho Salmon-




Yellow Perch



Gizzard Shad—

77
68
59
•50
77
68
50
36
68
59

73
68
59
50
111
77 Summer^-/
77 Winter^
59
50
lil
77
F) Lethal Temperature (fFj
feL .
92
91
86
82
78
79
75
61
73
73
(69)'
77
77
76
75
73
90
86
82
77
70
93
Lover
Ii3
111
32
32
Ii8
39
37
33
(3*)
(3^0
(32)
Mi
lio
38
35
32
liO
32
32
32
50
37  Hart, 1952
2/  Unpublished .Datas BCF, Ann Arbor, Michigan
3j  Parenthesis denotes estimates from short term tests.
    Huntsman.and Sparks, 192^.
jl/  Brett, 1952
5/  Hart, 19^7
-------
                                                                   1792
Table 1.  Recommended month lymaxi mum surface temperatures for heateS
          discharges into Cake~Michi£an.
              Lake Michigan—     ...      Recommended Monthly Maximum
Period  Surface-Temperature (° F)—          	- Surface Temperature s
'Maximum

Dec.
Jan.
Feb.
March
April
May
June
July
August
Sept .
Oct.
iiov.

50
te
37
37
M
53
65
71
7^
72
65
5*
Minimum

33
32
37
32
32
36
te
^
50^
50^/
50
V2


55
50
50
50
50
55
70
85
85
85
85
70
I/  Surface te:nperatues are the 3T readings recorded at 0.0 feet.
2/  Excluding Green Bay.  Surface temperature range in Green Bay in
~   June, 1963 vas 15-9 - 25.0° C and in July, 1963 2>i.3 - 17-7° C.
3_/  Fron stations less than 5 miles froa shore and avay frora river
    mouths contained.in:  Lake Michigan Basin Office, BT Data, 1962
    end 1963 .and for vinter r.onths from Noble and Michaelis, 19^8.
   "Winter temperature data from Federal Water Pollution Control
    Administration, (Great Lakes - Illinois River Basin Project)
    Buoy Stations."
^J  Personal connunication, Mr. John Carr, EC?1, /Jin Arbor, Michigan.
-------
                                                                               1793
Cons, hhl                                              November 6,  1969
Fishery .Resource Management
       SOME ADVERSE EFFECTS OF THERMAL POLLUTION ON AQUATIC ECOSYSTEMS


I.   Through habitat changes

       A.   Aquatic_plants

          1. Overstimulation of plant growths present.

          2. Shift to less desirable plant forms.
               Eg, from diatoms or greens to blue-greens.

       B.   Reduction -_of water body' s capacity to decompose organic wastes

          1-. Increased decay -1 overutilization of dissolved oxygen in
               local area, hence lowered decomposition capacity downstream.

          2. Stratification isolates organic matter in anaerobic
               bottom waters.

       C.   Increase stratification period

          1. Degraded conditions for fish in hypolimnion ( protracted 0?
               depletion,   food consumption, etc)

          2. Longer growing season in epilimnion.

II.  Throuf;h_gffects on aquatic organisms themselves

  Perspective:  Temperature  responses have  been  studied in less than yl° of the
    approximately 1,900 specie? of North American fishes.   To date virtually
    all of these  have been  studies of mshort-term  temperature effects.
          1. Thermal shock (sudden)
               a) Through condenser  cooling cycle
               b) Into or out of plume of heated water

          2. Heat death (gradual)

          3. Death in early life stages
               o) Before hatching
               b) Directly after hatching
               c) Deformity -' abbreviated life span
                              (continued  on p.  2)
-------
                                                                              179^
       B.   Death thru indirect ecological effects  of  elevated temperatures

          1. Accelerated metabolism + lowered 0?  carrying  capacity of
               haemoglobin = Greater need for 0  in env't.  But higher
               temp -* lower 0? in water.   Results:

                 a) Extreme cases: Asphyxia

                 b) Less extreme: Weakening.   This, plus more direct effects
                      of higher temp.;  can produce:

                      (1) Lowered resistance  to toxic  substances  (copper,
                            cvanid0% insecticides,  detergents, etc.)

                      (2) Lowered resistance  to fungus or  disease, plus  more
                            rapid proliferation of  many pathogens.

                      (3) Decreased ability to forage, escape predators, etc.

          2. Disruption of food supply through changes in  hatching dates
               and/or growth rates.

                 a) Heavy mortality of food organisms  hatched too early  in
                      spring.  (Example:  mayflies hatched  in March unlikely
                      to survive or reproduce.)

                 b) Food organisms of suitable size no longer available  when
                      needed by predators (Example: Small  walleyes heavily
                      dependent on larval perch.)

                 c) Larvae induced to move into areas  not  rich in plankton.

          3. Interference with spawning activities  of  adults.
                 a) Block migration.
                 b) Fhysiol. trigger fails at too rapid rise.
                 c) Trigger missing if temp,  never  reduced?

       C.   Changes in species composition, through:

          1. Competitive replacement by spp.  more temperature tolerant

               Example: ?2F. optimum for Igmth bass, not  for trout

          2. Competitive replacement by creating  conditions more  favorable
               to growth and/or reproduction  of other spp.

               •Examples: longer growing season +  higher temp, might  caucc
                           alewives to reach  spawning  si'/.e at Age II instead
                           of III.
                         Longer growing season can provide opportunities for
                           more  spawning in one season (certain  spp.)
A. W. E.
-------
                                                       1795






                      Mrs. L. Botts




          MR. STEIN:  Mrs. Lee Botts.








              STATEMENT OF MRS. LEE BOTTS, OPEN




              LANDS PROJECT, CHICAGO, ILLINOIS








          MRS. BOTTS:  Mr. Chairman, conferees.  I am Mrs.




Lee Botts representing the Open Lands Project, a private




nonprofit conservation organization with offices at 53




West Jackson here in Chicago.  My chief responsibility on



the project staff is to serve as executive secretary for




the Lake Michigan Federation that has been organized as a




clearinghouse for conservation and civic groups in the



four States that border Lake Michigan.




          For this conference, as for the Illinois



Pollution Control Board hearings last week, I have been



authorized by the Project Board of Directors to urge that



the Department of Interior be supported in its effort to



protect Lake Michigan from possible thermal pollution.



This position was necessarily taken without consideration




of the lengthy and sometimes detailed and factual presen-



tations made here this week in opposition to the Interior




recommendation.  Yet after hearing most of the testimony




given this week and studying most of what I did not hear



in written form, I must still conclude that a strict thermal
-------
                                                       1796






                       Mrs. L.  Botts



standard is the only means now available to assure prevention



of damage from thermal pollution.  It is a danger I and



some scientists who have not been retained as consultants



to utility companies still consider the likely consequence



of use of Lake Michigan waters for once-through cooling in



the quantities required by nuclear plants and the large



fossil fuel plants now contemplated on its shores.



          This conclusion has been reached not so much



because of the strength of the Interior reports issued



in defense of its proposal as because of the weakness of



the alternatives offered by those who have demonstrated



historically that their chief aim is to produce electricity



as cheaply as possible regardless of the cost in natural



resources.



          Those of you who attended the Milwaukee meeting of



this enforcement conference last March will remember my



complaint then that the Federal Water Quality Administration



was a paper tiger in the way it confronted, that is, failed



to confront the need for a thermal standard.  I am in



sympathy with the power companies who have been allowed to



proceed with the building of their very expensive plants



without the guidance of a definitive standard applicable



to the whole lake and who are now confronted with the



tiger that is somewhat erratically but nevertheless charging
-------
                                                       1797
                      Mrs. L. Botts




at lasto



          Even so, I am glad the tiger is here.  I am even




more in sympathy with the public that is still being con-




fronted with the need for a decision without conclusive




scientific evidence and with conflicting and contradictory




assertions about the issues from scientists and other




technical consultants whose appearance here is financed



by vested interests seeking a standard that will impose




as little restriction as possible on their activities.




          In speaking here I have three purposes:  One is




to point out some of the contradictions and unresolved issues




that have been raised in the previous days of this conference,




and the second is to make available some pertinent expert




knowledge from independent sources in the public interest.



Finally, following these independent presentations I wish



to make a proposal for an alternative means of achieving



protection of the lake from thermal pollution which, if



accepted by the power companies, might indeed make it



possible to have our power and keep our lake safe, too.




          1.  The first question I would like to raise is




whether there is any contradiction in arguing that the



power companies only wish to produce electricity as




cheaply as possible in terms of direct costs for the benefit




of a public that is presumed to consider electricity
-------
                                                      1793





                      Mrs. L. Botts




paramount in maintenance of "the good life," and then denying




that public's right to question this purpose by terming it




hysterical.  Surely neither Dr. Edward Raney, in his professed




regard for human ecology (undefined), nor Mr. Brandt of




Consumers Power Company, in his labeling of an unconvinced




public as hysterical, would deny that it is the public, one



way or another, that will ultimately pay the cost of whatever




decision is made by this conference.




          I submit that the first duty of this conference,



the Department of Interior and the power companies is to



carry oat the public's desire„  As a member of the public,




I applaud the Department of Interior for acknowledging that




I would prefer to pay a bit more for my electricity each



month to make certain that my lake remains free of thermal



pollution.  I trust that those who would use the lake to



produce power would not deny that it is my lake and my



neighbor's lake and that of my fellow citizens in Illinois,



Indiana, Michigan, and Wisconsin rather than the property




of corporate interests whether they produce power, steel




or paper pulp.  This brings me to my next question.



          2.  All the discussion by scientists representing




utility interests this week has concerned demonstrating that




no damage would be done to the lake in terms of its present



condition, as if that condition were satisfactory for all
-------
                                                        1799





                      Mrs. L. Botts



purposes, except for a few complaints that thermal dis-



charges were receiving unfair attention when other sources



of pollution are more culpable.  I would point out that the



members of the public who are most concerned with avoiding



all possibility of thermal pollution are for the most part



the same persons who would seek to correct the damage being



done by other means, such as overloading with sewage, chemi-



cal wastes and so forth.  Further, I would point out that our



concern with the condition of the lake has been generated not



by our fellow, if you will, hysterical citizens but by your



fellow scientists and technical experts.



          Here in this very conference we have heard a



report from Jacob Dumelle suggesting that the quantity of



phosphates in the lake has been greatly underestimated.



          Repeatedly in public hearings and on other occasions



ever since the Stoermer-Yang report on "Plankton Diatom



Assemblages in Lake Michigan" was released last spring, I



have cited their conclusions in explaining my own fears about



the future of the lake.  As I said before the Illinois Board



last week, Stoermer and Yang state that the changes that have



already occurred in the population of planktonic plants and



animals indicates that the decisions made in the next 10



years or less will determine whether the life now in Lake



Michigan will become more like the present life in Lake Erie.
-------
                                                       1SOO





                       Mrs. L. Botts



          I have never heard this conclusion refuted.



Indeed I have never heard any part of the Stoermer-Yang study



disputed, unlike the controversies that have raged around



some of the scientific reports made by consultants to the



power companies.  Not only lay members of the public but



other scientists, some of whom fortunately have undertaken



to interpret the situation for the public, are worried.  I



would like to read briefly from an article prepared by Dr.



William Beecher, director of the Chicago Academy of



Sciences and member of the Open Lands Board, for the new



publication "Illinois Environment."  The title is "An



Ecologist Looks at Water," and he says:



          "I saw Lake Erie the year before it died.  With



Dr. Paul Ehrlich and Dr. Joseph Gamin, both then on my



staff, I visited Middle Island to collect for an experiment



on miteborne diseases a quantity of the watersnakes that



live on that limestone island .»..  At Middle Island more



than once we saw the big snakes swimming in from the open



lake with mud-puppies in their mouths, the amphibians known



to comparative anatomy students as Necturus.  It was a minor



part of the food chain.  I relate this because the following



year the snakes were not there.  The mud-puppies had died



off, mayflies had ceased to hatch and the whole food-chain



of western Lake Erie had collapsed.  The end had come with
-------
                                                        1301
                      Mrs. L. Botts




stunning suddenness — and all we had noted was an unusually




large amount of algae along the shores and in the small bays!




          "Of course it could happen to Lake Michigan!   The




clear, cold waters, teeming with splendid fish, noted by




Marquette and Joliet, are already clouded by the algal slime




that betrays a last-ditch attempt of the ecosystem to replenish




the oxygen used up by bacteria in combatting pollution. ...




          "Lake Michigan has two basins, separated by a high




ridge that runs between Milwaukee, Wisconsin, and Grand Haven,




Michigan.  The longshore currents come down the west shore



past Chicago and then tend to swirl around in the toe of the




lake, trapped by the ridge.  Sediments produced and deposited



by industry in this lower or southern lake basin tend to




accumulate on the bottom, perhaps to be periodically brought



into the surface waters in the spring and fall overturns of



the lake, due to warming and cooling of the top layers.  In



the fall of 1964 this may have happened.  I announced that



Lake Michigan had become a Killer lake when several of us



found 10,000 gulls and 2,500 loons dead on the Illinois,



Indiana, and Michigan shores.  The cause of the deaths of



these very tough birds was never determined but the mayflies



have ceased to hatch out of Lake Michigan, and last year




there was a die-off of inud-puppiec, some picked up on Oak



Street beach0  The warning flags are uo and I remember how
-------
                                                       1302






                      Mrs. L. Botts




quickly Lake Erie turned the corner!   But Lake Erie is part




of a broad river of lakes and can be  cleaned up by flow-




through once pollution stops.  Lake Michigan is a cul-de-sac



and the canal would be ineffective in saving its life if it



turns for the worse.1*




          It is unfortuante for the utilities, but the fact




remains that they seek to use a lake  that already needs




restoration in large areas, which brings me to my third




point o




          3.  Repeatedly testimony has been given this week




that damage to water quality by existing thermal plumes




cannot be demonstrated, with the Waukegan plume most




frequently cited.  My question has to do with the fact that



this discussion has been in terms of the present condition



of the lake in that area where relatively little life as



evidenced by fish or other biological signs can be found,



apparently either inside the plume or outside it.  No one



has attempted to assess the possible past role of heat in




relation, say, to the input from the North Shore Sanitary



District in bringing the lake to its present state there.



          When I have asked whether anyone has compared the




present ecological state to a previous one, I have been




told there is no baseline  data available from, say, 25 or  45



years ago or longer.  All  I know is that formerly there was
-------
                                                        1303






                      Mrs. L. Botts




a much greater commercial fishery out of Waukegan Harbor



than now and that this past summer almost all of the beaches



in the area were closed to the public as unsafe.  It is con-



tradictory to say that the future effects of heat will be



studied without attempting to assess its possible past role,



          My fourth point also has to do with difficulties of



field studies.



          4.  I have heard many references this week to the



difficulty of making judgments based on laboratory findings



without field experiences to confirm them.  I have also



heard this week Dr. Donald Pritchard's descriptions of



possible diffusion systems based on calculations derived



from mathematical modeling and the assertion that Dr.



Pritchard has proved that with a properly designed diffusion



system based on results of his calculations only a small



fraction of the lake's area will be affected by thermal



discharges from the nuclear plants.



          Is it not contradictory to reject some laboratory



findings of potential thermal pollution and accept Dr.



Pritchard's mathematical proofs of protection for most of



the lake with his mathematically-tested diffusion system?



And, considering the public ownership of the lake already



discussed above, who will have the authority to impound even



the very small areas Dr. Pritchard says will be needed,
-------
                      Mrs. L.  Botts




99 acres at Zion possibly, provided his calculations are




substantiated in application?   Finally, when and how will




actual field tests be made of  the system he proposes, to




determine whether, in fact, it is mechanically feasible and




the required engineering is achievable in Lake Michigan where




it would be needed?  In short, is it not contradictory to




reject some laboratory predictions and accept others?




          I have another quarrel with Dr. Pritchard, which




constitutes my next point.




          5.  Dr. Pritchard asserts that the money required



to build cooling towers would  be better spent for, for example,



sewage treatment plants.  Is he suggesting to Commonwealth




Edison that the money this company would have to spend at



Zibn to avoid discharge of heat be made available to the



North Shore Sanitary District  already mentioned?  Certainly



the need is there, and if this kind of tradeoff — a term I



learned in studying power production issues — is possible,



then I believe the public might find it worth considering.




          Unfortunately, our past experience leads to



believe that the money Commonwealth Edison saves by not




building cooling towers will be put to use by the company




for its own purposes unless, as already has happened in




Illinois, some public body like the Illinois Commerce




Commission directs otherwise.   I am among those who regrets
-------
                                                        ISO 5
                      Mrs. L. Botts



that we do not have a public body with the power to give



such directives in the present case, and remain convinced



that a strict thermal standard is the only means available



to protect the lake.



          Still another question has been raised by Dr.



Pritchard's presentation.



          6.  If Dr. Pritchard's recommendation for a



discharge system proves reliable, then how will the public



be assured that the best possible system will be used on



all nuclear plants discharging into the lake?  I am submit-



ting to you with this statement an updated fact sheet on the



existing and proposed Lake Michigan nuclear plants on which



the variations in discharge systems is apparent.



          The only instance in which a design of a discharge



structure has been substantially changed to my knowledge is



at the Donald C0 Cook plant near Bridgman, Michigan, where



the point of discharge was moved from 150 feet offshore



to 1,200 feet.  There the change resulted from public



protest to the Corps of Engineers about possible erosion



damage, not from the company's concern with Lake Michigan.



          Indeed, it is the Corps of Engineers that grants



permits to build discharge structures, and under its new



policy of implementation of the National Policy Act,



presumably applications for any new plants would be
-------
                                                       1306
                      Mrs. L. Botts



submitted to the Department of Interior and FWQA for review.



But what about these five plants where the discharge



structures are already under construction or are already



completed?  Under what authority will they be required to



make changes?  The Corps of Engineers has observers here,



but is not participating.  Are we to assume that the power



companies will voluntarily initiate needed action?



          I became interested in the methods of discharge



myself when I observed about a year ago that at the Point



Beach plant in Wisconsin the cooling water would be dis-



charged at the shore on the surface, in accordance with the



theory that Dr. John Ayers espouses about the means for



achieving most rapid dispersal of the heat into the water.



Yet I knew that at Zion the discharge would be diffused



700 feet offshore under water in accordance with the theory



now advanced by Dr. Pritchard.  When I asked the represen-



tative from the Wisconsin Power and Electric Company about



the difference, especially since the plants are both on the



same side of the lake although 200 miles or so apart, and



had been built by the same company, Sargent-Lundy, he talked



for 10 minutes and then said, "I guess I haven't answered



your question, and I have to say we don't know, that we are



proceeding according to our best judgment.11



          Well, I will have to say that I think it is
-------
                      Mrs. L. Botts




contradictory to reject the right of the Department of



Interior to proceed according to its best judgment and




still retain the right to proceed in that fashion as the




prerogative of power companies.  This discussion of the




possible need for change in plant design brings me to the




next point.



          7.  Is it not contradictory to assert the




impossibility and the economic hardship involved in changing




plant design during construction but before the plant is




being operated, and yet to assert that it will be feasible and



the power companies are willing to suffer the financial loss




involved in adding cooling facilities later, provided, of



course, it becomes necessary owing to proved damage to the




lake?  This leads me to yet another question.



          8.  How and by whom will the damage be determined?




By consultants to the power companies?  I am afraid that



will be unacceptable to those concerned about the possi-



bility of damage.  By the State agencies?  But we are already



confronted with the difficulty of separating the interests



of at least some State agencies and the power companies.




By the Federal Water Quality Administration?  I suppose



the outcome of this conference will indicate whether and




the extent to which the paper tiger has indeed changed its




stripes.  This question of authority to make assessments
-------
                                                       1303






                      Mrs. L. Botts



brings me to point number nine.




          9.  We have heard this week of Dr.  Edward Raney's




conclusion that with judicious placement, a large number of




nuclear plants could be operated on the shores of the lake




without danger, yet Dr. Raney did not tell us his criteria for




judging the sites nor who would do the judging for future




sites much less who will review the existing sites.  That




brings us back to the question of whether the power com-



panies will agree to change existing sites if they prove




unwise, and I am afraid the answer is obvious.



          One specific criterion has been mentioned this




week and that is that thermal discharge plumes should not




overlap.  In one existing case on the lake it has always



been a matter of concern to the conservationists that the



relationships of the Point Beach and Kewaunee plants only



5 miles apart on the same bay have not been assessed.  Who



will determine now whether their plumes will overlap and



assure us that something will be done about it if they do?




The question of assurance brings me to point number ten.



          10.  Mr. Kopper of the Indiana and Michigan




Power Company spoke of his company's assurance that no




injury will befall Lake Michigan and of their efforts not



to intrude on the environment through use of paint of a



particular color and proper design of the building.
-------
                                                      1809





                      Mrs. L. Botts




          Unfortunately for the public's peace of mind,




this is the company that installed a coffer dam that started




an erosion process the company's own geological consultant,




Dr. Jack Hough of the University of Michigan, said in an




open hearing would extend 20 miles down the shoreline unless




stopped.  Still more unfortunately for those particular




members of the public whose property was directly affected,




they had to resort to a lawsuit to secure replenishment of




sand on their beaches.



          I believe one of those property owners is present




today and I will leave it to him to tell you whether he




thinks sand-colored paint and low-lying buildings provide




adequate environmental protection at the Donald C. Cook site.




          11.  My last point in this series concerns a most



fundamental assertion that has been made repeatedly by




various spokesmen this week, and that is the statement that



the addition of heat from the nuclear plants might prove,



or some say would prove, beneficial to the lake.  Exactly



what is meant by beneficial has not been clearly defined.



          If it means that there will be even less trout




and salmon and more carp, I question how many members of



the public will agree, even if they can catch carp all




winter near powerplant outfalls.




          If it means an increase in total biomass, as
-------
                                                       1810





                      Mrs. L. Botts




asserted by Dr. Mary McWhinnie before the Illinois Board




last week, how does this equate with a denial that the




additional heat will accelerate eutrophication,  when the




first stage of advancing eutrophication is just  such an




increase in the total quantity of living matter  in a body




of water?




          Another suggestion has been made by Dr. Fred Lee




that addition of heat to the water might increase its




capacity to deal with pollution by increasing the rate of




chemical reactions.  Apart from the fact that I  am confused




as to how this increase is going to take place if Dr.



Pritchard is correct, shouldn't it be possible to confirm




this assertion by the finding of improved water  quality




near existing outfalls?  Yet we are told there is no dis-



cernible difference within a plume and outside it.



          In conclusion of this part of my statement, I



believe it must be obvious by now that at least  as many if



not more questions have been raised for me by this week's




workshop as have been answered concerning thermal discharges




and Lake Michigan.  In view of all the contradictory



assertions, is it wonder the public is confused  if not



hysterical?




          There is one point on which I find myself in




agreement with the power companies and their consultants
-------
                                                       l&Ll






                      MrSo L. Botts



who have appeared this week, as well as Dr. Philip Gustafson



of Argonne National Laboratory and others, and that is on



the lack of information about existing thermal discharges.



          It has seemed to me that not only are more facts



needed about effects of existing powerplants but that we



also need the judgment of independent scientists who are



qualified to advise us to their opinion about the probable



long-term results of using Lake Michigan for seven or more



large nuclear plants.  Finally, I believe that for the public



to make its decision about its willingness to bear the



greater direct costs engendered*by avoiding use of the lake



as a heat sink,advice is also needed by independent experts



about the cost of using cooling devices relative to the



benefits obtained,.  Thus I am happy to be able to introduce



two sources of independent information,,



          The first is Miss Edith McKee, a consulting



geologist, who has interrupted an almost completed study



of Traverse Bay to describe here the effects she has observed



of operation of the Big Rock Point nuclear plant there.



Her background and qualifications will be described by



Lowell Gomes, a member of the consulting firm with which



Miss McKee is associated.



          The second is Dr. John Bardach, a distinguished



aquatic biologist of the University of Michigan, who has
-------
                                                       1S12






                      Mrs. Lo Botts



come from Ann Arbor to serve as a consultant to the public.




          A third person, Dr. John Langura,  an economist,  who



had intended to make a presentation on the  costs of cooling




devices relative to the means of the companies to provide



them, has had to go out of town to attend a funeral.  His




presentation will be filed with you as soon as he returns.




          I have been supplied with an abstract of an




article by Dr. Beeton from the University of Wisconsin,




and copies have been given to the conferees.  Dr. Beeton




sent this material at our request because of the points




that had been raised during this week on whether there was



any difference between the inshore and offshore waters of




the lake, and I will read a one-paragraph abstract of the




same.   (See  Pp.  lSl2a-l&L2f)



          "Significance to the eutrophication problem of



inshore-offshore differences in nutrients and the



planktonic diatoms of Lake Michigan.



          "Many engineering studies dealing with water



supply, disposal of sewage, waste heat, and industrial




waste have been based upon the assumption that the entire




volume of Lake Michigan was available for dispersion and




dilution of the pollutants.  Recent studies have indicated,



however, that inshore waters in most areas of the lake proper




have different concentrations of phosphorus, nitrogen, and
-------
                               SUBMISSION OF PAPER

                AMERICAN SOCIETY OF LIMNOLOGY AND OCEANOGRAPHY,  INC.
                               33rd Annual Meeting
                             University of Rliode Island

                              August 26 - 29,  1970
NAME
        Beeton
Ruth
                                                                     Holland
                                              First
                                     Initial
             Last

CO-AUTHORS (If appropriate)   A. M. Beeton	

ORGANIZATION     Center for Great Lakes Studies, University of Wisconsin-Milwaukee

ADDRESS
                   Milwaukee. Wisconsin 53201
TITLE OF PAPER:    Significance to the eutrophication problem of inshore-offshore differences

   in nutrients and the planktonic diatoms of Lake Michigan.	^^^
                                                                        i
ABSTRACT (Approximately 200 Informative words.  Use attached sheet if necessary)!
       Many engineering studies dealing with water supply, disposal of sewage,
 waste heat, and industrial waste have been based upon the assumption that the
 entire volume of Lake Michigan was available for dispersion and dilution of the pollutants-
 Recent studies have indicated, however,  that inshore waters in most a**eas of the
 lake proper have different concentrations of phosphorus, nitrogen and Silica from
 offshore areas.  These inshore and offshore differences in the distribution and con-
 centration of nutrients are reflected in the distribution and abundance of planktonic
 diatoms and in the species composition of the Melosiras.  The present study was
 undertaken to further document inshore and offshore differences.  Samples were
 obtained by car ferry on a transect which ran across  Lake Michigan and Green
 Bay from Frankfort, Michigan, to Menominee, Wisconsin.  The new data substantiated
 earlier findings, and indicated in addition that there were differences between inshore
 and offshore waters  in Green Bay.
  »ge3ted Division;
          Environmental Enrichment
          Deteriorating Environment
          Natural Environments
          Other
DEADLINE:  May 15,  1970
               MAIL TO:
                           Projection Requirements;

                          	Vl/4" x 4"
                                  Overhead Viewer
                                                             Dr. I. E.  Wallen
                                                             Office of Environmental Science
                                                             Smithsonian Institution
                                                             Washington, D.C.    20560
-------
    OFF  MILWAUKEE
OFF LUDINGTON
I8l2b
                             27 May,  1970
         415
                          Fragiloria  crotonensis

                          Tabellaria  flocculoso
                          Stephanodiscus  hantzschii
                                                                                 MAP
   MILWAUKEE


Pig.  1.  Example of inshore-offshore differences in distribution of three species of diatoms in
Lake  Michigan.  Inshore samples were taken 3 miles off Ludington and Milwaukee, offshore sampling
locations were greater than 10 miles from shore (from paper by R. Holland Beeton and A.M. Beeton,
presented at 33rd annual meeting of the American Society of Limnology & Oceanography, Kingston,
R.I., Aug. 1970)
-------
     OFF  MILWAUKEE
                                           OFF LUDINGTON
       8001
I8l2c
                           STATIONS
,-ig. 2.  inshore-offshore differences in concentrations of silica, total Phosphorus and non-


I^S3ffiSSf±'^^
of Limnology and Oceanography, Kingston, R.I.-, Aug.
-------
                                              Made in United Stales of America
                                              nU'*! tioiu LIMNUI.O(;V ANp OcicANCXMiAi'i
                                                   Vol. 13, No. 3, July 1068
                                                        pp. 5S5-557
CORRELATION OF MELOSIRA SPECIES WITH TROPHIC CONDITIONS IN
                          LAKE MICHIGANI
  Certain  species  of  the  diatom  genus
Melosira have been associated with differ-
ent trophic conditions, that is, the degree
of  available  nutrient  supply.   Hustedt
(1945) has called Melosira granulata (Ehr.)
Ralfs the planktonic diatom most charac-
teristic  of  eutrophic waters in  Europe.
Melosira granulata and, to  a less marked
extent, Melosira ambigua  (Grun.)  O. Mtil-
ler  characterize strongly  eutrophic bodies
of water in Britain (Lund  1962fl). Melosira
bintlerana  Kiitz.  has  become one of  the
predominant diatom  species in  western
Lake Erie in the past 30 years (Hohn 1968),
while the waters of Lake  Erie have under-
gone accelerated eutrophication during the
same time  (Beeton,  in  press).  Melosira
islandica O. Muller is the  dominant diatom
in Great Slave Lake, which is considered
oligotrophic (Rawson 1956; Lund 1962b).
The distribution of these species in certain
regions of Lake Michigan appears also to
be correlated with trophic conditions.

                METHOD
  A Van Dorn sampler was used to collect
219  samples at 2, 5,  and 10 m from five
regions in  Lake Michigan  and southern
Green Bay (Holland, in  prep.).  The  di-
atoms were cleaned with nitric acid. After
most of  the acid had boiled off, the mix-
ture was  diluted  and  passed through a
0.45-/i membrane filter.  Diatoms were  ex-
amined at 970 X under phase contrast from
a portion of dried filter made transparent
with immersion oil. Each complete valve
was counted as one-half diatom frustule,

    DISTRIBUTION OF MELOSIRA SPECIES
  The  species  association  in  southern
Green Bay was  markedly  different from

^^Contribution No.  ijjfr Center for Great Lakes
Studies, University of \Vfscnnsin-Mi1waiikeo.
                                     those of the regions sampled in Lake Mich-
                                     igan  itself (Fig. 1).  The  flora of Green
                                     Bay was characterized by species that have
                                     been associated with eutrophic conditions:
                                     large numbers  of M.  granulata and sec-
                                     ondarily, M.  ambigua  and M. binderana.
                                     Although M.  Islandica occurred only occa-
                                     sionally in the  waters  of Green Bay, this
                                     species was  the dominant form  in Lake
                                     Michigan near  the  western shore and  in
                                     the open lake areas.  It was a codominant
                                     with M. ambigua near the eastern shore.
                                     Melosira granulata and M. binderana were
                                     seldom found in the lake.

                                                COLLATERAL DATA
                                       Collateral  data from the five sampling
                                     areas  provide  a comparison  of  relative
                                     trophic  differences.   Average diatom  con-
                                     centrations were higher in Green Bay than
                                     in the lake (Table 1).  Diatoms were more
                                     abundant in the ncarshore areas of the lake
                                     than in the  offshore areas, but  numbers
                                     were  about   one-third  greater  at  inshore
                                     Michigan than at inshore Wisconsin.
                                       Total and  partlculate phosphorus were
                                     considerably  higher in Green Bay than in
                                     the lake, while  average nitrate-N levels in
                                     the bay were  almost  three  times lower
                                     (Table 1), and at times were  not detect-
                                     able  (Allen 1966).  Presumably most of the
                                     nitrogen was  tied up in the plankton and
                                     little remained as nitrate. Beeton (in press)
                                     has established  that southern Green Bay is
                                     a eutrophic area.  Average  values for  total
                                     and particulate  phosphorus  near the Michi-
                                     gan shore were much lower than those in
                                     Green Bay, but were higher than those of
                                     the other areas  of the lake. Nitrate-N lev-
                                     els in  waters of inshore  Michigan were
                                     higher than those in Green Bay hut lower
                                     than nitrate-N  levels  in   other areas  of
                                     the lake.
-------
656
NOTES AND COMMENT
                                                                     	'	» Melnsira ambigun
                                                                     ——— Mnlor.irg (underarm
                                                                     —-.— Melosira granulate
                                                                     ___ MelOEira islandico
  Fio, 1.   Sampling location* and abundance of predominant species of Melosira (frustulea/ml) in
wnithern Green Bay and Lake Michigan, April into November 1065.
TABUI 1,  Avtnge poneentratiant of phoiphartu, nitrate, and total diatom*, April into November 1085,
and oaU volume and total btomau (tn parentheses)  of predominant speciet of Meloiira at ((me* of peak
abundance in touthern Green Bay and Lake Michigan,  (Value* of phosphorus and nitrate in pvb from
Allen J00fl;  diatamt in fniittiles/ml; cell  volume in n's total species biomasi in n'/ml.  A = absent or
                                          uncommon)

Tcrta] P
Dtemlved P
Particuthta P
Nitrote-N
Dlatomi
Af, fwibigittf

MI fc
-------
                                                                                                   I8l2f
                                 NOTES  AND COMMENT
                                       557
           TROPHIC SIGNIFICANCE
  The distribution of species  of Melosira
appears to reflect trophic levels:  eutrophic
conditions in  Green Bay, oligotrophic con-
ditions in offshore waters and  waters near
the  Wisconsin  shore  of Lake  Michigan,
and  intermediate conditions near the Mich-
igan shore.
  The size of the standing crop of Melosira
in the different areas  (Fig.  1) supports
the  above   conclusions.   Eutrophication
generally favors the  development of large
numbers of cells as well as the occurrence
of  large  forms or  colonies  (Findenegg
1965). Although M.  islandica at times had
a greater cell volume than the  forms which
have been associated with eutrophy, the
greater combined numbers  of  the latter in
Green Bay produced a significantly  greater
total biomass there (Table 1).  Thus, the
total biomass of Melosira was greatest in
Green Bay, least along  the western shore
and in the  open  lake,  and  intermediate
near the  eastern shore.
  Nalewajko  (1966)  reported  a  similar
phenomenon  of differences in  diatom  spe-
cies among regions in Lake Ontario. Melo-
sira  islandica was a predominant species of
the  central   lake,  while  Stephanodiscus
tennis predominated in  coastal areas,  sug-
gesting differences in  trophic  levels be-
tween inshore and offshore waters.
                       RUTH E. HOLLAND"
Center for Great Lake Studies,
University of Wisconsin-Milwaukee,
Mihvaukee   53201.

                REFERENCES
ALLEN, H. E.  1066.  Variations in phosphorus
    and nitrate in Lake Michigan and Green Bay,
    1063.  Paper,  Oth  Conf. Great Lakes  Res.,
    Chicago, 111., March 1066.
BEETON, A. M.  In Press.  Changes in the envi-
    ronment and biota of the Great Lakes. Proc.
    Intern.  Symp.  Eutrophication,  Natl,  Acad.
    Sci.
FINDKNECG,  I.   1065.   Relationship   between
    standing  crop  and  primary  productivity.
    Mem. 1st. Idrobiol, 181 fiuppl, 271-089.
HOHN,  M.  H.  1068,   Majpr changes  in  the
    plankton  diatom flora  of  the Bass Island
    region of  western  Lake Erie,  1038-1065,
    Paper, llth  Conf. Great Lakes  Res.,  Mil*
    waukee, Wise., 18-20 April  1068.
HUSTEDT, F.  1045. Pie  Diatomeenflora nord-
    deutscher  Seen mit besonderer Berticksicht-
    igung des holsteinischen Seengebiets.  Arch,
    Hydrobiol., 41«  302-414.
LUND,  J. W.  G.   1062o.  Phytoplankton  from
    somo lakes  in northern Saskatchewan  and
    from Great Slave Lake.   Can. J. Botany, 401
    1400-1514.
	. 1062b.  The periodicity of Meloiira (•-
    landica O. Mull, in Great  Slave  Lake.  J,
    Fisheries Reg. Board  Can., 19i 801-504.
NALEWAJKO, C.   1066.   Composition of phyto-
    plankton in surface waters of Lake Ontario,
    J. Fisheries Res. Board Can.. 231 1715-1705.
RAWSON, D. S. 1056.  Algal indicators of trophic
    lake types.  Limnol. Oceanog., li 18-25,
  "Mrs. Alfred M. Bee ton.
-------
                                                      1313






                      Mrs. L. Botts



silica from offshore areas.  These inshore and offshore



differences in the distribution and concentration of



nutrients are reflected in the distribution and abundance



of planktonic diatoms and in the species composition of



the Melosiras.  The present study was undertaken to



further document inshore and offshore differences.  Samples



were obtained by car ferry on a transect which ran across



Lake Michigan and Green Bay from Frankfort, Michigan, to



Menominee, Wisconsin.  The new data substantiated earlier



findings, and indicated in addition that there were



differences between inshore and offshore waters in Green



Bay."



          We are grateful to Dr. Beeton for making this



information available to the public interest.



          Now, I would like to introduce Dr. Gomes, who



will introduce Miss McKee, who has slides and materials



relative to her findings in Little Traverse Bay.



          Then, with your permission, I would like to



read into the record Dr. Bardach's recommendation, a



statement he made regarding the potential for heat input



to Lake Michigan and Dr. Bardach himself is present to



answer questions about his statement.



          Mr. Gomes.
-------
                                                     1814





                           L. Gomes



               STATEMENT OF LOWELL GOMES, SENIOR



               ASSOCIATE, THEODORE S. LEVITON &



                ASSOCIATES, CHICAGO, ILLINOIS








          MR. .GOMES:  .1 am Lowell Gomes.  I am a Senior



Associate with the firm of Theodore S. Leviton & Associates,



at 203 South LaSalle Street, Chicago.  One of my projects



has been to coordinate our firm's various research efforts



concerning Lake Michigan and the other Great Lakes, and



I am here to present my firm's general viewpoint on the



thermal standard question.  Miss Edith McKee, our Chief



Geologist, will present the specific findings to date,



following my presentation.



          We are in favor of a responsibly moderate approach



to this problem.  We realize that the importance of keeping



the lake as an unspoiled natural resource must be balanced



with the necessity of increased power generation by non-



fossil fuel means, both to ensure adequate power and to



reduce air pollution.



          We maintain that, because of the exigencies of



the situation, we must take a very practical approach:  one



that utilizes to the fullest any existing hard information



on the lake from whatever source obtainable.  It would be



nice if we had great amounts of scientifically exact data
-------
                                                       1815




                      L. Gomes




stretching back decades, covering all parameters measuring




lake quality.  We don't have this data,  at least for the




most part.  But this does not mean that  no information




exists; rather it indicates that we must look more deeply




and more broadly than we have.




          Our research shows that it is  grossly misleading




to speak of the lake as a whole; it is only slightly less



deceiving to divide the lake up into "the open lake" and




"the inshore lake."  We maintain that the ecological and




environmental effects of discharging heated water at any




particular site can be accurately assessed only by complete



study of the site in question.  It is dangerous to attach




unmerited significance to results of isolated laboratory




study or to conclude with any degree of finality from one




or two studies of existing thermal intrusions that such



interference is not dangerous to the Iake0  Models and



laboratory studies eliminate many variables that exist in



nature; studies conducted at other sites are bound to



involve variances which may make the conclusions inapplicable



to other sites.



          Cross-disciplinary efforts are necessary to help




eliminate the effects of insufficient data and of conclusions




based on studies which exclude important parameters.  We




have attempted to do this by taking a hard geological look
-------
                                                       1316





                      L. Gomes



at the whole lake in general, and at Little Traverse Bay



in particular.



          There has been considerable testimony on



biological, biochemical and meteorological aspects of the



thermal problem, but very little has been mentioned of the



geological impact, a gap we will attempt to plug.  Beyond



this, we have interviewed responsible long-time residents of



the Little Traverse Bay area and have questioned them con-



cerning changes they have noticed.  While a beach-side



resident may not be a qualified biologist, he certainly is



competent to observe when the water washing  up on his



land was clean, when he first noticed significant algae



growth, or when he no longer was able to see the bottom.



With no conclusive historical scientific data in this area,



we cannot ignore this sort of observation without violating



our responsibilities to preserve the lake as a natural



resource.



          Our research on the lake generally, and on Little



Traverse Bay in particular, enables us to reach some



tentative  conclusions which lead to the following recom-



mendations:



          1.  That   1-year studies of any heated discharges



are not sufficient to detect significant trends, even



locally, that will predict long-term effects on the quality
-------
                                                      1&L7





                      L. Gomes



of the lake.



          2.  That it is not prudent to assume that we can



permit heated discharges to approach the projected 19^0



levels, without risk of serious effects.



          3.  That the number of powerplants allowed to



use lake water for once-through cooling must be severely



limited until long-term studies are completed on existing



plants•



          4,  That long-term or perhaps perpetual studies are



needed at each site to monitor and determine effects of



thermal discharge on the ecology and the environment.  These



studies should be made by governmental and other agencies



as well as by the power companies.



          5.  That such studies should be cross-disciplinary



and that they should be of a scope and depth which will



allow the gathering of data from all available sources.



          6.  That more extensive work in several scientific



disciplines, including lake geology, should be incorporated



into site location studies and planning.



          7»  That any harmful effects of thermal discharges



may be significantly lessened by consideration of geological



factors.  This would be primarily of use before site con-



struction.



          30  That a 1-, 3-» or 5-degree temperature
-------
                      L» Gomes




standard would not necessarily be sufficient to protect




the lakei as well as presenting enforcement problems.




          9o  That the standards pertinent now are necessarily




qualitative rather than quantitative; thus the laws promul-



gating these standards should be framed to implement this




idea of quality-oriented standards.  The measured effects



must be legally interpreted in each case.




          10.  That if new powerplants are allowed to  come



onstream, they may do so only with the written and legally




enforceable understanding that they may be required to alter




or terminate their usage of lake water for once-through




cooling  if sufficient harmful effects are detected.




          The specific research on the lake in general and



Little Traverse Bay in particular will be presented by Edith



M. McKee, Certified Professional Geologist, and the Chief



Geologist with Leviton & Associates.  Miss McKee has an



unique, varied and in-depth knowledge of Lake Michigan



gained over 27 years of professional and personal experience




with the lake that gives her a valuable overview of scientific




knowledge tempered with great personal involvement,  A back-



ground brief is attached to the outline of her presentation.




I would add here that her presentation is printed only in




outline form due to the shortage of time available to




formulate this information; Miss McKee only returned from
-------
                                                        1819
                     E. M. McKee




her research at Little Traverse Bay this Tuesday.  Although




the Little Traverse Bay study is not finished, several new




factors will be presented from the study that previously have




not been adequately considered.




          Miss McKee.








          STATEMENT OF EDITH M0 McKEE, CHIEF




          GEOLOGIST, THEODORE S. LEVITON &




            ASSOCIATES, CHICAGO, ILLINOIS








          MISS McKEE:  I am Edith M. McKee.  I am a geologist




with 27 years of diversified professional experience with the



U0S.G.S. and industry in inshore and offshore, surface and




subsurface exploration and development programs in the



United States and foreign areas.




          Since 195$, I have worked as a consulting geologist,



currently acting as chief geologist for Leviton & Associates



of Chicago.  The Illinois Geological Society has certified



me as a qualified professional geologist.  The American



Institute of Professional Geologists has awarded me the title




of certified professional geologist, based on detailed




examination of academic training, specialized training,




geological experience, and ethical conduct.



          My area of special interest is the integrated
-------
                                                        1820






                        E. M. McKee




mapping of surface and subsurface geological structures,




tectonics, stratigraphy, georaorphology, and paleogeomorphology



as they relate to mineral accumulations and land use.  Water




is a mineral and an erosional depositional force and within



the geological area of concern.




          The Chicago area has been my family base for several




generations.  Since the 1890's, family vacations have been




spent in Bay View, Michigan, located on Little Traverse Bay




at the far northern end of Lake Michigan.  Petoskey, on this




large map at the head of the room, is located on Little



Traverse Bay.  Bay View is one mile east — a short walk.




          While not a member of the 1890 vacationers, I



have had a long established interest in the entire lake.



Since 1932, however, I have been intimately familiar with



the waters of Little Traverse Bay as a distance swimmer,



boater, fisherman, and summer resident.  Since 1938, I have



known the Little Traverse Bay shores, basin, and waters as



a trained geologist.  Except for the summers of 1947» when




I was working for Shell Oil  in Texas, and 1950, 1952, and




1953» when I was working for Aramco in Saudi  Arabia, I



have been able to visit Little Traverse Bay for at least




short periods each year since 1932.



          Since 1967, I have been engaged in an ongoing



program to map in detail the bottom terrain and associated
-------
                                                      1821






                        E. M. McKee




geology of the Great Lakes.  Lake Michigan was the first




lake study.  This summer has been spent studying Little




Traverse Bay and the north basin of Lake Michigan.  Indeed




I was called off the U.S. lake survey's research vessel,




Shenahen, this week to attend this meeting and will have




to complete the survey late this month as the snow falls




out there along with the temperatures.




          Water quality — last Saturday I was out, we got




two stations and had to come back in.  We were standing




on our ears.  Sleet was coming down at the same time.



Water quality, currents, ecological and geological data




obtained since June 1970 are relevant to the thermal




pollution concerns of this meeting.  In fact, I feel a



little bit of an outsider having visited and worked with




the site of the only nuclear plant operating on Lake




Michigan0



          The only place in Lake Michigan where the effects



of the thermal plume  from a nuclear powerplant can be



studied is Little Traverse Bay at the far north end of




the lake.  The Big Rock nuclear plant is located northeast



of Charlevoix on Big Rock Point which makes an abrupt




eastward trend of the shoreline to form the southern shore




of Little Traverse Bay.  This bay extends eastward for



14 miles.
-------
                                                      1322






                      E.  M.  McKee




          East-flowing surface currents carry the thermal




plume from the Big Rock nuclear plant along the south



shore toward the head of the bay.




          There has been an  unfortunate attitude that




Little Traverse Bay is too small and the water is too cold




to afford critical data concerning lake circulation and




water quality.  This is not  a valid assumption.




          Both Little Traverse Bay and the south basin of



Lake Michigan are partially enclosed basins with consider-




able-topographic relief and similar geologic formations.



Both have well established currents throughout the water




column going at different directions.  Both are scheduled




to receive slightly more than one and a half million gallons



of heated water for each square mile of surface water every



day from nuclear powerplants.



          Little Traverse Bay has been receiving this



heat input since 1963> and negative changes in the water




quality appear to be accelerating since 1964*



          Now, to get down to the presentation of the




geological materials developed since 196? and including



the work done this summer, we will start the slides here




and I will quickly talk, trying to go as fast as possible




here.



          When I took these pictures to Earth Day programs
-------
                                                      1323





                      E. M. McKee



at a number of high schools in this area, the question was



always asked:  How many years ago did you take a picture



like that?  The water at the north end of the lake is still



blue on a bright summer day.  Inshore it is cloudy.  There



is algae beginning to come in, but you can still see the




beautiful picture.



          If you would please run these through —



apparently this isn't working — if you would please run



these though at a steady rate of about a second per —



this is the offshore picture.



          Now, this series of maps is called paleogeo-



morphic.  It shows the entire development of the Great



Lakes region.  This is part of the 196? study that covers



600 million years of development of the Great Lakes area.



Each one of the maps in this series extends from north of



Lake Superior to south of Tennessee; from Iowa to the



eastern seaboard, New Jersey.



          How do we put these together?  We still have



today in the world active volcanoes pouring out lavas.



This is a picture of a lava field in the Belgian Congo.



          This is a recent crater in the Philippine



Islands.  We can go to places — geologists can — and



know what happened even that long ago0
-------
                      E. M. McKee




          The waters came and the waters went.  For most




of this time, this part of the new continent has been




covered by a shallow warm salt sea.




          This is in the Persian Gulf where we have sand




spits built up.  The same thing we can find in the subsurface




now in this area.




          Gradually the Michigan Basin, of which most of




the lakes except Superior are evolved, was surrounded by



the coral.




          As they go through, you can see there is a change




in the water — I mean the sea and land relationships.




Gradually the seas drained off.  We had enormous rapid




chemical erosion, physical erosion, because there were no




plants on the land surface.  We have the same thing today



in the desert areas in the middle east.



          This series is taken over in SaudJ  Arabia, but



it is the same type of terrain which I can map in the



subsurface, and all of these have importance on the whole




economic program, the whole use of this region.




          After about 300 million years of this rapid



erosion, we had developed a circular pattern with the




center of the Michigan Basin about Saginaw.  The hard




rocks stood up as ridges around the edge; the soft rocks




had been eroded.  It was at this time that the major basins
-------
                      E, M. McKee



for the Great Lakes came into existence.  It is this type



of topography, subaerially eroded, that we are finding in



all of the Great Lakes.  In many places, it is covered by



modern sediments, post glacial sediments.  I believe Dr.



Collinson talked about that sometime at this meeting.



          It was on top of that topography that the



glaciers came down.  It did not scour the basin.



          We will now go on up to the lake again.  It is



always fun to get offshore.  In order to know the lake



basin, in order to know the amount of water in the lake



basin, you have to know in detail the shape of that basin.



There is onshore geology; there is offshore geology.



          Now, this is a picture of the bottom of Lake



Michigan, which has been developed through this on-going



study done in cooperation with Dr. J. L. Hough at the



University of Michigan.



          The Mid-Lake High is a 200-foot barrier rising



from the bottom dividing the north basin from the south



basino  The area of the south basin is very much restricted.



It goes down to better than 500 feet on the south end but



nonetheless it is comparatively small.  The Mid-Lake High



has a 200-foot vertical cliff on the north side.  The



darker colors indicate the deeper waters.



          As you can see, the deepest hole goes up southwest
-------
                      E. M. McKee



of Frankfort.




          This is an enlarged portion of the Mid-Lake High



which in the Chicago area is particularly important because



this is the big barrier that controls the curents within



the south end of the lake and, even as we will see later,



controls the surface currents.



          And this is up at Bay View.  The cliff here is



Traverse limestone.  It is exactly the same geological



formation.  It looks exactly the same — because we had a



submarine and went down and looked at it — as the western



cliffs of the Mid-Lake High off Milwaukee.  It reacts in



the same way.



          This is called a fence diagram.  It was con-



structed from the oil well records in Michigan; the water



well records in Wisconsin.  We had dredged the samples0  We



knew bedrock outcrops in the bottom of the lake.  This is



the first time that we have been able to project accurate —



well, with reasonable accuracy — the geology beneath the



lake basin.  This is of importance because of the input of



ground water at some of the contacts that we will see later.



          This is a bedrock geology superimposed on the



topography of the lake.  We will be interested in the



yellow-green, at the moment, which is the Traverse forma-



tion, and the blue-green outside of this.  Little Traverse
-------
                                                       132?






                      E. M. McKee



is up at the extreme end, just above the legend.  It is at




about a third across the bay that we have this contact




between the yellow-green — the Detroit River — and the




blue-green.  It is along this contact that we have a series




of artesian wells input of water 39 to 41 degrees instigat-




ing and carrying out year-round west-flowing bottom currents,



          We have the same juxtaposition of geological




formations off of Milwaukee.  We have the Detroit River



formation recognized onshore.  We have the Traverse forma-




tion in the Mid-L^ke high.  It has not yet been determined



if there is ground water input along that to increase the




current flow or not0



          Back up in the north country again.  This is the




head of the bay in the sag between these two geological



formations.  The sand has moved in — dune sand*  It is



very permeable.  Any building back there where they have



had septic tanks, the drainage has been directly into the



bay.  That is now controlled.



          At the far southeast corner of the bay for many



years there was a cannery, and I remember that distinctly




because, as a swimmer, I would head over towards Harbor



Point which was 3-and-a-half miles away, and as I would be




swimming along, I would know where the currents were; I




would know where I would suddenly be swimming in 70-degree
-------
                      E. M. McKee




water and suddenly down to 40-degree — you know that»




There is no doubt when you hit it.




          This is a picture of Harbor Springs, one of the




best natural harbors on the lake.  It has been developed



along this geological contact between the Traverse and the




Detroit River.  There are springs in this harbor.  It has




deep enough water to take — well — some of the largest




boats that come in.




          This is one of the big cement boats that took



shelter in there this summer.




          Right off Harbor Point, the currents flow eastward




into the bay so strongly that they keep the point cut



sharply, but there is a bottom current that flows so strongly




to the west that it takes out the fishing nets.



          All of the weather in Little Traverse Bay comes



from the west.  There are a few days when it will come from



the east, but that is most unusual.  You will remember that



Big Rock Point is located approximately 14 miles west of




where this pier is.



          The plume from Big Rock is held quite close to the



shore and moves along at a good rate.  When we get a storm




such as this was a few weeks ago, it stirs up the bottom,



but it also tears up the algal growth that has come in.



          When I knew the bay as, say, just a swimmer, until
-------
                      E. M. McKee




the early sixties, there was no algal growth on the rocks.




There was no algal growth on the bottom.  Now, when waves




come over on the dock, there is so much vegetation,algae




that has been torn up that the dock itself is green.  You




can rake up the piles of algae.




          Just a few years ago, as I say, about 1962, the




waters were clear, such as this.  You could see down 50




feet very easily.



          This summer, only twice have I been able to see




the bottom off the Bay View dock.  If we had the lights off




I think you could see that there, is enough algae contained




within the shore waves this summer so that it looks like




a vegetable soup.  This growth of algae has been noted by



people familiar with the area, one of them being — I




don't quote everybody that I talked with up there, but I




will quote Edison Tanner, who is a real estate salesman



up thereo  He lives directly on the bay about 2 miles west



of here toward Petoskey and toward the nuclear plant.  He



moved there in 1962.  At that time, there was no growth




on the bottom.  In 1969 —



          MR. FETTEROLF:  Excuse me a moment.  Where were




these photographs taken?




          MISS McKEE:  Little Traverse Bay.



          MR. FETTEROLF:  Where?
-------
                                                      1330
                       E. M. McKee



          MISS McKEEs  At Bay View, Michigan.  The dock I



have been showing is the dock at Bay View, Michigan,  which



incidentally —



          MR. FETTEROLF:  Which is downcurrent from



Petoskey?



          MISS McKEE:  That is right.  It is east of



Petoskey 1 mile.  And, incidentally, the dock which is



shown on the current U. S. Lake Survey charts went out with



a magnificent form in 1927.  The current dock at Bay View



was built in 1934-1935 and I am not sure if this indicates



that — the Lake Survey and Corps of Engineers have not



been in there since — but if you try to dock at the old



dock, you are going to have to go about 20 feet down.



          MR. STEIN:  May I reiterate that I have at



least 37 more speakers listed, and we want to hear every-



one.  So I ask you and everyone who speaks to recognize



time is limited and to give consideration to those people



who are waiting to follow you.



          MISS McKEE:  I will try to go as quickly as



possible.



          This summer, I have been gathering information —



I have seen the water quality — as I am a geologist, I am



not a biologist — but this summer, the University of



Michigan ship, Inland Seas, has been based at Harbor Springs.
-------
                                                     1831





                      E. M. McKee




They have had a full series of biological tests they have




been making off Nine Mile Point, which is a few miles east




of the Big Rock plant.  Also the Corps of Engineers Lake



Survey research vessel Shenahan has been based at Mackinaw




City making a 2-week run around the north end of the lake,




making water quality studies.  They also have a station off




Big Rock and possibly Nine Mile, and it is this ship which




is coming into Little Traverse to make my own surveys




there.




          I have pinpointed where the very cold bottom



waters come in through the bay.   It climbs naturally out




towards the big lake in a westward flowing current




naturally.  There are compensatory east-flowing mid-depth



and surface currents which take the warmth from Big Rock



directly along the shore.




          Fishermen again.



          I will quickly go through a lot of these.



          There was, for the first time that has been



recorded,actual scientific work going on in the bay this



summer.




          This, going in with the currents and showing



how they follow the bottom topography, ties in with the




study of Lake Superior I did last summer.




          Here again is the bottom topography,,  This is
-------
                                                     1332




                     E. M. McKee




why six geological provinces were noted.




          Now, this is taken from a drift bottle study




made at Marquette University, and the currents which were




indicated here followed the topography, the bottom




topography very much indeed, very closely.  I won't go




into how these things are made, but they are very well




documented.




          We will now come down to the currents in the




entire Lake Michigan area.  These are the currents without




topography.  As you will see, there is a division about



Milwaukee.  These are the bottom currents.  These currents




have been adopted directly from government reports.




          We will now put the same current patterns over



the bottom topography.  It is easy to see how the Mad-Lake




high, the 200-foot barrier, influenced the very bottom



currents, the mid-depth currents, and even the surface



currents.  They are all put together here and they all



tend to have a general pattern.




          We have our air pollution, and fading away into




the sunset, as any good travelogue does, at the moment.




          But this is accurate scientific work available




in Little Traverse Bay, in other areas.  It can be docu-



mented — the changes that have occurred since 1963 — whon




the Big Rock plant went into operation.




          Thank you.
-------
                                                      1333
                       E. M. McKee



          MR. STEIN:  Thank you, Miss McKee.




          MR. CURRIE:  May I ask a question, Mr. Chairman?




          MR. STEIN:  Well, I don't know.  Mrs. Botts, do




you want to handle this?  Do you want questions now or




after you complete your presentation?




          MRS. BOTTS:  Mr. Stein, I have spoken to Dr.




Bardach, and he is willing to let the public officials —




you told us were waiting to speak — speak now.  He would




be glad to do that, and then he would go ahead with his




presentation.



          As to whether Miss McKee answer questions now




or later, it makes no difference to us.  I will leave that




to youo



          MR. STEIN:  We will take the questions from Miss




McKee.



          MR. CURRIE:  Miss McKee, have you found any



evidence of harm caused by heat inputs in Little Traverse



Bay?




          MISS McKEE:  There has been decided erosion of



water quality in Little Traverse Bay.



          The visibility has dropped to nil.  Most of the




summer — only twice this summer have I been able to see




the bottom clearly from the Bay View dock, and it would




be only about 12 feet down.
-------
                                                      1334





                      E.  M. McKee




          This has been remarked upon by boaters, by




fishermen, by long-time residents.  There has been one




thing about the distinctive qualities of the Big Rock plant




put into a chart, I believe prepared by Open Lands — if




I am not in error — that the Big Rock had the coldest




waters of the lake.




          This summer I have  kept temperature records of




Little Traverse Bay June, July, and August, and from July




they have been consistently and even up to nine points




higher than the temperatures  reported here at Chicago.




For the first time, this summer the waters got up to 75.




As I say, usually up there if the water hits 6$ it was good



swimming.  At 70, it felt too warm; and this year, it was



over 70 for the entire month  of August.  Whether this is



due to the plume or not, it hasn't been coordinated in



with the biological and water quality studies.  But there



are indications that there has been definite and acceler-



ating degradation of the water.



          MR. CURRIE:  I think my problem is, as you




recognize, one of causation*   There are many areas of



the lake in which considerable degradation has occurred,




and a number of different paranefcers of water quality have




changed, and I wonder if there is any way that we can move



along toward identifying which of the changes is responsible
-------
                                                     1335





                      E. M. McKee



or which group of changes is responsible for the changes



we see.



          Do you know, for example, that nutrient content



of the water is unchanged and the only change has been



heat and therefore there is a causal relationship between



heat and degradation?



          MISS McKEE:  The input of sewage effluent has



been cut.  In 196 5» the Bay View summer resort, by order



of the government, stopped its own sewage  plant and



switched into the treatment plant in Petoskey.  There have



been several other resorts which have done the same thing



so that the sewage input has been cut.  There has been a



comparatively stable population.  There are no farms and



no, say, kept lawns or parks along the lake that would



add to the fertilizer input.  The streams are comparatively



shallow which go into the lake because of the pitch and



slope of the geological formations which are responsible



for the bay being where it is.  The color of Bear Creek



which comes in at Petoskey is a deep brown; that is tannic



acid from the cedar swamps, but even that is a very short



rate.  The only major change that we have been able to



recognize since the early sixties in the way of downgrading



the water is the heat input.



          MR» CURRIE:  And you say that phosphate and other
-------
                                                     1836
                     E. M. McKee




nutrient inputs to the bay have been decreasing.  Is it




also true that phosphate concentrations in the bay itself




have been decreasing?  I take it that as long as you keep




putting any new nutrients in there is a possibility that




concentrations will continue to increase even though the




rate of input has decreased.




          MISS McKEE:  That I do not know.  I have been




working with the geology.  I am leaving the water quality




up to the Lake Survey people whose job it is.




          MR. CURRIE:  Do you know whether the water




quality problems are worse within the plume from the Big




Rock plant than elsewhere in the bay?




          MISS McKEE:  Unfortunately you caught me with



my plume down!  That is part of the work which has to be



done when I get back up there.  As a matter of fact, I was



scheduled to be mapping on Tuesday, instead of coming



down here.




          MR. CURRIE:  Does the study that you are under-




taking have biologists factored into it?




          MISS McKEE:  I am told it can.tie in with the



biological studies done this summer by the University of




Michigan, and they had the Inland Seas based at Harbor



Springs from May through August.




          MR0 CURRIE:  Thank you very much.  I think that
-------
                       E. M. McKee




this kind of study which you are undertaking is exactly what




we need to help us with this kind of very difficult decision,




          MISS McKEE:  Well, that is one of the big points




that we make —that we have to have cross-discipline




studies.  You can't have it just from the biological, just




from the geological, just from industry, just from city




point of view,



          MR. FETTEROLF:  Miss McKee, I too have been very




fortunate in having had a great deal of experience in Little




Traverse Bay.  We had a summer home at Wequetonsing prior




to World War II, and it was my intrigue with the water at




that time that led me to become a biologist.




          Now, I would like to ask you if you have traced




the heat input from the Big Rock plant along the shoreline




of Lake Michigan?



          MISS McKEE:  I have taken some temperature



readings, but not as complete as it will be after I have



had the Shenahan in, which is equipped with electronic



equipment of all sorts including the electronic thermo-



graph.




          MR. FETTEROLF:  What is the draft of that boat,



ma'am?




          MIG3 McKEE:  The Shenahan, I think, is 4 feet.




          MR. FETTEROLF:  I hope you'will be able to get
-------
                       E. M. McKee




into shore close enough to measure plume.   We have done




extensive work in that area both prior to  the construction




of the plant and after in relation to radiation monitoring,




and we have mapped the plume on many occasions.  We do not




find sensible heat beyond a mile from the  plant along the




very inshore areas.  We do note Cladophora and green algae




growing on the rocks occasionally in the area of the plume,



but we relate this more to the fact that the plant has an




on-site water treatment facility than to the addition of



heat.




          As far as collecting Cladophora for radiation




sampling in the area of Big Rock, we find it extremely




difficult and we are forced to go to the spits of land on




which the gulls perch and fertilize the lake, and that is



the only place we find Cladophora.



          Now, I agree entirely that the clarity of the



water in Little Traverse Bay has decreased tremendously



over the years0  I believe that we would relate this to the




discharge of treated sewage from Petoskey and from Harbor




Springso  Both of these wastewater treatment plants are



under order from the Water Resources Commission to cut



their phosphate loadings in accordance with this inter-




state conference's decree.




          MISS McKEE:  Good.  I know both Petoskey and
-------
                      E. M. McKee



Harbor Springs are in the throes of putting in new sewer




systems to take care of all of the communities, summer




and winter, on both sides of the lake.  But this is the




type of input where the geologists and the biologists and




the physical chemists, physicians, etc. should get




together and discuss it.



          MR. FETTEROLF:  I think you would find that long-




term temperature records for the bay would be available from




the water intakes of the communities around the bay.



          MISS McKEE:  Good.  You are the first one who has




known that.  I have been asking this summer at every com-




munity and nobody has known of any records that have been




kept.




          MR. STEIN:  Are there any further questions of



Miss McKee?




          Thank you, Miss McKee.  I knew you were my kind



of biologist-- the kind that would be possibly caught with



their plume down!  I knew that when I read your bibliog-



raphy.  Anyone who has written an article entitled, "Are



All these Dry Holes Necessary" is great!



          At this time, we would like to hear from



Congressman Mikva,
-------
                     Hon. A.  J.  Mikva








          STATEMENT OF THE HONORABLE ABNER J.




           MIKVA, U. S. HOUSE OF REPRESENTATIVES





                      WASHINGTON, D. C.







          MR. MIKVA:  Mr. Chairman,  members of the panel,




I would like to strongly urge you to follow the Department




of Interior   recommendation  that "...  no significant dis-



charge of waste heat into Lake Michigan should be




permitted."  The great lake is not and  should never be



considered an industrial dumping ground.




          If there is any single issue  before this four-



State enforcement conference, it is not whether industry




must pay more or less for stopping its  pollution but



whether, in the future, the lake itself will be used



primarily for the profit and exploitation of industry



or whether it will remain a great natural resource of



the people.




          The people who live along its shores will quickly




tell you that Lake Michigan is their lake.  They swim in




it, boat in it, sun bathe on its shores, fish in it, drink



its water,,  At least they used to be able to do all those



things.  Its presence has given their residential neighbor-




hoods a distinctive quality.  If the temperature of the
-------
                                                 1341-1843
                     Hon. A. J0 Mikva
lake rises and the death of the lake accelerates and the
salmon leave and the lake trout go away and the beaches
become clogged with dead alewives and algae and the bacteria
count in the drinking water rise, then the quality of life
for the people along its shores will change.  A Chicago on
the bank of a dead lake is a different Chicago, and probably
a dead Chicago.
          Our Government must begin to care about the
quality of life of its individual citizens as much as it
cares about the prosperity of its corporate giants.  This
conference is a good place for that caring to begin.
          Experts have been produced by both sides arguing
for or against the damaging effects of heated discharge
water on the life of the lake.  No definite answers have
been found.  Commonwealth Edison has argued that heated
wastewater will damage plant and marine life but the
damage will be minimal.  Environmentalists, on the other
hand, have argued that heated water discharge from nuclear
powerplants will do irreparable injury.
          Dr. Wesley 0. Pipes, professor of civil engineer-
ing and biological sciences at Northwestern University,
has informed me that he believes it would be impossible to
find any group of scientists qualified to carry out a study
of thermal pollution who would also be completely objective
-------
                     Hon. A.  J. Mikva




about the interpretation of the data due to the present




public concern and polarization about water pollution.




Last weekend a biologist testifying before the Illinois




Pollution Control Board argued that more data on thermal




pollution would be needed before "realistic and meaningful




limits" could be set on heated water discharges.




          When expert confusion abounds in such situations




involving the public good and the quality of life, then




government agencies should err, if err they must, on the




side of the people, and place on polluters the burden of




proving beyond any doubt that their discharges will cause




no injury.  Indeed the watchword ought to be:  not in the




lake unless you can prove beyooa  a reasonable doubt that




it will not adversely affect the lake.



          I am not an expert on the technical aspects of



thermal pollution.  I represent the interests of the people



in my congressional district along the shore of Lake



Michigan.  Last winter a number of my constituents brought




to my attention Commonwealth Edison's questionable use of




the Pipes and Beer study of thermal discharge from the



utility's Waukegan powerplant.  I understand that the study




is being referred to in the present controversey.  The



study, conducted by Wesley 0. Pipes and Mr. Lawrence P»



Beer, has been labeled by the power company as a preliminary
-------
                                                       1345






                     Hon. A. J. Mikva




 environmental investigation which  proved that the Zion



 Station discharge would have no detrimental  effect  on  the




 lake, and  I suggest that it proved no  such thing.




           According to Professor Pipes, his  study states




 simply that, "... there is no  indication of  any  deleterious




 environmental effects due to the Waukegan Station discharge




 ...."  The Waukegan Station, however,  is hardly  comparable




 to the Zion Station in both size and power production.




           In a letter to me, Professor Pipes disagreed




 with Commonwealth Edison's use of  his  study  and  assured




 me that it "... does not provide scientific  assurances




 that no harm will be done to Lake  Michigan by discharge




 from Zion  Station."  It was, he added, ",..  an extremely



 short term study."




           It is my understanding that  the data for  the



 study was  gathered on J days in April  1968.  The man who



 supervised the gill net catches for the study, Mr.  Bruce



Munch, Director, Northeast District, Division of  Fisheries,




 Illinois Department of Conservative, has informed me that



 he believes that any conclusions drawn from  the  study's



 gill net catches would h;..•/? very little ecological




 significance.  I understand from conversations with Mr.




 Munch that the fi:;h caught in  the  gill netting were




 simply attracted to the location by the warm water  and
-------
                     Hon. A. J. Mikva




that there was no way to determine how long they had been




in the heated water or whether it was harmful to them or




not.




          To a layman like myself, Professor Pipes' and




Mr. Munch*s reservations about the conclusions drawn from




the study by the power company make its current use as a




backstopping outrageous.  I was sorry to learn that




Commonwealth Edison is still referring to it to buttress




their argument that the Zion Station discharge will, not be




harmful.  The argument is not true.




          The formula that we are dealing with here is very



simple.  If there is any possibility that heated water dis-




charge will damage the lake then the discharge of heated




water must be restricted.  Feasible and economically



reasonable alternatives such as cooling ponds and towers



exist to do so.  Unless these alternatives are used, not



only will we accelerate the eutrophication of the lake, but



we will open the flood gate for the accelerated industrial




and commercial exploitation of the lake as wello



          A basic policy decision on the use of the lake




must be made.  Gentlemen, in making that decision, I hope




you will  keep in mind that in the long run no one will




really profit from a dead lake, not even Commonwealth




Edison or its power customers.
-------
                      Hon. A. J, Mikva



           Mr. Chairman, I said I make myself feel as though



"I saw this picture before.*1



           I am sure this discussion about whether the



steel companies should dump their wastes into the lake



was like the discussion you hear from some of the new



mothers at the present time — that just because there is no



proof as yet that birth control pills will not do any harm,



this is not assurance that they will not do any harm.  Maybe



at the time that U. S. and some of the steel giants built



their plants  there wasn't any proof.  But we have proof



now, and it is to the sorrow of all of the people on the



lake that there wasn't some far-sighted public officials



at that time who said, "Not in the lake unless you can prove



it won't do any harm."



           Thank you for your time.  (Applause)



           I would be glad to answer any questions but I



suspect I will be caught with more down that the previous



speaker!  But go ahead.



           MR. STEIN:  Are there any questions of Congress-



man Mikva?  I guess not.  You have been very persuasive.



           MR. MIKVA:  I hope so.



           MR. STEIN:  Thank you very much.



           May we hear from Attorney General William



Scott?
-------
                     W. J.  Scott








          STATEMENT OF WILLIAM J.  SCOTT,  ATTORNEY




          GENERAL,  STATE OF ILLINOIS,  SPRINGFIELD,




                        ILLINOIS








          MR. SCOTT:  Mr. Chairman,  gentlemen.   For the



most part of this past week, you have  been listening to




the hired spokesmen of the polluters,  the great corpora-




tions, the electric companies, the municipalities and




others who are using Lake Michigan as  a free sewer.




          As an attorney general of the State of Illinois,




I am here to seek equal time for the people who are the




victims of the polluters —the 30 million citizens of




the four States that you people represent who are depend-



ing on you and have entrusted you with the responsibility



of preserving their environment.



          Now, during the previous days of testimony,



we have heard scientists and representatives tell us in




effect that they don't know what is going to happen  when



they pour billions of gallons of heated water into Lake




Michigan.  They have said, in effect,  give us 4 or 5 years




of lenient standards so that we can determine what will




happen.  They have asked you people who are entrusted with




preserving Lake Michigan for the millions of unborn
-------
                                                     1S49






                     W. J. Scott



generations to give them 4 or 5 years of using Lake



Michigan as a test tube.  They further said that if some-



thing goes wrong  they will pay for it.  They have said,



in effect, that if something goes wrong  we will pay for



it; go out and buy a new lake.  They have said, in effect,



that it is scientifically feasible to recirculate. but it



is going to cost millions of dollars^.     Qf course, they



have added to it, on top of it,"We have already gone ahead



and located some of our plants in places where it may be



physically impossible to build cooling towers or to



recirculate.



          Now, I submit to you that on one side we have



private corporations that have been granted a monopoly



to sell electricity in a given area.  On the other side,



we have citizens of your States who have entrusted you



with preserving their environment.  And the main question



before this conference is:  Where is the burden of proof



going to be?  Is the burden of proof going to be on the



people that want to use the lake as a free sewer, or is the



burden of proof going to be on the citizens that you



represent?  I submit to you that the answer is fairly



obvious —that if we are going to do our job of repre-



senting our constituents that we have to insist on the



strictest possible standards; that we have to say. wherever
-------
                                                       IS 50
                     W. J. Scott




scientifically feasible, that we use the high scientific




knowledge available to preserve the environment; that we




have to say,wherever there is a question of doubt, the doubt




has to be resolved in the benefit of the people that are




going to depend on Lake Michigan for their drinking supply,




for their recreation,and perhaps for their very health and




lives.



          So the real question that you have to determine




is:  Where does the burden of proof fall?  Because nobody




can tell you what is going to happen when they start




recirculating the lake through dozens and perhaps as many




as a hundred atomic reactors.  Nobody has been able to tell



us that.  They refer to examples.  Congressman Mikva mentioned



the thermal pollution from the plant at Waukegan.  I submit



to you that last summer the public health official for



Lake County, Illinois, where the Waukegan plant is located,



ordered the closing of every beach in Lake County.  Now, we



don't know what the cause of that was.  We don't know




specifically where the major causes were.  But we do know




that the pollution came from the municipal sewerage; it




came from U. S. Steel; it came from Commonwealth Edison;



and it came from Abbott Laboratories.  The combined factors




resulted in the loss of those beaches to the people of




that county.
-------
                     W. J. Scott




          I think that it is very clear that you people have




the responsibility of insisting on the highest standards




possible .  I am hearily in accord with the Federal report




which says that there should not be any significant discharge




into Lake Michigan.  In fact, I think that wherever it is



scientifically feasible, the word "significant  discharge "




should be interpreted to mean none whatsoever.



          It is going to cost money; we realise that.  But




nobody can put a price tag on an aesthetic Lake Michigan.




Our tourism, our boating industries, our fishing industries,




our recreational industries are all dependent on that Iake0




          But more than that, the lives of the 30 million




people in the four States that have designated you and that




pay your salaries to protect their environment are depending



on you to set standards that will do that.     I am here to




urge you that wherever scientifically feasible, you insist



that the water be recirculated rather than just utilized



as a free sewer.




          Thank you.   (Applause)



          MR. STEIN:  Thank you.




          Thank you very much for your presentation.



          May we go back to Mrs. Botts?




          MRS. BOTTS:  I would like to say that a statement



has been mailed to me.  The postal service didn't cooperate
-------
                                                       1352
                     Mrs. L. Botts




in getting it here in time.  I will have to submit it into




the record later.  Dr. Frank Hooper, a biologist at the




University of Michigan, will give you his predictions about




the possible effects of heat on the future of Lake Michigan,




          (The statement of Dr. Frank F. Hooper follows in




its entirety.)
-------
                                                                1853
                   Statement of Frank F. Hooper
                Professor of Fisheries and Zoology
            Regarding thermal inputs into Lake Michigan

     My name is Frank F. Hooper; I am a professor in the School
of Natural Resources, The University of Michigan.  I teach a
course in aquatic ecology.  My specialty is water quality and
lirnclcgy and my graduate students and I have r.ade substantial
research contributions in this area.  Formerly I was employed by
the State of Michigan as an aquatic biologist*  In this capacity
on several occasions I served as a consultant for the Michigan
V/ater Resources Commission regarding pollution problems in the
State of Michigan.  I have ser\red as an aquatic ecologist for the
Atorrdc Energy Commission a&d in this position I have advised tueia
on vratcr quality and liinnological matters (additional credential.?
are attached).
     I do not favor further licensing of power plants requiring
cooling water on Lake Michigan until the appropriate regulatory
agency has set limits for the annual and seasonal thermal inputs
into this lake.  Such limits must be set with the reasonable ex-
pectation that they will protect existing fish stocks and in-
vertebrates and that they will preserve existing aesthetic features
of this resource.
     Limits, standards or criteria used in regulating heat as well
as any other pollutant must be set on the basis of the concentration
-------
                                                                 1854
                               -2-

the pollutant ultimately makes in the receiving water and not
upon the concentration of the substance or condition (i.e. tempera-
ture) in the effluent discharge.   Only in this way is it possible
for agencies to regulate or protect a resource.  There is an abun-
dance of evidence in the history of water pollution control on
major river systems which substantiates this principle for regulation
and administration of water use.

     In the case of heated effluents entering a largo lake such as
Lake Michigan, limits set upon the temperatures in individual plumes
should not be used as a control over thermal effects upon biological
systems.  Since 2 or more adjacent plumes may merge and form an in-
shore water mass that retains its identity for considerable periods
of time and have serious biological effects, it is essential that
limits be set upon total heat input into inshore waters.
     Inshore water masses heated by the thermal discharges in the
spring may have serious biological effects upon fish spawning, re-
production of invertebrates and upon the growth rate of plankton.
Integration of all of these changes in the system uay ultimately
completely alter food chains so that an entirely different community
of animals and plants is produced.

     With large thermal discharges algal blooms in the spring and
early summer might be anticipated.  Environmental perturbations of
this sort bring about decreases in diversity of the flora and fauna
-------
                                                                 1855
                               -3-
and lead to high densities of a few species and create nuisances
as far as recreational uses are concerned.  I would envision that
during the spring and early summer months many of the recreational
facilities along the shoreline would be jeopardized by the inputs
from a number of nuclear installations or other sources of hot
water.
     Thermal limits should be established for specific sections of
Lake Michigan since the shoreline varies widely in its biological
characteristics and upon its capacity for production o"~ various
species of plants and invertebrates.  Standards set in this manner
would then allow thermal inputs up to a prescribed maximum at which
time further cooling water discharges must be brought to ambient
lake temperature.  Regulated in this way, it should be possible to
avoid adverse ecological changes.
     With relatively little effort and using only existing data it
should be possible to arrive at useful estimates of thermal liwits
which should be set for various sections of Lake Michigan shoreline.
Although all of the desirable data are not at hand (and may never be)
given the best available expertise the regulatory agency can at the
present time arrive at safe and conservative approximations for ther-
mal loading.  Such limits or standards must be subject to revision
as additional data are provided.  However, at this stage it is im-
portant that resource standards be established since such action will
-------
                                                                   1856
                               -4-

clearly define the principle upon which future decisions can be
expected.

     The map of projected or proposed nuclear power plants generat-
ing on Lake Michigan shoreline is exceedingly impressive.  The
anticipated power needs for Michigan and adjacent states can only
lead one to believe that many major installations will be constructed
in the future.  Thus it is essential to establish appropriate regu-
latory criteria at this time.
-------
                                                           13^37
Frank F. Hooper, Professor of Fisheries and Zoology.

University of California, 1939. A.B.
University of Minnesota, 1948. Ph.D.
University of Chicago, 1942-43 (meteorology).
Oak Ridge Institute of Nuclear Studies, 1957.
Teaching Assistant Zoology, University of Minnesota, 1940-42,
      1946-48.
Air Force Weather Officer, Alaska, 1942-46.
Instructor, University of Michigan, 1948-52.
Biologist, Institute for Fisheries Research, 1952-1962; 1964-65.
Aquatic Ecologist, Division of Biology § Medicine, U.S. Atomic
      Energy Commission, 1962-63, 1966.
Biologist in Charge, Institute for Fisheries Research, 1965-66.
Professor of Fisheries, School of Natural Resources and Professor of
      Zoology, College of Literature, Science and the Arts, 1966-
      Present.
Treasurer of American Microscopical Society, 1953-56.
Executive Committee, American Society of Limnology § Oceanography,
      1957-1960.
President, American "Society of Limnology and Oceanography, 1966.
Associate Editor of Journal of Wildlife Management, 1959-1961,
Associate Editor of Transactions of the American Fisheries
      Society, 1964-1968.
Associate Editor of Ecology, 1970-present.
-------
                                                                              1358
                                                     September 24, 1069

                     Publications by Frank F. H
Hooper, Frank  F.   1947.   Plankton collections fzoa  the  Yukon and
        Mackenzie  River systeas.  Trans. Ar,er. Hicr.  Soc., LXVX(l): 74-84.
        _ ___ 1948.   Th3 effect ox debris root  (z-otenone)  upon plankton
        and bottom fauns organisms of a small Minnesota lake.  Proc.
        Minnascta Acad.  Sci., 16: 29-32.

        ___ 1949.   Age analysis of a population  o£  the gsaeiurid fish
        Sshi lbegjgs^_ so 1 lis_ (Herasia).  Copsia, April  15(1):  34-3S.

           1951.   Litaaologieal features of a Minnesota  seepage lake.
        The AffiSTiesn  MidXassd Naturalist, 46(2):  462-481.

         _ 1952.   Ravie;-,'.  Lisnolegy by Paul S.  Kolch,  second edition.
        McGra*  Hill Book Co.. New York, 538  p.,  SO tigs.  Ccpeia. 4: 285.

          _ 1DS3.   Revise.  Fisjidsg-sp.taSs of Linaolcgy by Frans Ruttner,
                edition,)  19S2;" English translation  by D.G.  Fycy and F.E.J.
                       '
        Fry.   Univ.  cf 'TGi-sato Pirsss, Toi.-oaso,  19SS:  XI * 242 p., 51 figs.,
        Copsis.,  No.  S: 195-196.
________ r __ ____, Robsz.^  C.  Ball. sii-J Hcwasd A. Tanner.   1S53.   An
      ~" iw the  artificial ci3?£ul£.tioa of a small Michigan lalie,  Trsas.
        Asaar. Fish. Soc., 82(1952): 222-241.

 ^^^.^ _____ » sj?.d AJ.fired i>S. Elliott.  1&53.  Rsisase of inorganic phosphorus
        flrova extracts  of laJ;s jsad by protosos.  Trans.  Aassy. ^"ic^. Soc.,
        LXXIS(S):  276-281.

     ____  1954.  Liirnolsgical features of Weber Lal;es  Chsbcy^an Ctnisty,
        Michigan .   Psp. Mich. Acad. Sci.s XXXIX (1953):  223-240.

Lagisr, Karl F., and Fra?& F. Koc-p&r.  1SS4.   Fish production In inland
        waters. Univ. of Michigan E;:ten?.ion  Service.,  Teieccarss Syllabus,
                srit  ,1S  Fis'n an.d Fishing is Recv^sticn £ad Cc^sssree } 6 p.
Hccpsi*4  P.P.,  K:d A. Be Ccck, Jr.   19£50   Chsr.fic-rl control of subniorgad
         water  weeds with scrlito ivi'ssnite.   Midi.  Dapt. Cons., Fish Div.
         Penphlet No.  16, M&i-ch, 6  p.

Hoops? ,  F.F.   1SSS.  Eradication o£ fish  by ehssiieal treatssnt.  Mich.
         Dspt.  Ccns.,  Fish Div. Per^hlet Ho. 19, Decsn-bc-T, 6 p.

Koopar,  Frsjik  F.  1356.  SDKS cho^lca.1 and  r.o:-.*phopot2'3.c charactsristics
         of scitthsra Miehigar. IE!;SS.   Pap,, Mich'. Acad. S^i., XLi'(19SS):
         109-130.

/jidsi'son,  Richs.i'd 0., ar.tl Fran'c ?e Hac-por.   19S6.  Saasonal abv-v^dajics
         and production of Httical bott<::3 fir^ia in a scathorn Michigm
         lake.   Trnns. Asis?. Mic~.  Soc.s LXXXV(3>: 2SD-2TO.
-------
                                                                             1859
Ball, R.C., and F.F. liocpe?.   19S6.   Edited translation by Michael
        Ovchyanyk  of "Byiisiriies of the total benthie bicsass in ths
        p?cfundsl  of Lake Bsloie" by E,V. Borutsky, Proc. Kossiao Linrso-
        logical Station of the KydroMSteoyalcgical Service of U.S.S.R.
        22(1939):  1S6-213.  Repre&jcs-d by Mich. Dopt, Cons., 26 p.  plus
        illustrations.

Hocpsr, Frank F.   1357.  Vegetation control problems in wildlife  habitats-
        fish.  Proc. 13th North Centi'sl Wse-d Control Conference:  24-25.

Hoopa?, F.F., end  A.3.  Ccck,  Jr.  IS57.  Chasici-l ccnti'ol of sub«-3rged
        w&tey ws&ds with scdiua c?s&nit:@.  Mich. Dipt. Cons., Fish  Div.
        Psnphlet Ho. 16 (Revision of 1935 publicytic3i)9 July,, 6 p.,
        1 fig.

      , Frcssk F.,  aid Alfred R. Gssssda.  1337.  The use of Toxsphcri*
        as £ fish  poisoa.  H'ans. tass.% Fish. Soc., -S5(195S): 1CG-190.

     ?, F.F.  1958.  Eradication of algss v/ith ch'Smcals.  Mich.  Dept.
        Corss., Fish  Div. Paaphlet No. 25 s Fobruniy, 5 p., 1 fig.
Kospsrp Fs-ssi!< F.   1SS8.   Review.   Giaids to fisliss of K&w K
        by Willis® J.  Koster.   Asasv. Inst. Biol. Sci. Bull. 8:29.

Bsatty, Lse D, „ and  Fran!? F.^Moopsi-.  1958.  Bsnthie associatic^s  of
        Sugar loaf  Laks,   Pap.  Mich. Asai. Sci., .XLIII: 89-106,

       , K.G., snd  Frank  F.  Hoops?.  195S.  Tosr-phsse (Chlorinated
        Csoplieaa)  as a saSective  fish poises.  Prog. Fish-Cult. , 20:
           - ISO.
    sr, Frenk  F.   1959.   Review.  A treatise of  (en) liruioSogy, by
        G. Evelyn  Kutchinson.-  J. Wildl. Mgrat.,  2S:
           1958.   Popalatioa ccatrol by chemicals snd seis i'e^iiltir.
        p^oblstns.  Tysins.  2nd Saieinar on Bioltgici^.i Frcbloas i>3 i'/at&r
        Poliuticn, U.S,  Public Sfeelth Son'., R&by^t A. Teft. Scsiitc-^-y
        Enginesring  Cesi
           1959.  Use  of the nowoy organic insectici
-------
                                                                                 I860
Knight,  Mlsn, Robert  C.  Ball, r.rsd  Frrtnk ?. Hooper.   1952.  Scss
         eat ira^es of wis-asy production vatc-s in Michigan ponds.
         Midi. Acad. Sci., XLVII(19S1):  2J9-233.

Schalske,  C7.ai5.-e  L. ,  Frcnk F. Koopsr,  and E.J. flaercl.  19-52.
         R3St3oas3s c£ f- snsri lake to chslatec* is.*£ili-
         yit^ri   Tr-^-Af   &«-•  n-s^'ri   Cf-f   ^t'iffi- t •«»'?,? 7%
         £,^ltAOj».  ii-'-^i^^'a  
-------
                                                             1861


                            -4-
Sohacki, Leonard P., Robert C. Ball and Frank F. Hooper.  1969.
        Some ecological changes in ponds from sodium arsenite and
        copper sulfate.  Michigan Academician (Papers of the
        Michigan Academy of Science Arts and Letters), 1:149-162.

Bahr, Thomas G., Robert C. Ball and Frank F. Hooper.  1969.
        Arsenic 74 Metabolism in an aquatic ecosystem.  Michigan
        Academician (Papers of the Michigan Academy of Science
        Arts and Letters), 1:163-174.

Hooper, F. F.  1969.  Eutrophication Indices and their relation
        to other Indices of Ecosystem change .  In Eutrophication:
        Causes, consequences and corrections.  Proceedings of a
        Symposium, Nat. Acad. of Sciences, Washington 1969.
-------
                                                       1862






                       J0 E. Bardach




          MRS. BOTTS:  At this time, I would like to




introduce Dr. John Bardach who, as I mentioned before,  is




a distinguished aquatic ecologist, who has consented to




appear as a consultant to the public.




          Dr. Bardach.








          STATEMENT OF JOHN E. BARDACH, PROFESSOR




          OF NATURAL RESOURCES, UNIVERSITY OF



              MICHIGAN, ANN ARBOR, MICHIGAN








          DR. BARDACH:  Mr. Stein, conferees, ladies and




gentlemen.  I am John Bardach, and I am a professor of




natural resources at a reasonably well known educational




institution.



          My credentials are attached to the statement



which the conferees have in their hands.  I would like



to add that I came here paying for my part of the jet



emissions that are added to the skies over Lake Michigan




and that I am extremely concerned from a long-range point




of view over what is happening.  (See Pp, 1737i-17?*7o)



          I would like to preface my remarks by saying



that on my flight today I paid for insurance for a rather




unlikely contingency, namely that my airplane would drop




down.  We are concerned here with what insurance we should
-------
                                                        1363
                     J. E. Bardach




pay for another contingency, a contingency that in my




scientific opinion is far more likely to occur, namely the




galloping eutrophication of Lake Michigan if heat is permitted



to be discharged in an unabated fashion as is now planned




over the next 20 or 30 years or so.




          I think the key word here is "eutrophication,"



because from it follow all other consequences.




          It has been though not completely but reasonably



well established that during crucial periods of the year




— that is in the spring and in the fall — the shore waters



of Lake Michigan form a rather discrete entity.  Now, why




are those crucial periods?




          The spring is a crucial period because in it




unfold the succession of algal species.  If the heat regime




is altered upwards, we will have undesirable algae early



and we will have different successions of algae, as has



been demonstrated in some cases in smaller lakes and as is



apparent now even in some shore regions of Lake Michigan.



Let me add that it is not a question of heat being the main



or the only culprit.  We all know this.  It is a complex




situation in which effluents may hold the limiting factors




for eutrophication, but in which heat unquestionably — if




these factors are present — speeds the biological




processes.
-------
                                                      136*.
                      J. E. Bardach
           The other crucial period is in the fall where
there is an equally discrete segregation of water in the
shore regions.  In the fall, a rather unique set of fishes,
the whitefishes, come to spawn, and they come to spawn in
the shore areas.  They spawn only if the water temperature
goes down at a certain rate.  We do not know what this rate
is, but we do know that the water temperature has to become
lowered at a certain rate and reach a certain lower tempera-
ture for these fishes to spawn at all.
           Now, it is quite possible that regionally or for
that matter locally these conditions will be so altered that
the spawning of whitefishes will be inhibited.  Recently
we have introduced salmon into Lake Michigan.  They are
doing very well.  It is possible regionally, again, locally
that the temperature changes, if permitted to occur in an
unabated fashion, will affect some of the biological
characteristics of the salmon.
           I will give you an example.  The conversion
efficiency, that is the efficiency with which the salmon
converts food into its flesh, declines from 32 to 22 percent
as the temperature goes up from 56 to 6? degrees Fahrenheit.
There are many other such influences that are temperature-
conditioned or temperature-influenced.  I am not telling
you anything new if I say that there are very many of them
we do not know.
-------
                                                        1365






                       J. E. Bardach



          I was in Switzerland this spring, where I grew up,



and in the last 30 years a very beautiful lake, Lake Zurich,



in which I used to swim as a boy, has undergone irreversible



changes.  It is now a rather nasty soup.  When I talked to



some of my friends in Switzerland they said, "What are you



going to do with your Great Lakes?  We understand that some



changes have already occurred." — And I think that the



Stoermer-Yang diatom studies indicate this. — "Are you



going to stop what we didn't stop?"



          I said, "I don't know.  I hope we will."



          Let me stress:  The effects of eutrophication,



including the partial effects of heat, are cumulative and



not lineal.  They start slowly, accelerate, and accelerate



very fast once they have started to do so.  In fact, a



before-and-after study done at a plant site several years



after the plant has started putting heat into the lake



may tell you nothing or so little that you can't make any



predictions from it.  Natural variations may mask these



effects, but it is not difficult to assess that the



contribution to the heat load of the lake from a large



number of plants in the southern end would have a cumulative



effect that works in a synergistic fashion with the enrich-



ment.  There is nothing naturally good or bad about either



a trout, a salmon or a whitefish as opposed to a perch,
-------
                                                        1366






                     J. E. Bardach



carp, sucker, or alewife lake.




          These are sociocultural values but I think that




we have stated them.




          Lake Michigan is a unique environment.  There




isn't another one in the world.  And we said that we would




rather have a lake trout, whitefish, and salmon lake.




If we do not want to wake up — not "we," but perhaps your



children and some of the young people in the audience —




if we do not want to wake up in the year 2020 reading in




the newspaper that there was a severe carp die-off in the




shore waters of southern Lake Michigan because of nocturnal




oxygen depletion, if we are to keep a unique natural environ-



ment as little changed as possible, we must as a society,




as one of the many things we do, take measures to hold to



an absolute minimum the heat discharges to the shore waters



of Lake Michigan.  Whatever the technical means by which we



do this, these are open to discussion, but there is no



question about the fact that unabated discharge of heat




into Lake Michigan will have the effects predicated on




analogies by many biologists.



          In fact, even if we do abate heat discharges, we



may not have much of a chance.  It may already be too late.




Eutrophication is like a disease.  It has an incubation




period.  It starts rather slowly and then it becomes
-------
                                                      IB67
                     J. E. Bardach



galloping.  But if we don't try now to do something about




this one factor which we are here to consider and discuss,




we do throw away much of our chance to keep Lake Michigan




as it is now or perhaps even improved.




          Thank you,  (Applause)




          MR. STEIN:  Thank you, Dr. Bardach.




          Are there any questions?



          MR. CURRIE:  les, Mr. Chairman.




          MR, STEIN:  Yes.



          MR. CURRIE:  Did I gather, Dr. Bardach, that one




of the things you said was that whatever adverse effects heat




discharges may have on the biology of Lake Michigan are




likely not to be reversible?  We had statements from several



industry witnesses the other day that if there were chances



in the biology of Lake Michigan due to heat discharges they



were likely to be reversible.  I take it you disagree,



          DR. BARDACH:  No, I didn't say any such thing.



I did not say they were irreversible.  They are? in fact,



reversible or very likely to be so.  But what is the ti.ie




frame? We are now in 1970.  By 2000, I understand, the heat




load should be from various sources and not only the power




companies, about 10 times what it is now.  At the same time




it seems doubtful to me that by then we will have cleaned



up all our effluents.
-------
                                                        1363
                      J. E.  Bardach



          The changes of exit ro phi cat ion are reversible,  but



I think Lake Michigan is a case where these changes are



likely to go slowly because  of the sinking effects of the



lake.



          MR. CURRIE:  And this is true of whatever part of



eutrophication is caused by  heat as well as whatever part



of it is caused by too much  nutrient, in your opinion?



          MR. BARDACH:  I would think so.



          MR. STEIN:  I think this is a very important



point and I want to see if I understand it.



          If I understand what you are saying, you are



saying that perhaps the total effect of eutrophication can



be reversible in a very long-range time frame.  I think that



is what we know generally about eutrophication.  But I



think what Mr. Currie was referring to is that, even in the



short range, if we had heat in the lake and that proved



to be harmful, this is just  transitory.  By removing that



heat, the effect of that heat would be dissipated maybe



in a season or two, and we wouldn't have to wait for this



long-time recovery in order to reverse eutrophication.  We



know how long that is, having tried to reverse eutrophication



in other bodies of water.



          DR. BARDACH:  Well, these are hypothetical



situations, Mr. Stein.  Let us assume that we go along as
-------
                                                        1369
                      J. E. Bardach



we are going now, and in 19#5 we say,  "Okay,  enough.



Tomorrow no more heat into Lake Michigan."




          Are you asking me how fast the reversal of



eutrophication would be?



          MR. STEIN:  What I am saying — I am trying to



split this into two questions.  I believe I have read




enough of the literature, been in enough conferences, par-



ticipated in enough meetings and discussions to know how



difficult it is to reverse eutrophication.  I think that




the point that Mr. Currie raised is a closer one here.



That is, if we stop heat say by 1975 if there proves to




be damage, by stopping that heat we will not have



accelerated eutrophication on our hands because of that



heat.  We will not have to wait for that slow process of



reversal if it ever is to come.  But once we stop the heat,



the effects of that heat or any damage it may have caused



will immediately disappear.  The heat wouldn't have



caused any damage at all, except in the sense that it is



going to have a transitory impact on the lake.



          DR. BARDACH:  Well, I am going to make a guess.



That is all I can do.  It would still take a number of




years.  I don't know how many.  But if you could pinpoint the



effects; if you could abstract the effects of heat




and take the effects of heat singly, and nobody can do this
-------
                                                       1870






                      J. E, Bardach



now — it would still take a number of years — and I



don 't know how many — before the aftermath of these effects



or the conditions to which these effects have given rise



would disappear.



          MR. STEIN:  Thank you.



          Are there any other comments?



          MR. FETTEROLF:  Dr. Bardaeh, I think you are



basing your premise on if a large segment of the shore



waters of Lake Michigan were warm.



          Now, if you had a plume from a single plant and



for some 3 or k miles down shore from there you had increases



in algal growth possibly due to added heat, and then you



ceased that input of heat, would the reversal then take



several years or a short time?



          DR. BARDACH:  It would take a shorter time;



probably not several years.  But — well, let me day again:



My concern is for the year 2000 and the year 2050.



          MR. STEIN:  Are there any other comments or ques-



tions?



          MR. CURRIE:  Yes, Mr. Chairman.



          MR. STEIN:  Yes, Mr. Currie.



          MR. CURRIE:  I think I might be helped a little



along this road, Dr. Bardach, if you could give us a more



precise indication of the way in which heat increases
-------
                                                       1371






                     J, E. Bardach




eutrophication.  We have heard from several people on this




subject, and I have been trying to get it straight and I am




not sure I have it.  I think we have been told so far that




heat inputs will not increase the total mass of algae present




at any given time in the lake.  Would that square with your




opinion?




          DR. BARDACH:  Well, again, you see, you are




trying to divide something that is hard to divide.  But




let me say this:  Assuming that you have all signs of




algal growth early during the year because of changed heat




characteristics of the inshore waters, you would have for




that particular alga a longer time to multiply than you




would otherwise have.  So you would, at this point, increase



the total amount of algae that are present as opposed to



the amount of algae that would have been present had no




heat been discharged.



          MR. CURRIE:  Yes, I think that is an important



point, and that helps me a good deal.




          Is that change one that would be irreversible?



I would think that the next year, if the temperature of




the lake were reduced, that then you would not duplicate




that condition, is that right?




          DR. BARDACH:  Locally — well, if you talk now



about one plant and you stopped completely heat discharge
-------
                      J. E. Bardach




from that plant, the next year you would, of course, not




duplicate that condition, but that does not mean that in




that particular year you would have no algae at all.




          MR. CURRIE:  Dr. Bardach, have you conducted




studies on the effect of heat on eutrophication in Lake




Michigan or in comparable waters?




          DR. BARDACH:  I have not conducted studies on




heat effects on eutrophication in Lake Michigan, but I have




done some studies on comparable waters.  The unfortunate




thing is that there are no comparable waters, and there




are no even slightly comparable waters on which such studies




have been conducted.  All such studies have been conducted



on smaller bodies of water.




          The only analogy we have — and there again they



are unfortunately rather incomplete cause-and-effect —



for what they are worth — data on Lake Erie and Lake



Ontario, And Lake Erie and Lake Ontario have deteriorated.




          In Lake Erie, the change in average lake tempera-




tures since — I think it was — around the 1920's by only




2 degrees Fahrenheit is suspected — you see, you are sort




of extrapolating backwards — is suspected to have caused



the demise of the lake herring and related fishes which




were living at that time at the extreme range of their




temperature tolerance, and that this gradual warming has
-------
                      J. E. Bardach




been tantamount to displacing Lake Erie 50 miles to the




South.




          Unfortunately the studies of heat effects on



eutrophication and the studies specifically of heat on




fishes and other aquatic organisms are relatively scarce.




There are some — for instance, I would like to know —




the statement has been made that young fishes of this



peculiar and specific species complex that we have in Lake




Michigan may be particularly vulnerable during the early




part of their lives to heat loading.




          Now, there are lots of things we don't know about




them.  For instance, we don't know whether all of them or



only some of them have to come to the surface to gulp air



to fill their swim lungs„  If we knew this we might be




able to make a somewhat better prediction, given hypothetical




situations, of surface temperatures.



          Let me add one other thing:  I am not concerned



about fish kills as such.  Well, no, it would be wrong to



say I am not concerned;  of course, I am.  But I am not




as concerned about the 5»000 fishes that die because some




powerplant shut off its effluents and the fishes were sub-




jected to a cold shock, say, or the reverse.  I am much




more concerned about the very slow and gradual effects.



I have done or my students and I have done some studies
-------
                                                       1374
                     J. E.  Bardach




on the effects of raising the temperature in the fishes'




environment close to its lethal temperature.    We have




looked at what does this do to the animal's behavior?  We




have studied the most heat-tolerant fishes — fishes that




one day may abound in Lake Michigan,  And we have  found that




as you get past the comfort zone of these fishes,  their



behavior becomes quite different; they become very much more




aggressive to one another;  they cover much larger distances




in search for food and comfort.  They may, in fact, be




very much disturbed in their reproductive behavior.




          Now, that is something that will have effects




that go over 4, 5, 6, 7 years or longer, and eventually



their numbers in the lake or a body of water are reduced,




None died, or nobody died earlier than they should have.



But he or she was adversely influenced.



          MR, STEIN:  Are there any other questions from



the panel or —




          Mr. Petersen.




          MR. PETERSEN:  Thank you, Mr. Chairman.




          Dr. Bardach, as I understand what you have said,




you are concerned principally with the effects of heat




over the long range.



          Dr0 Bardach, would that be properly interpreted




to mean that it would not appear that the effects of any
-------
                                                       1375
                       Jo E. Bardach



one plant would be noticed in Lake Michigan?




          DR. BARDACH:  In answering this, let me say that




I have great sympathy with the power industry in one




respect:  They have been subjected to a lack of guidelines




from public quarters, quite understandably so.




          Now, one plant may or may not have a local




effect.  That is all I can say.




          MR. PETERSEN:  You wouldn't expect one plant to



have by itself an effect on all of Lake Michigan in the




manner in which you have described,in what you have had to



say today?




          DR. BARDACH:  I think it only fair to say no.




          MR. PETERSEN:  Do you theorize that the presently




existing plants are having that effect?




          DR. BARDACH:  They unquestionably contribute to



eutrophication; to what degree, I am not prepared to say0



Let me be quite frank with you.  It may be that this effect



is so small that it is very hard, if not impossible, to




detect.



          MR. PETERSEN:  In this regard, you are relying,



as I understand, on the idea of a separate and unmixing




body of — what was it? — shore waters?




          DR. BARDACH:  Yes.



          MR. PETERSEN:  What do you mean by shore water?
-------
                                                       1376






                      J. E. Bardach



          DR, BARDACH:  I mean water to a depth of about 10



meters, which during certain parts of the year, as set



forth in several publications — one of them "The Lake



Currents in the Lake Michigan Basin," by the Federal Water



Pollution Control Administration Great Lakes Region,



November 196?, and again in this publication, "Physical



and Ecological Effects of Waste Heat," as pointed out



there, because of specific thermal effects on the water,



there is a thermal barrier that prevents the mixing during



certain parts of the year.     I am not sure to what extent



the duration of these separations has really been determined



accurately.  But let it suffice to say that they are part



of the year, and I think they are not part of the year,



the spring and the fall, where these thermal barriers exist,



that would separate out about 10 percent of the lake water



from the rest of the lake.



          MR. PETERSEN:  Does this thermal barrier keep the



mixing of the lake totally or is it merely a partial bar



to mixing?



          DR. BARDACH:  During the time it exists?



          MR. PETERSEN:  I presume — you said it is not a



continuous phenomenon.



          DR. BARDACH:  No, when the bar is removed, there



is mixing with — well, in the summer, there is mixing
-------
                     J. E. Bardach




with  the  epilimnion, and if the bar does not exist, during




turnover times, then there is mixing in the  entire lake.




          MR. PETERSEN:  My question was:   Does the bar




prevent mixing between the inshore and the  offshore part  of




the lake  totally  or is it only a  partial bar to mixing




during the  time that it exists?




          DR. BARDACH:  From what I know about the matter,



it does prevent effective mixing.




          MR. PETERSEN:  Now, doctor, have  you performed



any studies in relation to the thermal bar  in Lake Michigan?




          DR. BARDACH:  I said from what I  know.




          MR. PETERSEN:  Are you  familiar with the study




which Dr. Pritchard described when he was here, wherein he



noted not less nr^ing but greater mixing over the thermal



bar were  difficult studies?




          DR. BARDACH: I wasn't here when Dr. Pritchard



presented his testimony.



          MR. PETERSEN:  You were not aware of that?



          DR. BARDACH:  I was not aware of  that.



          MR. PETERSEN:  Could that in any  way have any



change ?




          DR. BARDACH:  Yes, certainly,,  If this were found,



if this were ascertained, certainly,,




          MR. PETERSEN:  As I understand it, you have done
-------
                     J.  E.  Bardach




no studies within any existing thermal plumes.




          DR. BARDACH:  I have done tank studies with




thermal plumes, again on the behavior of fishes.




          MR. PETERSEN:   What kind of studies?




          DR. BARDACH:  Tank.




          MR. PETERSEN;   Ah!  But not within —




          DR. BARDACH:  No, I have not studied  thermal




plumes within Lake Michigan.




          MR. PETERSEN:   All right.  You have no reason to




believe that fish will swim into the thermal plumes and




remain there to the point that they are killed  or hurt?




          DR. BARDACH:  Sometimes yes; sometimes no.




          MR» PETERSEN:   Sometimes you believe  they will



swim in and be killed?



          DR. BARDACH:  Sometimes I believe they may well



be, if not killed, so affected that they do not recover or



are susceptible to other either disease or environmental



factors that may befall them after they have had either a




heat or cold shock.




          MR. PETERSEN:   Ah!  From shock, you are speaking?



          DR. BARDACH:  Yes.  Well, I think you have to



separate.  There are unquestionably instances where it may




happen that the fish are actually killed, not immediately




but within — you see, a fish doesn't die like this —
-------
                     J. E. Bardach




(Dr. Bardach snapped his fingers) — it is affected and it




may be a few hours later that it gives up the ghost.




          But in other cases it may get a heat or a cold




shock and may die even 2 or 3 weeks later, and it is very




difficult to say that this was it.  Certainly in the lake




I can only make this study under highly controlled condi-




tions.




          MRo PETERSEN:  It is my understanding that you




reached this present theory at least 2 months ago.




          DR. BARDACH:  Which present theory?




          MR. PETERSEN:  The present theory which you have.




          DR. BARDACH:  I have many theories.




          MR. PETERSEN:  The theory of damage to Lake



Michigan from thermal effects that you have enumerated to




this audience today,,



          DR0 BARDACH:  No, I wouldn't say this, Mr.



Petersen.  I wouldn't say this.  I have been concerned



about the effects of eutrophication on Lake Michigan for



quite awhile.     When I helped Consumers Power Company



to design the before-and-after study for their Palisades




plant, I stated in the document that I presented to Consumers




Power Company that I am very concerned with possible eutro-




phication effects — synergistic eutrophication effects of



effluents and heat.
-------
                      J. E. Bardach



           MR, PETERSEN:  In this regard,  doctor,  has



Consumers Power Company asked you for the  scientific basis



of your conclusions?



           DR, BARDACH:  Consumers Power Company has, at



this time, accepted my suggestions to conduct a study.



Consumers Power is to be congratulated for having initiated



and being in the process of conducting this study,,  Later



— that was several years ago — as I have continued this,



I have become more concerned, and my concern has reached



somewhat greater proportions than it had when I designed or



helped to design this study for Consumers Power Company.



           Consumers Power has asked me, at this point, to



be good enough and tell them what kind of study they should



conduct — well, how can I put it? — to foretell



with as much confidence as possible the effects of the



Palisades plant.  I am in the process of thinking about



how this might be done.



           MR. PETERSEN:  And has the fact that you have



performed work for Consumers Power Company prevented you



from speaking your mind today or any other day in Indiana



or elsewhere?



           DR. BARDACH:  It has not.



           MR. PETERSEN:  Thank you, Dr. Bardach.



           MR. STEIN:  Any other comments or questions?
-------
                        J. E. Bardach




          Dr. Bardach, will you wait?




          MR. HIPKE:  My name is Jack Hipke, Wisconsin Power




and Light Company.




          First question:  You say that eutrophication is




discrete in the spring and fall in small lakes.  V/here does




this heat come from?




          DR. BARDACH:  Eutrophication can occur without




additional heat sources, and does occur without additional




heat sources, and I have never slid that the heat that will




be put into Lake Michigan causes eutrophication.



          MR. HIPKE:  Okay.  Question number two:  Are the




fish that you have mentioned in your study in the conversion




of food able to make a choice in temperature?



          DR. BARDACH:  Are they able to make a choice in



temperature in the experimental situation?




          MR. HIPKE:  Correct.



          DR. BARDACH:  No, they are not, because such a



study would be impossible to perform.



          MR. HIPKE:  Isn't it possible, then, that fish



in actual surroundings could make a temperature choice and



thereTors there won't be a depletion in the weight of the




 "ish due to the conversion of food?




          DR. BARDACH:  It is certainly possible.  But



let us assume that the salmon has no particular desire to
-------
                                                       1832
                     J. E. Bardach




go to some particular place.  If he does so, and if, in




fact, it could consciously ascertain that his conversion




is adversely affected, it is likely that he would choose,



but the fish doesn't know whether he is in — what his




conversion efficiency is.




          MR. HIPKE:  Question number three:  You mentioned




oxygen depletion in the year 2020, I believe.




          DR. BARDACH:  Yes.




          MR. HIPKE:  Was this in reference to the area of




the plume?




          DR. BARDACH:  No, it had no particular reference.




This was a very hypothetical situation, in reference to




almost anyplace in southern Lake Michigan.  And let me add:



It may well be that you have this contingency even if you



have no waste heat.



          MR. HIPKE:  Okay.  Thank you, doctor.



          MR. STEIN:  Are there any other comments or



questions?




          MR. COMEY:  I am David D. Comey, representing



Campaign Against Environmental Violence.




          Dr. Bardach, you mentioned that certain fish have




to go up to the surface in order to fill their air




bladders very early in their Iife0  Could you describe a



little bit more what that mechanism is and what it would
-------
                      J. E. Bardach




moan if on further knowledge it turns out that many species




have to accomplish this function?




          DR. BARDACH:  Yes.  Fish use their air bladders




or gas bladders to assume weight or density equal to that




of the water.  That makes it easier for them to remain at




a particular depth level.  They have to expend less muscular




energy to do so0




          There are essentially two kinds of fishes:  Fishes




that have a duct to the esophagus from their gas  bladders,




and those fishes that have not.




          In either case, much of the exchange of gas in



the swim bladder — that takes place through special tissues




that secrete gases from the blood.



          But to begin with, when the fish first hatches,



very many species, in order to stimulate that tissue to




perform, hsve to take one small gulp of air, and that



small gulp of air, of course, has to be taken at the sur-



face.  Now, there are, again, hypothetical situationso



Let us assume that a small hatch of these fishes came to



the surface.  They are small fishes, not very well able to




move and swim along, and they are carried by surface currents




into ex n area of very much higher temperature — say 5 or 6




degrees higher than the one in which they were immediately




before.  As they cannot navigate very well at that stage,
-------
                                                       1334






                      J, E. Bardach



they might be trapped there, and thus either die or be so



affected that they don't survive the next few weeks.  It



is indeed likely that those places are rather small, if



they exist at all.  But if I look at the perimeter of



southern Lake Michigan and the powerplants that are planned



there or may undergo modification to make them somewhat



larger, I think that these areas may become somewhat more



extensive and may depress the survival success of these



species.  We do not know to what extent, but the possi-



bility certainly exists.



           MR. COMEY:  Mr. Petersen, counsel for Consumers



Power Company, asked you a question about a study concern-



ing some dye-testing currents.  Are you familiar with



another study done by Gabriel Csanady at the University of



Waterloo several years ago indicating that dyes run through



the condenser of a nuclear powerplant on Lake Huron tended



to hug the shore for many miles and not disperse?  Are you



familiar with that study?



           DR. BARDACH:  No, I am not.



           MR. COMEY:  Well, let me go to another question



then0  You are familiar with the food chains of salmonids



in Lake Michigan and other cold water lakes?



           DR. BARDACH:  Yes.



           MR. COMEY:  Would you say that benthic organisms
-------
                      J. E. Bardach




that would be entrained at a condenser intake located




approximately 3»000 to 4»000 feet from shore would survive a




100 percent Delta T in the condenser of 25 to 28 to 30




degrees Fahrenheit?




           DR. BARDACH:  I doubt it.




           MR. COMEY:  Do you think Mysis Relicta, for




example, would survive such a thermal shock?




           DR. BARDACH:  Mysis Relicta happens to be a very




cold-loving crustaceon, and I am not aware of any tempera-




ture tolerance or thermal shock studies that have been done




on Mysis Relicta.  It would be my guess that they would be



very seriously affected.




           MR. COMEY:  Is the zone in which most of these



intake pipes are located which are out there in order to




get at least 25 feet or 35 feet of depth for the Corps of



Engineering navigational purposes — are they located in



a zone of high biological production from benthic organisms



and other elements in the fish food chain?  Is that a zone



of greater productivity than the immediate inshore zone?



           DR0 BARDACH:  By and large, yes.  But I think



you would have to really look at each particular plant




intake before you could make any general pronouncements.




           MR. COMEY:  One last question and that is:  Are




fish attracted to a warm—water discharge?
-------
                                                      1386
                     J. E. Bardach




          DR. BARDACH:  Oh, yes.




          MR. COMEY:  Do they have a tendency to prefer




water that is, say, just a few degrees below the level at




which they tend to exhibit the characteristics that you




have earlier described?  In other words, are they like




butterflies in the sense that they go towards light when




perhaps if they knew better they shouldn't?




          DR. BARDACH:  Well, some fishes do.  I would




suspect that some of the fishes we are most concerned with




might not.  Some studies have been done at Lake Me'.ndota




where there is a very, very strong discharge of heated



water, and bluegills, carp, yellow bass, apparently were




attracted to the outflow, and they were attracted to the



outflow in part because in the outflow zone there happened



to be more food at certain times of the year.



          Let me say here that I am convinced — and I said



so in a number of statements that I have made — that there



are beneficial effects on fishes.  You have got to make your




choice.  What is it you want to fish for?




          Let me please add one more thing.  There is a




possibility in heat abatement to turn heat into a rather




beneficial contingency„  It would be possible, ladies and




gentlemen, with 100 cubic feet per second of equithermal




waters — that is water that has the year-round a temperature
-------
                                                       1887





                     J. E. Bardach



about 1? to 1$ degrees centigrade — to raise in an intensive




fashion a million pound of trout.  So there are possibilities




here.




          MR. COMEY:  Do you know of any present powerplant




that plans to use that —




          DR. BARDACH:  I do know of several powerplants




that use heat,   One is the Long Island Heat and Power,




which uses it for oyster-growing.  J> nd there are several




powerplants — many in Russia — that do this.  Experiments




have been conducted with growing fish in heated effluents



in Hindustan, in Scotland, where it was possible to speed



the rate of growth of perch and sole to maturation and legal




size to 1 year as opposed to 3 years in the Irish Sea.




          MR. COMEY:  Yes, I believe the New York Depart-



ment of Conservation plans such a fish hatchery at the



Bell Station on Lake Cayuga, but the Bell Station did not



materialize.



          DR. BARDACH:  Well, there is a problem here, Mr.



Comey, and that is that the amounts of heated water are




so great that only a part of it could adequately be




accommodated in an economically sound enterprise.




          MR. COMEY:  Thank you very much.




          MR. THOKE:  My name is H. Thoke.  I am a



representative of the State of Wisconsin Southeast Chapter
-------
                       J. Eo Bardach




of Trout Unlimited.




          This question is related to a question from the




representative from Wisconsin Electric Power Company



regarding choice of the fish going to a warmer or a colder




area of a plume.  What effect would a heated plume have




on the migrating instinct of the trout and salmon that are




presently in the lake?  Would it deter them for accomplish-



ing the migrating instinct to go up the stream to spawn?



          DR. BARDACH:  You are asking me a very difficult



question.  Under certain conditions, it is possible that it




might.  It depends at what stage of their migration they




encounter this heated water.




          MR. THOKE:  Obviously the thing I am trying to



point out here is that there is another approach to, I think,



the direction the question was directed, and I will just



leave it there.



          DR, BARDACH:  Yes.  Well, I think that one thing,



gentlemen, if you may permit me to say so — one thing that




these questions brought out is that there is a heck of a




lot we don't know.




          MR0 STEIN:  Go ahead.



          MR. PETERSEN:  0. K. Petersen again.



          You were asked a question about benthic organisms



entrained in water coming through a plant.  Do you envision
-------
                      J. E. Bardach




many benthic organisms being entrained in water moving at




one-half of a foot per second?




          DR. BARDACH:  I couldn't answer that question,




Mr. Petersen.




          Mo PETERSEN:  Would you expect benthic organisms




so entrained and if hurt, damaged, or killed, to signifi-




cantly affect the benthic population in the area of a steam




electric generating plant?



          DR. BARDACH:  It would depend — well, probably




it would not have, but let me add one other thing.  It may




be that if there is a benthic organism so entrained, and




if it is spewed out again and it is half dead, it may still



be eaten by a fish.  But I don't think that these are



really — well, these are questions directed at me as a



physiologist and I can only hedge because, as you notice,



we just haven't got the data, and I can give you best guesses.



          But let me repeat:  The concern is one about



synergistic overall long-range effects.




          MR. PETERSEN:  And, doctor, you haven't yet




replied to Consumer Power Company's request for the back-




ground on your theories, have you?




          DR. BARDACH:  Would you like me to tell you here



what I wrote to Mr. Brandt?




          MR. PETERSEN:  I have seen the letter which you
-------
                                                      1390






                     J. E. Bardach




wrote to Mr. Brandt.




          DR. BARDAGH:  Well, I am trying to do so as fast




as I possibly can ,      Mr. Petersen, it may well be — it




may well be that I have to throw up my hands, not that I




cannot help you, but that I cannot help you to satisfy you.




It may well be — (Applause) — it may well be that we



have to mount these studies in a somewhat different way.




          MR. STEIN:  Thank you.



          Are there any other comments or questions?




          Well, thank you very much, Dr. Bardach.




          Mrs. Botts, are you ready to conclude?




          MRS. BOTTS:  Very sorry our presentation has




taken so long, and I am aware that there are people waiting,



My conclusion will be quite brief.



          It should be obvious that the expert witnesses



you have just heard have not appeared here in support of



a particular point of view.  I myself believe that is why



their participation in this procedure is all the more




important,and I wish to express the gratitude of the Lake




Michigan Federation and the Open Lands Project to them.




          Earlier I stated that I would conclude by making



a proposal for an alterrv: tive of protecting the lake to




adoption of the Department of Interior proposal to prohibit




discharge of heat into Lake Michigan.  Before discussing
-------
                     Mrs. L. Botts




it, I would like to make clear that in the absence of any




other alternative, the Open Lands Project will continue to




support the Department of Interior   recommendation.




          My proposal is to establish a new means of siting




powerplants, based on public participation through review




by hearings in the early stages of the process, and with




enforcement powers lodged with an interstate agency estab-




lished for the purpose.  Policy for the agency would be



determined by an advisory commission representing various




sectors of the public, the power industry, and State and



local governments.




          The first step toward establishment of this new




system would be development of criteria to serve as guide-



lines for the following processes:




          1.  The location of powerplants.




          2.  The operation of powerplants.



          3.  Means of evaluating environmental effects



of operation of powerplants.



          4.  Definition of conditions under which power-



plant operations would be suspended temporarily and/or




permanently.



          A good start toward development of criteria may




have been made in this enforcement conference, where thanks



to the brashness of the Fish and Wildlife Service, the
-------
                                                      1392





                     Mrs.  L.  Botts




issues are at last out on the table.  Perhaps the process




could be carried further by a roundtable conference in




which the scientists would be free to challenge each other




and members of the public free to challenge them.




          I am certain the Lake Michigan Federation advisory




council would welcome an opportunity to join with Common-




wealth Edison, other power companies, and the staffs of the



various Interior agencies in planning and carrying out such




a conference.




          When it met, I do not think there would be any




disagreement that the first task would be to define the




research needed and to set a timetable for its accomplish-



ment.




          Parallel with establishment of criteria, the



States around the lake would have to enact their own legis-



lation in support of the interstate siting commission, and



approval of Congress would have to be obtained.



          Obviously, this is a very cursory discussion of




a complex process, but it is offered here to demonstrate




that conservationists object to the way powerplants have




been sited in the past, not to their being sited at all.




I believe this conference has demonstrated the urgency



of arriving at a decision on the question of whether the




existing nuclear plants should be permitted to operate as
-------
                                                         1393
                      Mrs. L. Botts



constructed.




          Because of the time that would be required to



carry out my proposal, even if adopted, I see no alternative




except interim acceptance of a prohibition against dis-



charge of heat into the lake, and soon, in the interests




of power as well as the lake.




          If at this point the power industry continues to




refuse to accept the public desire for prevention of thermal




pollution, then it should be recognized that responsibility



for any future of failure of power supplies rests with the



industry that refuses to fulfill its function rather than




to change the way it carries that function out.



          Thank you.



          MR. STEIN:  Thank you, Mrs. Botts.  (Applause)



          Mrs. Botts, you suggest a procedure where we have



a forum for scientists to confront each other, and to be



questioned by the public.  I have been here for a week and



I think that is what has been happening.  This is a



rhetorical question you don't have to answer.  Also I



wonder, Mrs. Botts, if you have ever checked — because




this is one of my fields of specialty — on how long it




has taken us in the past from the idea of a reception to



get an interstate agency established in any field in water.



          MRS. BOTTS:  I am aware of that.
-------
                                                                                        1894
             EXISTING AND PROPOSED NUCLE-AR POWER PLANTS QN LAKE MICHIGAN
                                         FACT SHEET              September,  1970
Plant Name,
Location
Company
Capacity,
Megawatts
Cooling Water, *
Gallons /Day
Intake
Discharge
Maximum
Temperature
Elpyat.inn
Construction
Permit Date
Scheduled
Ooeration
Engineer-
Architect
Reactor
Contractor
Unique
Environmental
Factors
Ci- *ent
Sta.uS
Zion
2 units
Zion, 111.
Common-
wealth
Edison _,_.,
1085
each unit
1 billion
each unit
2600 ft.
offshore
760 ft.
offshore
19.6
degrees
December
1968
1972
1973
Sargent-
Lundy
Westing-
house
Multiport
diffuser
discharge,
small
site
Much pub-
lic opposi-
tion, 2
lawsuits
pending
Donald Cook
2 units
Bridgman,
Michigan
Indiana &
Michigan
Power Cg^
1054
1060
1 billion
each unit
2200 ft.
offshore
1200 ft.
offshore
21 degrees
March
1969
1972
American
Electric
Service
Corp. 	
Westing-
house
Shore
erosion
problem,
Harbor
permit
soueht
Discharge
distance
increased,
1 lawsuit
pending on
erosion
damage
Point Beach
2 units
Two Creeks
Wisconsin
Wisconsin
Electric &
Wis-jyiich.
497
each imtt
500 millioi
each unit
1750 ft.
offshore
150 ft.
offshore
19.3
degrees
July
1967
1970
1971
Bechtel
Corp.
Westing-
house
Five
miles
from
Kewaunee
Interven-
tion filed
to oppose
operating
license
Palisades
1 unit
South Haven
Michigan
Consumers
Power
Co.
700
700
million
3500 ft.
offshore
Canal to.
Lake
28 degrees
March
1967
Spring,
1970
Bechtel
Corp.
Combustion
Engineering
Highest
discharge
temperature
on lake
Intervention
hearing
underway
since June
Kewaunee
1 unit
Kewaunee
Wisconsin
Wisconsin
Public
527
520
million
1600 ft.
offshore
220 ft.
offshore
19.2
degrees
August
1972
Bailly
1 ,~,
1 unit
Burns
Harbor. Ind.
Indiana
Public
Service Co.
657
660
million
No permit
application
Big Rock
lunit
Charlevoix,
Michigan
Consumers
Power
Co.
75
70
_jmiUion. .
1600 ft.
offshore
No permit Canal
application > to lake
About
20 degrees
20 degrees
Announced j 1960
Feb., 1070 I
1976
Pioneer j
Service & Sargent-
Engineering Lundy
Westing-
house <
Five j
miles !
from
Two Creeks
On
schedule '
1
|
General
Electric
Inside
Nat'l Park,
warmest
intake
water
Capacity
increased,
public oppo-
sition befor<
constructior
1962
Bechtel
Corp.
General
Electric
Smallest
nuclear
plant on
lake,
coldest
water _
Experi-
mental and
only operat-
! ing reactor
on lake
* All the nuclear plants now being planned for Lake Michigan are of the pressurized water reactor type
 and are designed to use once-through cooling techniques, except the Big Rock and Bailly boiling
 water plants.
 This fact sheet has been prepared by the Open Lands Project, 53 W. Jackson, Chicago, Illinois 60604.
-------
                                                      1395
                     Hon. R. E. Mann




          MR. STEIN:  Thank you.




          May we hear now from State Representative Robert



E. Mann?








          STATEMENT OF STATE REPRESENTATIVE ROBERT




          E. MANN, CHAIRMAN, LAKE MICHIGAN AND AD-




          JOINING LAND STUDY COMMISSION, CHICAGO,




                           ILLINOIS








          MR. MANN:  Chairman Stein and other conferees.




I am appearing before you today as chairman of the Lake




Michigan and Adjoining Land Study Commission of the State




of Illinois to urge that you adopt the 1-degree Fahrenheit




thermal standard recently recommended by the U. S0 Depart-




ment of the Interior and that you do everything within



your power to see that your respective State water pollu-



tion control agencies or State legislatures make this stan-



dard enforceable under your State law.  The opportunity to



adopt a thermal standard which will protect Lake Michigan



is a rare if not unique opportunity for this conference.




Hopefully no serious irreversible damage has yet occurred




in Lake Michigan because of past and present discharges of




heat.  Action now can protect the lake from the very real



prospect of future damage.
-------
                                                        1896






                       Hon, R.  E. Mann




          All too often in the past the attitude of the




people who had the power to preserve the lake has been either




to wait until damage has occurred before acting or to take




action without knowing it would solve expected problems.




          To date, two Federal-State conferences have been




convened to deal with pollution of Lake Michigan.  There




should never have been any need to call these conferences.




If action had been taken in time, the pollution of the lake




would never have occurred.  Let me be more specific.




          The first conference which dealt with Lake




Michigan was convened in March of 196$.  This conference




which centered on the Calumet area took two basic steps to




abate the pollution which was reported in a United States



Public Health Service document published a year earlier.



First, it adopted water quality criteria for the lake and



surrounding waterways; second, it adopted requirements for



improvements in the waste treatment methods of municipalities



and industries, setting deadlines for completion of these



improvements.




          On first glance this sounds fine.  But the




standards specified only how bad we would let lake water




become, not how much polluters would be allowed to dump




into the lake.  And the schedules for waste treatment



improvement have often been laxly enforced.
-------
                                                      1S97






                     Hon. R. E. Mann




          As could have been expected,  in August 1969» a



preliminary report of a technical committee which had been




appointed to "assess ,.. the results obtained by conference




actions and determine whether further action by the con-



ference would be required by the conferees to achieve




satisfactory water quality in the conference area, ..."




concluded that in general, water quality in the conference




area was still unsatisfactory based on sampling data taken




between August 1966 and March 1969.



          The point is that long ago we knew our lake was




deteriorating yet the Federal-State enforcement conferences



took a circuitous route to meet the problem, without sig-




nificantly bettering the situation.  These conferences




didn't go to the heart of the problem.   They didn't regulate



how much junk could go into the lake by adopting effluent



standards.  As a result of not adopting such standards we



are at this late date, according to State of Indiana




authorities, subjecting our lake to the following punish-



ment in that State alone:



          513,36$ pounds of suspended solids per day



          115,316 pounds of oil per day




          12,&2& pounds of cyanide per month.




          Let me cite another example of the laxity which



I think has pervaded these conferences in the past.  In
-------
                     Hon. R. E. Mann




April 1964 a report of the United States Public Health




Service suggested that although algal growths in the




Calumet area were not as dense as in other areas of the



lake, this may have been due to the presence of toxic sub-




stances which inhibited algal growth despite the high




nutrient content of the water in the south end of Lake



Michigan.  At the first session of the Two-State Conference




in 1965» Mr. Hyman Gerstein of the Chicago Water Department



stated that one of the most alarming features of the




pollution picture was the indication of accelerated Lake



Michigan eutrophication.  He reported that nutrient levels




had increased and that algal growths of nuisance propor-




tions had occurred.  Yet the conference made no reference



in its recommendations to nutrient problems.  In fact,



by only requiring secondary treatment for municipal sewage,



the conference virtually assured that phosphorus, which is



perhaps the key nutrient to be controlled in preventing



eutrophication, would continue to enter the lake in signi-




ficant amounts.  Only in 196$, when the Four-State Confer-




ence was convened did eutrophication receive significant




consideration  And that action may have been not only too




late but too little.  Mr, Jacob Dumelle, formerly with




the Federal Water Quality Administration and now a mcnbnr




of the Illinois Pollution Control Board, has recently
-------
                                                      1899






                     Hon. R. E. Mann




 stated that original estimates of Lake Michigan phosphorus



 input may have been too low.  This raises the question of




 whether the 80 percent removal standard adopted by this




 conference is sufficient to retard eutrophication of our




 Iake0



          I realize I have strayed from the precise topic



 of your deliberations today.  I felt it was necessary,




however,  to graphically demonstrate that you as  conferees




 have some amends to make to the citizens of the States you




 represent.  I can suggest no better way than by taking




 strong action to retard, if not eliminate, the heat loading



 that is currently plaguing and planned for our lake.




          The Lake Michigan and Adjoining Land Study



 Commission has formally recommended the adoption of the




 proposed 1-degree Fahrenheit standard.  This was done after



 a serious review of the available literature which left



 no doubt in our minds that deleterious effects were quite



 likely to result from gross thermal inputs into Lake



 Michigan, that the technology to avoid this danger was



 available and that no better method existed to spur




 development of alternative  and nonpolluting sources  of



 power.  I am submitting for your consideration a copy of




 the brief we prepared to support these conclusions.




          I must add one caution.  The 1-degree Fahrenheit
-------
                                                        1900





                     Hon. R. E. Mann




standard will be meaningless if powerplants are allowed to




be constructed in such a way that tremendous amounts of




heat will continue to pour into the lake through dilution




by merely increasing the amount of cooling water used in




the plant.  I trust that such a safeguard will be made part




of your recommendationo




          I want to pause just a moment to say something




about the Zion plant.  When the Illinois Pollution — when



the permit was granted to the Zion plant, it was granted



for the purpose of construction only; no commitment was made




to Commonwealth Edison that they could operate.  Now, when



Commonwealth Edison, through its paid mercenary experts,




testifies and implies that only one plant will do no damage




to Lake Michigan, it is ignoring the realities of Illinois



politics.



          I have been in the Illinois General Assembly for



& years.  I know from bitter experience how effective and



pervasive the special interests of this State are.  If




you permit Zion to operate without fully putting the burden




of showing that no damage, no degradation to the lake will




take place, then you will not be able to stop a ring of



powerplants around this lake.




          I hope I don't sound dogmatic on it; I hope I



sound bitter, because it is from experience of 8 years on
-------
                                                      1901
                     Hon. R. E. Mann




the Illinois General Assembly,  and I am saying this pointedly




to my constituents.




          Chairman Currie, I know, has already demonstrated,



I think, great expertise in his new role, but I want to




share that one piece of experience that I have had as a




member of the Illinois General Assembly.




          I think Commonwealth Edison, I think this con-




ference, I think State Representative Bob Mann, I think



everybody else concerned with the lake owes accountability




to the people of this State.




          That lake is held in trust for the people of the




State of Illinois, and I would hope that one of the resolu-




tions which would come out of this conference is that



Commonwealth Edison ought to be put on notice that the




fact that they have invested millions of dollars into that



plant has nothing to do with the welfare of the State of



Illinois or with that lake.  If they have made a mistake,



that is their problem; that is not our problem.  (Applause)



          In closing, let me state a principle that I think




should be the guidepost in your deliberations.  Our natural




resources are a public trust precariously held in your




hands in this instance.  As our trustee, you must demand




that those who propose to tamper with the lake prove



beyond any reasonable doubt that no deleterious consequences
-------
                                                       1902
                       R. E. Mann



will result from their actions.  After the delays of the




past, nothing less than this is acceptable.




          And I would add just one thing,  Chairman Stein.




I have not meant to go into the gunnysack with regard to




past actions.  These are over and past.  But I think that




all of us can learn from the bitter experience from the




past and realize that the time is reached where we must



now have no — no further degradation of our land.  Thank




you very much.  (Applause)



          MR. STEIN:  Thank you.  Are there any comments




or questions?




          Mr. Mann, I would like to ask you one question,



if you would wait —




          MR. MANN:  Yes, sir.



          MR. STEIN:  — just for a second.



          MR. MANN:  Yes, sir.



          MR. STEIN:  I would like to get your views on



that since you have had experience with this.  As I under-




stand it — and I have heard this sometimes before in other




areas of the country — that you indicate that when these




plants were built, and particularly the Zion plant, the




construction — the plant was built and now you are faced




with operation.  Is that correct?




          MR. MANN:  Yes, sir0
-------
                                                      1903
                       R. E. Mann



          MR. STEIN:  In light of that, what do you think



of the proposal that we heard from the power industries




that we permit them to discharge heated water into the lake




and after a couple of years if you find it is doing damage




to take corrective action?




          MR. MANN:  I don't like it because I don't believe




it.



          MR. STEIN:  Are there any other comments or




questions?  If not, thank you very much, Mr. Mann.




          MR, MANN:  Thank you, sir.




          MR. STEIN:  Several of the people have submitted




statements for the record, and without objection, I would




like to put them in as if read:  Charles D. Sigwart, Student




Council on Pollution and Environment; Robert A. Butler,



President of Rosemary Beech Association; and Dr. C, H.



Mortimer, Director, Center for Great Lakes Studies.



          We try to accommodate everyone, but I think we



have come to the point where our reporter just has to have



a break, and we are going to have a five-minute recess.



          (Short recess.)




          (The statements above referred to follow in




their entirety,,)
-------
                                                                  1904

         Statement on Thermal Pollution     Oct. 2,1970

   Charles D. Sigwart                   B.S. engineering, MIT 196?
               currently a PhD candidate Northwestern University, Dept.
                 of Biological Sciences

   representing! Student Council on Pollution and Environment (SCOPE),
        an advisory committee to the Dept. of the Interior;   and
        Northwestern Students for a Better Environment (NSBE).

     The current growth rate in energy production and in energy use
per capita will probably continue.  Inevitably a large part of the
energy is transferred to the environment as waste heat.  In view of
this trend we must seriously consider the precedents we are setting.
We must not view only the effects of single sources of thermal effluents
today but must consider the total effects as the thermal load on our
lake doubles redoubles with coming decades.   Current practice favors
applying the thermal load to nearshore waters  which are the biologically
most productive areas of our lake.   If we continue the effect on
Lake Michigan will be substantial.   At a minimum, even small  changes
in temperature can cause large shifts in the relative numbers of
various species of fish.  It is not pertinent to argue relative merits
of particular species, but it takes only small changes to disrupt
the reproductive cycle of some species or to eliminate their food
supply(l)(2).  Another serious problem is that the nutrient levels
in nearshore waters are approaching the levels found in Lake Erie
and increases in temperature will tend to encourage excessive algal
growth{3)»    These nearshore waters do not freely exchange with
the rest of the lake due to the longshore currents and the periodic
development of the thermal bar(4).
     In view of the complexity of the problems we cannot hope for a
simple standard which will protect the lake into the forseeable future.
Therefore we reccomend thatt
 A.  In granting permits to discharge thermal effluents it should be
incumbant upon the applicant to show adequate reason to believe that
his discharge vrill not cause ecological damage.
 B. and that Thermal discharges should not be allowed in nearshore
waters.including plumes swept there by currents, which exceed one
degree Fahrenheit.
C.  Larger, temperature differences from ambient might be tolerated
provided (A.) is satisfied and it is shown that heated water does not
reach nearshore waters.
     The need to protect the most biologically active waters is
pointed up by the various reccomendations of the National Technical
Advisory Committee on Water Quality Criteria in 1968  of a 3°F.
standard for lakes and a 1.5°F. standard for estuaries in summer(5)*
particularly where spawning areas are involved.
     These reccomendations are made with due consideration that there
are technically feasible alternatives to reduce the thermal load on
Lake Michigan which are economically feasible(6).	
(1.)  Mackenthun,  Ike  Practice' of  Water  Pollution  Biology, FWPCA,  1969,p.l9ff
(2)  Physical  & Ecological Effects  of Waste  Heat  on  Lake Michigan, Bur.
 Commercial Fisheries, Great  Lakes Fishery  Lab,  Sept.  1970,  p.7-18
(3)  ibid.  p.78
(1*)  ibid.  p.21-22
(5)  National  Technical Advisory  Committee,  Water Quality Criteria.  1968
  FWPCA         P.33,P.42,p.70
(6)  Feasibility  of Alternative Means of Cooling  for Thermal Power Plants
Near Lake Micniffgn"   l''WQA August,1 i"9~7"0~
-------
         2  WO t0
Mr.  Chairman:                          -<£, /, -
                                                            /cy         ^ X_ t_£
       My name is Robert Butler and as President of the Rosemary Beach


Association I am representing that group at this conference.  The Rosemary


Beach A ssociation is comprised of 33 families who live immediately north


of the Donald C.  Cook Nuclear Plant in Bridgman,  Michigan.  We are very


much disturbed by the gigantic enterprise that is being developed next door.


And in particular, we fear the consequences of thermal pollution since, ac-


cording to present plans,  millions of gallons of heated water will be dis-


charged daily approximately 1100 feet from the shoreline.  Prevailing winds


in the summer will bring this plume of hot water directly to our beach.  A


prolific growth of undesirable forms of algae would render our recreational


facilities  completely unsuitable.  Moreover, should the duration of  ice form-


ation in winter be shortened,  our beach would be subjected to devasting


erosion from the winter storms.  On more general and important terms,


we are gravely apprehensive about the future of the lake as a viable natural


resource  to be enjoyed and admired.


       What will happen if the power companies are permitted to discharge


hot water into the lake and our fears become a reality?  A  representative


from the Michigan Water Resources Commission had a suggestion.  At a


public hearing  before the Army Corps of Engineers in Bridgman, Michigan
last year exclaimed: "If you have a case, take it to court. " But it would be
         A

absurd to believe that our group with its most modest financial resources


could counter successfully a giant such as the American Electric Power


Company.  Because of the complexity of the problem, legal action on our
-------
part would be enormously expensive.  We simply could not afford such an


undertaking.  Furthermore, we were distressed to hear this advice from


an official of a state agency formed ostensibly to protect the public interests.


This is why we feel the desperate need for a governmental board comprised


of dispassionate experts in ecology; a board empowered to act decisively


to protect our natural resources.   To permit the power companies to in-


crease the rate of eutrophication of Lake Michigan for purely  economic


reasons would constitute a stark betrayal of public trust.


                                    Respectfully submitted,
                                    f^ &     r<~^
                                    Robert Butler, President
                                    Rosemary Beach Association
                                    Stevensville,  Michigan
-------
                                                                190?
              Lake Michigan Beach Zone V. aters:
              Vjriatio/is in Temperature Arising
                    from Natural Causes
                             by
                  C.  H. Mortimer, Director
               Center for Great Lakes Studies
              University of Wisconsin-Milwaukee


                        September 1970
A Contribution to discussion of the Report by the U. S. Department
of the Interior,  Fish & Wildlife Service (September 1970), "Physical
and Ecological Effects of V. aste Heat on Lake Michigan",  presented
at the Third Session of the Federal-State Enforcement Conference
on Pollution of Lake Michigan, 28-29 September 1970, Chicago,
Illinois.
-------
                                                                              1908
   Lake Michigan Beach Zone V< aters:   Variations in Temperature Arising
                           from Natural Causes
Contribution* to discussion of the Report by the U.S. Department of the Interior,
Fish & Wildlife Service (September 1970), "Physical and ideological Effects of
Uaste Heat on Lake Michigan", presented at the 3rd Session of the Federal-
State  enforcement Conference on Pollution of Lake Michigan, 28-29 September
1970, Chicago, Illinois.
                                   *by
                         C. H. Mortimer,  Director
                       Center  for Great Lakes Studies
                    University of U isconsin — Milwaukee
                        Milwaukee, V>isconsin 53201
 Introduction
         Seventeen years ago, on my first visit to this country,  I began looking
 for clues to Lake Michigan water movements in the temperature records of
 municipal water  intakes.  Because of the large volume flow, the temperature
 of the raw water taken into the plant is virtually the same as that at the intake
 point, typically some 50 ft below the lake surface and some 5000 ft offshore,
 i.e., just outside the "beach water zone" defined in the above Report.  I was
 astonished at the large and often rapid temperature fluctuations  at the intakes
 in summer,  apparently related to motion of the thermocline.  I  also discovered
 that, when the thermocline remained for several days near intake depth,
 wave-like fluctuations were seen (example in Fig. 1).  These led to a study of
 internal waves, which continues today.
         If the intake temperatures are plotted on a less open time scale than
 in Fig. 1, and stations on opposite sides of the lake are  compared (Fig. 2),
 large, irregular fluctuations are apparent,  and these are often out of phase
 across the lake. This behaviour indicatps motion of the whole basin,
 involving an upwelling on one shore (producing low intake temperatures) and
 a "downwelling" on the other shore (producing high intake temperatures).
-------
                                                                         1909
        One of the principal questions before this Conference concerns
"thermal stresses" which may arise in inshore waters of Lake Michigan from
the expanding requirements of the power industry and other municipal and
industrial users.  The purpose of the present note, therefore,  is to describe
the natural background against which the anticipated "stress" must be
examined; and a memorandum was prepared for the Conference before the
recent receipt of the above Report.  As that Report gives background infor-
mation on the annual thermal regime of Lake Michigan, that portion I have
therefore  omitted. But I find that, presumably because of space restrictions,
the Report does not treat the natural variability of  temperature in more than
a paragraph (p. 11) and in a greatly smoothed annual diagram (Fig. 6, "beach
zone water temperatures").   The present shortened note may,  therefore,
serve a useful purpose in drawing attention to the conspicuous variability
during summer and also by making the point that the Chicago water intake
(used in the preparation of Rept.  Fig. 6) shows  much less summer variability
than do intakes situated along the middle reaches of the basin.

Coastal Upwelling
        The cause of the major fluctuations in intake temperature—upwelling
induced by wind stress combined with the influence of the earth's rotation—is
well illustrated by comparison of Figs. 2 and 3. By a fortunate coincidence,
the Fig. 3 multi-ship survey was carried out, on 9 August  1955, just  after
two days of strong wind from the north* had brought about massive upwelling
along the  greater part of the  eastern shore. On 7  August there were sharp
rises and falls of temperature at intakes on the western and eastern shores,
respectively.  At Milwaukee  and Racine, for example,  Fig. 2.  shows a rise
of 15nF in 12 hours,  with an  even greater rate of fall in temperature (20°F in
6 hrs) at  intakes on the eastern  shore.  As Fig.  2  is based on  6-hr means,
         t Ayers et_al. 1958.
         *The Lak~e appears to be particularly sensitive to winds veering
 from west to north, see mortimer 1963.
-------
                                                                        1910
the actual temperature changes must nave been more rapid than the figure
indicates.
        The order of magnitude of commonly occurring rates of temperature
change  can better be assessed in Fig.  4, in which the intake temperatures
are plotted,  for the months of July and  September 1963, as hourly readings,
or hourly means derived from  thermograph records. The greatest
variability and the greatest rates of rise and fall were again found at the
eastern intakes:  Ludington, iviuskegon, and South haven,  where rates of fall
of 8°F per hour were not uncommon, while the rates of rise at these intakes
were generally less.  At the corresponding western intakes—from waukegan
northward--the rates of rise and fall were consistently less than on the
eastern shore, values of 3QF per hour being typical. The variability at
the southern end of the basin--Chic ago  and Michigan City--was considerably
less than that further north.
        The general conclusion is that temperature variability in beach zone
waters is greatest at stations in the middle reaches of the lake (there are no
intakes north of Jttostok) and least at Chicago.  In general, the rates of
temperature rise and fall are highest on the eastern shore,  where also
the highest maximum temperatures are attained  (and maintained for longer),
for example, reaching a 1963 maximum of 75°F  at Muskegon and Michigan
City.   During 1955 (Fig. 2) the temperature  maxima were 80° F at
iViuskegon and 82°F at benton harbor and iviichigan City,  maxima during
1955 at intakes along the western  shore were some 8°F lower.  There is
considerable variation from year  to year* both in timing and dur^ion of
upwelling periods (compare, for example, Figs. 2 and 4); but the high
summer variability with rapid temperature changes is a persistent feature
representing a randomly-occurring thermal stress to organisms in  the
beach zone waters.  The occurrence of this stress is as unpredictable as
         *I have assembled 20 years of summer records with the kind help
of "pen friends" in various municipal filtrations plant.
-------
                                                                       1911
the occurrence of the wind systems which cause the upwellings. Vvith the
sediment disturbance and high turbidity which follow onshore winds on long
stretches of Lake Michigan shoreline, and with winter icing and the wide
summer temperature range here described, the beach zone waters of Lake
iviichigan represent a biologically unfavourable environment and one in which
the bottom fauna is generally relatively sparse.
        The controlling influence of Lake-wide motions on inshore tempera-
tures is confirmed by comparison between the intake temperatures illus-
trated in Fig.  4 and the cross-Lake temperature distributions illustrated for
selected railroad ferry crossings from Milwaukee to Muskegon in Figs.  5,
6, and 7 (from Mortimer 1968).  The upwelling and downwelling zones
occupy, typically,  near-shore strips of order 10 km width. Further offshore
the influence of (near-inertial) internal waves is  dominant.  That the wave
pattern  is not confined to the  cross-Lake section is demonstrated by Fig. 8,
which shows not only western upwelling on two sections (compare
Milwaukee and fcheboygan intake temperatures for 29 July in Fig. 4),  but
also (portions  of) wave patterns in the N-S longitudinal section.
        Up to this point, this note has dealt in facts relating to natural
variations in Lake Michigan inshore temperatures. In conclusion, I offer
a few

Comments prompted by a first reading of the report
        Tae neport makes tae commonly ueld assumption that power
generation, now doubling approximately every decade, will continue to do
so until the year 2000,  i.e.,  an eight-fold increase over the 1970 figure.
The Federal Power Commission,  however, has not yet forecast beyond
1990. My own rough estimates up to that date (see Tables in appendix)
are not at variance with those in the Report. They indicate that the Lake-
wide effects will be small (for example, the only important Lake-wide
effect appears to be that, by 1990, the water loss would increase by not
-------
                                                                        1912

                                                                       5
more than 2% above natural evaporation,  representing also about 2% of the
mean Lake discharge), but that the main thermal effects will be concentrated
locally.  The crucial unanswered question is:  "How locally?"
        As the Report emphasizes, the added heat must pass through near-
shore water before complete dissipation in offshore regions; and turbulent
diffusion is usually the principal transport mechanism.  The rates of
turbulent diffusion will largely control the residence time of the added
heat in the beach water zone.  In appendix Table II this zone is defined as that
bounded by the 10 m (33 ft) contour.  A guess at a possible mean residence
time of 10 days for the heat added to this zone yields an increase of 0.66*C
above "ambient" averaged over the whole of the zone.  The use, if any, of
such an estimate is to indicate an order of magnitude only.  The residence
times and the amounts of heat added will vary greatly between one region
of the beach water zone and another.
        The  greatest and most serious unknown is the magnitude and the
variability, in space and time,  of the eddy diffusion coefficients. That
variation is certainly extremely wide; and this makes realistic modelling
an almost intractable task.  For example, we may visualize two extremes:
one, case (a), in which an upwelling movement, of the kind described in this
note, removes the whole inshore water mass from many miles of coastline
in a few hours (see Fig. 3); and another,  case (b), in which diffusion rates
are low during a temporary minimum  in inshore  current activity, or during
the  early stages of a developing thermal bar.*  Case (b) is, of course, the
        *The mechanism of the thermal bar, with a brief account of the his-
torical development of the concept,  is outlined in the appendix and Fig. 9.
V< hile it is likely to be an important factor in thermal loading of the Great
Lakes, the thermal bar should not be looked upon as a nearly complete barrier
to heat transfer  (as the Report appears to suggest on p. 22).  V^hile the "bar"
temporarily impedes horizontal mixing between the water masses on either
side of it, there is continual mass (and heat) transport toward the convergence,
and a downward  transport of the mixed water mass to deepe4 regions of the
lake is maintained (see Fig. 9b).   It would be useful to have a rate comparison
between the vertical transport in the thermal bar and horizontal transport by
turbulence when the bar is not present.
-------
                                                                        1913
                                                                       6
critical one for thermal loading; but, with present knowledge, prediction of
its frequency or probable duration is highly unreliable.
         In view of the difficulties outlined above, the Report cautiously
assumes the worst case, thereby maximizing the "thermal stress" in the
beach water zone.*  The Report also attempts, again with proper caution,
to list all the harmful ecological effects which present knowledge suggests
might occur.  Some of the suggestions on the list are necessarily specula-
tive; but equally speculative advantages of added heat have not been con-
sidered (for example, enhancement of the capacity of the Lake for self-
purification from the polluting wastes, which today pose a much more
serious threat to the Lake's ecological health than do thermal additions).
         ]Viy principal disappointment with the Report is that while it
catalogs what might happen, it has not sought evidence (or recommended
research to discover) what in fact has happened to the ecology of the Lake
near the cooling water outfalls of existing large power plants.  Some of
these plants, of size-order comparable to the planned nuclear plants,
present us  with ready-made full-scale experiments which have been
running for years.  In view of present uncertainties and ignorance (both
physical and biological) this is an opportunity which should not be passed by.
A thorough study near such plants could lead most directly to realistic
assessment of safe  thermal limits, to criteria for siting new power
stations well away from biologically sensitive areas, and to a well-informed
public value judgment on this issue.
        *Its companion Report, U.S. Dept. of Interior (August 1970),
"Feasibility of Alternative Means of Cooling for Thermal Power Plants
near Lake Michigan" does not examine the possibility of piping the
effluent two miles or more offshore to reduce thermal stress in the beach
zone and to achieve better entrainment and dispersal.  This possibility
may also be worth considering in future for municipal sewage  plant and
storm water outfalls, which in favourable circumstances might be com-
bined with power station outfalls.
-------
                                                                    - 1914
                                                                    7
        The public is already paying heavily, in one way or another, for
an astonishing multiplicity of research effort on "thermal pollution".
Nevertheless, I would:
Recommend that an integrated effort be made to answer, through ade-
quately planned and adequately equipped studies carried out on a year-
round basis at selected existing Great Lakes power plants,  the following
questions:  "What variations are there in patterns of heat dispersal in the
Lake ?" and "What influence have these patterns had on Lake ecology ?"
An answer to the first question will involve descriptions of the currents
and the turbulent regime under different weather and  Lake conditions,
based not only on the dispersal of heat, but perhaps also on the dispersal
of more conservative (chemical) properties, for example, the chloride
input from major rivers, or controlled artificial additions.  (For example,
Dr. Ayers'studies of dispersal of river water in the Lake indicate, I
understand,  a comparatively high rate of turbulent dispersal.) An
answer to the second question will involve control studies in regions not
influenced by thermal addition.  If this (applied) research program is
adequately conceived to answer the above two questions, then it will
also teach us a great deal we need to know about Lake Michigan.
                                          C. H. Mortimer
                                          24 ^mber 1970
References
Ayers, J.D., D. C. Chandler, G.H. Lauff,  C.F. Powers, &E.B.Henson
      1958. Currents and water masses of Lake Michigan. Univ. Michigan,
      Great Lakes Res.Div.,  Publ No.  3, 169 p.
Mortimer, C. H. 1963.  Frontiers in physical limnology with particular
      reference to long waves in rotating basins. Proc. 6th Conf. Great
      Lakes Res. ,Univ. Michigan, Great Lakes Res.Div., Pub.No. 10:49-45.
Mortimer, C. H.  1968.  Internal waves and associated currents observed
      in Lake Michigan during the summer of 1963.  Univ. Wisconsin-
      Milwaukee, Center for Great Lakes Studies, Spec.Rept. No.  1,
      144 p.
-------
                                                                  1915
                         APPENDIX
         Tables I and n and Note on the "Thermal Bar" presented
 at the 2nd Annual Four-State Conference "Power Production and
 Protection of the Lake", sponsored by the Open Lands Project, at
 Zion, Illinois,  2 May 1970 (also embodied in a memorandum pre-
 pared for the Argonne National Laboratory entitled:  "Electric
 Power Stations on Lake Michigan:  A Simple Approach to Assess-
 ment of Physical Effects on the Lake", March 1970). Line 4
 (power to be dissipated,  109 BTU's/hr) has been added for compari-
 son with Table 8, p. 29, of the  U.S.Dept.  Int. 1970 Report.
  Lake Michigan:  Estimated thermal influence of electric power
            generation for the years 1970-1990, I.
Units
Estimated electric power generated lo9 w(e)
Assumed overall efficiency
Power to be dissipated
Power to be dissipated 10s
Daily equivalents: (i) Heat*
(ii) Area and volume of "slab"
of cooling water, 1 m thick
raised in temperature by 10° C
%
109 w(h)
BTU's/hr
1013g-cals
km2
1012cm3

1970
n
i
30
16
54

33


1975
14
33
28
95

58


1980
20
35
37
126

76


1990
50
40
75
255

154


w(e) = watts of generated electric power; w(h) =  watts dissipated
         as heat.

*109w(h) =  103 Mw(h) = 2.06 x 1013 g-cal/day =  3.415 x 109 BTU's/hr.
                               8
-------
       Lake Michigan: Estimated thermal influence of electric power
                  generation for the years 1970-1990, II.
                                                                       1916

Power to be dissipated (cf. Table I)
Daily equivalent heat input
(i) whole lake surface
(5.81 x 1014cma)
(ii) inshore strip of depth
< 10m*
Temperature rises, assum-
ing 10-day storage:
(i) whole lake volume
(4.78 x 1013cm3)
(ii) inshore strip of depth
< 10m (2.3xlOI3cm3)
Equivalent evaporation(per year)
(i) volume
(ii) decrease in whole lake
level
(iii) percentage of mean out-
flow (46 x 103 cfs)
(iv) percentage of natural
annual evaporation (26 in)
Unit
109w(h)
g-cal/cm2
g-cal/cm2
°C
°C
1014cm3/yr
cm/yr
%
%
1970 1975 1980 1990
16 28 37 75
0.57 1.0 1.3 2.6
7 12.5 16 33
.0007 .0012 .0016 .0032
.14 .25 .33 .66
2.0 3.6 4.7 9.5
0.34 0.62 0.81 1.63
2.3
2.5
* 8% of whole lake surface
^assuming all heat dissipation is through evaporation (590 g-cal/cm3  at 10°C)
-------
                                                                          1917
                            The Thermal Bar

   The thermal bar convergence will probably turn out to be an important fea-
ture of the annual temperature cycle and nearshore circulation in all very large
temperate lakes.  It arises because, in such lakes, the inshore shallow waters
cool off more quickly in the early winter and warm up more quickly in spring
than do the deeper offshore waters.   Thus, in late December and early January
in Lake Michigan , inshore waters have cooled below the temperature of maxi -
mum density (4*C) while the offshore well-mixed deep waters still remain
slightly above that temperature.  Forel (1895) was the first to observe  (in the
Lake of Geneva, Switzerland; see his schematic representation in Fig. 9a) that,
in the mixing zone between the inshore and offshore water masses, the mixture
(at maximum temperature near 4"C) is denser than either of the component water
masses; and it consequently sinks.  The conversity of the curve relating tem-
perature and density of pure water,  with a maximum  at 4°C, shows why this
should be so.
   The sinking mixed water mass is replaced by surface convergence of more in-
shore and offshore water, leading to continued mixing and sinking.  This conver-
gence mechanism, recognized by Tikhomirov (1963) both in spring and early win-
ter in Lake Ladoga (Fig.9b),  acts as a temporary thermal barrier to horizontal
exchange between nearshore and offshore water masses. The thermal bar is
most strongly developed in spring and early summer  and forms a sharp division
between stratified water with high surface temperatures inshore and unstratified
water below 4*C in the deep offshore regions.
   As spring heating continues, the thermal bar moves  progressive o!fchore
until stratification is established right across the Lake  (Fig.9c, after Rodge»s,
1966).  A similar sequence of events during spring will probably be found in Lake
Michigan, first in the southern half and later in the northern half of the basin;
and Fig.9d (Church, 1945) probably represents the aftermath of a thermal bar in
the northern half of the Lake.
   Currents induced by the thermal bar have components parallel to the shore-
line and normal to the shoreline (i.e., toward the convergence); and there are
also  (smaller) descending currents in the convergence (Huang, 1969).
-------
                   References (Thermal Bar)
Church,  P. E.  1954.  The annual temperature cycle of Lake Michigan
      (n): Spring warming and summer stationary period, 1942.  Misc.
      Rept. No. 18, Inst. Meteorology, Univ. Chicago (Univ.Chicago
      Press).

Forel, F. A.  1895.  Lac  Ldman.  Monographie Limnologique,  Vol. 2
      (Paris),  651 p.

Huang, C. K.  1969. The  thermal current structure in Lake Michigan,
      a theoretical and observational model study.  Univ. Michigan,
      Great Lakes Res. Div., Spec.Rept. No. 43 .

Rodgers, G. K.  1966. The thermal bar in Lake Ontario, spring 1965
      and winter 1965-66.  Proc. 9th Conf. Great Lakes Res.,  Univ.
      Michigan, Great  Lakes Res.Div.,  Pub. No. 15: 369-374.

Tikhomirov, A. I.  1963.  The thermal bar in Lake Ladoga.  Bull.
      (Izvestiya),  All-Union  Geogr.Soc., 95_:  134-142  (Amer. Geophys.
      Union Translation, Soviet Hydrol., Collected Papers No.  2).
Legend to the following Figure 9.  The Thermal Bar:  (a) in winter in
      Lac Leman (Forel,  1895); (b) in spring and winter in Lake
      Ladoga (Tikhomirov,  1963); (c) formation and development in Lake
      Ontario (after Rodgers, 1966); (d) aftermath of a thermal bar in
      June in northern Lake Michigan (Church, 1945).
      [ Fig. 9b is attributed to Tikhomirov in S. V. Kalesnik's book
      "Lake Ladoga," Leningrad, 1968.]
-------
 1919
  -a
w c
C ?H
TO 0)
£',
  O

  Jj

  bfl
  C. C
  rt 0
o. o o;


S §^
"I « 13
 til
 0)  !H  I
 Q)
   .
   o
 0
     o


     M

     «
 QC
-------
                                                                            1920
                                                       i I I i i i i i i i i i i i i

                                                       LUDINGTON
                                                      A J        s  '>
                                                      ''»?,  A     •   \
                                                  -_,/_>U-\^/'	1'.^
                                   DATE OF FiG. 3 CRUISE
Fig. 2.  Temperatures, °F, at the following municipal water intakes (July to Sep-
        tember 1965): Two Rivers,  Wis.(35); Ludington,  Mich. (45); Milwaukee,
        Wis.(55); Muskegon, Mich. (50); Racine, Wis.(29); Michigan City, Ind.
        (38).  The numbers in brackets indicate the depth of the intake in feet  belov;
        the lake surface.   The above graphs represent 6-hr mean temperatures,
        prepared  from thermograph records or from other readings, except for
        Two Rivers and Ludington, tor which only daily readings were available.
-------
                                              SURFACE TEMPERATURE
                                                      °C
                                                   SYNOPTIC  3ZI
                                                   9 AUGUST  1955
                                                                     1921
Fig.  3.  Lake Michigan surface temperature, °C, S August 1955, based on a
        multi-ship survey (Ayersj^tjil. 1958).  The corresponding temperatures
        at the coastal water intakes are shown in Fig. 2.
-------
              1922
Figure 4.
-------
                       kilometres  from  Milwaukee  breakwater
   1923
120  127
Fig. 5.  Lake Michigan 1963:  Distribution of temperature,  °C, in the Milwaukee
        Muskegon section (selected from a series obtained on railroad ferry
        crossings, Mortimer 1968), Run. No. 164, 19 July.
-------
20
                        Kilometres  from Milwaukee  breakwater
                           40     .     6O          8O
                                              100
                                                             1924
                                                         120  127
Fig. 6.  Lake Michigan 1963:  Distribution of temperature, °C, in the Milwaukee -
         Muskegon section (selected from a series obtained on railroad ferry
         crossings,  Mortimer 1968), Run. No. 192,  6 August.
                                               -3.-TIMEtCS.TJ                      1
            20
                          21
                        -JL-.
                        22
                                                      23
                                                                     1
-------
                 20
kilometres  from  Milwaukee  breakwater
   4O     .     60         80
                                                               too
                                                                             1925
                                                                          120  127
Fig. 7.  Lake Michigan 1963:  Distribution of temperature,  °C, in the Milwaukee-
        Muskegon section (selected from a series obtained on railroad ferry
        crossings, Mortimer 1968), Run.  No. 214, 16 August.
-00

,
|

	 1 	 L_
LAKE MICHIGAN 1963: TEMPERATURE DISTRIBUTION. 'C,
IN THE MlLWAUKEE-MUSKEGON SECTION

1 . . . 1 , , , 1 , _.
RLIN NO 2i4
DATE: 16 AUGUST

1 , , ,
] " ~:

i i
-------
                                                                         1926
  Me
Fig.  8.  Lake Michigan 1963: Distribution of temperature, °C, along the cruise
        path of R/V "Cisco" on 29 July, from Milwaukee to mid-Lake,  then north
        for 16 km, then west to Sheboygan.  Isometric projection; direction in
        degrees (true).
-------
                                                                            1927
                 The thermal bar.
     Forel'e concept
 [«]
                LAKE  ONTARIO


SURFACE TEMPERATURE       MID-LAKE, N-S TEMPERATURE SECTIONS
                                                                       Surface Temperature

                                                                             i C«nhgro4<

                                                                          Junt 7-9.1942
          **t|
28-30 JUNE, 1965
                                                             • -V1 '   -'"' '   fc
                                                               si" v-   / '  MA
                                                               ,y»}  ,,'  i  ,,/•
                                                                    '•:67
                                                                                66*
                                                 Figure  9.  The thermal bar.
-------
                                                      1923






                     J. T. Sobota




          MR. STEIN:  Let's reconvene.




          William Singer.




          MR. SINGER:   I prefer to wait for the conferees.




          MR. STEIN:  You may have to wait a long time.




          MR0 SINGER:  I have waited since 9:00 o'clock.  I




think it is rude to ask someone to testify when there is no



one here to listen.  I have waited since 9:00 o'clock.  I




would rather not testify until the conferees are here to




listen.



          MR. STEIN:  Dr. Sobota.








          STATEMENT OF JOSEPH T. SOBOTA, M.D.,




          PRESIDENT, TEMP, KALAMAZOO, MICHIGAN








          DR. SOBOTA:  Chairman Stein, the Federal Water



Quality Administration, the Bureau of Commercial Fisheries,



the Bureau of Sports Fisheries and Wildlife, members of the



Lake Michigan Enforcement Conference, and ladies and gentle-




men of the public.  My name is Dr. Joseph T. Sobota.  I




live at 2312 Glenwood Drive, Kalamasoo, Michigan, and I am



speaking on behalf of myself and Mr. Ron McCandlis, $619




Clato Street, also of Kalamazoo.  I am Executive Director



of TEMP (Thermal Ecology Must be Preserved); Mr. McCandlis




is President of the Michigan Steelhead and Salmon Fishermen
-------
                                                       1929





                     J. T. Sobota




Association.  More importantly, we represent the public in a




contested Atomic Energy Commission hearing concerning the




Consumer Power Company's Palisades Nuclear Plant in Covert,




Michigan.  The Michigan Lakes and Streams Association and




the National Sierra Club have joined us in this AEC hearing




being held in Kalamazoo, Michigan.




          Mr. McCandlis and myself, as citizens of the State



of Michigan, are represented by the Michigan Water Resources




Commission with regard to water pollution problems.  In




196? this Board gave an order of water use determination to



Consumers Power Company allowing them to prospectively




operate the Palisades Nuclear Plant, in spite of this plant's




planned normal operation of dumping daily into Lake Michigan




561,000,000 gallons of water heated 28-degrees Fahrenheit



above normal lake temperature.  No reconsideration of this



order was made in the intervening years, even though much



new substantial evidence of thermal pollution connected



with nuclear powerplants has since been developed, some



of which you .heard in the earlier parts of this morning.



          In March 1970, the AEC gave notice in the Federal




Register of its intent to license this plant unless parties



whose interest would be affected intervened.  At this time,




the State of Michigan remained  without water temperature




standards approved by the Department of the Interior,  In
-------
                                                       1930






                     J. T. Sobota




turn, the Department of Interior had neglected to promulgate




regulations of thermal input into the essentially Federal



Lake Michigan.




          This dual vacuum of inactivity by the Department




of Interior and the Water Resources Commission in failing




to set thermal standards provoked our intervention April 2,




1970.  Our petition for a public hearing included the



request for implementation of the National Environmental



Policy Act (NEPA) as a vehicle for coordination of AEG,




Department of Interior, and Water Resources Commission



consideration of thermal pollution in Lake Michigan.  A




determination on thermal pollution in an AEC hearing on



nuclear plant licensing would affect not only the Palisades



Plant but would serve as a precedent to the many other



plants of this variety planned or actually under construction



on the shores of the lake.



          The hearings began in Kalamazoo June 23, 1970, and



are still in progress.  In these hearings the Atomic Energy




Commission staff and the applicant, Consumers Power Company,




have by legal maneuvering attempted to avoid the topic of




thermal pollution and the effect of the Palisades and




similar nuclear powerplants1 total impact on Lake Michigan.



Until as recently as September 25, 1970, they have been




eminently successful in preventing such discussions.
-------
                                                       1931
                     J. T. Sobota




          Through the brilliant legal representation of




Mr. Myron Cherry, our attorney, the AEG Safety and Licensing




Board in session in Kalamazoo referred to the Atomic Safety



and Licensing Appeal Board in Washington the following




September 3 ruling for judgment:




          "The ruling that the National Environmental Policy




Act ... requires the Staff of the Commission to transmit



the application of Consumers Power Company (Palisades Plant)




to the several agencies of the Government for comments




respecting the environmental considerations enumerated in




said Environmental Act.  In addition, the ruling requires



the Staff to prepare an environmental policy statement




based upon the comments submitted by the several agencies



of the Government and direct it specifically to the items



enumerated in the Environmental Policy Act."




          In other words, the Safety and Licensing Board in



Kalamazoo asked thaf the Consumers Power Company and the



AEG staff, under the requirements of the National



Environmental Policy Act, consult with all concerned




agencies of the government, both State and Federal, regard-



ing the ecological impact of the Palisades Nuclear Plant




and the other nuclear plants in the lake basin.




          The Appeal Board in its answer docketed September



25, 1970, Noo 50-255, essentially said that this type of
-------
                                                      1932
                     J. T. Sobota




report is not necessary for a one-megawatt license,  but is



necessary for a full power license.




          This is the first such implementation of questions



outside those of radioactive consideration to be addressed




by the AEC.  After 4-and-one-half months of tedious,




difficult and considerably technical matters, our strategy




of using the National Environmental Policy Act as a vehicle




of introduction of thermal pollution at an AEC hearing had




paid dividends.  The opportunity now exists, through the




AEC, to circulate the Palisades Nuclear Powerplant license



and an environmental report of the ecological impact of




this plant for comment to all appropriate Federal agencies




which might have expertise in this matter, so that this



will be addressed to you gentlemen now at this meeting.



          We interpret this ruling as opening the door for



a significant participation by the Department of Interior



in respect to this licensing activity.  Since the State of



Michigan has no thermal standards and since the Department




of Interior, through the agencies represented here  (Federal




Water Quality Administration, Bureau of Commercial Fisheries




and the Bureau of Sports Fisheries and Wildlife) has



recommended a one-degree limit of heat input at the point




of discharge in its excellent report presented at this




meeting, we maintain that the Interior Department has the
-------
                                                      1933
                     Jo T. Sobota




only guidelines available for licensing this plant and




any other nuclear plant on Lake Michigan's shoreline.  The



Appeal Board ruling specifically states:




          "The determination (under NEPA) as to whether an




action constitutes a major Federal action significantly




affecting the quality of the human environment is one to be




made by the agency proposing or authorizing the action; and



we find this confirmed in the relevant legislative history.




As to the matter of making the determination, we find




nothing in NEPA which would preclude agencies from imple-




menting this responsibility as they implement others,




through the issuance of regulations which treat the categories




of agency actions."



          Since the State of Michigan has no thermal stan-



dards for Lake Michigan, and while the Department of Interior




has no regulations, the only valid documents or guidelines



by the Interior Department are the ones submitted regarding



the 1-degree limit for heat input into Lake Michigan at



the point of emission.



          In a matter of weeks, the environmental report




of the Consumers Power Company and the Palisades licensing




application will be forwarded to you gentlemen representing




the Department of Interior and the otate agencies here.



On the strength of your report submitted here entitled
-------
                                                      1934






                     J. F. Sobota




"Physical and Ecological Effects of Waste Heat on Lake




Michigan," the AEG will have no choice but to enter in



testimony regarding thermal pollution at the hearing, and




to resolve the considerations under which this plant will




dispense heat into Lake Michigan.




          This is the way that the regulations and the




guidelines will be implemented in an action that demands




decision at this instant.  These hearings are being held




at this instant.



          I urge you to immediately request the license




and the environmental report from Consumers Power Company,




and immediately notify the AEC Hearing Board regarding Docket




No. 50-255 of your eminent participation in this hearing



on the matter of thermal pollution.  It is within your power



now, on the basis of the AEC's own ruling, to so participate



and effectively promote the conclusions stated so well in



the previously cited paper "Physical and Ecological Effects



of Waste Heat on Lake Michigan." The Department of Interior




must utilize this opportunity to either promulgate a pro-




tective thermal standard without a pollution coefficient




and actively participate in the  current AEC decision-making




hearings, the Palisades hearing  in Kalamazoo, Michigan, in



particular, or the significance  of this conference will be




nothing more than a fraudulent exercise of public
-------
                                                     1935





                     J. F. Sobota




appeasement.



          The Department of the Interior can now assume,




to a great extent, the responsibility abdicated by the




Water Resources Commission of the State of Michigan for




the past documented 32 months.  As far back as January 196$,




the distinguished former Secretary of the Interior, Stewart




Udall, in a letter to the then Governor Romney of Michigan,




stated, "I am at this time excepting (Department of Interior)




... approval of temperature parameters as these apply to



the (fish, wildlife, and other aquatic life) water use for




all interstate waters covered in the Michigan State's




original and supplemental standards submissions, including




the waters of the Great Lakes.  I believe that further dis-



cussions regarding these temperature 'parameters are neces-



sary, and I am instructing my people to contact your



officials without delay to begin working out such modifi-



cations as would afford great protection to this important



water resource use.  I would greatly appreciate your



cooperation in this matter, and I remain confident that



our mutual efforts will result in modified temperature




parameters which I can approve."   This letter was written



January 1968.




          The Michigan Water Resources Commission has still



not proposed temperature standards which are acceptable
-------
                                                       1936






                     J. F. Sobota




to the Department of the Interior.  Is this the type of



inaction to be expected from a responsible representative




group?



          The responsibility also has been abdicated by




Consumers Power Company management.  While they consistently




live within the letter of the law, they maintain public and




hearing positions which are contradictory.  Publicly




Consumers Power Company maintains that no thermal pollution



will occur with the Palisades Nuclear Powerplant.  In the




Atomic Energy Commission hearings in Kalamazoo, however,



they have legally briefed against hearing in an administrative



process their scientific proof and substantial alternate




scientific opinion on thermal effects such as the concise




paper just submitted by the Interior Department, and



remarks by eminent scientists like Dr,  Don  Pritchard.



We may surmise something of the soul of Consumers Power



Company management from tactics of the type just cited.



Apparently, in the area of thermal pollution where anti-




pollution controls are feasible and available and documented,




Consumers Power Company management has arbitrarily decided




not to provide the power of the Palisades Nuclear Powerplant



to the citizens of Michigan, rather than add one of the




available and feasible means of cooling the nuclear power-




plant water effluent.
-------
                                                       1937





                     J. F. Sobota




          The organizations I represent have always operated




within the established rules of practice of the Atomic Energy




Commission, and other legal restraints that we are obligated



to work under.  Delays of the plant in no way add substance




to our organization's aims.  Our position as simply stated




is additional power supply to Michigan without pollution.




We refuse to accept a utility company's promise that any



harmful effects to the environment caused by a nuclear




powerplant would be taken care of if and when any occur.




          I would like you to remember the earlier presen-



tation of the algae in Little Traverse Bay.  That was




interesting news to me.  I would like to know now what



material action will be taken to cure that if, in fact, it



is secondary to the Charlevoix big water plant.




          While maintaining this posture, utility companies



neglect to define "harm" and exactly what action they would



take if such future -damage occurred.



          We are not willing to play Russian roulette



with Lake Michigan.  We have no evidence historically,



scientifically, nor can we deduct intuitively, that damage




once it occurs to the lake is reversible.  Also, in view




of this fact, we must be on guard to prevent plants of the




Palisades type from gaining a vested interest by mere



active operation, enabling them to hide behind grandfather
-------
                                                     193^
                     J. T. Sobota




clauses, such as those which exist in the Federal Water




Quality Act of 1970.




          Accommodation to pollution is an abomination




which should not be tolerated "by anyone in this room charged




with protecting the public interest.  This applies as much




to power company representatives as to Federal and State




representatives.  While the power companies must live




within the letter of the  law, and they do, we charge them




to live within an enlightened outlook in an unpolluted



world.




          In summary, the organizations I represent have




acted in a novel way to introduce the implementation of



thermal standards in an AEG hearing of a license to operate



a nuclear powerplant on Lake Michigan.  The legal ruling



established in this hearing to date now affords the



Department of Interior the opportunity to act directly,



with guidelines and regulations, in areas such as the State



of Michigan, where no thermal standards exist, as an active




participant in forming the licensing stipulations which



will be in effect for the operation of such plants.




          We charge them to act in a responsible manner at



the Palisades nuclear power hearing now under way in




Kalamazoo, Michigan.  This action will serve as a precedent




to all other nuclear power facilities in the Great Lakes
-------
                                                       1939






                     J. T. Sobota




Basin and effectively implement the guidelines which were



so well presented by the Department   papers released at




this conference.  Successful participation on the part of




the Department of Interior, or better yet, responsible action




by the Water Resources Commission of the State of Michigan,




would provide the national precedent needed to blunt massive




thermal pollution threatened by a rapidly growing nuclear




power industry.




          Thank you very much.  (Applause)




          MR. STEIN:  Thank you, Dr. Sobota.




          Any comments or questions?




          MR. FETTEROLF:  Yes.



          Dr. Sobota, at the meeting of the Michigan V/ater



Resources Commission held on October 27, 1966, the order




of determination was adopted relative to Consumers Power




Company, Palisades Plant.  This was before temperature



standards were required, and in the absence of temperature



standards I would like to read you Section 6 of that order



which states:  The company shall not impart heat nor con-




tain any substances in sufficient quantity to create con-




ditions which are or may become injurious to the oublic



health, safety, or welfare, or which ar° or may become




injurious to domestic, commercial, industrial, agricul-




tural, recreational, or other uses which are being made
-------
                                                       1940
                     J.  T.  Sobota



of such waters, or which are or may become injurious to the




value or utility of riparian lands, or which are or may




become injurious to livestock,  wild animals, birds, fish




or aquatic life, or the  growth  or propagation thereof.




          In Section D of this  order of determination, it




states:  The company shall make measurements of wastes




discharged to Lake Michigan and shall perform such analyses



as are necessary to demonstrate that the requirements of




this order are being met.  Reports of such analyses and



measurements shall be available for inspection by




authorized employees of the Water Resources Commission,



and an annual report thereof shall be submitted to the




Commission by the company.




          With respect to —



          DR. SOBOTA:  May I answer that statement, please?



          I have read that statement, and I would like to



again go back to the text of my remarks and substitute



"utility companies" for the Water Resources Commission.




While maintaining the posture in that document which is so




elegantly stated, the Water Resources Commission and the




companies have failed or neglected to find harm in exactly




what action they would take if such actual damage occurred.




          Now, without the possiblity of using measuring




sticks for decision-making, and language of that type, I
-------
                                                      1941






                     J. T. Sobota




doubt whether, in fact, anything could be said other than




a very nice-sounding rhetoric to that statement0  (Applause)




          MR. STEIN:  Any other comments or questions?




          MR. FRANCOS:  Mr. Chairman, do we have copies




of that presentation now for the conferees?




          DR. SOBOTA:  I have a certain number of copies




available.  1 don't know whether there will be a sufficient




number for all of the members of the conference.




          MR. STEIN:  '.tfhy don't you bring up the ones you




have ?




          Mr. Petersen.




          MR. PETERSEN:  Thank you, Mr. Chairman.  0. K.




Peterson.




          Dr. Sobota, I understand you are a medical




doctor?




          DR. SOBOTA:  Is that a question?




          MR. PETERSEN:  Is that correct?




          DR. SOBOTA:  Yes, I am a physician.  I specialize




in pathology*




          MR. PETERSEN:  Are you also a lawyer?




          DR. SOBOTA:  No, I am not.




          MR. P3TER3EN:  Then your comments as to the State




of Michigan not having standards in effect as to Lake




Michigan are your conclusions as a doctor rather than as
-------
                                                      1942





                      J. T. Sobota



a lawyer?



           DR, SOBOTA:  They are my conclusions as a physi-



cian, as an interested party in these hearings, as an active



participant in the intervention in a nuclear plant, and as



a citizen.



           MR. PETERSEN:  Are you aware that such standards



were adopted even if they were not approved by the Depart-



ment of the Interior — Secretary of the Interior —



correction.



           DR<> SOBOTA:  I understand that there were stan-



dards that were attempted to be promulgated, but were



consistently denied approval by the Department of Interior,



yes.



           MR. PETERSEN:  Is it my understanding that if



Consumers Power Company should put up cooling towers at



the Palisades plant that you would have no more difficulty



with the plant, and you would withdraw your opposition



to the licensing of that plant?



           DR. SOBOTA:  We would like to discuss that



possibility with the Consumers Power Company.



           MR. PETERSEN:  Then, when you say you would like



to discuss the possibility, you are not saying that is the



standing of your group?



           DR. SOBOTA:  Our standing is that we would like to
-------
                                                     1943





                     J. T. Sobota



protect the ecology surrounding that plant, and protect the




impact of heat dissipation from multiple nuclear plants




on Lake Michigan by whatever feasible means are available




for antipollution devices that would be attached to such




a set of plants.




          MR. PETERSEN:  When you said here that Consumers



Power Company had deprived the people of Michigan of that




electricity instead of putting up cooling towers or taking




other cooling action, you were not stating your entire



case, were you?




          DR. SOBOTA:  What I was stating there is that



Consumer Power Company management because of whatever




policies might have been the basis of the foundation for




designing and implementing the use of that plant had not




put on that plant feasible antipollution devices, and



because of that particular problem, and because of the



void of standards — thermal standards both by the Federal



and by the State Government, certain citizen groups adopted



a policy of intervention so that these questions would be



answered properly before the operation of that plant began.



          It is a 40-year plant, and the operation of



such a plant, in the face of unknown irreversible damage




to a lake, and at a time where it may become a precedent-




setting plant and license for all of the plants around the
-------
                                                       1944






                     J. T. Sobota




Lake Michigan basin was also some of the reasoning for the




intervention in that particular plant by conservation



groups.




          MR. PETERSEN:  Your theory, then, is to oppose



this plant at this stage of operating after it has been




built instead of opposing future plants on a construction




basis, as you did not oppose this plant when it was being



constructed.




          DR. SOBOTA:  We do not oppose this plant, and




I think I want to make that very clear.  AEG has seen fit




not to license this plant until after a hearing of all" of




the issues involved in the safety, in the performance




evaluation of the plant, and in the other considerations




that are made for the licensing of such a plant.  It is



the AEG, in fact, that has not given you an operating



license.



          MR. PETERSEN:  Did you or any of your group



oppose the construction license for this plant?




          DR. SOBOTA:  I was not in the State of Michigan




at that time.  We were not even formed at that time as far



as an organisation.  But I must say we probably do have a




much quicker reaction time especially in view that we




understand technology races along and may leave the decisions




behind before adequate decisions could be made.  And in that
-------
                                                     1945






                       W. S. Singer




regard we did act rather decisively and quickly after we




had analyzed the data that were available to us and also




to the conferees at this conference, and also to the Water




Resources Commission of the State of Michigan.




          MR. PETERSEN:  I take it your answer is no.




          DR. SOBOTA:  We did not participate in the con-




struction or permit hearing which was rather perfunctory,




after reading the transcript, because of the absence of




both my personal presence and the absence of organizations




concerned with this problem at that time0  (Applause)




          MR0 PETERSEN:  Thank you very much.




          MR0 STEIN:  Thank you.



          May we have Alderman William Singer?








          STATEMENT OF WILLIAM S. SINGER, ALDERMAN,




                43rd WAHD,  CHICAGO,  ILLINOIS







          MR. SINGER:  Mr. Chairman and members of tho



conference.  I am pleased to have the opportunity to appear



before this Third S -ssion of the Lake Michigan Enforcement




Conference and to testify regarding the proposed standard




before you at this time which would provide that "... no




significant amounts of waste heat ..." be discharged into




Lake Michigan.
-------
                                                      1946
                     W. S. Singer




          Today you will hear testimony from the public on




this proposed standard and it is a fair guess that the




testimony will be relatively uniform in favor of your adop-




tion of this standard.  This is no secret, but it occurs to



me that it is fair to go beyond the mere unanimous public




support for this proposed standard and probe the reasons for




this public support.



          First, it must be abundantly clear that the people




of the States surrounding Lake Michigan fear its ultimate




death within this decade.  The Lake Erie tragedy and the



constant reports of the eutrophication of our lake has




justifiably alarmed residents of the four States bordering




Lake Michigan.



          Second, against this background of fear is a total



lack of trust and unwillingness to go further with those who



have polluted the lake for too many years.  Industry now



says, "Give us a few plants and some more time."  And the



public says, "Damn your time" — and rightly so.




          What basis is there for trust when day after day



the pollution of the lake continues primarily through the




efforts of industry?  The simple fact is that industry does



not deserve our trust.




          Third, the public has seen too many examples of



"Try now, pay later."  Drugs have been placed on the market
-------
                                                      1947






                     W. S. Singer




with insufficient testing, with often disastrous results.




Pollution of our environment has been caused by any number




of devices or products which the public was told would




help create "the better life."  The public has paid dearly



for the better life and, indeed, if the same processes




continue, the end of the better life may be around the




corner.



          Fourth, and perhaps most important, the public




knows what our science and technology can do if pushed far




enough.  I would add here that the intent of this statement




is that it knows that the plants can continue their opera-




tion without thermal discharge; it knows it because even the




industry has said that there are alternative means such as



cooling towers, circulation systems.  The powerplants on



the lake are the path of least resistance, economically




speaking, for the industry.  The proposals to use lake



water and to discharge it at substantially higher degrees



are similarly the path of least economic resistance.



          I understand that one witness has stated that



the proposal before you "is economically unrealistic<,"



Economically unrealistic to whom?  To the public?  No,




it is economically unrealistic, or stated perhaps more




accurately, less advantageous to the power industry.  But




it is quite realistic to the public who will have to pay
-------
                                                       1943
                       W. S. Singer




if thermal discharges are found to be harmful to the lake.




          Gentlemen, no one of us can ever accurately reflect




total public sentiment on any issue, but on this proposal




there can be little doubt that the public does not want to




take any more risks with the future of the lake.  They




don't trust industry and they know that time is short.




It is unacceptable, as one power company spokesman has



suggested that it might be, to let the plants go ahead




and then we can test to determine if there is damage.  But




that same spokesman has said that if after a year of study




damages did occur, it might take 2 or 3 years to change



the processes and eliminate the thermal discharge.  That




means a period of almost 4 years during which time the




thermal discharges would continue unabated.  Can we afford



any chance like this with Lake Michigan?



          The public, I believe, says that we cannot, and



is asking you to say to industry that there will be no



more chances.  It is asking you to say no thermal dis-




charges.  I urge you to adopt such a strict standard at




this session of the conference before it is too Iate0



          Let me add:  It occurs to me that another public



reaction might be gleaned from the testimony before you



today of the seeming confusion that might result if one



were to ask, as you have, who and in what period of time
-------
                                                      1949
                       W. S. Singer



will come forth with a standard which will be effective to




stop any possible damage to Lake Michigan resulting from



thermal discharges?  Who?  Is it you as a conference?  Is




it the Department of Interior?  Is it each individual




State?  The public doesn't really know, and I must say I




doubt you gentlemen know what the fastest way to achieve




that standard is.




          But you gentlemen, collectively or individually




through your own States, have some power, and the decision




ought to be to exercise it as fast as possible even if it



means adopting a standard and promulgating a standard for




your individual States which may only be an interim one,




because an interim one will at least give the public




assurance that not until there is a clear and demonstrated



— it is clear and demonstrated that no harm will result



will thermal discharges be permitted.



          If you want to label it "interim," fine, make



this clear, too:  It will be interim until the industry



has made its case clear.  And I suggest that if the public



is going to have any confidence in the political process



in terms of ending or turning around the process of




eutrophication of Lake Michigan, indeed all over this




country, if they are going to have that confidence in the



political process, then you gentlemen have it within your
-------
                                                      1950





                       W. S. Singer



power to do something about it soon.




          We cannot continue the game of "Whose back is the




monkey on?"  You can do it individually or collectively —




I don't care which — but I urge you to do it.




          Thank you very much.  (Applause)




          MR. STEIN:  Thank you, Alderman Singer.




          Any comments or questions?




          If not, may we have Mrs. Louise Erickson?




          While she is coming up, I have several telegrams




which I would like to put in the record as if read, and




the statement of the Elk River Drainage Basin Council,




submitted by Mr. Ted F0 Miller, Chairman, and Mrs. James



Janis, Secretary, and one more telegram I would like to




read:




          "It is my understanding that the FWQA will be



concluding an enforcement conference today concerning the



pollution problems of Lake Michigan and that the major



problem on the agenda will be that of thermal pollution




from powerplants.



          "Whereas the scientific evidence regarding this




problem is admittedly inconclusive, it is my hope that it



will be regarded as sufficient to permit agreement on a




specific thermal standard for all plants on the lake.  Any



such standard will necessarily be an imperfect approximation
-------
                                                       1951
                     Hon. P. A. Hart



of what is needed.  Yet it would appear nonetheless to be




an improvement over the current system in which different



plants are held to different standards of beunt (sic.)




depending on which State's shoreline is involved.




          "As for what the new standard should be, as you




well know, I lack the scientific competence to so much as




hazard an intelligent guess.  As a lawyer, however, I can




advise that difficult questions of fact are often best




resolved by reliance on the issue of burden of proof.  With




the question of thermal pollution, it would appear that the



burden as to safety must lie on those who would introduce




potentially dangerous elements into the environment.




Unless that burden is sustained we may risk intolerable



dangers to a resource we all hold dear.




          "I wish you every success in your efforts.



Sincerely yours, Philip A. Hart, Chairman, Subcommittee on



Energy Natural Resources and the Environment."



          I would like to place that telegram in the record,



(Applause)



          I guess, knowing Senator Hart — I suspect I will




be before the committee to explain whether it is successful



or not successful in the future.




          (The telegrams and statement referred to pre-



viously follow.)
-------
                                                     1952
                     Telegrams



          (The following telegram was received from F. M.




Baumgartner, President, CNRA.)




          "The Citizens Natural Resources Association of




Wisconsin strongly support Secretary Hickel's standard of




one-degree increase in water temperature from atomic




powerplants."




          (The following telegram was received from E. K0



Born, President, Sheboygan Chapter, Izaak Walton League



of America.)




          "The Sheboygan Chapter of the Izaak Walton League




of America and the Sheboygan Chapter members serving as



officers and directors of the state league heartily endorse




that the water temperature increased by nuclear powerplant




located on Lake Michigan be held to one degree.  The state



league is represented by 2000 members and the Sheboygan



Chapter by 215 members."



          (The following telegram was received from Mrs.



Betty Priebe, Waukesha, Wisconsin.)




          "Favor stand against water pollution.  Am owner




of bonds in Consumers Power.  Environment most important."




          (The following telegram was received from the




Staff of Virginia's Beauty Salon, Eleanore Grace, Manager,




Milwaukee, Wisconsin.)



          "We urge your continued effort to set standards
-------
                                                      1953






                        Telegrams




for Lake Michigan at the tolerable limit of one percent




thermal addition above water temperature, according to




Secretary of the Interior V/alter Hickel's statement.  We



the general public may not be vocal but you have our full




support.  Happy New Year, dear Mr. Stein, to you and




yours0"



          (The following telegram was received from Keith




A. Ziolek, Park Ridge, Illinois.)




          "Adopt strictest standard under consideration.



Save the lake."




          (The statement presented by the Elk River




Drainage Basin Council follows in its entirety as if read.)
-------
                                                              1954.
            ELK RIVER DRAINAGE BASIN  COUNCIL
                    TO PROTECT THE WATER AND LAND RESOURCES OF OVER
                   BOO SQUARE MILES COMPRISING THE ELK RIVER WATERSHED
                           STATEMENT TO THE FEDERAL
                 ON POLLUTION OP LAKE MICHIGAN AW ImS TRIBUTARY
                 BASIN - THIRD SESSION.  October 2, 1970,
                                   Chicago, Illinois
                   Thank you for this opportunity to be heard relative
            to  the  preservation of Lake Michigan in general, and to
             .ermal pollution in the Basin in particular.
                   The  Elk River Drainage Basin Council operates in
            northern lower Michigan between Traverse City and Charle-
            voix  and represents 30 municipalities and almost that
            many  groups and organizations.  Organized under Michigan
             ct 200 in  December, 1969, the sole purpose of the Council
            is  to work  towarde the preservation of the natural resources
               the  over $00 square miles within the Elk River Drainage
             asin.   The Basin outlet is at Elk Rapids, flowing into
             ihe East arm of Grand Traverse Bay.
                   This part of the country Is still beautiful.  But,
            even  our clean waters now show increasing traces of algae,
            detergent foam, oil slick, muddy waters and the usual
            debris  of litter which follow man's activities.  Tourism
            provides the main economic base for the area - hunting,
            fishing, skiing, boating, etc.  Agriculture is a mainstay
            with cherries being the  special product.
                   Because  of its natural attractiveness, many
            "downstaters" and out-of-staters are anxious to visit
          A COUNCIL OF MUNICIPALITIES AND ORGANIZATIONS IN ANTRIM. CHARLEVOIX,
GRAND TRAVERSE, AND KALKASKA COUNTIES. ESTABLISHED UNDER MICHIGAN PUBLIC ACT 2OO.
-------
                               2m                                 1955
and live in this area.   However, preventitive measures must  be  taken
to protect those resources which are attr acting the Increasing numbers
of part-time and full-time residents.
    Because of this Increasing population and the great potential for
this increase, our Council is concerned about the future  supply of
power for homes and industries. Our power currently is supplied by
several utilities - Consumers Power Company and Cherryland Rural
Electric to name only two.  New or enlarged power plants  in  the Basin
could cause conflict in several ways, ranging from the aesthetics to
the thermal discharge which has been an inherent part of  any power
Installation to date.
    Our waters are generally cold  wateir streams and lalces which support
an ecology of cold water fish and  plants.  Any type of mixing zones
permitting heated effluent would alter the ecology of the involved area
and permit the speed-up of deterioration of the waters because  of the
higher temperatures.
    Our Council has not formally been Involved in a detailed s tudy of
temperature standards,  types of preferable cooling systems or construc-
tion techniques.  It Is felt, however, that the entire community would
support strict enforcement of the  highest standards for control and
avoidance of thermal discharge. We would hope to have the opportunity
to review and comment on any proposal for power plant construction within
this Watershed.
    We urge a Lake Michigan Basin  adoption of the 1 degree ma xlmum
discharge temperature of heated effluent as recommended by the  Federal
Water Quality Administration.  We  are apprehensive of the ability to
measure the temperature of mixing  zones at all times of the  year and
so would encourage the measurement of the effluent at the point of
discharge.

    Strict enforcement of the strictest standards will be the only way
-------
                                                                   1956
in which cold water recreational uses can be preserved and  true

conservation attempts can be successful.

    Thank you.



                                     ELK RIVER DRAINAGE BASIN COUNCIL
                                     Ted F. Miller, Chairman
                                     Elk Rapids, Michigan 49629
                                     June Janis, Secretary
                                     Route 1
                                     Williamsburg, Michigan ^9690
-------
                                                    1957
                     Mrs, L. Erickson




          MR. STEIN:  Mrs. Erickson.








          STATEMENT OF MRS. LOUISE ERICKSON, CHAIRMAN,




          RACINE COMMITTEE FOR THE NATURAL ENVIRONMENT,



                      RACINE, WISCONSIN








          MRS. ERICKSON:  I am Mrs. Louise Erickson from




Racine, Wisconsin.  I am speaking for the Racine  Committee




for the Natural Environment.



          By an analysis of the ecosystems of Lake Michigan,




by studying the huge numbers of carp, alewives, smelt, and




other fresh fish, it is apparent to most of us that Lake




Michigan is already a lake which is ecologically very ill.



Therefore, the Racine Committee for the Natural Environment



maintains that thermal pollution of Lake Michigan should



not be allowed, and toward this end supports the proposed



standard of one degree temperature rise.



          I should like to make some further comments.



First, I am going to make some comments in regard to Green



Bay.  As you saw Green Bay on the map — the geological




maps which were shown earlier — you could see that Green



Bay is essentially a very shallow bay, particularly in




its south end.




          I have been in the area of Green Bay all my life
-------
                                                       19 53





                     Mrs. L. Erickson




in summers.  We have a cottage on Washington Island and




I have been in this area every summer since I was 3 years




old.




          On the peninsula, there is a beautiful park called



Peninsula Park, and there is'a tower here, and I can remember




as a girl that looking off that tower over Green Bay the




water was blue as blue could be, and now when you look at




the water, it is very brown.  The fishermen who used to



fish in Green Bay cannot fish there anymore.  They can't



catch fish in Sturgeon Bay.  You can't catch fish off the



west side of the peninsula.  In order to get good eating




fish most of the time they need to go off the end of the




peninsula.  Green Bay itself must be too polluted, too



disturbed for proper fishingo



          The algae have become thick in Ellison Bay.  I



swam there this summer.  The rocks are just absolutely



covered with green.



          I heard a fisherman speak 3 or 4 years ago at




a water quality hearing on Sturgeon Bay.  He said they




used to cast their nets out at Sturgeon Bay but they can't




do it now and sometimes when they put their nets in the




water, the fish would be caught alive and a tide would



come over and the fish would die before morning in the



nets.
-------
                                                       1959
                     Mrs. L. Erickson




          The algae are beginning to come to Washington




Island where our cottage is.  I can remember some 20 years




ago that one could see the bottom in 30 feet of water.




Well, you can't do that anymore; it is getting cloudy.




They are beginning to get many carp there on this island




which is quite a ways out in the middle of the lake, in the



bay.




          Now, none of this, I presume, is directly



attributable to the power companies nor their thermal load




that they may place on the lake.  But I should like to make



a special plea that Green Bay is almost dead at its south




end, that it receives a huge load of pollution from the




Fox River every day.



          A statement was made at a Green Bay conference




on the lake that the amount of pollution going into Green



Bay was equal in biological oxygen demand as if a city of a



million people were putting its pollution into Green Bay



every day with no treatment.  So you can see that the



south end of Green Bay is a great problem area*



          So, therefore, I would like to. make a plea that




Green Bay be considered as a special instance of — a



special part of Lake Michigan, and that due to its high




priority as a problem area that plants be not allowed to



be sited on Green Bay and contribute to the thermal
-------
                                                      I960
                     Mrs.  L.  Erickson




pollution of this particular area until all of the sources




of pollution can be cleaned up.




          In regard to siting,  I would like to make another




statement:  I, too, bewail the  fact that the Kewaunee plant




and the. Point Beach plant  were  allowed to be placed so




close to each other.  One  of these is a double plant, and



they all three are fairly  large, and so this is,  in effect,




locating three plants within just a few miles of each



other.




          Now, the thermal effects of this can be rather




disastrous.  I think this  was a very great mistake in




siting of plant location.




          Then, I want to  make  another plea in regard to



siting of a nuclear plant  or plants0  There is actually



no reason why these plants should be allowed to be sited



immediately adjacent to recreational areas.  I personally



have long enjoyed the Point Beach Park.  But when I go



there now and have to see  these ugly towers in the plant




that is already there, I feel that there is a certain




amount of visual pollution of the beautiful Point Beach




Park.



          The Point Beach Park is also near to the Point




Beach Forest in Wisconsin and isn't a very good help for




that area.
-------
                                                      1961





                      Mrs. L. Erickson



           The Cook Plant over in Michigan is right in the



middle of the beautiful Grand Marais area which is being



attempted to be preserved as a natural area.  The Indiana



Dunes are also having trouble becuase they have a fossil



fuel plant that is sort of a problem for that lakeshore.



           Wouldn't it be possible to have our electric



plants placed somewhere that is not adjacent immediately



to some beautiful area that we have preserved for the people



to use as a recreational site?  (Applause)



           I would like to say that it seems apparent to me



in reading some of the testimony and in hearing some of the



statements at this meeting — I have not been here the whole



time — that it is not only the power companies in Illinois



that have a monopoly on not caring so much about the envir-



onment but I would like to point out that our Wisconsin



power companies do not seem to do this either.



           Then, in closing, I would like to say that I am



very much concerned about Lake Michigan as a whole, and I



feel that we may be approaching the point of no return.



           I can remember when scores of fishing boats



could go out in the lake and could reap the fish from the



lake, and now the catch of whitefish and trout in — Lake



Michigan trout, and so forth, is almost miniscule.



           I think we may be reaching this point of no return,
-------
                                                       1962
                      R. McCandlis




           We may be reaching the point that Dr, Bardach




mentioned for the lakes in Switzerland, or for Lake Geneva




in Switzerland, when he spoke of the increasing rate of



eutrophication.  We don't know but what Lake Michigan may




be on the beginning of this steep climb toward complete




eutrophicationo  So I think we should be very careful



and want to preserve our lake immediately before it is too



late.  So let us say — borrowing a phrase of Dr, Bardach




— let us not contribute to the "galloping eutrophication"




of Lake Michigan.  (Applause)




           MR. STEIN:  Thank you, Mrs. Erickson.




           Any comments or questions?



           If not, thank you very much.




           Ron McCandlis.  As I understood it, Mr. McCandlis,



you said your statement will be 2 or 3 minutes.








           STATEMENT OF RON McCANDLIS, PRESIDENT



           PRO-TEM, MICHIGAN STEELHEAD AND SALMON




           FISHERMENS ASSOCIATION, KALAMAZOO,




                          MICHIGAN








           MR. McCANDLIS:  Ron McCandlis.,  I live at  5619



Clato Street, Kalamazoo, Michigan.  I am President of the




Michigan Steelhead and Salmon Fishermens Association.
-------
                                                     1963




                     R. McCandlis




          I wanted to take a minute to enlighten you



gentlemen here at this table a little bit about how directly




temperature affects fishing in Lake Michigan, or the Groat




Lakes as a whole, or actually fish around the world, as  we




are learning.



          I have here in my hands a typical type of




thermometer we use.  This is an example of an electronic




thermometer which I utilize in my research sport fishing



on the Great Lakes for over 35 tackle companies.  I do




this as an avocation.



          This is a Vexilar-Z'pnar thermometer.* V/e can




measure temperatures from curfr,ce to depths as great -\s




100 feet.




          You may question how important this is.  V/ell,




I can give you a good example.  V/hen we can reach 54-degrcG



temperature water, we can catch fish on nearly any lure




readily.



          I was about to point out this particular tie



clasp the second gentleman is wearing.  If a hook were



attached to that tie clasp, it would catch salmon in Lake



Michigan in 54-degree water.  Ao you move away from 54-degree




water, each degree becomes important for the coho salmon.




With lake trout, we are talking about 50-dogree, in



contrast to salmon, and we have learned to find the exact




 *Trade naiue
-------
                                                       1964
                     R. McCandlis




temperature and we look for a temperature within one degree




when we are fishing.




          Now, this has been verified time and time again0




If you want documentation of some of this, I do have records




of my 1,500 documented hour's of fishing on Lake Michigan.




          A good example is over the past 6 weeks we have




had fishing in Lake Michigan as one has never seen before,,




Three weeks ago in 10 hours I boated with a single rod and



reel over 700 pounds of salmon, 5^ fish, because the water




temperature of 54 degrees could be attained exactly with



great ease with the lure.




          Earlier it was alluded to in the question of




Dr. Bardach what happens in the thermal bar, in mixing



across the thermal bar.  Fish, especially salmon and lake



trout, stay shoreward of the thermal bar.  They will not



cross the thermal bar in the spring and in the fall.  A



number of times I have experienced finding the thermal bar



with my electronic thermometers.  Fishing back and forth




across the thermal bar and, as I suggested, to the inside




of the thermal bar, I get a fish maybe on every rod,



maybe sometimes on just one or two rods.  When one crosses



to the outside of the thermal bar, no fish appear on the




electronic finder, where you can actually identify the



species "beneath the boat.  You can note there are no fish
-------
                                                      1965





                     R. McCandlis




on the outside of the thermal bar; within the inside of




the thermal bar there are fish.




          Also it was asked of Dr. Bardach and some other




people here, or there was a suggestion or possibly an




inference, that fish can escape heated water.  This is




not always true.  The best example that I can think of is




in 1968, when the salmon were returning to their home




streams and the urge of spawning due to reproductive hor-




mones in the system of the fish was driving the fish




instinctively home to its river.  It could not find any




water temperature less than 64 degrees.  It was impossible




during that time to catch fish, and this has been documented,




          The other example I would make on the —



          MR. STEIN:  How much longer will it take you to



complete your 2 minutes?




          MR. McCANDLIS:  I will complete it with that.



          I merely wish to point out that the temperature



i~ vu-y specific; within one degree, we can catch fish.



And if you question how many people utilise this, I would



like to end my comments in pointing out that on Labor Day




of 1967, there were 39,000 fishermen fishing between the




ports of Ludington and Manistee on Lake Michigan.




          Give it some thought.  (Applause)




          MR. STEIN:  Thank youc  Are there any comments
-------
                                                      1966
                      D. Schindler




or questions?



          Mr. McCandlis, thank you very much.



          Again, I would say, we are here to hear you out,




but the question is that some of you have waited a long



time.  The shorter everyone is in his presentation the



nicer people who are waiting are going to think he is.




          Dana Schindler.








          STATEMENT OF DANA SCHINDLER, MANISTEE




           COUNTY ANTI-POLLUTION ORGANIZATION,



                   MANISTEE, MICHIGAN








          MISS SCHINDLER:  Gentlemen of the panel and



representatives of the conference, I am representing the



Manistee County Anti-Pollution Organization, Manistee,



Michigan.  This is a small organization, but we bring this



chloride problem to your attention because of its urgency



for all members of the Lake Michigan watershed area.




          MR. STEIN:  Miss Schindler, how long will your




presentation take?



          MISS SCHINDLER:  It will take from 15 to 20



minutes, sir.



          MR. STEIN:  Miss Schindler, I am afraid we have
-------
                                                      1967





                      D. Schindler



a problem here if we are dealing with thermal problems as



well as chlorine problems.



           Now, you can speak on this, but I am afraid we



are going to have to give priority to thermal problems.



Now, if you can't summarize your statement, I am going to



have to ask you to step down and we will have people on



thermal problems come first.



           MISS SCHINDLER:  The letter of invitation did



not —



           MR. STEIN:  I understand that.  I am just talk-



ing about when you get on.  Can you summarize this or do



you want to wait until later?



           MISS SCHINDLER:  I will go on.



           MR. STEIN:  Can you summarize your statement?



           MISS SCHINDLER:  It is immoral for Michigan



industries to pollute water that the people of Illinois,



Wisconsin, Indiana, and Michigan are going to have to try



to drink.



           MR. STEIN:  Miss Schindler, I take it you are



not going to summarize.



           MISS SCHINDLER:  I will summarize.



           MR. STEIN:  Thank you.



           MISS SCHINDLER:  I hope that most of you have



had the opportunity to review this presentation0  Your
-------
                                                      1963





                      D. Schindler




future drinking water is at stake.



          Our organization took water samples and had them



analyzed.  Through investigation, we found that our drinking



water was being contaminated with chlorides.  For example,



the chloride testing of Lake Michigan, 20 feet northwest of




the Packaging Corporation of America's pipeline in Lake



Michigan registered 220 parts per million.  Michigan's



State-Federal standard is 50 p.p.m.  This is compared to the




Indiana and Illinois State-Federal standard of 10 p.p.m.



          Within the text of our attached report given at




a Natural Resources Commission meeting in June, titled,



"The Unpolluted Truth About the Water Pollution Problem in



Manistee," we outlined every problem we were able to find



in our area concerning the ground and surface water contamina-



tion.  Nothing stated therein has been refuted by the Michigan



Natural Resources Commission or their subsidiary agencies.



          In our attempt to stop the chloride pollution of



the ground and surface waters of our area which includes



Lake Michigan, we drafted a letter to Ralph Purdy of the



Michigan Water Resources Commission on June 30, 1970, a



copy of which is attached — June 13, excuse me.  (See




Pp. 1994-1996)



          In this letter, our engineering data outlined



three feasible methods to discontinue chloride discharge




completely within 30 days, the simplest and most economical
-------
                                                       1969
                      D. Schindler


being to return the brine back to the now inoperative wells,


thus returning the salt to the Sylvania level from whence


it came.  This would eliminate ground and surface water


contamination•


          The MWRC will not issue the cease and desist


request which was included in the above letter saying that


conclusive evidence of injury does not exist.  If conclusive


evidence does not exist, one would wonder, then, the mean-


ing and the purpose of the water standards.  Why have them


when if they are violated it is not evidence enough?


          On July 30, the MWRC issued a letter to all salt-


and brine-producing industries.  We attach a copy of this


letter and ask you to note especially the target date of


December 1, 1971, for the "elimination of concentrated


chloride discharge."  (See Pp. 1999-2000)  We have since


spoken to the MWRC and have inquired as to what disposition


will be made of the lower concentrations of chlorides


entering Manistee Lake and River and Lake Michigan both


legally and illegally.  The MWRC advised that they will


probably have to establish a program, but to our knowledge


there is no program planned except to ask these industries


to voluntarily discontinue concentrated chloride discharge


by December 1, 1971.


          May I repeat that our engineering data has


shown that this can be economically accomplished in 30 days.


          We were not satisfied with this target date and
-------
                                                      1970
                      D. Schindler

our next step was to draft a second letter to Ralph Purdy

again giving engineering data on how the major chloride

producer could alter his process in a minor way to greatly

reduce chloride discharge.  To date, Mr. Purdy has not seen

fit to reply to this letter dated August 2S, 1970.

          Turning specifically to Lake Michigan, the

Packaging Corporation of America is creating a reverse

estuarine by dumping 1 million pounds of chlorides per day

into Lake Michigan which they purchase from Standard Lime

and Refractories.  This figure was confirmed by Norman

Billings, Assistant Executive Secretary of MWRC, in a letter

of May, 11, (P. 2017) the point being that Section (k) of

the Corps of Engineers 1956 permit for this pipeline allows

a maximum of 5»000 pounds of solids to be discharged daily.

We are talking about a discharge of a million pounds.

          Therefore, it is MACAPO's opinion that the terms

of the permit are being grossly violated by this chloride

addition.  Incidentally, these chlorides are added to

increase the specific gravity of Packaging's 10.5 million

gallons of paper mill waste dumped daily into Lake Michigan.

These chlorides are supposed to make the very dark brown

effluent sink and, therefore, disappear.  The industry

does this with the blessing of the MWRC.

          You might arrive at some indication of the

strength of the effluent which PGA is attempted to sink by

considering the fact that in June  1950, paper mill waste
-------
                                                      1971



                      D. Schindler



from this above-mentioned industry, in combination with



weather conditions caused a fish kill in Manistee Lake



believed to have been the largest fish kill in the history



of Michigan.



          The 1956 order of determination did require



improved waste treatment facilities but nevertheless please



note particularly that a September 1963 letter from Mr.



Purdy speaks of the improved condition of Manistee Lake,



explaining that portions of the Packaging Corporation



effluent had been diverted to the Big Manistee River and



to Lake Michigan, as these bodies of water, he states, "...



have ... the capacity to dilute the salt and assimilate



the oxygen-demanding effluent." (See P. 2022)



          Since this letter of 1963, our Nation has become



aware that our oceans and Great Lakes do not have this



sempiternal capacity, that our earth and water and air



are limited in what they can supply without care, and that



we are drawing close to that limit.



          We hope that our Water Resources Commission would



act according to this knowledge, even if it would mean



reversing previous orders.  And yet when the Packaging



Corporation of America completes their $6.5 million secondary



waste treatment plant in December 1972, we have been informed



by Donald Voigts, their Environmental Director, that the



brown color of their mill effluents will remain and that the



chlorides cannot be discontinued; that they are "necessary



to sink the color."  (Out of sight, out of mind.')
-------
                                                      1972






                      D. Schindler




           We are not saying that Packaging Corporation is




not doing something about their pollution.  Six and a half




million dollars means they are doing something.  But we




are wondering if the priorities are correct.



           Just a minute more.




           We are gravely concerned about the continued




addition of chlorides to Lake Michigan as this is a



freshwater lake, and adding a million pounds of chloride




daily is bound to have ecological consequences unnatural



to freshwater.




           I asked Donald Voights what he thought a million




pounds of chlorides entering Lake Michigan daily would do




and what effect this would have, and he shook his head



and said, "Nasty."



           Ecological consequences are of utmost importance



especially when ground water contamination of the Manistee



area and no doubt dryness and various misuses in other areas



will force the Lake Michigan watershed area to rely on




Lake Michigan for drinking water.



           Our concern is multiplied threefold as a result



of MWRG's Regional Engineer, Robert Courchaine's statement




to MACAPO's secretary, that the MWRC may consider exempting




the Packaging Corporation from the concentrated chloride




dumping termination date of December 1, 1971> "as it might
-------
                                                      1973






                      D. Schindler



work a hardship on theme"



           The temperature as it leaves the factory is 90



degrees.  Charter boat fishermen have said it is 4 degrees



higher than the surrounding waters.



           MACAPO has no desire to shut down any industry.



The industries are only doing what the MWRC has allowed



them to doo  The economically feasible, technological



methods are available to stop this willful pollution, but



it is our opinion that the MWRC has placed the people of



Wisconsin, Indiana, Illinois, and Michigan, second to the



special interests of industry.



           MR. STEIN:  Is that the conclusion?



           MISS SCHINDLER:  It would seem a most reluctant



attitude —



           One can only conclude that if this — just a



minute, please.



           The scope of this deterioration is not by any



means a local problem.  Those of us who have taken part



in this Four-State Lake Michigan Conference can readily



see that this vast volume of high parts per million of



chloride can saturate the total volume of Lake Michigan.



           One can only conclude that if this continues and



no cease and desist is rigidly enforced, the whole of Lake



Michigan will approach and surpass the high chloride
-------
                                                      1974






                     D. Schindler




standards set by Illinois and Indiana.




          In conclusion, it is a sad state of affairs when




the attitude of our State agencies is that of the old cliche;




Speech is Silver, but Silence is Golden.




          But this is an era when something must be said;




more importantly, something must be done.




          I thank you for this opportunity to speak, and




we hope with your help that all pollutants of Lake Michigan



will cease and desist.  (Applause)




          MR. STEIN:  Thank you, Miss Schindler.



          Are there any comments or questions?




          MR. FETTEROLF:  Yes.



          I do not feel that a total response to this is




called for at a conference on thermal pollution.  But



very briefly, I would like to say that in response to the



letters sent out by the Michigan Water Resources Commission



in August of 1970 asking the salt companies to enter into



a voluntary agreement to virtually eliminate their brine




discharges by December 1971 have been responded to, and




the companies are investigating various techniques and




will submit their plans as soon as they are prepared.



          Now, once the plans are submitted, then we feel




that these voluntary programs will then be incorporated



into an enforceable stipulation by the Commission.  For
-------
                                                       1975
                     D. Schindler




various reasons it is impossible for them to go ahead




immediately.  The areas are simply not available for them




to dispose of their brines, but, Miss Schindler, there is




one area in which your organization could be of a great




help to the industry in that area:  the Packaging




Corporation of America is proceeding with plans for




secondary treatment and disposal of their wastes.  They




are having a very difficult time in having any of the




townships agree that they want this treatment facility on




that land.



          If you could perhaps work with the local




officials up there to aid Packaging Corporation to find a



suitable site which could be properly zoned, this could




certainly expedite the matter.




          MISS SCHINDLER:  The people don't want the



Packaging Corporation clime because it creates a horrible



odor and it kills the trees.  It is brown, untreated



effluent, and no township is willing to accept this.



          And in response to  our statement about finding



ways to return chlorides, or eliminate the chloride




pollution, I am wondering why Mr. Purdy will not respond



to our letters and what is wrong with the five or si;c




methods we have suggested for eliminating chlorides?



          And it does seem that there is no more
-------
                                                     1976





                     D. Schindler




technological method than simply returning the salt back




into the wells from which it came — the inoperative wells.




This would eliminate ground and surface water contamination




without any problem at all, and our own engineering data



has shown that this can be accomplished in 30 days.  We




have received no word from the MWRC as to why this plan is



no good; if it is no good.




          MR. FETTEROLF:  I would be pleased to take this




up when we get back in Michigan, but in the interest of



time — if that is your attitude, I would be glad to go




into a detailed explanation of this.




          MR. STEIN:  Are there any more questions or




comments?



          MR. CURRIE:  Yes, Mr. Chairman.



          I find this testimony profoundly disturbing, and



what I find disturbing about it is the possibility that



any such things as- described in the testimony may be



happening to Lake Michigan.



          I think this conference once again should be




urged to reconvene at an early date in order to consider




such problems as chloride accumulations and chloride




inputs to the Iake0  I recognize that this is primarily



a thermal pollution workshop.  I think we have to get




back together very soon and consider all our other problems
-------
                                                      1977



                      D. Schindler



of Lake Michigan, and I would urge the conference to recon-



vene soon in order to determine whether or not there has



been compliance with the deadlines set down by the confer-



ence itself in the past and, if not, to cause legal action to



be instituted wherever necessary to assure that compliance



takes place; and finally to reconsider the adequacy of the



standards themselves.



           Again, I would like to note the comparison that



Miss Schindler drew between the Illinois standard of 10



p.p,m, of chlorides for as long in the future as 19$0, a



standard which I criticized yesterday as too lenient, and



the Michigan standard of 50 p.p.m.  (Applause)



           MR. STEIN:  Mr. Currie, I have always said the



four States up here had some of the best water pollution



control programs in the country0  I spent a good part of



the fifties and perhaps some of the early sixties down in



the southwest dealing with oil well brines and salt pollu-



tion on a massive scale.  I thought we had that licked.



I thought we had the remedial facilities down there with



reinjection.



           We have cleaned up tremendous oil fields where we



had brine problems, and I surely hope the States can do this



here without any assist from us again because we hate to



slip backn



           (Miss Schindler's report follows in its entirety*)
-------
                                                 1978
            THE CHLORIDE CONTAMINATION
                       of
               Lake Michigan at
               MANISTEE, MICHIGAN
                  Presented by
              Miss Dana Schindler
                  representing
                     the

MANISTEE COUNTY ANTIPOLLUTION ORGANIZATION  (MACAPO)
                     of
                MANISTEE, MICHIGAN
                  PRESENTED TO THE
                     FOUR STATE
        LAKE MICHIGAN ENFORCEMENT CONFERENCE
           September  23 - October  2,  1970
                       at the
                    SHERMAN HOUSE
                   Chicago, Illinois
-------
                                                            1979
 Representatives of the conference:

        It is immoral for Michigan industries to pollute water
 Chat the people of Illinois, Wisconsin, Indiana and Michigan
 are going to have to try to drink.

        I hope that you have all had the opportunity to review
 this presentation.  Your future drinking water is at stake.

        When MACAPO was founded April 29, 1970, we decided to
 tackle the worst pollution problem our area had; water pollution.
 We didn't know what to look for.  As one of our members put it:

        You can see it,
        You can smell it,
        It's NOT water;
        It's something else?

        So we took water samples and had them analyzed.  A copy
 of the analysis is attached.

        Through investigation, we found that our drinking water
 was being contaminated with chlorides.  These chlorides come from
 salt producing industries of our town; namely Morton Salt,
 Morton Chemical, Hardy Salt and Standard Lime & Refractories.

        Within the text of our report, "The Unpolluted Truth About
 the Water Pollution Problem in Manistee," we outlined every
 problem we were able to find in our area concerning the ground
 and surface water contamination.  Nothing stated therein has
 been refuted by the Michigan Water Resources Commission or their
 subsidiary agencies.  A copy of the report is attached.

        In our attempt to stop this chloride pollution of our ground
 cind surface waters, which includes Lake Michigan,  we drafted a
 letter to Ralph Purdy on June 13,  1970, copy of which is attached.
 In this letter our engineering data outlined 3 feasible methods
 to discontinue chloride discharge completely within 30 days.
 The MWRC will not issue the cease and desist request, which was
 included in the above letter, saying that conclusive evidence
 of injury does not exist.  Copies of their letters to us of
 June 18 and July 30 are attached.

        In early June we also learned that the MWRC had just
 completed a 2-year study of the Manistee area to determine what
 was responsible for the chloride contamination and what feasible
 methods could correct this.

        On July 24, 1970, after much pressure on the MWRC from
 our group,  Ken  Childs,  Geologist for  the  MWRC  presented his
study in Lansing.   His  findings, opinions,  and recommendations
are as outlined  in our  news release dated July 25,  which is attached.
-------
                                                                1980

 His  study confirmed everything  our previous  reports
 had  already  brought to public attention and  then  some.
 Also attached is MACAPO'S presentation to  the MWRC on
       The MWRC  then, on July  30, 1970 issued a letter to all salt and
 brine producing industries.  We attach a copy of this letter and ask you
 to note  especially the target date of December 1,  1971 for the
"elimination of  concentrated chloride  discharge." We  have since  spoken
 to the MWRC and have inquired as to what disposition will  be made of
 the lower concentrations of chlorides entering Manistee Lake and
 the Manistee River, both legally and  illegally.  The MWRC  advise that
 they'll  probably have to establish a  program to take care  of that.  So to
 our knowledge,  the MWRC has no program plan except to ask  those industries
 to voluntarily  discontinue concentrated chloride discharge by
 December 1, 1971.  By figuring the daily chloride  discharge to Manistee
 Lake  and Lake Michigan, these industries now have the green light to
 pollute  YOUR drinking water with over 1 (ONE) BILLION more pounds
 of chlorides before they legally must stop.
       We were not satisfied with this target date  and our  next  stop was to
 draft a  second  letter to Ralph Purdy, again giving engineering  data on
 how the  major chloride producer could alter his process in a minor way
 to greatly reduce chloride discharge.  To date, Mr.  Purdy  hasn't seen
 fit to reply to the letter dated August 28, 1970,  which we also attach
 for your perusal.
       Also attached is a copy of our  letter to Governor Milliken
 dated September 1 , 1970.
       We have been in contact with the Corps of Engineers, our  United
 States attorney and the Federal Water Quality Administration, urgently
 requesting their intervention on behalf of the people of the United States.
       We have been advised that a federal investigation of the Manistee
 area  waters is  scheduled by FWQA, although we have no specific  date
 when  this will  take place.  We have furnished evidence to  the Corps of
 Engineers and requested an investigation of the waters surrounding
 Maniotee so they may furnish our United States Attorney with proof of
 violations of the 1399 Rivers and Harbors Act.  To date, we have received
 no confirmation if or when the Corps  of Engineers will investigate.  The
 United States Attorney will not act until the Corps  of Engineers furnish
 the evidence.
       The  Packaging Corporsion of America  is creating a reverse estuarine
 by dumping 1  (ONE) million pounds of chlorides per day into Lake Michigan
 which they purchase from  Standard Lime & Refractories.  This figure  was
 confirmed  in  Norman Billings'  letter of May  11, 1970, which is  attached.
       In 1956,  the Corps  of  Engineers  issued a permit to the Packaging
 Corporation for their  present 24 inch  pipeline to Lake Michigan.   Section
-------
                                                       1981

of the permit allows a MAXIMUM of 5,000 pounds of solids to
be discharged daily through this pipe.  Therefore, it is
MACAPO's opinion that the terms of the permit are being
grossly violated by this chloride addition.  Incidentally,
these chlorides are added to increase the specific gravity
of Packaging's 10-1/2 million gallons of paper mill waste
dumped daily into Lake Michigan, which is supposed to make
it sink and "disappear."  This industry does this with the
blessings of the MWRC.

       In Manistee Lake in June of 1950 the paper mill waste
from this above-mentioned industry, in combination with weather
conditions caused a fish kill believed to have been the largest
in the history of Michigan1  Please note that a September 1963
letter from Mr. Purdy speaks of the improved condition of
Manistee Lake, explaining that portions of the Packaging
Corporation effluent had been diverted to the Big Manistee
River and to Lake Michigan which he states, "have the capacity
to dilute the salt and assimilate the oxygen demanding effluent."
Since 1963 our Nation has become aware that our oceans and
Great Lakes do not have this sempiternal capacity.  And yet
when the Packaging Corporation completes its $6-1/2 million
secondary waste treatment plant in December 1972, we have been
informed by Donald Voights, their Technical Director, that the
brown color of their effluent will remain and the CHLORIDE
CANNOT BE DISCONTINUED; that they are necessary to ...SINK THE
COLOR:

       We are gravely concerned about the continued addition
of chlorides to Lake Michigan as this is a freshwater lake, and
adding 1,000,000 Ibs. of chloride daily is bound to have ecologi-
cal consequences unnatural to freshwater.  Ecological conse-
quences are of utmost importance, especially when ground-water
contamination in the Manistee area and no doubt dryness and
various misuses in other areas will force the Lake Michigan
watershed area to rely on Lake Michigan for drinking water.

       Our concern is multiplied as a result of MWRC Regional
Engineer Robert Courchaine's statement to MACAPO's secretary -
that the MWRC may consider exempting the Packaging Corporation
from the concentrated chloride dumping termination date of
December 1, 1971,"if it might work a hardship on them."

       MACAPO has no desire to shut down any industry.  The
industries are only doing what the MWRC has allowed them to
do.  The economically feasible, technological methods are
available to stop this willful pollution, but it is our opinion
that the Michigan Water Resources Commission has placed the
people of Wisconsin, Indiana, Illinois and Michigan second to
the special interests of industry.

        Please refer to the news clipping which is attached as
-------
                                                       1982 -1983
one further example of the ever complacent attitude of the
MWRC In regard to the pollution problems of Manistee.  Even
after an exhaustive 2-year study by their State geologist,
pointing out the extreme adverse chloride and paper mill waste
deterioration which plagues the surface and ground waters of
our area, members of the MWRC now take to the public podium
to reinsure the main chloride polluters that any small gesture
in reducing the chloride parts per million, whether by adding
a volume of water or other devious means to perpetuate this
facade upon the public can now stand reassured that the courts
will take no action in public or private suit for cease and
desist of chloride contamination as specified by MACAPO and
highly recommended by their state geologist as a first step
in the restoration of the waters of our area.

       We of MACAPO feel that this is just another gesture by
the MWRC to gloss over the major problem of our area, by
usurping the final verdict of the courts of our land in favor
of the continuation of this most immediate deteriorating pol-
lution problem of our area.

       The scope of this deterioration is not by any means a
local problem,as any of the States bordering Lake Michigan
who have taken part in the Four State Lake Michigan conference
and are concerned over the chloride parts per million can readily
see that this vast volume of high parts per million chloride can
saturate the total volume of Lake Michigan.

       One can only conclude that if this continues and no cease
and desist is rigidly enforced, the whole of Lake Michigan will
approach and surpass the high chloride standards set by Illinois
and Indiana.

       It would seem a most reluctant attitude on the part of the
MWRC to ignore the major problem by inserting other pollution
problems of the area, rather than attacking those which have
been exhaustively researched for final and conclusive analysis
as to their ultimate solutions and corrections; such as the
chloride problem rather than the sewage problem which is a
universal problem throughout the United States and the world, and
it is a handy pawn to cast into the foray of pollution problems
so as to create a diversion while the major stigma of our area
runs rampant, unabated by any such firm cease and desist of
chloride pollution.

       It is a sad state of affairs when the attitude of our
State agencies are that of the old chliche..."Speech is silver,
but silence is golden."  But this is an era when something MUST
be said and something MUST be done.

        We  thank  you  for  this  opportunity  to  speak and not be
 silent.  We hope that  something  will  be done in the immediate
 future.
-------
                                                                  r. D. W'K'ttS^lPr '-*1! •^•'^  ^*
\\' I  L I.I AM S  &  WO K  KS
I  . "4  o  I  - N  F  I.  R  S  -  0  U  KVCYO  R  S . —  P  L  A • N  NER-S

                                                      250 MICHIGAN ST KEF. r. M C
                                                      GRAND RAPIDS. MICHIC.ATJ -I'lOm
                                                      TELEPHONE 459-4.-OI

  May 22   1970

  E-75650
 Mrs. Carol Magnus
 103  Sibben
 Manistee, Michigan  49660

 Dear Mrs. Magnus:

 Subject:  Lab analysis for Manistee County Anti Pollution Organization

 Enclosed please find our lab report covering the water samples you brought
 to our office concerning  subject project.  Also included are two sheets of
 "Water Standards" published by the U. S. Public Health Service and State
 Water Pollution Control-Board,  Sacramento, California.

 The  cost for this analysis will be between $70 and $90 for which a billing
 will be issued shortly.

 Sincerely yours,

 WILLIAMS & WORKS


 - . U.' •- v '- '-• •(<>• •- • - '-'•'
 F% Winchester

1ml

 Enclosures
DlRFCTORS T C 'WILLIAMS t 1. THOMPSON, G. H STADT, K. W ANDERSON, M. M. CHAMBERS. F. E SPICER.
             K l f'LloIT. J  A MtrtDZINiKl. Z R. MILLER, L. VAMIK HORS1. A. O. HU5IVCDI
-------
                                                                             19S5
Client :
j,t>ri.-<- ' U-L v/V
    LABORATORY DLl'ARTMHNT




Water - Waste Water - Soils






	 _        Project No.




                  Date:  •?*
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 ccii Jlr.i«t aad maintain a 5'?  ineh pinallna  frriu tla-air J?ll«r City,plant ts

 t© )tarjl:?t of "e7apcrater'-riadfinsaie frsn  cbenical .rscovory
 ec.;l rri^'ral black sulfits .Liquorss pulplu^ aarl blacchins irest« 3^5
                                  sulfita 3«a.i»ciie^!iQal and
       -.r?.'ifls 'Dsoem^'sr 19&3>  the Wt'fe^r ?ssc ureas Csjasio  dlaausas'tSstQd "that
 tia". K-,3 vid ss irabls sdcr*  sjid vc-l-azs 5.n. Laic's il3.clil,ssji3  &3 a result c
 ta«.« P3l.disc'saz-g'?!, v^ys dc."'<:-lm<5ntal to asa£ *33lns icads csf the !afc®e
 P'QA f'io ;^«iiu-st^a tv take serra^tive a?stdsno.  2ha compea-y prapessd
 t7 :E'S Kjirsai  8illir,gsa l.rfctev to izs ef May 118 19700'
      Trtis 30 inch pipe!3.a«  Is  supposed tc bo eU^Qked aoauallyo
 aj>'f riling to. KXRO staff eus'ifisers Geerge HdclS;, this outfall hej* nst
 bsij  sjhac'ked fer 2»>2^ ycar":->0  «yc Llddle statofi at sur iteefeiag Kay  23tf ,19?J
 tiif.'  Its is  satisfied  In hla tzyjwlsfiga «.f whet tJis outfall co
 si it soes no  r-eaBcn ta eaoipl-^ this n^w t.oeau.ss a PCU.  ssca
         il .plant ie ta be in operation DaGsabe? Ij, 1972£
-------
                                                                     1989
                 ivs en E3.ll  sr;ill s^splala af c-fivir end water diseol&ra^lc
Irs  ." s.vfear bffiafe fisfc.er.r5 a' advise thai; tinder osrtsdn eeu.clItioJiS 8 .this
•".-". s f ^crat^ojj Rictecfs ffpii ib.3  otsifall as far smth as PTaa*:fe.ri(,
^(VcLgaao   I'he sharper tea's  fisherasoa alas ad/isa  that, they hare seen  and
Sf:"i le-yad  papor refiise fr^a  this area ©f feh© cutfall on.' asay aceaaianso
H,«5 hf.ve  also taicsn vatar teap era tares at this  out-fall asot adrlaa that
tsti^i 3  io afecsut a A dagroe- Mglxer sempsra^arg at  the Csutfall than in
tl.c  i;i[a£ent watar area^o
     It. 2s eur conte-Zitioa that'ths reereati-^aaX  use of this araa '«Tf
IH-JIS Michigan has bean sovc-rcaly iiapair-sd by th'ls outfallo  A ehlorids
If -7-5 1  of 220 rag/?. Tras tsflsil s.''s this I©satl3a0
     At cur Q«stlng M.iy 28,  Geergd Liddls ifs^ asked if he was aware
e£ 1ao l'i-ct. that a numbsr cf pEiirats residejxees  tmd the U0 S0 Coast
Gtiai 2,  snstisn on ths end ©f  Fifth Avenut vor@ pviunlng raw sawage
d:,«s";l~ iato ths Kaaistss 5iT8rc  He said th*a*  he was awara of this
f u«1 3
     Shsra -is a fircie ths Kanistea Plating boapsiiy-., vhlch-.-ls located
©n tii 3 I-Isaisfesa &-srsrc  Aei-crdlias to the ,!-!ie!ilgai3.  Daparfeia^at of
Has.* t"a A3,r Pellutisa Surysj^  ©f  19648 this company  usas the fellowlag
                          Kydrcehloric
                          Suifuric Aold
Gi^zgo  Lf.ddls was asicsd at v.ur ngatins May 289  "What d© th'«y ^g.
wltl thoir vasts chealeals?"   Mr0  Liddle than ajslsed v.ga "De yfeu know
i" 'hay e^ tc tha lefca or ti  the eaaitasy syEtem?"   He tfi®n said
"?a: b-ii33 we tsusht t& loci into thls0"  This platlag CQiapanya being
    .ta.i tin the .nsrth side of  tha ehaimel is in  aa area of t©wa vh«re
    9 If not alls, ©f the ssTrags is diaaped raw into  the eh anno !„
   i oi-23 llttla  diffsT^eneo T.-hat vho plating e@mpj>ny does with their
   : «3:aty  it still es.uld ge'5  to the ehaanslo  Ihis  eempaay eould  ba
     "9l*fiiia0  cur  •Jfsr^y is that they haven °t been «hseksd0
     In <5he lianistee Eivar there are a group of aduotor pipes located
     fcha Memorial Exldge0  Th5,s Is tha disc,ha^3 pcint for 387oOOO
     3  ».f  ohlo rid ea par day^   1'we  of' ths iadustrlas using these pipes
ara   S2iai
-------
                                                                  J.990
{ 5';,, a "te^il  Mass sells to-la* -c 2QA to sink i;;s pollv,taats IE. Ls!:a. Michigan,,-)
     .Echigpa Tcol Ocijoif.'-'AOag a diirisica -:f Manistee Irsn Works  is
l'»«?«".$ id ©a Kaaistes Lak&j, .;t ths asouth  of cap Mania-fees.Rivaiv   This
e/jsne;^ Is aoms^aa'fe of aa taku&vn, quantity with our greu?0  Thsy ar^
b3£'..aaias  "to> landfill part of the lalso  and vs suspeot th&t ssae ssrt-
of f-isshargej,  perhaps cII8 Is cennectsd with this operation but as yat
10 tannet  say for osrtain«
     Michigan Ch>3cii©al is located on the east shsrs of Maaietea LaSe0
           ha3  issued an Oyde-r of Defcerainatlaa for their discharge' iat3
         Laka0  Ths eheaic?.! they -.prsdU'Se 5,3 l)TO"a.ine0  -The.state
tia  tlislr disoaar-gs is "iasignifloanto*  Hs-^vers, the state alsa
tli&-  Ihoy  d© nst phyBic^liy sample thesa pljjgs asmually0  We hars  had
rsp? r-is that this filsehas^s pipss.dees  Q2aAt br4E.ss sometiass in largs
q.acj .titles,  but ve have not, .as yet iaade- a psaitivs chssko
     Haydy Salt is located on-the west  sh^ra of Msjaiste© Lake and  ire
bal. s?a this company to be a chief offender es 6s chloride
TTia. Sss.*e  of Michigan hs,s na  Order of "Detenainatiab. fer th^ir
    c*,ra water tests analysed by a private la'ssratezy show this  area
    ,slaai3taa-Lalc:ep plus  waste p&nds aheira cu fefe
    5a addition to its 30 :lnoh pipeline into lake Michigan,,  «hlXe -the
    ;rlds leiral shsxild be leas in this areaB our tests ohov 50 ?..*
es  \ndlcated on our Taap0  ihelr dlsehexgs pipes into Kwiigta
contain @n©iu;;h solid materials P© as to have fosaad «, Iftstfii
  ft ,«aulle  eati©a0  This fill eztends^ at least 25  yar-.U iota
     tho
-------
                                                                         1991

                     ta,te.'~  • ::.:> vb, ycxincUr^s" -^  this 25" yaztl p*»iat9 s 5,15s -
  ri': t a  agr^-adc.   In a^-I.-y.pi', -islv
  Si-; £ 'i.v'ry " rssicraSj, i-axv   ri^'.'lgS                        _
                ttf that arounet 1952* -fas State  ef Mic>tijga,a g&vs  PC4'
                15 por oea-s  of the flev af  tlie "Llttla  Mtnlstaa SiTsy.rs
 tfc'e sr pradu^tion ©f papciro   Tv*^ vsa  at -Is^-st 1,000 erlea. is  il
 3 rr &r  t;f  Vsils'a 33 '§3-3 -to  b.j'u 'fast or 3© at^va th^-
 wit r ;.* "k^a  '2b9  fill r>at-;-:lil is
                                         . " *                                >
 Iv  *i,.a  ^6 consist Esst.1/ v.r wssd fits??  ^cd  Q3.*k  id,th as^lltr f..-s -ia'
 e*  £,3=-vuile vn:ri,e0   Th« f'.ll py?seatl7 e-rtsnds i«j tha. «dg« of  »*. «;--.!
 « ss? ai.-   fhia fill S3 fcelT^  u'.:uapsd dlrsetliy  late -fs.tEr<>  . *-;»ra  «?•=
 sir £.1: rriuu-il'j.,.; tiriu^h "shH; ^'irsho   feTe e-^nt^n-l that  th« fill i--*^. --,•"
,1 17' ii <::'  ih? /ill  ar-3 lei;,.- th* "ardlaiar/ 'ai^h 'n,fsr
kis- 1 :;• j«:9  tbs ij-jdea  haa nr-? 7>3t B-^guji %h-* aur-Ts,/ »n4
lit;  L'- .U  landfill  as taar ^.-'s-anisAtlea rs-iu^BtsA la '3ar latter t®. .,,
¥15' k- r <* "/--v f  1CJ7'(*>
    -i       ~«*       »'                                                   --
 s.i'3 t v-3*'v.,liji%3 sariy va^i.^  Siqusra  frotn -,'OA  s
 f)' ; a XyH,r>"0   1'htJi^  is rJ?e<:;a to b«H«ve
 a.il fe vet  a  rigid Laapgeti-sia  schsd^le  has i.
                  vt l^rOp ar:u.tar wall ser
   .)'   );v-ic   Tiis mitsr ffR3 a  tl^sJc eslcr -ac.
h ,1!  -,f.i 1h*  5aat of  their r.las% art? t
• uc.i*it ;'sr
                           Tb-  wall v^ax  bsd j---,ei  -^' -~r    *  .&st,  c,.
P' WE* j ' •;.;  disturbed  bj a 6, r^lias' "4,0  incrs-aae  djv:i1n9.-;e  inta ih
W;  s TT net -pa^ltlTa  this was  tho cauae8  b^.A ths  "^i
e- m 1 si'°,en0
-------
                                                                     1992
   1
     £4.ia/.pira.B3 th-;.?. *o zmh  POA fros uhss.e
   1 . discharged  to Lake Michigan sad to Korion  Intoraatleaal £ x-en
     '.e It sTgafeually enters Manistae Laks or ths  M&als-tee Jlivaro
hsrs t?3$td othar pipes eomSsg • farom Sfcaadard Lime with ona tssfe
l^.sJ'O ppm of hsxana extS'aotablss (dll)0  Standard. Lime h33 alsa
fill d ;>a:ct of the laS:ec
      pips souit la 58 to dates with 4 pipes  arssently disc@ygr®4
In t » l-lanistes Blve3P0  The^'3 are ©nly the pipes  that are' ab©Ta vat©rc
T^3 < f those pipes ay® leaiuig ell lat-a Msalstea  Lake0  W
Mr0 ; Udle that ws ars will Jag to furnish a beat  end personally
hij •© iihos® two  oil pipes 9 ©f "Whleh ha is not aware0  When-ws
>Ir, MadlR if lie  was going to shut down ths 38 Illegal pipes that hs
dlia-t Jacw a^^ufe he rsp23.edu "N«p I caa8t shut  tlism dawn until I tai&v
vhit li eomlng out ©f them0 w  'this Is In spite of ^he faet that the
ce.ip. al«s haTe eonstrueted illagal disehargg pipes »  and that thsy
n® 0. dsr ©f D®te2tt.lQatl©n tc esver their disehsygSo
     A3 you G0a.S3S from th-s absTe,, we da ha-re a various pr@blea0
Ouif : air has bsen landfilled by Ind-astxlal 2fubblslis  polluted by
talsy fj^ra raw elty esirage "t.e high pateuey ehemicils and ehl©rld§p0
Ons ( f -Jiho VfilO bl©l©gists9 Michael Nswton admitted th-at ttueh ©f the
bottia is dead and the rest af it is bslow aysragjo   Thielc sludgs and
seit! l:^s fa^m these Industrial psroesssea have e©it;ed the bottom of
ttt-j ra^po  For exaapl89 off tha Hardy dlsobaxges,  'she daoth s©uad«r
go js fixm 42 feet to 18 feet t© 38 feetp ijadlcatias  a substantial
b® 5',t a buildup*   Wa do not willingly sat th$ penflah in Msaistss I>a\;a
b*'?5tt so of their bad tasta.0
-------
                                                                  1993
      u
      AT. & gr»wp8 va ara susQied and disgusted by th« "roadblocks threrea.
    c  We ar® disgusted  by svasira-
         end by departments vhleh naie up thai? «r>fh. rubles tfhioh are "net
 S2i>f.i£j.e£lly.witten Into the  lawa end by Siate afflciala  vlio tali its.
 tli at if,perts aad answers we  ask about are Maone Qf your, bus in«S30"
 tfii r:a,cji at tlis Infer-anea ^hc-fe we ers not into3.--igi3at enough to raad aad
 e-yalUvV e' stats repoxrss<,
      Si-nee tais papsr wss ';rrittens •we hava fcnoxd ssm»""or th.s extent
 ©f em" ehlsrida problem te l!anist^a«  The city has had t»» water- w®ll3
 t'ss--  art tea salty to us$<,   We have found that thora Is, an extenaiT.e
 c'il- arlt'Q report that Is a&t  yet"completsd0  Once ehlo rides se^p into
 6ir d^'niclag watafg >«•« -Kill  be 3,E t rouble 0- -Wo-h-^va found  that sur
 li^ shifts cwuld puap thsir  ehlcrldss bacfe dc'tm .Into the brine valla
 tfia: « <:.hny csaa fr&s0  Th-uy  could stop this chloride pellutloa within
 a  v ry short tlm®0  Th« tlr.3 Is n©v t« fore© ths^i to do thisc  This
 wil', a;-uae thea a©ms expanse and they won't gat 'fehe revenue  fr©m this
 wis- 3 Vi'iJis as th$y do nsifc  But vs nust st*p tnls ehlc-rld®  pollutiss
 o? * u ^ drinking vats^p en® of  ©ur nsest nesessar/ resouress0   -
 ON -w-Km
      ¥.' cant and that the Psople of tho State of Michigan and ©ur
 dia'al; hCJog natural i^oscTirosa  hs.Ta been plased s seend to th® spsoial
 lit r^: ts" ef inauat-iyo  We' hsrely roque0t a cemplete investigstlen af
 t"ie Mi Mgaa Hatar Basouces  GoEasission9 as the M,U000C0 will pr-9?@a«,
 fe^ *Jb-3 aaylieat possible Eorasnto
      T..6 time is now to put  priorities in proper perspeetiveo  W«
 M7S-"1 p--,t an end t© this prae-tioe of State ponaissiveaeps t©was4 industry c
      Wj hays Iaw30  Since you  fully enforce them whers the prlrat*
-alS ',**•'. is eonesrae^j, thsn we  D£MAJJD y@u squally anfsres th«a
 iid '.at-.yo
-------
                                                                                         1994
                               Ti^ CuUMTf Aiv'Tl POLLLi'i'lOW
                                         (MACU'O)
Box 282
I-ianictee, jiichi^an 49"»0
June 13, 1970                                                       •

                                                             \T'\
                                                           f"\ v         ,,                .,
Kr. Hal ph. ,/.  I\irdy, Executive Secretary                       v        •' ,               '  '
Uater j\esoui-ces Co^.assion                        /      I           /  ,.^            \
Stevens T. Ilacon BAilding-                         !       v •''       {
         Michigan
Dear Kr. j^urdy:
Wo, the ircmbeas of i-iAC^'O, request tha/i, the Water Aesources Commission, give most urgent
consicseratiou to a Cease ana Desist Order of Determination for chloriae tatposal.  by all
industries  in i-,ardstee Comity.

The time period for the uease and. itesist oruer shoulc.  be  liberal, thus beariii,,  .TO hardship
on any incuLtiy aiu <;Q ru^ .-/-3t  tne c^nf-JLO'^ration 01 a  JO  uay Li-ue period, et^cctive July 3'J
of this year,  v/nich is norc than  rraple to coTi^ly with  the above oraerx- in our opinion.

[.'he Cease and Desi&t orcier should be explicit in the elimination of chlorides beinc
disposed in the following areas:

                1.  Laice Kichigan
                2.  I-ianictoe Las.e
                3. ' £i£ Kaiaetee fiiver
                4.  Little kixnistee llivcr
                5.  Any lana area  of hanistee County where seepage or process of
                    osuosis vill allov; cnloricies to ccntasiriate adjoining waters
                    and/or properties above the iiylvania level.

To cay that the ?.bo\e Ccare and Denict orcer IE not practical or i'easible because of
the reco!O..cnc1-:ci J'J d:\. co:n;>lif:r.ce period, XP to oelittle  the .\n^-enuity 01 free  enterprise
aua tiiaL old iiuJste laiov; h;» in. ^et'vinj a jo'^j c;.;, .

il'Li 'o liio i. .(in. trif n ol I • ni •. te-:  cr<- v -.'!ii_ tr_':th- r  in  dic;-^-inj 01' crJ.oricPS into
the surrounding waters of this  coiuity and Lruce i'dcrd^an,  ic s^eiiis onl> equitaoie that
they shouLa WJI-K jointly in the coifipliaaice witu the Cease ana Jebisi oruer  ana  acco.-^lich
B?t.'.a f'jup in tht- ctbuve pe.aocl o:'  ^J a/.ys.

ii' i.l;tio 1;; a J-'.c.; OL i •  ].:.•: lion Ox t'u. c iu i.vu-...-,:^, It- t. u>j t- c t'-.e J.^  ' >r n^_ T v.rh
to the problem as the simplest  solution wit hi very well be the cheapest unc. uost practical.
Therefore,  tlie folJov/inr plans are subiuitled for  solutions to accompliening the Cea^a
nii'J  iX:::i£t  oi-oc-r vii; in the  ti-;^ p( lioa allowed.

1.   l.ort'.in  &ilt mid ClciMct-l,  ataii«.''.ra LLno and *;efrBctoricc, ana Karuy oalt arc tU* irtjor
     chloriue dia^orcrr. to  the  aiiovc liieutiuac-u v.aton;,  tuiu luuroiore,  should wor.. jointly
     in  the  solution of t:iis  probli m«
-------
                                                                                        1995
pace 2     iiaJph \i.  lloray

     A.  Horton iiilt cc Chejaical, have in their possession,  abandoned salt wells
         below the Sylvania level capable of receiving waste  chloriae ana chemical
         solutions.
     B.  Standard iiime has in their possession cnemical  brine  wells that are
         pUFipin^.  on a marginal oasis.  These marginal wells  could be tbe recipient
         of  tail  brines wnich v->ula erhance the static level ol  the fiela .within
         the near vicinity in the Sylvania level.

     C.  La; dy  ,^alt has a variety of wells, .some of which  are  not conducive to the
         production of quality proaucts ana could be used  for  receiving excess
         chlorides and/or chemicals.

'Kierefore, each of the above industries has, witnin its  own  industrial complex, some
facility by  vmich the aauition 01 a pump and length oi pipe  cun  retum the excess
chloriaen end waste ohloric.es to the strata from whence  they came ana meet the pO day
cojspl.iaace period.   Tnus the cost annually would be the  Dumping  of these proaucts
ana by-proaucts to tho strata arid tne luss of a slight s~mount  of money from the profit
column of their annual statements since tnece cliloriues  •will not be sola for the
purpose of hiding other industries contaminants.

2.  Providing imagination is lactcin£; for the §bove program by  which each industry
    v;ouJa have  to proviae has own pipe and pump, the following method is suggested.

     A.  de jointly owned I*." pipeline v;nich presently  icstoons i:?.l v.cll, \'T.Th
         S-4, o-^,  :>-o or S-2, v'nich air; all close to 3-1, as  a  stanaoy well for
         alt '•".•'4 "'.to Li?f-o~r'}  ;ii.-n.-^-.e-,j tv'ur- allowii\. tl e  ijf«  oi one ot the above
         mentionea veils as an alternate wnile pieventative  maintenance is Deing per-
         foii'H;u on .j-1 to iai''Utain its £,ooa receptive properties,   ihus by selecting
         I>1 cir.d  or,o ol  t'.c raoi • :'^n"v i ^r.eti r. "r.j"i.i-1i pjoauoiu^  veils ar a aitposal
         systea,  the area vuula be ensured of continuous and complete oisposal of
                < c; •- i .id i: : '•: t. !ovi..t'.'. nn  !„••.; .'•'•...
    If thu abovt; t\;o  mentioned rnetaods are of such iiagiiitude  as  to ruaKe tne loss of
    profits ccc;a thcpe  icotnous impractical, the followir)u, metiiod will ensure each
    oi the above- or the three jointly ol a profit iroa  the  sale  of taeue cnloridcs.
-------
                                                                                        1996
page 5      Ealph U. J-'urdy


     A.  'Hie production of  calcium  chloriae is within tiie financial justification
         of tha aoove three mentioned  industries,  due to the high quality of ciiloriae
         brines wiiich aie now wastea as a contaminant of various waters,  it is
         comaion knowledge that  standard iiime o. Refractories has considered, the
         construction oi' such a calcium chloride facility on a profit malting basis.

Ihereiore, we can only conclude that industry can and will craiply v/ith"..a Cease and
Desist order, if issued, as each has within its own industrial complex, er jointly,
a sy.stea for fiisposing ol these chlorides on a no profit or profit basis, a.o the
three can jointly choose.

Because oi the multitude of contaminants entering the watws of our area, we select
but one lor the Cease and Desist oruer as a lirst step in the elimination of the
many contaicina/its that must oe  stopped irom entering our waters,  although this is
or4y one, our members feel  it is tne easiest to elirairiate, through and by the above
mentioned r.ethods.  A copy  of your  Cease and JJesist order iu regard to all chloride
Orders of Determination iseuea  to these three companies will be greatly appreciated.

Our Senators sod Representatives are most anxious to see the total elimination 6f thcoe
contauiiu-iiitc and we feel that this  s/nall step vriJ.1 be a bi{; move in the ri^ht direction
for the eventual'cessation  of all pollutants to thete waters.


                                             Respectfully subniitteo.,
                                             (Mrs.) Carole K:-,^.UUS, Secretary  reprefcunting the
cc:  Governor Milliken
     ben. itocert uriifin
     Sen. t'hilip Hart
     Hep. Guy Vanc.orjnet
     xiep. Deiuiis Cawthorne
     oc-n. Orour B'^vrta
     ben. JacK  'x'oepp
     iialpli Nacknllan
     Dale ur;-ii'i;r
-------
                                                                                     1997

                                      STATE OF MICHIGAN
 NATURAL RESOURCES COMMISSION                      _,.—,                        WATER RESOURCES COMMISSION

  AUGUST SCHOLLE                               't&^-ii                         JOHN E. VOGT
   Chairman                                   t * —/J                          Chairman
  CARt T. JOHNSON                               '	'                          STANLEY'QUACKEN3USH
  .  .. .,.-.-..                       WILLIAM G. MILLIKEN, Governor                Vice Chairman
  t. fn.* LAI I ALA

  ROBERT c. MCLAUGHLIN       DEPARTMENT  OF  NATURAL  RESOURCES

  HARRY  H. WHITELEY        STEVENS T. MASON BUILDING, LANSING,  MICHIGAN 48926    J|M OILMORe

                                    RALPH A. MAC MULLAN, Director                 GEORGE F. IIDDLE

                                                                         JOHN H. KITCHEl, M.D.
                                       June 18, 1970
    Mrs. Carole Magnus,  Secretary
    Manistee County Anti-Pollution Organization
    Box 282
    Manistee, Michigan   U9660

    Dear Mrs. Magnus:

         This will acknowledge  and thank you for your letter of June 13 relative  to  the
    problem of water pollution  in Manistee Lake, the Big and Little Manistee Rivers  and
    Lake Michigan.

         The aggressive  interest  of your group in the enhancement of the quality ~o_f.
    these waters is sincerely appreciated and will unquestionably be. of considerable
    help to the Water Resources Commission in 'its program to place and keep them  in
    the condition they must have.

         Your letter will be presented  to the Commission at its June 25-26 meeting.   I
    would point out that the law  vests  its specified pollution control authority  in  the
    Commission—not the  Commission staff.   I shall, however, report that the matter  is
    the subject of ongoing, intensive investigation by the staff with intended very
    early submittal of its findings to  the Commission.

         Your group's support will be especially needed by the Commission in the  estab-
    lishment of unlawful pollution.  1  believe you are acquainted with the law's  defini-
    tion of unlawful pollution  (see Sec.  6(a), attached) and I would emphasize the
    fundamental need to  show that  a given waste disposal is or may become injurious  to
    any of the values cited therein.  You will appreciate that the Commission cannot
    rest its case upon presumption that a discharge must be pollutional.  Neither statutory
    law, constitutional law nor common  law will recognize a presumption that is not  based
    upon fact, and neither your group nor the Commission would gain anything from an
    action" that is not legally  founded.

         I accordingly encourage you very strongly to look beyond identification  of  the
    various discharges, important  though that is, and be preparing yourselves to  provide
    the Commission with testimony  on how the discharges are causing or may cause  injury.
    We of staff will be reporting  to the Commission on the nature and volume of the  dis-
    charges and will look to the Department fisheries authorities to evaluate their  ef-
    fects upon fish life.  Such information, however, cannot substitute for testimony by
    the people who are affected.
'.1!C;!!.G'AVJ
TMI  f  (~
CHfAT I    I
""'  I   /
«"" /., /
-------
                                                                              199$
Mrs. Carole Magnus                        2                           June 18, 1970


     In my capacity as a Deputy Director of the Department of Natural Resources,
I am also concerned about the question of the possibility of fills which may be
illegal under Act 291, of P. A. 1965, as amended.  Mr.  George Taack has discussed
with me your recent letter concerning fills, and we have underway a full survey
of the Manistee Lake 'area to determine what action may be warranted.   The survey
will be completed within 30 days .

     Again, we appreciate your support and shall look  forward to its  meaningful
continuation.

                                               Very truly yours,

                                               WATER RESOURCES COMMISSION
                                               Ralph W.  Purdy          XJ
                                               Executive Secretary
NB:bs
Encl.
-------
                                                                                     1999
NATURAL RESOURCES COMMISSION

 E. M LAITALA
   Chairman

 CARL T. JOHNSON

 ROBERT c. MCLAUGHLIN

 AUGUST SCHO1LE

 HARRY H. WHITELEY
                                      STATE OF MICHIGAN
           WILLIAM G. MILLIKEN, Governor

 DEPARTMENT OF NATURAL RESOURCES
STEVENS T. MASON BUILDING, LANSING, MICHIGAN 48926
              RALPH A. MACMULLAN, Diredr


                July 30, 1970
WATER RESOURCES COMMISSION

 JOHN E VOGT
 '  Chairman

 STANLEY QUACKEN3USH


 GERALD E. EDDY

 JOHN P. WOODFOSD

 JIM GILMORE

 GEORGE F. LIDDLE

 JOHN H. KITCHEL, M D.
      Mrs.  Carole Magnus
      Box 282
      Manistee, Michigan  49660

      Dear  Mrs. Magnus:

           Thank )you for your kind letters of July 27.  It was good to meet you  also.

           I do rtot sense that the Commission members' intend to await final publication
      of Mr. Childs1 report before initiating formal action against the waste disposers,
      but,  indeed, that  their purpose in hearing the summary presentation was so that
      they  could get on  with the job.  I further sensed the members' conclusion, as
      summarized by Mr.  Vogt, that such matters as the housekeeping, which appears to
      underlie a good bit of the problem, were to be pursued promptly and staff  will
      proceed with consultations along that line with officials of the companies in-
      volved, looking to such voluntary improvements as can be effectuated, even while
      the formal instruments are being developed.

           As stated at  the meeting, Mr. Chi^Lds1 report is in draft stage, and it will
      take  some time, probably a few weeks, before it finally clears the Central! Dupli-
      cating office of the State and can be mailed out.  You will have a copy just as
      soon  as it is ready.

           May I attempt in this letter to respond also to the questions you asked in
      your  July 24 statement.  I shall have trouble in doing so to your satisfaction,
      I'm afraid, because they involve, in part, matters of common law and constitutional
      law in which neither I nor any of our staff are really authoritative.

           1.  The Orders which this Commission is authorized by law to issue must be
      aimed at the prevention of unlawful pollution, which as you understand, are set
      forth in Section 6 of Act 245 (P.A. 1929).  While I believe that injury to the
      ground waters (or, technically, public health and welfare) seems well established,
      the -total prohibition of chloride discharge to surface waters would be extremely
      difficult and probably impossible to defend as being necessary to prevent  injury.
      A  "Cease and Desist" order does not appear to be prospective, but Final Orders
      of Determination,  or Stipulations leading to Final Orders if necessary, certainly
      are prospective.   I cannot now estimate the detailed requirements of those instru-
      ments and can only say that they will be whatever the Commission deems necessary
      to prevent unlawful pollution.

           2.  To insure against unlawful discharges, the Cormiission will undoubtedly
              submission by the industries of detailed sampling reports.  Commission
-------
                                                                              2000


Mrs. Carole Magnus                      2                       July 30, 1970


staff will keep the arfected industries under surveillance, both by sampling and
by inspection of operations.

     3.  The Commission has, in the past, pursued-penalty proceedings only in case
of flagrant or continuing violation.  Should such situations develop at Manistee
or anywhere else, we expect that it will take aggressive- action.

     1.  Requirements for pressure testing of pipelines may well be contained in
the Order or Stipulation.  Staff have not developed their detailed recommendations
for testing and reporting.

    r5.  Michigan's chloride standards for intra-state waters are 75 ppm at domestic
water supply intakes.  Numerical limits have not been set for the protection of
other values', but are stated in general terms.  Jor the Great Lakes, 50 ppm is the
maximum for domestic water supply, computed as a monthly average, and 10 ppm is set
as the desirable level where existing conditions are less than 10.  One hundred twenty
five ppm is the monthly maximum for industrial use protection.  Our chloride standards
for Great Lakes waters have been approved by the Secretary of the Interior.  I am
sorry that I do not know what the Great Lakes chloride standards are for the other
Lake Michigan states, but in any case, I should be unable to say why they differ from
Michigan's if they do.

     While we are glad to respond to specific questions as best we can, we~are rnost
especially interested in-conveying the sense of the Commission's position and pro-
gram on water pollution' control.  Perhaps your observation of the Commission's pro-
ceedings has given your group some reassurance in that respect.  In our earlier
correspondence we have emphasized the element of injury prevention as the Commis-
sion's statutory designated duty and objective.  The Commission cannot be arbitrary
nor act  peremptorily.  If proceedings seem unduly protracted, I must state that
the Commission acts on matters as rapidly as staff can place them before it.  You
saw at the July meeting virtually all of our administrative staff, and only a few
of them can be assigned to the exacting task of translating the assembled informa-
tion into specific action requirements.

     I believe that you can expect expeditious pursual of a corrective program on
the Manistee area problems.  We shall look forward to your continuing support.

                                        Very truly yours,

                                        WATER RESOURCES COMMISSION

                                                       n
NB:bs
                                        Norman Billings      S
                                        Acting Executive Secretary
-------
                               (M.-C-110)                             2001

POP. NS'iS  RELEASE -JULY 25, 1970


           S^ Hescures^ Ocir^iiae.lcn Elating :la  Lining,,  July 24, Sen Chillds
   logist ft-r the WSC, prase:.?-; ~d L~-5-c surf-ose  and  ground water study of
-ihe ^.Jiaista* area.,  'This sa.-.ci:/ tfd: 5..-1 sc-Jia 50  square  miles is. ?ad ar^un-i
I-:3,~ISX.3co

't-IXo Chiles n&ae s. brief sumaary cf the history  of tlip  salt* brine and
pap?r Indus-cries,:   His s*udy brought to light- industrial practices
           in the degradation of surface and ground waters =
Mr0 Guilds  study revealed that the Packaging  Corporation of iaerica
pump part of their papar aiill waste through a 30  inch pipeline into
lake Michigan.   This discharge contains approximately 8-10 million
gallons a day of papar mill traste, p3,us aacthar 1~1-|  tiillicn pounds
of. cliloriclss?  wiiiGh are used to siulr the effluaato
The Pao5:agi«s  Corpr ration also pump waste to ponds  in" Secbien 1? in
Stroaaeh.,  ccnsistiag of bet we an I5~60 nillion gallons par month or a
tctal of a minimiia aiaouzit of -ys- Billicn- gallcns  of  oiitraatsd vaste, which
infiltrates  into  ths ground water, causing watar degrada'cioric  M

Kr0 Ohilds study  revealed that tl"e salt companies;,  Morton & Hardy pump
the majority cf their industrial waste bir-iaes into  Manistea Lafca and that
they also  have an industrial practice of baclc flushing their salt v.rells0
Both of these  contribute to the de-gradation of ths  ground and surface
waters „

The brine  Indtis tries.  Standard Licie and Morten Cb.saical5  discharge
industrial waste  either to Maaistae Lake or ths  Maaist.ee  Ghanael eductcre,
further conti-ifcuting to ground and surface water degradation'o  Hr0 Ghilds
stated that  all c:C the brine arid salt -industries -"are guilty of m.an.y
general practirss cf hcusekaspirig in refersaoe to -operations at we-11
sites and  plant si'tes resulting in ground water  degradation0 "

Tvro other  'cypss of degradation of ground watar of minor significance
ware reported  by  !'irc Cihilds: - 10  Poor septic- tanlr isolation and  .
20  Ice er,d  cust  centre! nhlon pcAise aa inorasse  in chloride levels in
the shallow  via lls close to the rat'.xn arteries »

Mr0 Child s concluded:   "Shis &r?e. shctrs evidsnce  of ground and surface
water degradation from industrial cperating practices past and preaento"
"In the oi^Ser  cf  their importance:
      10   Ob.loride using indxis tries
      20   Paper mill industry
      3o   Ice  and dust .control
      40   Ssptic  tanks

"It is 'believed that if these reer>mr.endation3 are1 useable,  you could
virtually  eliminate  all present vas^age of chlorides  to surface and
ground waters  of  Manistse0"
      !„   Es'cura.  profiucticn t-mstc-s J;o brine formations and salt galleries0
      20   Terminate  back flushing pDr's.ctie&s of salt eompanieSo
      3c   Review  and improve upsi  general pvaotices that  are presently
           resulting  in vast age E,rouc.d plaat" and well sites.
      40   Terminate  the use of fb.s paper indastry lagoons ia Section 17
           In Stronaoh because additional Kaste,  assuming  the premise that
           they are providing recharge to the lake,  will only provide mere
           waste that will eventually reach the Iake0
-------
                                                                           2002
                            SlA^u O," MICHIGAN
                              WILLIAM G  MiL'JKtN, Governor


                    DE?Ai< f/.'*..: A i  G.- .''/-.. ^.\.AL R

                   STEVENS T. MASON r.UilDING. LANSING, MICHIGAN 4.3926

                                . RAIPM A fAAC A\UUAS, Director

                                   August  28,  1-970
                                                               JOHN E VOOi



                                                               STANLEY O:jAryi.r.2U'-,H
                                                                 Vice Ch'*'*"-    •^rrC-Z    <--J'
                                                               /   ttifl S* —
                                    Very truly yours,          '    " L/C+J
                                                                                /c
 er.c.
 RJC/N2/sb
~cc:   G.  E. Eddy
                                    WATER RESOURCES  COMMISSIOl
                                                        lf ' ^ *"'~C'J
r .
      ,-rost
G. Liddlo, Or.
;C. Chi Ids
R. Courchaine -.
                                    Norman  Billings
                                    Assistant  Executive Secretary
-------
                                                                      2003
                 Statement of  the


MAHISTBB  OOGHTY  AST I POI-I-USIOH OIK-MI&AIIGII

                 (MACIT'O)

         prsseatad bj".l-l:-:.-'j0 GsrcoXs -^.gnus 0



                     rcsa:v:!l:ig  the
         by
                      P-- ^,-,. -, '• --r\ <-.. .j
                      J. .U--V ... S.- ..tl  - 4.' i>
                   **l fci—^.O «.
-------
        2£ cr r~z Gc^=a.c^uaz:                                    . 2004

      It 3.3 our position v'.iat ti'.s ^e'jsnse of unnatural amotmt-s of
 ohlo.T2.fie in ou? g:?xjnd sad. ans^ac:.; raters pose a. grava throat to
 supplies in the Mauls tee araae

      2he State of !4leaisar. fel'- t!is pro-blea of chlorides in th-3 Maaistea
 araa serous enough to uei-.&il Kr0 JIt-ii  Guilds to spend the last two years
 compiling data, to identify the 'source  of tha problem.*

      The Federal Water Quality Administration considers the chloride
 problem In tlie Kanistee area of sufficient magnitude' to seliedul^ a
 detailed survey this susuaer 
-------
                                                                 2005

page 2

    . However, no Order of rstarainction was  issued to Kaaistea (Hardj
Salt) for their discharge of arises- to surface  waters por our discussion
With l-!y. ,Geo2g3 Jiiddls at our meeting Hay  28, 197'Q«  On® would logically
as^ ^7/ha^ doas  Kaaistee (Harfy) Ss.lt 4c "Jith thair waste chlorides?*
if tho Stats of 1'liohi.^an. h-?.s rafutsd --;h© statomont by the Federal ESS?
       that 7012 EGD of ua.3te br-iuc3 are ratujsied..-to deep wallso
     We know for a -fact -that Eardy Salt has .for sons tias fcesa, chisapiag
vast fconaasje of waste olilor5.G3 blouSs 3Ui'i;o their ssSi pit frea 'sr
thsy ass ^"asl^sd back int-o '-fer-Istse LpJ:a0^ In  a letter frsia Mre
Fiafieldj: ' Vice  President of Pvodtjc-tieii ct Hardy Salt to 2i© datsfi
July 2a 1970& our orgs'.nlzetlca was assaurod thtvfe aa alteraate
method had basn adopted Ijy Ee.^dj's ar,cl taat no mors
will enter Maaistea Ls^e f?osi this
     In Mr0  Gerald Sd-5/s let tar of Hcvsm'^sr 20?  19'63 to I-!a-0 H
h.a states tliat  Staadard Mae aad Octant IB  ssrlcusly consifisslns
return of Sriaes  to xrsllsB'
Quality Ac
en the
     One furthar point of sris-anis concajra  to us  aa€ the Federal' Water
 a
          ministration is the ulti^al'o offset  these chlorides iTill have
           a? quality cf laics Michigant ~ 3?aa-Ste4t-e»PedQral
          as ia -Lake Fdohigan is 50 rug/1«  H^trever,  our- o*fa water
      -s tsSea  ia the vleia'lty of t>.e outfall end analyzed 'by a private
            shotr a ehlorids Isvel of 220 s-g/l in May of 19?0?
     In-MTo- Ralph Pardy's let. tar tc 1-iTe H0 YmE  Butle? of Septemfcsr 22» 1964
Mrc Purdy quotss  ths Paclca^in^ Corporation of Assrlea-as follotsss

     W2he effluent to?2ch5^is tj,s shuro WES quits dilate, tiestias oalj
     • 144 ppa  chlorides vrhareas the. Lrina-Cflueat misture •will
          7M - 12H ppfflo !1
          weaild  seamingly -30 a gross fS2.at2.oa of Stater-Faderal staadards
    .a possible violation of the jpecornl Water Quality Ast of 19_65«
     With all of these faots before you and  realising that by .
the Miehig&u • Water Sssouro-as Ooiraaissicn Htxst nsie  the ultimate
to stop further ohlorids contsaaination of surfaos  aad ground waters,,
    orgsjiisatlca demands ausvers to the follo^rixig  questions 0
         The dats ishea the Gsaso aad Bssist order" on all chlcride
         disposal as  outlined iu our letter of  Jims  13 w5-ll ba issued?

         What Kathode t-hs MlfEO will enplby to ensure that no illegal
         chloride disposal -fill ooo-ur?

         What schedule of financial penalties will fce edoptsa and
         rigidly enforced for any end all illegal cr aooldeatal dumping?

         What schednla of regular State aad industrial pipslino aad
         wsll inspaction ^.21 b? aSoptud to ctiE^re that corrosion c^
         age of pips  ^rlli not pesait 3.sal:as3 er.d  subsequent
         coat asaiaatioa ?
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                                                                 2006


page  3
          Efcy diQ t'ae State 'of Kieliisia find it nsoessasy to as'tabiish
          a EiazajoKsx e3.1ot-7abl v .elilo:ri'i3 le^
          so la-aol* hlgaor tb,a;i t^ie otlisr -felires  Gcafsrses  in tatj F
          State LaS:© Michiga:-,
                      tlAO^PO -"i,!! ai-jpr^eiate rsseivlns your
to these questicas s.'i t-las  eiiiiesi  possible tiia90"  OJhsnk you
-------
              DI:L>ARV"L;N'T CT ii;;,.,;.::, :;^CAV;C:;, AND V.-ELFARE          2007
                          PUBLIC ;].:/.,/;;! SERVICE •
             Division or ..'.iter £«.vl >y and Pollution Control


         v (,  '                  GTArr  REPORT


                MANISTl'C  RIVER ( M1C.i 10AU)  tmd  LAKE  MICHIGAN


      The  City of Manistee discharges treated  domestic waste  effluent
 in  the Manistee River System  with  a  population  equivalent  (P.E.),
 measured  in  terms of biochemical oxygen  demand,  of 1915, one mile  above
 the mouth of the Big Manistec River.   Other domestic waste discharges
 are of.relatively minor  importance.  Industrial'waste.discharges arc
 significant.  Paper and  food  produces  plants  located near  the rr.cutr. of
 the river system have a  waste discharge  of almost  IS.,000 P.E.  .T/.-cSureo
 in terms  of  biochemical  oxygen-demand.   Chemical and salt'discharges
 from  industries in this  area  also  contribute  to  pollution  of the river
 system.  A total of 3.12 million, gallons  per  day (MGD) of  organic  wastes
 and 0.71 MGD of chemical and  brine wastes are discharged to  the Big and
 Little Manistee Rivers by industry.  An  additional 7.12 MGD  of brine
 wastes are discharged into deep wells  by  two  of  the industries.

      Water quality, studies have been made at  the mouths of 'the Manistee
 •and Li'ttle Manistee Rivers, on  Manistee  Lake, and  on' Lake  Michigan in
 the vicinity of the mouth of  the Manistee R-iver  during-the month of
 August, 1953.  These preliminary survey  results  show that  the total
 solids conteht in the Little  Manistee  River is 180 parts per million
 (ppm).  This indicates that the industrial waste discharges  to this
 stream do not affect it significantly.   The Big  Manistee River is
 affected by  the industrial waste discharges,  as  indicated  by the total
 solids content range of  300-500 ppm.   Ninety  percent of the  total  solids
 in the Big Manistee River are dissolved  solids,  largely of industrial
 origin.  The effect of industrial waste  discharges is further -indicated
 by the presence of chlorides  ranging from-37-266 ppm, in the Big Manistee
 River.  Compared with the 5 ppm chlorides in  the Little Manistee River,
 the increase seeir.3 significant.  The Public Health Service Drinking
Water Standards have a recommended limit  for  chlorides of  250  ppm  in a
water supply Before treatment.

     One of  the two sampling  stations  on Lake Manistee ($20)  shows a
wide variation in water quality, depending on the  depth of the sample,
 although the number of samples taken precludes any extensive interpreta-
tion.   Similarly, the connecting channel from Lake Manistee  to Lake Michigan
has significant variations, depending  on the  depth of the  sample,  based
 on the one sampling period.   The condition at- the  10 meter depth in
particular reflects conditions inimiceU. to.good  fish and benthic life
 development.
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                                                                 2008
                                  -2-
     In order to determine the overall effect of  the  Manistee  Piv-r
System on Lake Michigan ,--9« sampling stations-were, established  in the
iirjTiediate vicinity of the river's mouth.  Samples  taken  from various
depths show an area of questionable wate£ quality  southward along the
shore of Lake Michigan from the harbor mouth.

     At three sampling stations located inshore off the.  harbor or.trance,
some variation 'from normal lake water quality is reported.  >.or::.al lako
water quality is reported at Station 2^, located approximately 2.5 r.ile:
south of the harbor and 0.5 mile from the shore.

     An increased organic load was discharged to LeTke Manistee and the
channel from the -Packaging Corporation of America  at  Filer City for a
period this past summer, due to a. breakdown in the plant.

     All the discharges from the variouc, industries and  municipalities
in the Manistee area are under the jurisdiction of the Michigan "./at-sr
Resources Commission.
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                                                                                       2009
                                       STATE OF MICHIGAN
                            WATER RESOURCES COMMISSION
MKMAtl t.MIATECH, laming. Ominnflli               GEORGE W. ROMNEY, GOVERNOR                      FRANK J.MUEY

GEIAID t eOOY, V«» O«lin««l                             ^C^JT                  /J^"  [^.         	
                                                                 -   . \f4'             STAFF
                                                                   \1  ,         IORINGF.OEMING
XJHNCMAOOt                                  ..^. ~	               ,    ,-         NORMAN WLliNGS
CEOROf F. UDOU,Mwk*ge«                        LANSING 13, MICHIGAN                        WHN I. DESMOND

                                       October 7,  1963

               Mr.  H.  Schindler,  Jr.
               Executive Vice President  & General  Manager
               White Star  Trucking,  Inc.
               1750 Southfield
               Lincoln Park,  Michigan

               Pear Mr. Schindler:

               We recjret the  delay  in  answering your  letter of September 6,
               regarding Manistee area water problems.

               An investigation  including sampling at times when you experienced
               difficulties at your  Lake  Michigan  property this past summer
               would have  been most  valuable in  identifying the offending
               substances  and we  certainly wish we had been called at the time
               you  noticed the unsatisfactory conditions  reported in your
               letter.

               A report on studies made  to determine  the  feasibility of
               disposal of the Company's  waste with brine was  received from
               the  Company a  few  days  ago and we have not had  an opportunity to
               review  the  report  in  detail.   The admixture of  brine would be to
               increase the waste's  specific gravity  and  keep  it from moving to
               the water surface  or  the  shallows.   Tests  of this principle using
               hauled  brine have  been  very successful. A meeting between the
               Water Resources Commission staff and Company people is to be
               arranged to discuss the report and  other phases of the waste
               disposal problem sometime  during the week  of October 21.  The
               brine which would  be  used  in  such a project would be a portion
               of that which  is presently disposed of to  the Manistee channel
               through a pipeline and  eductor system  built jointly by Great
               Lakes Chemical  Corporation, Standard Lime  and Cement Company
               and Morton  Salt Company in \S6\.  This disposal  method for the
               spent brines was adopted  by the Companies  to reduce the dis-
               charge of chlorides to  Manistee Lake and is being done under
               Orders of the  Water Resources Commission with restrictions
               on the discharges.  These  Orders also  require the routine
               filing of reports.  The Companies have maintained compliance
               with the terms  of  the Orders.   Discharge through the disposal
               system averages about one  and one-third milliongallons per
               day of brines  containing about 10 per  cent chloride.   No
               reaction would  be  expected  to occur between the inert waste
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                                                                      2010
iir. H. Schindler, Jr.
October 7, 1963
Page 2
brines and the Packaging Corporation wastes which contain
small amounts of wood sugars, tannins, lignins and cellulose.

The Manistee Salt Company discharges approximately six  and
three-quarters of a million gallons per day of waste containing
about 0.08 per cent chloride into Manistee Lake.   The effects
of these discharges and those of Packaging Corporation  on
Manistee Lake have been evaluated and have not been determined
to create conditions of unlawful pollution.

Enclosed is a copy of Act 2^5, P. A. of 1929,  as  amended by
Act 117, P. A. 1949 which you requested.  We realize that not
everyone is in accord with the statutory definition of  unlawful
pollution; however, as you realize, we must work  within the
scope and authority of the present statute. While we have
been unable to demonstrate unlawful pollution  of  Lake Michigan
waters at Manistee we realize that it is not possible for our
surveillance to be on a sufficiently frequent  and regular basis
to provide assurance that we have observed the lake conditions
under all situations of weather, and of variations in waste
flow and water quality.

We feel some confidence that the forthcoming meeting will
result in early and substantial  improvements.   If it does not,
the matter will be scheduled for attention by  our Commission.

                              Very truly yours,
                              Norman Bill ings    f
                              Assistant Executive Secretary
RJC:bmc
cc—R. J. Courchaine
Enc.
 f
J
                                          ,333.355
                                           '
                               J I IS
-------
                         M i c~ 1 1 i o A N                 tint i rt _
                                                     f\IOV 25 if
                                                         ** " '
                 •: I'AKTM T.NT OJ' CONST. If VAT1ON
                                          November 20,  1963
OEKAI.n E EODY
   l nr« IOH
  Mr.  H.  Schindler,  Jr.
  Executive  Vice  President
      and  General  Manager
  White Star Trucking,  Inc.
  1750 Southfield
  Lincoln Park, Michigan

  Dear Mr. Schindler:

             I delayed  an earlier reply "to your letter of
  'October 25 because I  wished to discuss aspects of the
  Manistee River  situation with members  o.f my own staff
  as  well as with members of the staff of the Water Re-
  sources. Commission.   As you probably know,  as Director
  of  Conservation I  am a member of that  body.

             The Packaging Corporation of America is under
  orders  of  the Commission to remove freely settleable
  and floating solids,  to maintain -specified oxygen levels,
  and not to impart  objectionable odor,  color,  or turbidity
  sufficient to interfere with the development of public
  water supplies  or  with other industrial enterprise or
  other lawful occupation including recreational uses as
  to  injure  fish  or  aquatic  life.

             The Commission is well aware of the problems
  that exist in the  Manistee area and have been pressing
  the company for additional corrective  measures.  I believe
  that a recent  meeting has been held with top-level
  officials  of the company,  but I have not been advised
  as  to the  outcome.   Inasmuch as I am sending a copy of
  this reply to Mr.  Oeming,  Executive Secretary of the
  Commiooion,  perhaps  he can write an additional letter
  to  you  concerning  that mooting.
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                                                         2012
Mr. H. Schindler, Jr. - - page 2
November 20, 1963
          As you may know, the chlorides in Manistee Lake
have been greatly reduced due to Water Resources Commission
orders and despite some comments originating from the
Public Health Service that it produces "conditions inimical
to good fish and benthoni'c life.  There have been no
instances of actual injury reported.  Also I am advised
that the Standard Lime and Cement Company is seriously '
considering underground disposal of some of their waste
brine that goes into the Manistee Lake outlet.
                                       Sincerely,
                                       Gerald E. Eddy
                                       Director
GEE:ch
cc L. F. Oeming
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                                                                              2013

                                     STATE O? MICHIGAN               Qpn r> „

                          WATER RESOURCES COMMISSION       ^ iyb4 ICGAL cowm
   COMMISSION                                                                    tEGAL COUNoEl
    u „,.., ...  ,                    GEORGE W. ROMNEY, GOVERNOR
    • H RONK, Chorrmpn
 or JOHN C MACKIt                                ^ZX~
GERALD E EDDY, Vke - Cho.rmon
For RALPH A. MAC MULLAN
            D                             STAFF OFFICES
  5,01. H..IA Co™,,,.o..r                             200 M.ll Slr.el                              IORING f. OEMING
GEORGE s MCINTYRE                              ta_ 373 3i«o                                 b«^~. ?««..,
  D™aor =1 AB-ral.,™                                - - -                               NORMAN BILLINGS
JIM GiLMORE, JR, Kalomaroo                         STATIONS                               ~£Ki^
                                                                                OiiW, Hy
  Muur.ol M«i.g.m.« Or.,p.                        LANSING, MICHIGAN 46913
GEORGE F. UDDLE, Mu.Ugon                                                              "A""" w-
IYNN F. BALDWIN, Eoior, Rapidi                   September  22.  igo^t                       JOHN L DESMOND
  0,.»»..^ CUo.».                                       '                               °"

       Mr. H. William Butler                         Mr. H. Schindler,  Jr.
       Clark, Klein,  Winter, Parsons &  Prewitt      Execut i ve .Vi ce  President
       Counselors  at  Law                             White Star -Trucking
       2850  Penobscot Building                       1750 Southfield
       Detroit,  Michigan 48226                       Lincoln Park, Michigan

       Gentlemen :

       We have  recently received a report  from the Packaging Corporation
       of America,  Filer City, regarding their observations of conditions
       along  the Lake Michigan shoreline and  the  operation of the new  waste
       brine addition to their wastes discharged  th/ough the Company's
       Lake Michigan  pipeline since this system was put in operation on
       August 15.

       Following are  their comments:

             1. "During periods of calm, or  light  winds from any
                 direction up to 4 MPH, we  can  find no trace of the
                 effluent either on the beach or in the form of a streak
                 visible from shore or from  an  airplane..  Formerly
                 these conditions would generally  form a puddle of effluent
                 which would touch shore at  some point.

                 No  odor is apparent under  the  above conditions.

            2.   When  there is a appreciable wind,  above about 10 MPH
                 from  the quadrants of South to West or West to North,
                 there is a visible streak  out  in  the lake downwind
                 from  the spargers.  The streak becomes apparent about
                 500 to 600 feet downwind and  is apparently caused by
                 wave  motion bringing up the effluent from the bottom
                 strata.   The streak is generally  less dark than formerly
                 due to better diffusion and in S  or SW winds is almost
                 always completely dispersed before it hits the Manistee
                 breakwater.  So far it has  never  touched the shore.

                 Odors on shore are generally  less  pronounced and are
                 much  less frequent than prior  to  the brine addition.
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                                                                2014 - 15
Mr. H. William Butler and Mr.  H.  Schindler,  Jr.
September 22, 1964
Page 2


     3.  An East wind (approx. 7  MPH)  on one occasion was  found
         to bring the effluent into shore along  our property
         but had no tendency to move it North or South to  the
         other property owners' shoreline.  The  eff.uent  touching
         the shore was quite dilute, testing only \kk ppm"
         chlorides whereas the brine-effluent mixture' will  run
         7 M to 12 M ppm."

If you have had an opportunity to observe conditions since August 15
we would appreciate your comments and  knowing whether you  confirm
or concur in the observations of  the Company.

                                   Very truTy yours,
                                   Ralph W.  Purdy
                                   Chief Eng-ineer
RJCrbmc
CC--C. Harvey
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                                                                2016  - 17
          MANISTEE COUNTY ANT1 POLLUTION  ORGANIZATION
                              (MA CAPO)
Box 282
Manistee, Michigan 496GO
September 1, 1970
William G. Milliken
Governor
Executive Office
Lansing, Michigan 48926

Dear Governor Milliken:

Please find enclosed copy of our letter to Mr. Ralph Purely  of  the
Water Resources Commission.

Our organization is of the opinion that the State of I'ichigan  can  no
longer allow the -industries in th» .Manistee area to set  their  own
standards regarding -air and wuto'r quality.

The V/at«?r Resources. Commission has sot a  tentative target date  of
Dececiber 1, 1071 for the elimination of concentrated chloride
disposal to the surface waters in the Manistee area.  We feel  that
this date is much too far in the future,  and only a tentative  date
at that.

There is roughly 1 ,900,000pounds of chlorides entering the  surface
•waters in the Manistee area every day.  That means that until  Dec-
ember 1, 1971 these chlorid« polluting industries will be legally
allowed to dump over ONE BILLION pounds of chloride contaminants
into someone else's drinking water.

We forwarded a copy of our June 1.1, 1970  Cease and Desist request
on chloride disposal to you.  itACAPO outlined three possible
raethods that would eliminate chloride disposal to surface waters.
The V/ater Resources Commission has chosen to ignore our suggestions,
which would' have eliminated chloride disposal to surface waters with-
in 30 days.

It is immoral enough for Manistee industries" to pollute someone else's
drinking water, but to continue to pollute when economic and exprdicious
methods are available to correct this pollution is >> heinous act.

Very truly yours,
Mrs. Carole Magnus , Secretary
MAC l.PO
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                                                                                2018
                           DEPARTMENT OF THE ARMY    p.-:j  . /;   ^{i
                                                                               * *   ' • J
  •  NOTE.—It is to be understood that this instrument does not give any property rights either in real estate or mate-
 rial, or any exclusive privileges; and that it does not authorise any Injury to private property or invasion of private
"rights, or any infringement of Federal, State, or local laws or regulations, nor does it obviate thenecessity of obtaining
 State assent to the work authorized.  IT MERELY EXPRESSES THE ASSCNT OF THE FEDERAL GOVERNMENT so FAR AS CON-
 CERNS THE PUBLIC EtGHrs OF NAVIGATION.  (See Cu.inm.in.gs v. Chicago, 1SS U. S., 410.)
                                           PERM1 ije^g QJ.  iv0 si^trist Ergtessr
                                                    Detroit. Distrsc-bj corps of Engineers.
                                                                         Detroit 2o* irlchl-it
                                                          NOV 2 o 1-Jv	;_	, 19
 Filer Citj, 5.iical£.iri

Sij'ss

       Referring to  written request dated        10 Ar^itr/i TL?5^



 I have to inform you  that, upon the feccmaeiidation of the  Chief of Engineers,

 and under  the provisions of Section 10 of the. Act  of Congress approved March- 3^

 1899, entitled "An act making appropriations for the construction, repair, and

 preservation of  certain public v/orks  on rivers and harbors,  and for other pur-

 poses," you are hereby authorised by the Secretary of  the Army.
 to   ccssrbrust a 2h  ir^":i vs^te  cni^faia extending 1,100 fecb l^cv^ird vrith di
                                 (Here de-icriba tin* piopoied structare or woik.)
 e'i Vr.o  cater  crj
  * «   ^fi -i ••»'*• f- "^cn
  in  A-^"-*^ --*—««--*—,^,-vii
                            (Here to be narr.ed tht* river, ha:bor, or waterway concerned.)
 at ran'_r>tcsj  "!ichir:?.r.j  apprc^i-Titrly !>  r.ilc3  scuih frcra cntrcr.03-  to E?.r'>cr.--
  (Hera to fce named tlio neaie-^t Trell-kno^n locality—preferably a to.vn or clry—and the dMtarce in miles and teTitha froi^i somo dt.finito l^'r.t in
                    tho earae, stating -.\hother abo.u or bi_lo\v or £ivini; dnection by points oE cemyajs.)
 in accordance with the  plans  shov;n  on the  drawing attached hereto  *""
                         (Or dr.v.'.i.i^d ; g'vy £1-: aui..ker or ot'-ijr ucunlte idf i.iiflc^t'ca m.ar! 5.)
  subject  to the  following  conditions:
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                                                                                                2019
     (a) Thai the work shall be subject to the supervision anJ approval of the District Engineer, Corps of Engineers,
in charge ,of the locality, who may temporarily  suspend the work at any time, if in his judgment the interests of navi-
gation so jrequire.
     (6) That any material dredged in the prosecution of the work herein authorize'd shall be removed evenly and no
large refuse piles, ridges across the bed of the waterway,  or deep holes that may have a tendency to cause injury to
navigable channels or to the banks of the waterway shall  be left.  If any pipe, wire, or cable hereby authorized is l?.id
in a trench; the  formation of permanent ridges across the  bed of the waterway  shall be avoided and the back filling
shall be so done as  not to  increase the  cost of future dredging for navigation.   Any material to be deposited or
dumped under this authorization, cither in the  waterway or on ahort! above Hi^h-wattr mark, shall bo deposited or
dumped nt  the  locality shown on the drawing hereto attached, and, if no prescribed thereon, within or behind a goad
ond substantial bulkhead or bulkheads,  such or, will  prevent escape  of the material in the waterway. If the mate-
rial i3 to be deposited in the harbor of New York, or in its adjacent or tributary waters, or in Long Island  Sound, &
permit therefor must  be previously obtained from the Supervisor  of New York Harbor, New York City.

     (e) That there shall be no unreasonable interference with navigation by the work herein authorized.
     (d) That if inspections or any other operations by the United States are necessary in the interest of navigation,
all expenses connected therewith shall be borne by the permittee.
     (e) That no attempt shall be made by the permittee  or the owner to  forbid the full and  free use by the public of
all navigable waters at or adjacent to the work or structure.
     (/) That if future operations by the United States require an alteration in the position  of the structure or vrork
herein authorized, or if, in the opinion of the Secretary of the Army, it shall cause unreasonable obstruction to the fres
navigation of said water, the owner will be required upon due notice from the Secretary  of the Arrny, to remove or
alter the structural  work or obstructions caused thereby without expense  to the United States, so as to render naviga-
tion reasonably free, easy, and unobstructed; and  if, upon the expiration or revocation of this permit, the structure,
fill, excavation,  or other modification of the watercoursu  hereby authorized shall not be completed, the owners sT.3',1,
without cxpehso to the United States, and to such extent  and in such time and manner as the Secretary of the Army
may require.lremove all or any portion of the uncompleted structure or fill and restore to its former condition the navi-
gable capacity of the watercourse.  No claim shall be made against the United  States on account of any such removal
or alteration i
     (0)  That the United States shall in no case be liable for any damage or injury to the structure or work herein
authorized which may be caused by or result from future opeiations undertaken by the Government for the conserva-
tion or improvement of navigation, or for other purposes, and no claim or right to compensation shall accrue from
any such damage.
     (ft.) -That if the display of lights and signals on any work hereby aothorized is not otherwise provided for by Izrr,
such lights and  signals as may be prescribed by  the U. S. Coast Guard, shall be installed and maintained by and at the
expense of the owner.
     (»') That the permittee shall notify the said district  engineer at  what time the work  will ba commouccJ, and a~
•far in advance  of the time  of commencement as the said district engineer  may specify,  and  shall also notify him
promptly, in writing,  of the commencement of work, suspension of work, if  for a period  of more than one week,
resumption of work, and its  completion.
     fi) That if the structure or work herein authorized is not completed on or before _.!£hirt,-VfciCii;3'b4_	day
of	ir.'r.V.V.vA??..-	_, 19?2_., this permit, if not previously revoked or specifically extended, shall ceasa and
be null and void.
            Seo  additional conditions on pa^o  anno^od hereto  ar£
       part hero of e
 By  authority  of  the  Secretary of the Army:        PZTErl  0.  HYZTn
                                                               .Colcr.-l.,  Ccrcj  of  En
                                                                District;  E-~J.r.ssr
         1721  (Civ!!)  Tl11' '"™ 3'-pw Firm 00, di'.ed I Apr !3, which n.sy be uccJ until eihijjtod.
                                       o. 5
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                                                              2020
                  DEPARTMENT OF THE ARMY

                          PERMIT
     (k)  That*, the permittee shall provide adequate facilities to
extract freely -settleable solids from the waste water snch that the
remaining concentration will not exceed sifty (60) parts per million by
weight and the total daily weight of discharged solids will not exceed
5,000 pounds.  Should the District Engineer find that either the maximum
concentration or daily weight of suspended solids is being exceeded, the
permittee agrees to take -whatever action is necessary to reduce' the
amount of sclid.s to or below the allowable limits.

     (l)  That, if it is determined necessary to conduct sampling
tests of the waste water to check compliance with condition (k),  the
permittee agrees to permit ready access to necessary portions of its
premises by the District Engineer's representatives for this purpose.

     (m)  That, should the District Engineer determine that solids
discharged from the outfall sewer are causing an unreasonable obstruction
to navigation in the vicinity of the outlet, or un increase in the amount
of maintenance dredging in the authorized Federal project at tkuiistoe,
Michigan, the permittee agrees, upon notice b" the District Engineer, to
either remove and dispose of the deposit at its sole expense, or reimburse
the Federal Government for its cost of removal as determined by the
District Engineer.

     (n)  That, this permit is revocable by the Secretary of the
Army should the permittee -fail to comply with conditions (k), (l), and
(m) within a reasonable period as determined by the r>i strict Engineer.
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                                                                                          2021
                           The Manistee News-Advocate

                                    June  ?,  1950
  Hoffmaster Gives Views  021  Manistee Fish Kill
   LANSING —(UP)—  Nature
 and an industrial plant combin-
 ed forces to kill millions of fish
 ranging from shiners to 36-inch
 trout In Manistee lake, Conser-
 vation  Department  Director  P.
 J. Hoffmaster  revealed  today.
 Fish specialists have spent  two
reeks investigating the  havoc in
he four-mile long lake which has
eft  dead fish in piles  along the
horeline.
 "We   believe   organic  matter
lumped into  the lake by the  Am-
•rican Boxboard  Company plus na-
ural  phenomena  combined to de-
•lete oxygen in the water and suffo-
•*ta the  fish," Hottmastor said.
  He explained that when there is
a jump in temperatures, warm sur-
face water sinks to the bottom.'
   "In the Manistee»lake, it  set
  up  thermal currents which dis-
  turbed masses of organic mat-
  ter on the lake be^ and pushed
  them to the surfa'ixV  He said.
  "The organic matter absorbed
  the  oxygen and  the fish suffo-
  cated."
  Between 600 and 700   rainbow
trout between six and 35  inches
have died in the  fish  kill believed
to be the largest  in the history of
the state.  Hundreds of dead  pike,
bluegills. Bunfish,  perch,  and  bass
lie alonz the shore while an esti-
mated 100,000,000 shiners and 150,-
000 game fish under six inches have
died so far.
  G. B.  Bonfield,  Grand   Rapids,
American  Boxboard  Company  exe-
cutive, will appear before the Water
Resources Commission  June 20 to
explain the daily dumping of 40,000
pounds of waste matter in the lake.
  Hoffmaster said the waste dump-
ed b? the  plant Is roughly compar-
able to  the  waste from a  city of
250,0^0 population.
  ''There's nothing we can do about
it nt>w.  Even closing the plant
down would not help," Hoffmaster
said.' "Our worry now Is that the
fish  kill doesn't haonen azain,"_
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                                        >TA'i  -;; MICHIGAN                             .2022

      COVM. .,<..                WAT;:;? rrSO^CES COMMISSION
A/>r.HSEL f MIATECH Lii-.t, rnj..,.,               ~t. ol Aan.Ut, „
J/1MF'. S Cil'CVE, IP >,!,  i.-ao                          r.ii,~N~                               PAIPM V/ |U3'.»

r''S!Gt/c.c™'' ""-""•'"                         UN-.tr/,  I j, MICHIGAN                         JOHM :*-wr,,-.n

                                      September  20,  1963
      Mr.  Donald G. Jenrings
      Attorney at Law
      Board  of Commerce Building
      Man is tec, Michigan

      Dear Mr   Jennings:

      A  copy of your letter of June 7,  19&3  to  Senator Hart regarding Manistee
      Lake pollution was received fn this off ice'on September 3, '963 from
      H. W.  Poston, Regional Program Director of the U.  S. Department of-JJealth
      Education and Wei fare, "Publ i'c Health Service, Water Supply and P_oJLl jrt i on
      Cont rjl, Reg i on V.

      We are concerned with your position that  pollution exists and is worsening
      in the Manistee area waters, and would appreciate it very much if you  could
      provide  us with further detail on  the conditions to which you allude.

      As you may know, very considerable reductions have been made in the wastes
      going  to Manistee Lake, both with  respect to the salt brine and the paper
      miU wastes.  A portion of these wastes have been diverted from Manistee.
      Lake,  to the Big Manistes River and Lake  Micnigan which have abundant
      capncicy to dilute the sali. and to assimilate the oxygen demanding effluent.

      These  diversions were initiated and are proceeding under order and contin-
      uing surveillance of this Commission, which is the agency charged by  state
      law with the control of pollution.

      We would be happy to arrange a meeting with you to discuss waste control
      and water quality in the Manistee  area  if you so desire.  Our files are
      al'so available for your inspection at any time.  Please let us know  in
      what way we can be of any assistance to you.

                                              Very truly yours,
                                                  '  . i     •'';;'  .>    ,
                                                  ' ;-." -v™  ' -'-'  ' y   . •  ' -
      RJC: !nv:                                 Ral(.h W.'Purdy
      cc:  C.  Harvey                         Chief Engineer
           R.  Courchaine
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Manistee, Mich., Wednesday, Sept. 23,  1970
                                                                                        2023
                                                                                    World's
                                                                                 Fresh Water
                                                                              Salmon Capital
            P.E.  Society

            Hears Talk  on

            Waste Control
             Manistee-Ludington   chap-
           ter of the Michigan  Society
           of Professional Engineers had
           its  September  meeting  last
           night  at Coral Gables-Chippe-
           wa Hotel  in  Manistee  and
           heard a talk by George Liddle,
           district engineer  of the Water
           Resources Commission  in this
           area.
             Some 20 industry representa-
            tives  from Manistee and Lud-
           ington joined  members  and
           their  guests for a social hour
           and dinner before the meet-
           ing. .
             After a brief business meet-
           ing program  chairman Tom
           Stege introduced Georgs  Lid-
           die who gave  an informative
           talk  on existing  and pending
           legislation affecting industries
           .and municipalities in their con-
           trol of discharge of wastes to
           the natural watercourses of
           the state.
             Liddle  also  discussed  the
           latest legislation passed which
           allows individuals to sue indus-
           tries or municipalities if they
           feel aggrieved by air or water
           pollution. He pointed out that,
           in  most  cases,   the  circuit
           courts  having   jurisdication
           will  check with  the  state's
           regulatory agencies and if the
           defendant  is  complying with
           agency stipulations, the court
           will probably rule in favor of
           the defendant.
   During an informal question-
 and-answer   period   after
 Liddle's talk, the subject of
 chlorides   in  ground  waters
 in the Manistee  area was  dis-
 cussed. It was brought out that
 while  high  chloride  concen-
 trates exist at some well loca-
 tions in the area, the chloride
 concentration in the Manistee
 city water supply is well below
 Federal  water  control stan-
 dards,  way  below  the taste
 threshold  and, therefore,  not
 toxic or harmful in  any way
 to the users.
   The   pollutants  of   highest

concern to  the   commission
in  this  area at this time, ac-
cording to Liddle, are raw san-
itary  wastes   being  dumped
into Manistee Lake or Manis-
tee River.  It was pointed out,
however, that the  city has com-
pleted  preliminary engineer-
ing and is now vigorously pur-
suing the acquisition of  feder-
al  funds for a total program
for collection  and  treatment
of  sanitary wastes in the Man-
istee area.
 The chapter's next  meeting
will be  in Ludington  on Oct.
20, with the program to be an-
nounced later.
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              DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE                2023a
                         PUBLIC HEALTH SERVICE
             Division of Water Supply and Pollution Control


                              STAFF REPORT


               MANISTEE RIVER (MICHIGAN) and LAKE MICHIGAN


     The City of Manistee discharges treated domestic waste effluent
in the Manistee River System with a population equivalent (P.L.),
measured in terms of biochemical, oxygen demand, of 1915, one mile above
the mouth of the Big Manistee River.  Other domestic waste discharges
are of relatively minor importance.  Industrial, waste dischargee arc
significant.  Paper and food products plants located near the rr.ouin of
the river system have a waste discharge of almost 15,000 P.E. moacured
in terms of biochemical oxygen demand.  Chemical and salt discr.arges
from industries in this area also contribute to pollution of the river
system.  A total of 3.12 million gallons per day (MGD) of organic wastes
and 0.71 MGD of chemical and brine wastes are discharged to the Big and
Little Manistee Rivers by industry.  An additional 7.12 MGD of brine
wastes are discharged into deep wells by two of the industries.

     Water quality studies have been made at the mouths of 'the Manistee
and Little Manistee Rivers, on Manistee Lake, and on Lake Michigan -in
the vicinity of the mouth of the Manistee River during-the month of
August, 1963.  These preliminary survey results show that the total
solids content in the Little Manistee River is 180 parts per million
(ppm).  This indicates that the industrial waste discharges to this
stream do not affect it significantly.  The Big Manistee River is
affected by the industrial waste discharges, as indicated by the total
solids content range of 300-500 ppm.  Ninety percent of the total solids
in the Big" Manistee River are dissolved solids, largely of industrial
origin.  The effect of industrial waste discharges is further indicated
by the presence of -chlorides ranging from 37-256 ppm, in the Big Manistee
River.  Compared with the 5 ppm chlorides in the Little Manistee River,
the increase seems significant.  The Public Health Service Drinking
Water Standards have a recommended limit for chlorides of 250 ppm in a
water supply before treatment.

     One of the two sampling stations on Lake Manistee (#20) shows a
wide variation in water quality, depending on the depth of the sample,
although the number of samoles taken precludes any extensive interpreta-
tion.  Similarly, the connecting channel from Lake Manistee to Lake Michigan
has significant variations, depending on the depth of the sample, based
on the one sampling period.  The condition at the 10 meter depth in
particular reflects conditions inimical to.good fish and benthic life
devcJ opment.
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                                                                            2023b
                                  -2-
     In order to determine the overall effect of the Manistee river
System on Lake Michigan, 9 sampling stations were, established in the
immediate vicinity of the river's mouth.  Samples taken from various
depths show an area of questionable water quality southward along the
shore of Lake Michigan from the harbor mouth.

     At throe sampling stations located inshore off the harbor entrance,
some variation 'from normal lake water quality is reported.  i%:or:.:
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                                                               2023c
                                                          CO:   Rep.  Cavtho:
                   COtr.ITY A'.TTI  rjL'JJTlW  ORGANIZATION          Son.  Bouws::/.
                                                               sen.  Hart
                                                               Sen.  3 riff!
Box ?32                                                        Cor..  Van do
Mnnistec. Michigan A 9660                                       FWj.A
August 23, '1970'

Mr. Ralph W. Purdy, Executive Secrotary
rfater Hcnourccn Corinlcnio.-i
Stevens T. Man on Building
Lansing, Michigan 48926

Dnar Mr. Purdy :

To date, the Water Resources Gcmml ssion has -been  all  too  reluctant to
set standards, thus lettiag industry do its own regulating as  wa~  tVif;
case In the Orders of Do termination now in existance  covering  chloride
disposal issued in 1958 and 1959.  The pollution,  of chlorides  to Manic- te-
Lake and Lake Michigan continue under these Orders of Determination and
in accordance uith standards mutually agreed  upon, as set by industry.

As a first step, the Orders of Determination  should be drastically re-
vised so that "a minimum amount of chlorides will -be entering Lake  Michig
and Manistee Lake,  This will rive the" major  chloride polluters  some-
thing to really shoot for in their efforts to be  good citizens and a
working part of the community,

By actual test, the la.rge vcluTT.es- of chlorides allowed -tc-..enter-Kanistec.-
Lalce and Lake Michigan have at times exceeded even those  maximum levols,
thus causing an excellerated degradation  of the waters .in the  immediate
area.  Thus, it is the intent of MAGAPO to set a  more optimum  standard
and to take a more realistic approach to  the  problem.  We request  that
the Orders of Determination be revised so that a  minimum  amount  of
chlorides will be entering the waters by  December of  1971» and these
should be issued as a standard.

The major chloride polluters are the salt and chemical industries  in
our area, and our letter of June 13, 1970 gave recommendations which,
to date, have been ignored.  Mr. Childs surface and groundwater study
presented July 2^ and subsequent recommendations  coincide with .our
recommendations that these chlorides should be returned to the strati
from whence they came.  Thus, we feel that with such  professional  opinio
and recommendations, our request for a Cease  and  Desist should be  given
immediate consideration.  As of the month of  August,  the  ¥RC has en-
deavored to capitulate with the request of the Cease  and  Desist  by
making a step in the direction of asking  industry what they can do to
cease the discharge of concentrated chloride  wastes into  Lake  Michigan
and Manistee Lake.  We of MACAPO are dubious  of this  particular approach
to the problem of asking ; industry as to what  industry will do  in the
reduction of chloride pollution to Lake Michigan  and  Manistee  Lake.
MACAPO wonders if we are not getting back into the rut of 1958 and 1959
where industry stated then what they could" do. This  has  led us  to
the h'igh parts per million that we now experience in  our  area.  We
feel- that any ste.p in the reduction of chlorides  is a step in the  right
direction, but we feel that standards should  be set by the WRC,  rather
than by the major chloride polluters.
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                                                                    2023d
 page  2


 tfe  realize  the economics  of such  -i r.ove,  but  once  again  appeal  to  the
 WRC to  take a very thorough look'-into  the  problem  and  investigate  all
 of  the  possibilities.


 We, therefore, suggest that the largest  chloride polluter might revise
 his process in a minor way to  reduce the  chloride  level.

 Therefore,  we once again  appeal to the Water  Resources Commission
 as  laymen,  and offer the  possible solution of such an  economical step
 to  reduce these chlorides.  For example:

 1.  The production of MgO is through a two "stage reactor, thus  into a
 series  of three settling  ponds in which  the MgO precipitates  out and the
 chlorides are washed from the  JIgO, thus  giving a pure  product to be
 burned  and  thus known as  Magnesite.  It  is recommended by "us  that
 a simple change in the process of the three settling ponds  could easily
 facilitate  the immediate  reduction of large  concentrated chloride
 effluents.  By decanting  the high chloride effluent coming  from the
 first thickener and then  washing  in the  last  two thickeners.

 2.  The present setup at  this  pro-ducer of  Magnesite is an A3 &.  C
 thickener,system;  These  three are compiled of the three stage  settling
 and washing systems and we recommend that  one large thickener be
 placed  in operation, thus pumping to the "series of smaller  thickeners
 for washing.  This material would be pumped by Door-Oliver  pumps from
 the larger  thickener and  the chloride  liquor  decanted  off and returned
 to  the  ground strata from whence  it came.

 I an sure that the WRC, after  a quick review  of the process at  Standard
 Lisie and Refractories, the Magnesite producer above referred to, might
 perhaps be able to assist or aid the people with other suggestions in
 reducing the large concentrated chloride  effluents being.transported
 via the 10 inch pipeline  to PGA, thus being added  with their effluent
 and transported to Lake Michigan via the  30 inch pipeline.

 We would,  therefore, appreciate hearing  from  the. WRC on the following:

 1.  What' standards the WRC is  setting for  positive reduction of chlorides
    for the December 1971 target date?

 2.  What standards are being imposed on  those chloride polluters of
    Manlstee 'Lake who have no  Order of Determination whatsoever for
    their chloride disposal?

 3.  We would like to have an assurance'that all concentrated chlorid?
    effluent will be eliminated in the waste  disposal process of PCA
    to Lake Michigan by December 1971.

4.  We would like to be assured that a drastic revision of present
    Orders of Determinations will be immediately forthcoming to
    facilitate the ultimate reduction of' concentrated chlorides  t'o
    Lake Michigan- via the lakes, rivers and pipelines in this area
    by December 1971.
-------
                                                             2023e
5.  ft'e would like to know the schedule and method for monitoring the
    present and future effluent 'discharge stations emitting chlorides
    of any concentration into the waters in the Manistee area during
    the full 12 months of the year?

6.  What monitoring method is the WRC considering for the disposal
    of salt blocks and salt products now being discharged to -the
    waters in the Manistee area?

After once again hearing Mr. Childs report on August 24 on the. degra-
dation of surface and ground waters in the Manistee area, we feel that
the problem of chloride contamination is more urgent today than" when
we wrote our Cease and Desist request on June 13.

Therefore, we implore that a more expedicious and positive approacn
be immediately taken to facilitate the maximum reduction of chloride
effluents that now contaminate the waters 6f the Manistee area.


                                    Very truly yours,
                                    (Mrs.) .Carole Magnus^ Secretary
                                     MACAPO
-------
                                                      2024
                     R. F. Sturgis




          MR. STEIN:  May we have Raynor Sturgis?








          STATEMENT OF RAYNOR F. STURGIS, JR0,




          DIRECTOR, ILLINOIS DEPARTMENT OF GENERAL




              SERVICES, SPRINGFIELD, ILLINOIS









          MR. STURGIS:  Chairman Stein, conferees, ladies




and gentlemen.  Thank you very much, Mr. Stein,  for




inviting me to this meaningful and interesting conference.




          My name is Raynor Sturgis.  I am Director of




the Department of General Services for the State of




Illinois.  I am an engineer by training and have practiced




industrial engineering as a consultant in several extractive




industries around the country.




          The Legislature of the State of Illinois this




year granted the Department of General Services  appropria-




tions totaling $2,270,000 to engineer and build  pollution




abatement facilities where they are needed in institutions




operated for the State's taxpayers.  With this sura it is




expected more than   40  sources of a.i ^ and water pollution




will be corrected by the end of next summer.




          They include powerplant conversions from coal to




oil or gas at mental hospitals, correctional institutions,




and armories.  A sulphur dioxide extraction device is being
-------
                                                      2025
                     R. F. Sturgis




engineered for a new coal-burning powerplant at still




another State institution.




          Your deliberations this week treat alternate




waste heat disposal methods for nuclear and fossil fuel




powerplants.  I judge from the testimony that the cooling




tower alternative is projected to cost in the vicinity




of $300 million.




          The taxpayers for whom I work in northern




Illinois are also the purchasers of electric power.  Thus,



they would face the Illinois share of this expenditure.



          Justifying this huge expenditure upon imagined




conditions in the year 2000 highlights very well the




economic dilemma of pollution abatement.  Money needed




to improve the air and reduce water pollution around




Lake Michigan must be spent to produce results this year




and next.  The resulting environment should then permit



time for the specific research needed to fill in the gaps



of information so apparent from differing statements of



scientists participating in this workshop this week.



This does not mean that using a valuable natural resource




as a guinea pig is advocated, or the possibility of




irreparable damage is tolerated.  This thermal problem




is not in this category.



          Indications have been cited that sport and
-------
                                                      2026
                     R. F. Sturgis




commercial fishes may be found in greater numbers in the




vicinity of powerplant heat discharges in the fall,  winter,




and spring to the advantage of people around Lake Michigan.




          Should not specific research studies be undertaken




to determine how these valuable fish should be repelled




during the few weeks in the summer when heat conditions




might pose a hazard to the greatly improving Lake Michigan



whitefish, salmon, and trout fisheries?




          The cost of this research study would represent




a small fraction of a $300 million investment for cooling




towers.  A successful method of regulating fish movement




then could be employed by power companies, only when




required a few weeks in July and August, to assure prevent-




ing damage to the top of the aquatic life chain most



important to human beings in the vicinity of fossil fuel



and nuclear powerplant sites around the lake.



          And since temperature change rather than the



presence of heat has been indicated to be significant for




aquatic life, is it not possible to design parameters to




utilize the lake and still protect fishes?  Could this not




include relating different amounts of water discharge to



their specific temperatures, with outboard motors at one



end of the spectrum and powerplants at the other?




          Gentlemen, I submit to you — and I am not an
-------
                                                      202?





                     H. P. Read



aquatic scientist or a limnologist, but I wonder if one of




your options should be that you consider development of




these questions, or answers to these questions before




committing a huge expenditure which time could determine




might not be required.




          Thank you very much.



          MR. STEIN:  Thank you, Mr. Sturgis.




          Any comment or question?




          If not, thank you very much.




          MR. STURGIS:  Thank you0




          FIR. STEIN:  Herbert Read.




          Do you have a copy of your statement?




          MR. READ:  I have only two copies.




          MR. STEIN:  Could you give one to the reporter?



I would urge anyone, in view of the long day we are having,




if he has a copy of his statement,  please come up



with two, or get one made so you can give a copy to the



reporter because it is going to be very trying if she



doesn't havo it.



          MR. READ:  As soon as I get back to the office



Xerox machine I will get some more.




          MR. STEIN:  We havo one.
-------
                                                      2028






                     H. P. Read








          STATEMENT OF HERBERT P0 READ, STATE




          DIRECTOR, INDIANA DIVISION, IZAAK




          WALTON LEAGUE OF AMERICA, CHESTERTON,




                       INDIANA









          MR» READ:  My name is Herbert Read.  I arn the




State Director of the Indiana Division of the Izaak Walton




League and I live in Chesterton, Indiana.




          I will try to summarize this statement.




          One of the basic points I would like to make is




that we who live along the Indiana shoreline of Lake




Michigan are particularly concerned over thermal pollution




along with the others.  This conclusion is due, in part,




to a number of factors, some of which I wish to discuss.




The dissipating effect of heat, or for that matter any




form of viator pollution is slow, due to the sluggish




movement of water at the southern end of the lake,




          I will not elaborate, but the sluggish movement;




means this water dissipation of heat or other pollutants




do occur very slowly, which is a nrob1om rcr us in Indi'ma0




          It is in this lower basin of I/ike L.ichiran, with




the sluggishly rotating waters that most; of the electric




power generating stations would be located where the heated
-------
                                                        2029






                     Ho P. Read




effluent would be deposited.  There has been talk about some




25 or 30 sources of such heat flumes.  The power industry




would like to restrict us to consider only these stations




one by one, increment by increment, and prohibit any thought




of the total effect by the year 2000 or beyond.  We don't




do that and we will not accept that increment-by-increment




approach.




          I included in my statement a map of the Indiana




shoreline, the purpose of which is to show some additional




factors which make our problem more difficult, and that is




the existence of landfills jutting out into the lake.




The northern Indiana Public Service Company generating




stations, and their respective discharge flumes are or




would be located so that the heated effluent would be




trapped by landfills.  The effluent with its heat plus




whatever other pollutants are included — and I also dis-




cussed a bit of the other pollutants — will extend along




the shoreline of several parks including the Indiana Dunes




National Lakeshore.  While the uninformed swimmer may enjoy




the heated water, the subsequent increase of algae, ale-




wives, and other pollutants from NIPSCO's discharge pipes




will turn the beach into something less than desirableu




          In the statement itself I describe each of the




locations of the generating stations, which I haven't
-------
                                                    2030





                       H. F. Read



mentioned or gone into a great deal of detail here because



you can understand it better visually than for me to




describe it, and in the map I have included a red* area




which is the probable destination of any heat flumes, and




the problem here, of course, is that these heat flumes,




with whatever ill effects they have, will be spread along




public bathing beaches, public parks, the Indiana Dunes



and National Lakeshore, as well as city and State parks.




          We had some tests made by the Independant Citizens*




Water Pollution Research Associates, Inc., at the Bailly



and Michigan city generating stations.  At that time we



were testing primarily for other forms of pollutants, so



we did not go into an extensive heat test.  We did make



some.  We found that the discharge flume was #3 degrees



from the Bailly plant, and we could compare this to 66



degrees which was in an area that would be not normally



touched by heated discharge — differences of 1? degrees.



          How, this heated water discharge flume spread




along the beach of the Indiana Dunes National Lakeshore.




For a mile of the beach it still registered &1 degrees.



We didn't go along and make further tests.  We will.  But



I think it is quite obvious that we have special problems,



and that is why we want this body to take a hardline stand




on it.




*Solid black area
-------
                                                      2031






                        H. F. Read




          Mr. Stein, you did say that you did not want




discussion of other pollutants, but our experience with




other pollutants has a direct bearing on our positions




that most of the conservation groups are taking here today,




and that is that we have listened to all of the denials of




problems by steel companies, chemical companies, oil com-




panies*   They denied that oil would be damaging; they




denied that pickling liquor fr*om steel mills would be




damaging; and now we are expected to accept the notion




that'we would sit by here and let the generating stations




build their plants and then maybe sometime in the dim,




distant future, if their pollution can be proved, they




will do something about it0




          You people have not been able to do anything




about the pollution that we have — very little.  We have




not been able to do anything about it, and I don't see if




we have not been able to have much progress today how we




are going to automatically stop this in the year 1975,




which was the year that was mentioned.




          I think it should be mentioned that the pollu-




tants coming out of NIP3CO, including fused mangr.aece-




aluminum-titanium-silicon, commonly called clinker or




bottom ash; fly ash; iron II and iron III oxides; nickel;




chromium; magnesium; cobalt; and zinc — some of these
-------
                                                        2032






                     H. F. Read




materials, particularly the zinc, are more suggestive of




steel mill processes, and I understand that some inter-




connection of piping exists between NIPSCO's Bailly Station



and the adjacent Bethlehem Steel Plant.  It may be that




NIPSCO, as part of its "good neighbor" policy, is allowing




Bethlehem to flush some of its untreated wastes of




metallic refuse and perhaps also dissolved pollutants and




heated water directly into Lake Michigan.




          This is the reason why we want to get powerplants




— particularly NIPSCO — off the lakefront, and it is not




just the heat, it is the rest of the stuff that goes along




with it.




          I will end here.  Thank you very much.  (Applause)




          MR. STEIN:  Thank you very much, Mr. Read.



          Are there any comments or questions?



          If not, thank you very much again for your



statement.



          (Mr. Read's statement follows in its entirety.)
-------
                                                                  2033
To:   Third Session, lederal Conference  .m Lake  Michigan
      and.  its Tributary Basin  ,  Chicago

From: Eerbert P. Read, State Director, Indiana Division
      Izaak ..alton League of America
      M. R. L>ox 438, Chesterton,  Indiana 46304

Date: October 2, 1970

Vie who live along the Indiana  shoreline;  of Lake  Michigan sre  particularly
concerned  over thermal pollution  problems nov; being  considered.   '.This
is because the southern tip of  uhe lake  is where most  of the  pollutants
dumped into the lake end up — and  where most  of them  remain.   Our state
of Indiana is further notable  for being  the  worst  polluter  for having
the least  effective enforcement and totally  without  any  form  of leader-
ship from  any of the local or  state governmental units to correct the
problem,

In short,  v;e have a helluva mess  on our  hand^,, and if  the so-called
public utilities get their way, we .-light as  well start carying the
tombstone  for the Indiana shoreline of Lake  Michigan right  now.

This conclusion is due, in part,  to a number of  factors, some of which
I wish to  discuss.  -the dissipating effect of heat,  or for  that matter
any form of water pollution is slow,  due to  the  sluggish movericuib of
water at the southern end of the  lake,   'ihe  littoral drift  parallel
to the shore moves both east and  west, v. ith  a net  westerly  direction.
The effect is to hinder northward movement,  which  when it does occur,
upon reaching the underwater ridge near  Milwaukee, . usually  rotates
around to  return most of  bhe same water  to our shore.  I think most  of
us ere la.ailiar with this fact,  and there  is no  need for documentation.

It is in thi^ lower casin, with  the sluggishly rotating  waters that  most
ol the electric power generating  stations v.oald  ce located  end where the.
heated effluent would be deposited.   The power industry  hired-hand
scientists talk unconcernedly  atout the  little fishes  that  cavort glee-
fully in anc! out of a heat flume  which always has  suil'ieient  cold water
around to  quickly reduce it all dO'.;n  to  normal temperatures.   Conven-
iently ignored is the cumulative  effect  of 25 or 30  sources of such
heat flu-p.es, ringing the sluggish waters, already  rich in nutrients,
of lov;er Lake Michigan.

In common  vdth the Atomic Energy  Commission,  the power co:..pany spokesmen
would restrict us to considering  the  effect  only increment  by increment,
and prohibit any thought of the  total effect by  the  year 2,000 or ..evoncl.
This is  Because the total carnal-" tive  effect,  if  knovai, could  make the
aatives  r
The movement of v;ater along  -he  Indiana  shore  is  further hindered by the
existence of landfills  jutting out  into  the  lake.   The  HIPSCO generating
stations , err:  cheir respective discharge  flun.es,  are — or vould be —
located  so  bhat the heated effluent would be trapped  by landfills.
 The effluent '/ith its  heat,  plut, whatever other  pollutants  arc included
— an.; i  will subnit proof of  oilier  poliutants--v;ill extend along the
shoreline of ;.ever&l parks  including  the  Inuiana  Dunes Kntional Lnkeshor
While the uninformed sv.imiwr  may enjoy  th= heated -,.ater, the subsequent
-------
                                                                    2034
                               3

increase  of  algae,  alewives,  and oth-^r pollutents from riPSCO'o cischarge
pipes \vill turn the be&ch into a rooting, stinking morass.

  I  have included a  map for reference.  Consider first the existing  coal
ffired 603 !."'/ Bailly generating station.  The Lethlehem Steel landfill  is
directly  to  the west,  prohibiting any dissipation of water pollution
westward.  It ie in fact a pollution pocket, with the heat and other
pollutants spreading eastward along the teaches of the Indiana Dunes
National  Lakebhore, iijnediauely adjacent co the discharge flume.

On  August 18 and 26, 1970, a ceries of tests of various  types of
pollutents v.'ere made by the Independent Citizens' Water Pollution
Research  Associates Inc. at the B&illy and Michigan City generating
plants  of KIPSCO.  On .August 26, the temperature off the bailly otation
discharge flume wag 83 i', compared to 66  in the Buffington Tier area,
a difference of 17  .  The heated water, spreading along  the beach  of
the Indiana  Dunes national Lake-shore registered 01° along the first
mile of park shoreline.  At this rate, it /vould  take several additional
miles  to  return to  normal lak«j temperatures.  To aake matters vjorse, a
new nuclear  fired 657 II.; capacity station is planned for. this same site
for a  station total of 1,260 I:./.  The additional heat load will  create
quite  a "hot spot"  in the National Lakeshore.

Simultaneously, hard on the eastern  Boundary of the Indiana Dunes
Uationr,!  Lakecihore  is the discharge fluae of KIPoCO's Ilichigaa City
station.   In addition to the exi3^ing 208 1.1. / units , a 511 IIY;  unit
(otation  total 71^  :'?./) is ceing built, to Le followed by toother of
sindlar capacity, some 1,250 iK/, v.lth a discharge of (t>07,000 gpm
plus 350,0000gp.!i) 870,000 gpm.  The discharge would be,  by company
figures,  1-s,^-  above intake temperature, and some evidence exists that
the company  figures crc understated,  ihc heated c-fflue.no from this
otation \vuulu bo directed v;estv;ard onto the beaches of the .fndiane  Dunes
NaLionnl  Lskcshore.

Thus both ends of  tho main section of the National lakeshore v.-ould be
blanketed Ly heated discharged, to ^he point, if expansion continues st
the prose jio  rate, the flumes «ould join  , making continuous along  the
shore whatever ill  effects ei:d problems art aosociated \;ith the discharge

But even  with the aforementioned sources, the Indiana ^orc- s National
Lakeshore and its users may Buffer additional ebaset from KIP&CO.   A
new statioi1  is planned for Gary, ogain to be located adjacent bo  a  lend-
fill---x.hi ^ one being 'Jni^ed States bteel Co::pany*s.  Tiiu heated  effluent,
again located in a  "pollution pocket," would spread eastward, pact the
Gary Ilar^actt.,, lark cccch to the jest ^each unit of tht.  Indiana Dunes
I-Tational  Lektshor^, \<1hic.1-i v;ill be the heaviest use arm.  Alter  blauUfct-
ing thrio  beaoh, it  will be stopped on the east ^y the Ilid./est ^teel Co.
landfill, again polljuin;; a "pocket" of v.ater.
 but \/e're not through v.'ith tliis uroLlei.i  of  trapping heated effluent
 betv.ee'n landfills.  At  jh.  lllinoiL--lncliana  state  line  is ihd Cc;/.ionv.eal bh
 Ldison titatt. Lii.c Generating Station.  A few mileo av'ay the Inland Ctcel
 Company landfill fon,.s ai'.other "pocket"  with the Ma;. aoni anc1 ~»hiting
 benches in bt:t-..fcen.  'J-hc- chance..-: for cleaning  up  theje  poor, iorli;rn
 seg.acnts of the paulic real'a ,.uuld bo  forever  lost ;.ith :.:ore {.. nd i'iore
 healed ei fluent.
-------
                                                                 2035
One [i.ore source of Kli'COO'a  contribution to  heating up Lekt  ",'ichigan
is ihe. Liitchell Station, near the eastern edge  of  Gary,  end  the only
station not adjacent to a putlic beach.

1 think, you will now agree that the combinations of Geography,  landfills,
and MPbGQ's generating ststion locations pose  a very  serious pollution
problem for the Indiana shoreline.  But  HIPSCO's threat  to the  well
being to Indiana' t> citizens  does not  end here.

For soaie unexplained reason, KIPSCC's discharges into  the public waters
contain other contaminants,  'ihese  include fused mangnnese-alurainuia-
titaniu-n.-silicon, (commonly  called  clinker or botto.a ash); fly ash;
iron II and iron III oxideo; nickel;  chromium;  magnesiuai; cocalt;
end zinc.  Some of  oh&se materials, particularly the zinc, are  r.iOre
suggestive of steel raill processes.   J understand  that some  intercon-
nection of piping exists between NIPSCG's bailly Station end the adjacent
ciethlehe.-.i Steel Plant.  It may be that KIPSCO,  as  a part of  its "Good
Neighbor" policy, it; allowing Bethlehem to flush some  of its untreated
wastes of n.etallic refuse, an '• perhaps also  dissolved  pollutant^ and
heated water directly  into La/te ..lichigan.

This is another reason why ve want  to get power plants—particularly
KIPSCG—off the lakefront.

Another factor v.hic!. shapes  the response  of  Indiana conservationists
is the anrofor,:;ed, 19th century management attituce towards  pollution
problems.  i;iPSCO's public relations  men talk irapressivuly,  but we have
been on the scene long enough to compare  pror.ise with  performance.  A
public utility enjoys a government-protected monopoly, v/ith  protective
rates which assure stockholders of  generou-  profits,   There  is  no excuse
whatsoever for the resistance we have experienced  in Indiana, ariri v.hich
is very evident this past -.-eek at these  hearings.

As expected there are threats of "Brownouts" and "clackouts."  If we
permit the power lobby to blackmail the  public  in  this fashion, the same
tactic can(and .-/ill, be used  to excuse other  pollution  problems  in
addition to the heated v.ater.  Jn fact,  virtually  any  sin cen be
rationalized in this Manner.  'J-he fact if-,, of course,  that the  "blackout"
tactic assumes a false alternative—-that  the  choice is  between using
Lake Michigan as a "heat sink" or ueing without sufficient generating
capacity.  'c are tolcS that  until proven
otherwise, the heated discharge should be permitted.  At sorae future
date, after tests conducted  t,y, and for,  the pollat-ers,  if it can be
proven to their satisfaction that there  is danger, maybe--just raaybe--
iDraetiiing should be done about it.  Vihatevcr shortcomings we conserva-
tioniots have, we're not dumb enough  to  accept  that ridiculous  argument.
ite have hearc the sar.iC dei.ial of uanger  fror; steel companies and oil
companies, and recently I heard a Ph.D.  hired by  the Agricultural Chemical
Industry cloi.i that DOT is not responsible for  all those  fish kiils
and dying birds.  In fact, he iuplied,  DDT was  really  good for you and
-------
                                                                 2036
would cure everything from cancer  to corns.

Haven't we learned anything from the past?  Do Me  h?ve  to kill off
people fcy the thousands before  the polluters v/ill  adait the  danger
of their discharges?

The matter of enforcement nust  fee  considered.   I  am well acquainted
the pollution probleaa of Torthv;estern Indiana, and have attended
innucieratle public hearings and hoard  excuse after excuse.   I have
tried repeatedly to ottain local and state  action to reduce  pollution,
and I can state fro.n personal experience  that  the  performance of
Indiana authorities does not inspire confidence.

There can be no more delay.  The states would dawdle around  v/hile the
utilities flood Lake l/.ichigan with more and r.ore  heated effluent.  Lv.cn
if the states^iiltiiaately agree  on  a policy, 1 have little confidence
•ffcat the policy adopted will safeguard  i.ake Michigan.

There is only one way to go. .The U.S.  Department  of the Interior must
require the states to adopt ':nJ& recommendations as contained in the
-------
2037
-------
                                                     203S
                     Mrs. R. A. Barber




          MR. STEIN:  We have a statement for the record by



Mrs. Robert A. Barber who had to leave,  and without objec-



tion we will enter that as if read.








             STATEMENT OF MRS. ROBERT A. BARBER,




                    DEERFIELD, ILLINOIS








          MRS. BARBER:  I share the average voter's belief




that the lake is a natural  resource that can be  maintained




by sincere efforts at conservation.  Those of us  who have



been interested in the problems created  by pollution are




pleased that the State of Illinois has given us an




accountable group of citizens to set standards for



environmental pollution control,,



          We plead that the Federal Water Pollution Control



Agency propose standards to end the use  of the lake as a



heat sink by utilities, with the present state of scien-



tific information and engineering technology.




          MR. STEIN:  We have Seymour Altman, Commissioner




of the Highland Park Environmental Control. Commission.




          Mr. Altman.




          FROM THE FLOOR:  Mr. Altman will be back shortly.




          MR. STEIN:  All right.  We will call him again,




if he misses his turn, and I am not specifying when.
-------
                                                      2039




                         Mrs. S, Gruen








           Mrs. Shirley Gruen, Wisconsin Federation of




Women's Clubs, has a 3-minute statement.  Mrs. Gruen.








           STATEMENT OF MRS. SHIRLEY GRUEN, WISCONSIN



                  FEDERATION OF WOMEN'S CLUBS




                     GLENDALE, WISCONSIN








           MRS. GRUEN:   I will only take about three minutes



of your time.  I put down the Federation of Women's Clubs



because I got a phone call about this conference.  I am



a member of the Women's Club and I am a conservation chair-




man of the Glendale, Wisconsin Chapter, but I don't really




have anything in writing.



           I would rather  — before the 1-degree thermal




standard is set, however, I would rather talk as an



American citizen.



           My name is Shirley Gruen, and I live at 214 W.



Mt. Royal Road, Glendale, Wisconsin.  I am not a geologist,



a biologist, an expert on pollution, I am an artist, and




I am speaking here as an American citizen to plea for help




in saving Lake Michigan from further degradation.




           I have spent every summer of my life since 1923




— that is the year I was born so you can figure it out, I




am 46 years old — at our home on Lake Michigan 3 miles
-------
                                                      2040
                     Mrs. S. Gruen




north of Port Washington.




          Everything said here today about the phenomenal




change in the quality of water in Lake Michigan is true.




There are now very few clear water days.  After every storm,




enormous amounts of algae are tossed on the beach.  Other




people have told of this so I won't go into it.  I think




I am probably the only one in this room who lives close to




the color of the lake.




          In 1935, before the Port Washington powerplant —




and it is run by the Wisconsin Power Electric Company —




at that time, it was the wonder of the world.  People came




from all over to see this technological wonder.  Now, I




want to tell you that it is not very nice living next to




a powerplant,,  As the gentleman before me said, it isn't




only the pollution in the water, it is the air, it is the




coal, it is the coal boats, it is the dredging of the




harbor and the Army Corps of Engineers dumping in the




lake.  It is a relatively constant pollution.




          Ironically, even at the time this electric powi.r-




plant was built in 1935, it was not even in the public




interest then»  We lived 3 miles away and could not get




electricity at a reasonable rate.  It was not until 1941,




through the REA, that we got electricity, and I tell you




we were luckier then than we are now to be without the
-------
                                                       2041
                     Mrs. S. Gruen




electricity.




          I would like to speak here as a private person



on the feelings that a private person has —^he powerlessness




and the helplessness to right the wrongs of pollution that




we feel.  Technology and production can be great benefits




of man, but it becomes apparent that they are mindless




instruments, and if undirected they move with a momentum of




their own and destroy everything in their path —the land-




scape, the environment, the quality of life»   We can't




excape it.



          They begin to dictate how we are to live.  The




slogan in Wisconsin — I don't know if it still is — I



don't listen to that much TV — was: "'Live better elec-



trically." Well, I am not living better electrically; I




am living worse electrically      If it means that I have




to go without any electricity in my house for the moment



I will do it, because what kind of a life is it to live



inside a house \vith every comfort and convenience and not



be able to walk outside and enjoy the environment?



          So that is about all I have to say,, except that




as a citizen and as a mother of three children about the




ages of some of the children out there, you have to ask




yourself as you go through life: "'What is your aim in



life? "The environment has been very good to me in my
-------
                                                      2042






                     Mrs.  Mo  H.  Dunlop




years on Lake Michigan, and my aim in life is to pay a




little rent, and I am going to do everything that I can




as a single person in this world to try to save it.




          Thank you.  (Applause)




          MR. STEIN:  Thank you.




          Are there any comments or questions?




          If not, Mary Helen Dunlop also has a 3-minute




presentation.




          FROM THE FLOOR:   Mr. Chairman, may I ask a




question?




          MR. STEIN:  Will you come up, Mrs. Dunlop?




          I wish the power companies here could distribute




some of those electric clocks so people would know when




their 3 minutes are up.








               STATEMENT OF MARY HELEN DUNLOP,




                      EVAN3TON,  ILLINOIS








          MRS. DUNLOP:  Mary Helen Dunlop, a private




citizen from Evanston, Illinois.




          I came down here today to listen, and also to




make a statement of my own for myself and for other people




whom I think are of like mind.




          When I arrived here, I was told that Mr. George
-------
                                                       2043






                     G. Brown




Brown, representing the Committee on Lake Michigan Pollution,




had prepared a statement for that committee and was unable




to be here.  So I will ask permission to forego presenting




my own statement in favor of presenting Mr. Brown's statement




for the Committee on Lake Michigan Pollution of which I am




a member.




          Is that agreeable, Mr. Stein?




          MR. STEIN:  I take it that is no longer a 3-minute




statement.




          MRS. DUNLOP:  I will take longer than that.



          MRo STEIN:  Thank you.  Go right ahead.








          STATEMENT OF GEORGE BROWN, COMMITTEE ON




          LAKE MICHIGAN POLLUTION, WILMETTE, ILLINOIS




          (PRESENTED BY MARY HELEN DUNLOP)








          MRo BROWN:  My name is George Brown and I am



speaking in behalf of the Committee on Lake Michigan




Pollution, Box 5^3, Wilmette, Illinois.  The CLMP is a




citizens' organization representing members in 10




communities on the north shore.  Our main objective is




to eliminate and resist present and future pollution




threats to Lake Michigan.  The committee provides a



structure for the individual citizen to contribute to this
-------
                                                       2044





                        G. Brown




objective.  We have become more convinced over the 4-year




life of our group that on important issues relevant to the




lake it is important for the public to be heard since




reliance on industrial testimony or from political sources




is not representative,  We have consulted people with




expertise within and outside our organization.  However,




our testimony today will not be primarily technical in




nature; that is clearly not our comparative advantage.  We



do feel, however, that we can make a contribution to the




problem of establishing standards,,




          Our position concerning thermal standards is' as



follows:




          1.  A thermal standard should be stated in a multi-



dimensional framework.  It is not sufficient to establish




standards solely in terms of a single dimension such as



some stated increase in temperature level at the point of




discharge.  Other criteria must be included such as the



quantity or pounds of water discharged at a particular




temperature increment, the length of time the water is




discharged at a given temperature level and amount, the



rate of change in temperature level at point of discharge,




etc.  Reliance on one criteria, although administratively




simple, does not reflect strategies which vary the levels




of temperature, quantity of water discharge and time period
-------
                                                      2045






                        G. Brown




of the discharge.  Since combinations of these dimensions




have different ecological effects they must be reflected




in any standards.  Criteria should also be stated in terras




of subregions of the lake as well as for the lake as a




total system.  Failure to state the criteria in a multi-




dimensional sense denies the complexity of thermal effects




on our environment,




          2.  A complex monitoring system must be included




in the establishment of operative thermal standards.  This




position is based on the following rationale.  The amount




and quality of information on the effect of thermal pollution




on Lake Michigan is not well understood.  We are not in i




position at the present time to make predictions with r.ono




certainty on the effects of increase in temperature level




or B.t.Uo's on the ecological system of Lake Michigan, for




the near or distant future.  Any standards established now




would be somewhat arbitrary.  We would accept such a




standard as an initiax benchmar.-- if it ic tied to :i lake-




wide monitoring system.




          A monitoring system would provide the me^ns to




revise the composite standards.  It would nlso provide a




moans to orovide inriodi^to ^oedback on ecological changes




in the I'.tk^.  Although there will be many studios published




in the coning years which will attenpr, to show whether
-------
                                                      2046






                        G. Brown




thermal effects are significant and their relative




magnitude, these studies will not be definitive despite




their author's intentions.  If a particular study shows




no ecologically harmful effects occur at a particular




increase in temperature level in a given region that will




clearly not be an adequate date base for eliminating



thermal standards.  A study or even group studies will



not reflect the complex interactive effects that occur




in the Iake0  It is only with a continuous monitoring




and feedback system that the effect of thermal inputs



into the lake can be controlled.  Information technology




is clearly sophisticated enough at the present time to




provide the critical link over time between thermal inputs




and ecological changes.  This link is critical to any



decision-making about thermal standards.



          MR. STEIN:  Thank you, Mrs. Dunlop, for Mr.



Brown.



          Any comments or questions?  If not, thank you



very much.




          Some people have asked about getting up when



their names are called and if they missed their turn.



If you go out to eat and you come back and you discover




your name was called, I have got a check system here.



Just let one of our staff know and we will call you as
-------
                                                     2047






                      Co Mathews



soon as possible.  In any event, we are going to try not



to miss anybody.




          Mrs. Paul S. Quigg has a statement of about 4




minutes.  Mrs. Quigg.




          She is not here?



          Mrs. Edgar Wilkinson.  Mrs. Wilkinson?




          Clyde Mathews?  According to the information




I have, Mr. Mathews, your statement should take about



5 minutes.




          MR, MATHEWS:  That is correct.








          STATEMENT OF CLYDE MATHEWS, COMMUNITY




          ACTION TO REVERSE POLLUTION, GARY, INDIANA








          MR. MATHEWS:  Gentlemen, my name is Clyde



Mathews.  I am from Gary, Indiana, and represent CARP



or Community Action to Reverse Pollution.  CARP is a



group of local ci-tizens organized in opposition to the




proposed construction of a 500-megawatt fossil generating



plant planned by NIPSCO or Northern Indiana Public Service




Company for the western edge of Marquette Park in Gary




adjacent to U. S. Steel Gary Works.  We are committed to




the protection and improvement of our city's air, water,




and recreational facilities.
-------
                                                     2043
                        C.  Mathews




          An example of the utter disregard of the public




by a "public" utility is found in a position paper issued




by the Northern Indiana Public Service Company recently.




The paper is entitled "Position Paper on NIPSCO's Electric




Facilities and the Environment" and states, "... it




(electricity) provides economic and beautification




benefits to the Nation which far outweigh the effect




power installations might have upon their immediate




ecological neighborhoods."




          As residents of Gary, Indiana, one of the so-




called expendable ecological neighborhoods, we take strong




issue with this statement and attitude.  This statement




clearly demonstrates the environmental expediency and




irresponsibility which has been characteristic of the




power companies in dealing with the communities in which




they operate.




          We, therefore, demand the Federal and State




leadership necessary to protect the natural resources




essential for those of us who live in this industrial




complex and similar ones elsewhere.




          Recognizing the fact that there is much needed




research to provide absolute facts as to the effect of




thermal pollution, sufficient evidence has been presented




concerning the destructive effects of massive dumping of
-------
                                                      2049



                        C. Mathews


waste heat into Lake Michigan to make it mandatory for


this conference to act.  Both the Federal and State water


pollution control agencies must provide stringent interim


standards for waste heat discharge.


          In our local struggle with NIPSCO we find again


and again that they have no intention of reducing waste


heat unless forced to do so.  Municipal governments have


the responsibility of protecting the health and well


being of their citizens.  They must have uniform,


unequivocal standards upon which to base their local

                              **
legislation.  It is the undeniable responsibility of


this conference to provide our cities with these stan-


dards .


          We, therefore, strongly endorse the Interior


Department recommendation that "no significant discharge


of waste heat into Lake Michigan should be permitted,"


          Thank you.


          MRo STEIN:  Thank you, Mr. Mathews.


          Any comment or question?  (Applause.)


          Mrs. Miriam G. Dahl.  Mrs. Dahl, you also have


indicated a 5-minute statement.


          MRS. DAHL:  I took a guess.
-------
                                                      2050





                       Mrs* M. Dahl








           STATEMENT OF MRS. MIRIAM DAHL, IZAAK



           WALTON LEAGUE, WISCONSIN STATE DIVISION,



                    MILWAUKEE, WISCONSIN








           MRS. DAHL:  I want to express my appreciation,



after having to listen to all that you have this week, that



you still are willing to listen to us who are legitimate



public, and the general public I am representing today



amounts to — I have said 1,500, but it is closer to 2,000



people, so I am sure that all of them will be grateful for



your time which you are giving us.



           Mr. Chairman, and conferees.  The Wisconsin



State Division of the Izaak Walton League of America



representing some 1,500 citizens of the State of Wisconsin



reiterates today the firm stand taken initially against



the artificial addition of heat to our waters.



           In deference to the mathematical computations



that absolute degrees of return temperatures cannot be



equalled (though we think this statement .is subject to



question) we accept the allowance of 1 degree above water



temperature given in the statement by Secretary of Interior



Walter Hickel as tolerable.  We know this temperature can



be achieved by more than one method.  It is fact.
-------
                                                     2051





                       Mrs, M. Dahl



           We do not subscribe to the proposal by the State



of Michigan of a 3 degree tolerance using acres of lake



water to cool instead of cooling before returning used



water to the lake.  This method affects a far greater amount



of water at varying upward temperatures than would be



indicated in a stated 3 degree tolerance.



           In a study conducted in Tennessee by James



Speakman, tests showed that a 3-degree rise even in the



warmer waters has a devastating effect on the hardiest fish



natural to that area.  Other fish and aquatic life would



be affected more quickly.



           The Columbia River, famous spawning grounds for



our best salmon, has been ruined by atomic thermal addi-



tions,  A 3-degree rise in river temperature in this



nitrogen-rich water killed juvenile salmon in just 90



seconds.  That is 1-1/2 minutes.  Think of the effect such



temperatures would have on the coho salmon, trout and other



spawn in Lake Michigan.  If a 3-degree temperature is



possible, a 1-degree is equally possible.



           Cost has been made a strong point.  The actual



cost to the consumer will not be that great annually.  The



alternative to that cost may well result in uncontrollable



climactic changes, and no lake, ergo, no water.  The



alternative to this has to be wise use and sensible
-------
                                                     2052





                       Mrs, M. Dahl



administration.



           In July the National Izaak Walton League of



America in convention assembled in Norfolk, Virginia, voted



to support Secretary Hickel's 1-degree allowance in thermal



addition.  Wisconsin State Division supports that decision.



And I might say we pioneered the introduction of that into



the convention.



           Conservationists reach a large segment of the



"silent majority11 who ask us, "Why is continuance of such



malpractice allowed against our environment?  How can we



stop it?"



           It is no longer valid to say that economic



feasibility demands such action.  We are frequently asked



to "face reality" by economists and industrialists.  We



reply that this reality we face is the spendthrift race



to overuse, rape, and destroy our true base wealth which



economists state is our true wealth together with people.



Everything else follows this first premise.



           When we begin with this reality, we come to a



far different set of conclusions with a truly realistic



value which includes people, a future, esthetics, and



social values to make a whole life.  Then money takes



its proper place in purchasing the necessities, and not



as an end in itself.  Life depends on water, air, food,
-------
                                                      2053





                       Mrs. M. Dahl



natural resources.  Save these.



           We have heard all the excuses and testimonies to



substantiate the inability to meet a 1-degree standard.



We say that we can do anything we want to do.  We have



proved this in outer space and undersea explorations, in



creating synthetics (always from natural resources), in



medical transplants and other Jules Verne accomplishments.



Now, we must attend to our basics.  We must make fullest,



best use of our rapidly disappearing resources.  The



"waste-not-want-not1* maxim must replace the wanton disre-



gard of single use and discard the rest.



           We must depend on such government bodies as



yours to guide us to firm National standards with full



powers of enforcement to protect our remaining resources.



We, the conservation groups, and we, the public sector, urge



you to set standards of thermal additions to Lake Michigan



at 1 degree above temperature.  The fragility of Lake



Michigan demands this decision.  We hope it will become



the standard for all waters.



           Thank you.



           Respectfully, Miriam G, Dahl,  I am Chairman



of the State Division, Pollution Abatement Committee  of



the State of Wisconsin, and have just this year been placed



on the National Water Committee for the Izaak Walton League,
-------
                                                     205^






                       Mrs, D.  Trump



(Applause)



           MR. STEIN:  Thank you,  Mrs.  Dahl,



           Any comments or questions?  If not,  thank you



very much.



           We have Mrs. Paul Kaefer.



           Harold B. Olin.



           Mrs. Robert Herlocker.



           FROM THE FLOOR:  She will be back.



           MR. STEIN:  H. R. Thoke.



           Mrs. Donald Trump.








           STATEMENT OF MRS. DONALD TRUMP, CHAIRMAN,



           ENVIRONMENTAL QUALITY,  LEAGUE OF WOMEN



           VOTERS OF INDIANA, VALPARAISO, INDIANA








           MRS. TRUMP:  I will file with you a separate



statement.  (See P. 2055)  This is just from the League



of Women Voters of Indiana.



           I am now speaking for the Lake Michigan Inter-



League Group.  It represents 75 local Leagues of Women



Voters and the State Leagues of Illinois, Indiana, Michigan,



and Wisconsin.  Each unit has been working for local, State,



and regional environmental management programs which are



planned to improve the Lake Michigan Ba.sin.  Although other
-------
                                                             2055
                    Statenent to
         The Third Session Federal Conference on
         Lake I.ichigan and its Tributary Basin
            Workshop on October 2, 1970
                        by
      llrs. Donald Trump, Chairman Environmental Quality
        for the League of :/oraen Voters of Indiana
Our League members' longstanding concern on water quality and
its conservation has led them to inquire about the problems
created by water thermal changes as well as other problems. We
have learned that there can be aquatic changes, synergistic effects
of heat with possible toxic substances, and that deep lake water
seeisonal temperature stratifications can have deleterious alter-
ations, by placing a layer of warm water on it. Plus the value
of water for drinking, recreation and industrial use decreases
at l}igh temperature.
We have also learned about the problems that are presented on
cooling water systems, their possible detriment to atmosphere
with high construction costs, plus the large areas needed for
cooling ponds.
Therefore, on equating what the experts report, wucre they agree
and disagree, our members are saying it is important that the
country and the states move cautiously and slowly, with greater
safeguards than in the past. Now is the time to evaluate the
corrective devices through the present and nex-7 technological
aids. Because, once new water-using plants are built, it becomes
very difficult for states to require expensive alterations.
Further, we believe that when the term nondegradation is used
for water standards, it should mean no further man-made degra-
dation. Also, any regional or special area variances in temper-
ature standard requirement allows the problem of competitive
cost advantages to develop within industries. If careful planning
in locating plants produces a cost advantage  when equal standards
are applied, then the regulating bodies have succeeded in
their function.
Thank you.
-------
                                                      2056






                       Mrs. D. Trump



aspects of League efforts relate to local or broader



problems, as an Inter-League Group, we concentrate solely



on the preservation and improvement of the quality of



Lake Michigan.



           We are encouraged to witness the continuance of



the Federal-State Enforcement Conference and to see its



concentrated approach to Lake Michigan and its tributaries.



We believe that only through this type of regional, inter-



state, and multi-level governmental action can the necessary



complicated solutions to Lake Michigan problems be found



and enforced,



           Basic to the League approach to the task of



improving water quality, the League maintains that no one



has a right to pollute public waters and that those who



produce wastes should bear the cost of managing them.



           The question of placing thermal effluent in the



category of pollutants is one that has been thoroughly



debated.  The premise upon which we base our assumption that



thermal effluent, from any source, is a pollutant, is that



moment when the thermal additives cause a deleterious



effect upon the waters, the natural ecology within the



waters, the environment surrounding the waters, or affects



the use of the waters by area residents or visitors.



           Some authorities cite case after case of fish kill,
-------
                                                        2057
                       Mrs, D, Trump



environmental hazards, or speed-up of eutrophication as a



result of thermal additives.  Other authorities claim that



no proven case of known environmental or other effects can



be found.  League members can certainly claim no prescience



to pick that group of scientists which will turn out to be



correct.  League members know, however, that the confident



casual approach to looming problems has not been successful



in any instance in the past.  It seems that only after the



damage has become an obvious danger has concern and control



become visible and too little.



           Therefore, we encourage this Federal-State



Enforcement Conference to consider the recommendations of



the Federal Water Quality Administration which would main-



tain lake water temperatures as close to natural levels as



possible.  We believe that American technology can find



practical ways of achieving this high goal, thus preventing



the addition of at least one type of pollutant to Lake



Michigan,



           The League supports discharge requirements which



we think are necessary for State and Federal enforcement,



We find it difficult to see how stream standards could be



reached and maintained without setting standards for



effluent and monitoring at point of discharge.  The use



of mixing zones as a component of regulating thermal
-------
                                                      2053
                       Mrs. D. Trump



discharge can complicate the regular measurement procedures



and, in certain instances, confuse the possible identity of



an unlawful discharger.



           We believe that it is good in intent but possibly



unrealistic as a solution to require power companies to file



contingency plans when applying for construction permits.



These plans would outline remedial steps to be taken in



case their thermal discharge proves harmful.  If a power-



plant discharges its thermal effluent into Lake Michigan



for a period of some years before cumulative damage is



observed, it is possible that an established dependency upon



that powerplant by the consumer would necessitate continued



functioning of the plant while the contingency plan was



reviewed and implemented.  How long would that take and



what further damage could be caused in that period of time?



           Attention has been drawn to some of the recrea-



tional benefits derived at the point of discharge by



attracting large numbers of warm-water fish.  Others have



followed this point and have asked about the possible



effects of a plant shutdown on this unnatural fauna.  Would



a false environment be established which would then require




maintenance?



           Nuclear powerplants are now considered to be the



major "new" source of thermal additives.  If it is
-------
                                                     2059





                       Mrs. D, Trump



determined that cooling ponds are the preferred technique



for cooling the heated water, what are the guarantees that



the recreational uses proposed for these ponds will not



dangerously expose the users to radioactive leakage?  This



brings up another subject which is presently full of



unknowns and causes conflicting judgment of accumulated



data.



           League members have studied the questions



involved enough to know that there are no easy answers



and that simplistic solutions must be viewed in a suspect



manner.  The ultimate decision this conference reaches



will certainly not please everyone.  We urge caution and,



if necessary, that error be made on the side of prevention.



We ask that, whatever the final determination, a realistic



and yet firm compliance schedule be arranged, and that



continuing enforcement measures be incorporated and applied.



We urge that opportunities be automatically given to the



public to react and respond to powerplant construction



proposals before site work has started.



           League members, along with the rest of the



citizenry, must take a long hard look at our environment



and its growing misuse by growing numbers of people.



Perhaps it is time for new judgment values to be made on



both population and economic growth.  The estimates that
-------
                                                      2060






                       Mrs. D. Trump



the affluent citizens of the United States are responsible



for 50 percent of the world's annual consumption of natural



resources is frightening rather than satisfying.



           We must grow up, we must change, we must make



hard decisions. Here, today, is the chance to do this in



time to save Lake Michigan,



           Thank you,  (Applause)



           MR, STEIN:  Thank you, Mrs, Trump,



           Are there any comments or questions?



           If not, thank you very much,



           (The following document was submitted by Mrs,



Trump for inclusion in the record,)
-------
             MICHIGAN
                                                                                                2061
                          League of  Women  Voters
LAKE MICHIGAN INTER-LEAGUE GROUP
          INDIUM
                                     Thermal   Pollution
                                                                      April
                                                                      1970
League of Women Voters
67 E. Madison
Chicago, Illinois
60603
twenty
cents
quantity
price on
request
  Thermal pollution is the deleterious change in the normal
temperature of water caused by the discharge of waste heat.
  "In specific cases where heated water discharges are
causing actual death in an aquatic habitat, depressing repro-
duction and growth of desired  species, or degrading the
environment to a point where less desirable organisms are
favored,  then we  must consider that thermal pollution
exists," says Raymond Johnson, assistant director, Bureau
of Sport  Fisheries and Wildlife, Department of the Interior.

    POWER PLANTS AND THERMAL POLLUTION
  The nation's need for electric power is  doubling every
ten years. Massive  use  of cooling water to condense steam
in power plants is an integral part of the generating process.
Almost half the water used  in  the  United States is for
industrial cooling,  with the electric power industry using
about 70 percent of this amount. It is estimated that by the
year  2000, the need for water for industrial cooling will
equal two-thirds of the nation's natural daily water runoff
of 1,200 billion gallons.1
  A single power plant now in existence requires up to a
half-million gallons of water a minute for cooling purposes,
running at full capacity around the clock, this would mean
720 million  gallons a day. Some of this cooling water
evaporates; most of it, however, is returned at a tempera-
ture ten  to thirty  degrees above the temperature of the
water from which it was withdrawn.
  The projected growth  of the electric  utility  industry
during the next two decades is expected  to require  the
construction of about 40 new hydroelectric installations of
100 megawatts or  more,  50  new pumped-storage hydro-
electric installations of 300 megawatts or more,  and 90
fossil and 165 nuclear steam-electric plants on new sites.1
  Nuclear power plants now supply about 1 percent of the
nation's power; by the year 2000 they are  expected to
provide about 50 percent.
  "U.S.  Making Initial Move Against  Thermal  Pollution," by
  Gladwin Hill, New York Times, February 22, 1970.
  Joint Committee on Atomic Energy, "Environmental Effects of
  Producing Electric Power," October, November 1969.
                               THE EFFECT OF INCREASED THERMAL
                                  POLLUTION ON LAKE MICHIGAN
                           There is one nuclear power plant now operating on the
                         shores of Lake Michigan. Nine more are proposed or in
                         process,  with  all  but one  scheduled for completion by
                         1973. The ten plants will have  an electrical capacity of
                         7,100,000 kilowatts.
                                   Major Fossil-fueled and Nuclear
                              Power stations located on Lake Michigan2
                           •  Coal Burning     '
                           ©   Nuclear-operating
                           •   Nuclear-under construction
                           (Numbers indicate power capacity in megawatts)
-------
                                                                                                                  2062
  Existing fossil fuel3 plants, operating at full capacity,
discharge  an estimated 300,000 billion Btu1  per year in
cooling water  to  Lake  Michigan.  Nuclear reactor  plants
discharge  40 to 50 percent more  waste heat  per unit of
electrical  production to  the cooling water than do fossil
fuel plants. It is estimated that the ten nuclear plants, when
in full operation,  will discharge 388,000 billion Btu per
year to the  lake. If all plants, both existing and proposed,
were  to  operate  at  full  capacity (and  assuming complete
mixing  of the entire lake)  the  temperature  of the lake
would be raised a little more than 0.06°F annually.5
  The above calculation assumes no  reduction in the heat
of the cooling water  after its addition  to the  lake, but
actually there will be much reduction through evaporation,
radiation and other means. There will, however, be a resid-
ual  of the added heat that will be cumulative in the lake
until  an  equilibrium  is  reached  at a somewhat higher
temperature than that due to natural  causes. It  is estimated
that witn an average annual temperature of 50 F for the
lake,  the added heat would raise the average annual temper-
ature at equilibrium by 0.05°F to 50 05°F. With increasing
power production and no off-lake  cooling, it  is estimated
the  average  annual temperature would  be increased  by
0.4°F in the year 2000 and by 2.0°F  in 2023. This increase
would nullify  a two degree decrease  in average annual
temperature of the lake that has occurred, apparently from
natural causes, in the past one hundred years.1
  The possible  local  effects of  increased temperature  on
aquatic life are cause for more immediate concern than the
effect on the lake as a whole. Fish, and the aquatic  organ-
isms  that serve as their  food, are particularly  sensitive to
variations m  natural  seasonal temperature during  repro-
ductive and  juvenile stages.
  The value  of water for drinking and  for recreational and
industrial uses usually decreases at  higher temperatures.
Thermally polluted water  is less  capable  of  assimilating
wastes  While  present use of Lake Michigan waters  for
irrigation is minimal, local  temperature rises in areas near
intakes for  irrigation  water might affect seedlings,  plant
growth rate, and crop yield. As temperature rises, nuisance
plants, algae and rough  fish flourish while more desirable
life dies. The quality of water deteriorates as foul odors and
algal  slime appear.

                THERMAL POLLUTION
           AND THE AQUATIC ECOSYSTEM
   Thermal  pollution  can  affect the entire ecological bal-
ance  of natural waters. Water discharged from power plants
is often ten  to  thirty degrees warmer than the body from
which it was drawn. A temperature change of only three to
four  degrees  can,  under certain conditions,  have serious
effect upon  fish and other aquatic life,  depending  on  the
 - Fuels such as coal, oil, and natural gas
 - British  thermal unit, the quantity of heat required to raise the
   temperature of one pound of water one degree Fahrenheit
 - Statement of  F W   Kittrell,  Chairman, Committee on Nuclear
   Power Plant Waste Disposal, at the Conference on Lake Michigan.
   U.  S  Dept. of Interior, FWPCA, Proceedings, Volume II, Febru-
   ary 1969.
level, duration and  rapidity with which the temperature
change takes place.  Some effects  of thermal pollution on
the ecological balances of natural waters are

l)The addition of warm water may cause fish eggs to hatch
  so  early in the spring that natural food  organisms  are
  unavailable.
2) Temperature changes act as signals for fish  migration and
  spawning. If hot water from a power plant spreads com-
  pletely  across a river  or  stream, it  can  form a thermal
  barrier  preventing fish  from  swimming  upstream  to
  spawn or from  passing safely downstream to  carry out
  their life cycle.
3) Trout eggs will not hatch if incubated in water that is too
  warm, and salmon may not spawn.
4) The sensitivity of aquatic  life to many toxic substances is
  heightened at increased temperatures.
5) Fish double their consumption of oxygen for  each  ten
  degree rise in water temperature.  As water warms up, it
  can hold  less oxygen,  thus  lowering  the  amount of
  oxygen available to aquatic life.
6) Within certain limits bacterial activity is increased.

  In a statement before the Joint Hearings  on Atomic
Energy, Dr.  Johnson said,
   ... on June 25, 1969, temperature monitors installed by the
   Federal  Water Pollution Control Administration (FWPCA)
   personnel near the mouth of the Florida Light and Power
   Company's Turkey Point fossil  fuel power plant effluent
   canal recorded very warm water in Biscayne Bay. At this time
   biologists recorded high turbidity and evidence of significant
   kill of bottom living aquatic  organisms. Large numbers of
   dead crabs, pistol shrimp, benthic  fish, and dead or dying
   species of invertebrates and macroalgae were observed. The
   greatest concentration of dead crabs appeared to extend from
   the mouth of  the  Grand Canal  into the bay  about 1,000
   yards.
     Further observations  on June  28 found a variety  of
   sponges, coral, green algae, crabs and mollusks dead as far out
   as  1,500 yards. While available data  cannot rule out other
   factors,  the most  probable cause of death to these organisms
   was excessive temperature.

                THERMAL EFFLUENT
        AND THE ECOLOGY OF DEEP LAKES
  The most dramatic ecological  events for deep lakes in the
temperate  zone are  the  seasonal  turnovers.  In the spring,
surface waters warm to  30°F, sink and mix with the bot-
tom water, bringing the nutrient-rich bottom water to  the
surface. The  surface waters  cool in the fall  and again  a
turnover occurs. The algal blooms which follow these turn-
overs are  well known. The ecology of temperate zone lakes
is largely  determined by turnovers and by the stratification
of  the water into layers with varying temperatures during
the intervening periods. The chemical, physical, and biologi-
cal structure of lake ecosystems is keyed to these events. A
power plant which places a layer  of warm water on a lake
surface may  disrupt  the  circulation  pattern and either
prevent turnovers from occuring or change the time at
which they take place. The effects of this on lake ecology
can be drastic and  possibly disastrous.4
 ' "We're in  Hot Water", by  John Cairns,  Jr., m Scientist and
  O'rizen, October 1968.
-------
                                                                                                                2063
      Reported fish kills caused by heated waste water discharges from electric power generation plants
Date
Aug. 6-8, 1962
Aug. 11, 1962
Sept. 7, 1963
May 28, 1964
Aug. 19, 1965
Aug. 20, 1965
Jan. 19-22, 1966
Sept. 2, 1966
Jan. 1, 1967
Jan. 17, 1967
Jan. 1, 1968
Jan. 2, 1968
Mar. 1, 1968
July 1968
Aug. 22, 1968
Dec. 16, 1968
Dec. 24, 1968
June 30, 1969
State
Penna.
Mo.
II!
Tex.
Penna.
Ohio
Ohio
Penna.
Ohio
Ohio
Nebr.
Ohio
Utah
Mass.
Mass.
W. Va.
Ohio
Fla.
Stream
or lake
Raystown Branch,
Juniata River
Discharge canal
to Montrose Lake
Rock River
Unnamed stream
Schuylkill River
Greater Miami
River
Ohio River
Schuylkill River
Sandusky River
Sandusky Bay
Lake Hastings
Sandusky River
Price River
Cape Cod Canal
Cape Cod Canal
Ohio River
Sandusky River
Biscayne Bay
Nearest
town or
county
Saxton
Ladue
Rockford
Victoria
Reading
Montgomery
Toronto
Philadelphia
Sandusky
Erie County
Hastings
Sandusky
Castlegate
Sandwich
Sandwich
New Cumberland
Sandusky County
Miami
Degree
of
severity
Heavy
Heavy
Light
Light
Moderate
—
Light
Heavy
-
-
Moderate
-
Heavy
Moderate
Moderate
Light
-
-
Number
of fish
killed
3,441
Several
thousand
-
-
1,000
1 1 ,250
200
50,000
300,384
78,755
5,000
250,585
150
-
-
9,500
3,000
-
  Thermal  effluents  might become  a hazard  to  local
aquatic life during the summer months when surrounding
temperatures  are  higher  (60-70°)  inshore.  In the  mam,
however, Lake Michigan is cool even at  the  height  of
summer. During the fall and spring overturning of the lake,
a thermal bar, or barrier, is established several  miles off-
shore. The bar prevents the inshore and open lake  water
from  mixing,  and  hence might trap the heated discharge
waters and also the fish,  because of their  reluctance  to go
through the thermal bar. These close-to-shore effects, how-
ever improbabie, are possible. The only effective counter-
measure would be  to  shut  down, or substantially reduce,
the output of the station  causing them. If this were  to
become  a  recurring  phenomenon, serious consideration
would then have  to be given to use  of cooling ponds  or
towers.2

              SYNERGISTIC EFFECTS
              Of THERMAL POLLUTION
  Synergism is the simultaneous action of separate agents
that, together, have a greater total effect  than the sum  of
their individual effects In reference to water temperatures,
synergistic action  refers to  the fact that temperature rises
increase  the lethal  effect  of  many  toxic  substances  to
aquatic life forms and may also increase the susceptibility
of the fish to disease.
  Since  domestic and  industrial wastes are numerous  in the
nation's  waters, the synergistic action between temperature
and toxicity is a relatively  common occurrence. Fish kills
have accompanied small temperature rises which might have
been insignificant in a stream free of toxic substances. Thus
the concentration of  a substance  may be harmless at one
temperature, but may contribute  to fish mortalities when
combined with the stress imposed by higher temperatures.
For example, the myxobacteria Chondrococcus columnaris,
which can cause death through tissue destruction, becomes
more virulent as temperature is increased *

         OPINIONS ON THERMAL POLLUTION
           AND THE AQUATIC ECOSYSTEM
Industry.  At  the  Michigan  Governor's  Conference  on
Thermal Pollution, July  1969, Wayne L Wingert of Michi-
gan Electric Utilities reported, "Certainly, in some instances
the thermal effects could be detrimental. In other  cases,
these  may  well be beneficial, as for example the improve-
ment in oyster growth being demonstrated on Long  Island
Sound. We know of no problems which have resulted from
the addition of heat to the waters of Michigan "
  In his  report  at the same Michigan conference,  D.  H.
Brandt of Consumers  Power company said "there appeared
to be no gross  thermal  damage to the benthic (bottom-
dwelling) fauna of the main plume area" at their Campbell,
Michigan, site on Lake Michigan.

Government Agencies. The Energy  Policy Staff, Office of
Science  and  Technology,  said  in  their  Considerations
Affecting Steam Power Plant Site Selection
   In recent years we have come to realize that injecting huge
   quantities of heat into a waterway can create a new form of
   water pollution and for that reason the States, in cooperation
   with the Department of Interior's  Water Pollution Control
~ "Nuclear Power and Thermal Pollution," by Philip F Gustafson m
  Bulletin of the Atomic Scientists (preprint), March 1970.
- Industrial Waste Guide on Thermal Pollution, FWPCA, Northwest
 Region, Pacific Northwest Laboratory, September 1968
-------
                                                                                                             2064
   Administration, have adopted temperature limitations for the
   nation's interstate waterways.
     The Atomic Energy Commission has no present  juris-
   diction over the thermal effects caused by the siting of
   nuclear  plants   Many individual  state legislatures  have
   adopted water quality regulations. When selecting a site for a
   reactor facility, a utility must satisfy its particular state that
   it can comply with these regulations during the operation of
   the facility.
     Based on the data now available and experience with other
   wastes, it is only prudent that great care be exercised so as to
   avoid damage to the aquatic environment rather than to plan
   to correct gross problems after the power industry is heavily
   committed to the use of facilities which provide little  or no
   control over  the  effects of their activities on the  envi-
   ronment.
   The Federal Water Pollution Control Administration has
declared that waters above  93°F are essentially uninhabit-
able for all fish in the United States except certain southern
species. Many U.S. rivers already reach  a temperature of
90°F or more in  summer through natural heating alone.
The waste heat  from a  single power plant of the size
planned for the future (some 1,000 megawatts) is expected
to raise the temperature of a river carrying a flow of 3,000
cubic feet per second by  ten degrees, and  since a large
number of power plants are likely  to be constructed on the
banks of a single nver, it is possible that many waters would
become uninhabitable for fish.
   In a book produced by a Wisconsin  utility, Dr. Glenn T.
Seaborg, chairman of the Atomic Energy Commission, said
"Growth of nuclear power will help  abate air  pollution,
reduce traffic and  noise in the area surrounding the power
plant, and generally make the area a much more attractive
and healthier place to be."
   A warning was  issued by Lee C. White, the head of the
Federal  Power  Commission  for  most  of the  Johnson
Administration. Mr. White said some expeditious method of
resolving disputes  over the location of electric facilities
must be found. Otherwise,  the power industry's ability to
supply electricity  may, in many  locations, soon  be  out-
stripped  by the apparently  endless increases in public de-
mands for electricity. The public will no longer be able to
assume "there will be energy at the flick of a switch."

     PUBLIC OPPOSITION TO NUCLEAR PLANTS
   The public has actively  shown  its concern about  the
ten  nuclear generating plants planned along  Lake Michi-
gan  by 1973. These  plants  are in seven locations, three
being double plants. None is designed to reduce the  temper-
ature of cooling water before it  is  discharged into the lake.
   The  proposed Commonwealth  Edison plant at Zion,
Illinois, has stirred such  critics as  Senator Gaylord Nelson
of  Wisconsin  and Chicago  Alderman Leon  Despres.  Mr.
Despres says  the  company  should build  cooling towers to
reduce  the temperature  of the hot water before  it is  re-
turned to Lake Michigan. Some biologists and ecologists say
the  hot  water discharges will  change the temperature of
Lake Michigan and  alter the lake environment of native
marine life.
                INDUSTRY'S ANSWER
  Robert A  Hirshfield,  engineering consultant  for Com-
monwealth Edison,  has  said "many  of the critics  are
misinformed or jumping to conclusions." He said the Zion
    Power generation, population, and power
     per capita in Chicago area, 1950-19802
 I
 O 2
 II
 u '-'
 il
                                DOUBLING
                                   TIME
                 	  Power per Capita  12 years
                 	Population     46 years
                 	  Power Generation  10 years
                                                05
              I95O     I960     1970     1980
                          YEAR

nuclear power plant is designed to return cooling water to
the lake eighteen or nineteen degrees hotter than when it
came in. A 10-year study by Edison of offshore lake water
temperature showed  a maximum temperature of sixty-five
degrees. A nineteen degree increase in the warmest water
known to Edison would result in cooling water that would
be eighty-four degrees, said Hirshfield, thus meeting federal
and  state  water  pollution standards (of eighty-five degrees
for discharged cooling waters).

          REDUCING THERMAL POLLUTION
                OF NATURAL WATERS
   The alternatives developed thus far  for reducing thermal
effect on lake water quality are the use of cooling towers or
of artificial lakes  and reservoirs There  are two  types of
cooling towers:
   Wet tower. Heat is  removed by evaporation, cooling the
water by twenty degrees. The main disadvantage in the wet
tower is that large amounts of water are discharged into the
atmosphere. For example, the towers for a 1,000 megawatt
power plant would eject some 20,000 to  25,000 gallons of
evaporated water per minute.
  Dry  tower. The heat  is transferred  from  the cooling
water, through a heat  exchanger, directly to the air without
evaporation. The dry  system costs two and a half times as
much to build as the wet system.
What Industry Says About Cooling Towers
   Mr.   Hirshfield, Commonwealth Edison's  engineering
consultant, is opposed to the use of cooling towers at Zion,
Illinois. He says  cooling towers for a plant the size of Zion
would  increase the present cost of the project by $15 to
-------
                                                                                                              2065
$22 million. They would stand as high as thirty stones and
would reduce the temperature of used cooling water within
six to twelve degrees of that when it entered the plant,
depending on humidity.  ,
   "They are unsightly, they throw off huge amounts of
mist, and they could fog up the whole town of Zion," said
Hirshfield. "Cooling towers," he said, "can create fog for a
distance of 3/4 of a mile."
   Consumers Power Company is planning to use a reservoir
rather than cooling  towers  at their  Midland,  Michigan,
project.  "If we had planned  to use cooling towers at Mid-
land, we would be faced with an investment of $25 million.
The artificial reservoir is estimated to cost $6 million less,"
said  Harry  R.  Wall, senior  vice president  of Consumers
Power Company, at the  1969 Governor's Conference on
Thermal Pollution in Traverse City, Michigan.
What Government Says About Cooling Towers5
   Primary  concern is  with  potential  fogging conditions
caused by cooling  towers, but other possible adverse side
effects are being considered.
   Because  of the  large amount of water vapor expelled
from evaporative towers, extreme climatic conditions may
cause condensation, resulting in ground level fog or drizzle.
However,  such  conditions are not often  encountered. A
recent investigation of fogging problems from natural and
mechanical draft towers presently operating in the eastern
United  States  supports this  conclusion. Reports indicate
that natural draft towers did not produce  ground level fog
or drizzle  under any  weather  conditions.  Plumes rarely
dropped below the  top  of the tower for  an extended
distance, and generally dissipated within a few hundred feet
of a tower. Mechanical, induced  draft towers reportedly
produced  substantial amounts of ground level  fog, espe-
cially during the winter. The area affected by the fog was
very small, however, extending a maximum of about one-
fourth mile from  the  towers. Carry-over of some water
droplets was also  noted from the  mechanical draft type.
Resulting precipitation occurred in the immediate vicinity
of the towers, causing some minor icing problems up to 300
feet away.
   In general, undesirable meteorologic effects from towers
can be prevented or controlled to  a large degree  through
modern  design that incorporates effective drift eliminators,
air-flow  control, etc. In situations where problems arise, the
area  affected is limited to that immediate to the tower
installation.
What the Public Says About Cooling Towers
   Proponents of cooling towers say that  the $15 to  $22
million  quoted  as  the  cost of  cooling towers for Zion's
nuclear  power plant  is only 10 percent of the capital  cost
(adding perhaps 2 or 3 percent to the electric bill).

        UTILIZING THE THERMAL EFFLUENT
   Waste  heat  may be used  to prevent frost damage to
orchards, or to extend the growing season of crops  that
bring premium prices in an early market. Cooling ponds can
do double  duty as  recreational lakes. Thermal effluent
might be used in desalination plants to aid in  the evapora-
tion process, or to  improve efficiency of sewage treatment.
Others  suggest using the  effluent  for sea-farming with
selected fish tolerant of warm water, for heating buildings,
or for growing plants in water in a controlled way.

               ACTION TO MINIMIZE
        OR PREVENT THERMAL POLLUTION
   The Federal Water Pollution Control Administration of
the Department of the Interior established a provisional set
of  guidelines  for  water quality in 1967 that includes
thermal pollution. Maximum  permissible  water  tempera-
tures  for individual species of fish are  specified and units
for the heating  of natural waters for  industrial cooling
purposes are recommended.
   Senator Edward M. Kennedy has proposed that further
licensing of nuclear power  plant construction be suspended
until a thorough study of potential hazards has been made.
Senator Edmund Muskie's subcommittee on air and water
pollution held hearings  on thermal pollution  in 1969 in
many parts of the country.
   Thermal pollution control measures are costly and com-
plicated. An estimate by  the  FWPCA  places the cost of
cooling facilities needed through 1972 at $1.82 billion.
   Other action suggested includes:
l)Set specific  peak temperatures for each locality to pre-
   vent  fish kills  from temperature fluctuations. These
   criteria, however, might not assure the  maintenance of
   stable ecosystems in all their complexity.
2) Undertake  studies  of aquatic ecology. These studies
   might be financed by federal, state or private agencies.
3) Require the power company to prove that its use of the
   stream or lake would not impair other beneficial uses.
4) Monitor both existing plants and new ones as they go
   into operation to insure  that preliminary estimates were
   correct and that operating methods are sound.
            LAKE MICHIGAN'S THERMAL
            WATER QUALITY STANDARDS
   Of the four states bordering Lake Michigan, Illinois and
Indiana have temperature standards, approved by the Secre-
tary of the Interior, that require the maximum temperature
of Lake Michigan water not exceed 85°F after reasonable
allowance  for  mixing.  The  Wisconsin  standard,  also
approved by the Secretary, allows up to 89°F, after mixing,
at the shoreline and in harbor waters. Some, but not all, of
these standards also include various provisions limiting rates
of temperature increase and increases over natural tempera-
ture. The Michigan standard, which has not been approved
by the Secretary, establishes no numerical limits, but is a
general statement designed to abate or prevent injury of
any  kind, due to  temperature, to any type of water use or
value.
   The Federal Water Pollution Control Administration is m
the  process of formulating new water quality standards
pertaining to thermal additions  to Lake  Michigan. Within
the next few months the four Lake Michigan states and the
Federal  Water  Pollution Control Administration  plan to
consider  the adoption of uniform standards to control
thermal pollution in the lake.
-------
                                                                                                                    2066
  All  four states  grant approval  for  the  nuclear power
plants  with the  understanding that requirements  may  be
revised if experience proves such a need.
   THE REAL CHOICE: THERMAL POLLUTION OR
         A SHORTAGE OF ELECTRIC POWER?

   The ultimate decision to be made seems to be just how
much money and effort the public is  willing to invest in
cutting down heat pollution now in order to avoid future
problems.  It  must  be  recognized,  too,  that even if the
choice is made to invest to prevent heat pollution of the
water, the waste heat fron the power generation is released
into the air. Some scienlsts are concerned about the heat
balance  of the  earth aid the  effects  of  the increasing
releases of heat  and othir combustion by-products on the
atmosphere - ultimate}}  on the whole  ecology.  There is
clearly  a need  for  much more research to  determine the
amount of such releases fie atmosphere will absoib without
permanent change.  Alsqjiesearch is needed to increase the
efficiency of power genention to prevent pollution from its
by-products,  and  to  irtlize  such by-products,  including
heat.
                                                     REFERENCES
 Brandt, D.H., "Ecological Studies and Temperature Surveys at Con-
 sumers  Power Company  Electric Generating Stations." Talk pre-
 sented at Governor's Conference on Thermal Discharges, Traverse
 City, Michigan, July 18, 1968.

 Bukro,  Casey, "Pollution Toes Fear Atom Site," Chicago Tribune,
 July 6, 1969.

 Cairns,  John Jr,  "We're  in  Hot Water,"  Scientist and Citizen,
 October 1968.

 Clark,  John R., "Thermal Pollution and  Aquatic Life," Scientific
American, March 1969.

 demons, Neil L., "Pollution  Are  Nuclear Reactors  Safe?" Wall
 Street Journal, August 28, 1969

 Conservation Report, National Wildlife Federation, "Hickel Recom-
 mends Strict Control on Water Pollution,"  March 1969.

 Energy  Policy Staff, Office of Science and Technology, Considera-
 tions Affecting Steam Power Plant Site Selection, December 1968 •

 Federal Water Pollution Control Administration, Northwest Region,
 Pacific  Northwest  Laboratory, Industrial  Waste Guide on Thermal
 Pollution, September 1968.

 Gustafson, Philip F., "Nuclear Power and  Thermal Pollution," (pre-
 print) Bulletin of the Atomic Scientists, March 1970
 Hill, Gladwm, "U.S. Makiij Initial Move Against Thermal Pollu-
 tion," New York Times, Febuary 22, 1970.

 Hmes,  William, "New Way to Generate Electric Power," Chicago
 Sun Times, June 22, 1969.

 Joint  Committee on Atoma Energy,  "Environmental Effects of
 Producing Electric Power," Gbtober, November 1969.

 Radford, Edward  P.,  "Staement  of Concern,"  Environment,
 September 1969.

 "Thermal  Pollution: A  Thcat  to  Cayuga's  Waters0",  Science,
 Novembers, 1968.

U.S.  Department  of Interior Federal Water Pollution  Control
Administration, Conference 01 Lake Michigan, Proceedings, Volume
11, February 1969.  Statemeit  of F. W. Kittrell, chairman, Com-
mittee on Nuclear Power PlantWaste Disposal.


 U.S. Department of Interio:  Water Pollution Problems  of Lake
 Michigan and Tributaries, "Hie trie Power Plants," January  1968

Westmghouse Electric CorpoiUion, Infinite tnergy, 1967.
Wingert, Wayne, "Present aid Future Development for the State of
Michigan." Talk presented .is Governor's Conference  on  Thermal
Pollution, Traverse City, Michigan, July 1969
 This material may be reproduced in whole or in part provided credit is given to the League of Women
-------
                                                    206?
                       R. G, Hill
           MR. STEINj  Mr. Russell G. Hill, Executive
Secretary of the State Soil Conservation Committee, has
had to leave, and he has left his statement.
           Without objection, I would like to include it
in the record at this point as if read.
           STATEMENT OF RUSSELL G. HILL, EXECUTIVE
              SECRETARY, STATE SOIL CONSERVATION
                 COMMITTEE, LANSING, MICHIGAN
           MR. HILL:  The Michigan Department of Agriculture
has a concerned interest in pollution problems of the
Great Lakes.  Michigan, with the exception of about 1,500
acres in its southwestern corner, drains into the Great
Lakes.  Approximately 16 of our 37 million acres are used
for agricultural purposes.  The Department has several
programs directly related to the management of this land
and its surface water.  Runoff water due to its dissolving
and erosive powers carries a variety of substances which
may be classified as pollutants.  Likewise, mineral and
organic participates blown by wind are transported many
miles.  These particles and the material they carry may
also contribute to Great Lakes pollution.  It is known
that wind and water erosion, fertilizers, pesticides,
-------
                                                    206S
                       R. G. Hill



farm animal wastes and crop residues may  if improperly



used and managed  constitute a part of the pollution



problems.  The volume of several of these pollutants has



already been documented to your group by the U, S, Soil



Conservation Service and other agencies.



           Their report shows that major Michigan streams



annually contribute 1 million tons of sediment to the



Great Lakes,  It has also been strongly pointed out in



other reports that farmland is not the only source of these



pollutants.  The contribution of runoff and sedimentation



from subdivisions, home gardens, lawns, highways, stream-



banks, industrial developments, utilities, and shopping



centers is beginning to be officially recognized.



           The Michigan Department of Agriculture has



responsibility for several programs which have direct



relationship to reducing pollution in the Great Lakes,



           First let us look at insecticides.  All insecti-



cides in interstate commerce are registered by the U, S,



Department of Agriculture and applications for registrations



are routinely reviewed at the Federal level by the Public



Health Service, the Food and Drug Administration, the Fish



and Wildlife Service of the Department of the Interior as



well as the U, S. Department of Agriculture,



           Under Michigan law, the Michigan Department of
-------
                                                     2069
                       R. G« Hill



Agriculture may take further action to restrict registra-



tion of a pesticide upon recommendation of Michigan State



University Experiment Station.  This latter provision in



our law is a key to our regulatory action which we took



against DDT in 1969•  This action concerning DDT in Michi-



gan was not a ban but rather an extension of previous



restrictions on DDT registrations,  Michigan canceled regis-



trations for mosquito control in 196&.  Michigan was one of



the first States in the Nation to take this positive action



against the use of DDT.  Our action was based upon the fact



that scientists at Michigan State University, aware of the



long-range implications in the use of persistent pesticides,



have been working for years to phase these materials out



of our recommendations as suitable alternative materials



are developed,.



           Also in 1969 under the leadership of the State



Agriculture Department, an inter-agency pesticide review



committee was established.  Agencies participating in the



agreement with the Department of Agriculture are the



Departments of Natural Resources, Public Health, and the



Water Resources Commission.  More than 5»000 economic



poison registrations have been reviewed by the Department



of Agriculture laboratory since establishment of the



cooperative agreement.  Nearly 700 requests for review of
-------
                                                      2070





                       R, G. Hill



labels have been received from participating agencies.



The Michigan Department of Public Health was recently asked



to review all labels and more than 600 have since been



referred.  Of about 70 objections to registration, 3# have



been satisfactorily resolved and 32 are being studied.



It should be noted that Michigan farmers have replaced



most uses of persistent pesticides as agricultural research



has provided alternative insect and disease controls.



A recent survey of 5,100 farmers revealed that less than



one in a thousand reported any use of DDT last year.



Use of other persistent materials was very limited, mainly



to control certain corn and livestock pests.



           Mr. B. Dale Ball, Director of the Michigan



Department of Agriculture, stated that similar surveys of



agricultural use of pesticides were also conducted in the



other four Great Lakes States — Indiana, Illinois,



Wisconsin, and Minnesota — as part of the five-State



Governors Conference on Lake Michigan.



           A second program area within the Department



involves soil and water conservation.  The State Soil



Conservation Committee is a division of the Department



and has charge of the organization and supervision of



Michigan's Soil Conservation District.  The first district



was established in Michigan in 193&.  Since that period,
-------
                                                     2071





                       Ro G. Hill



every county but one has organized similar districts.



           One of the primary objectives of these organiza-



tions is the reduction of erosion by wind and water*  These



districts have been active in controlling erosion for over



30 years and have established an enviable record,  fhe #4



districts in Michigan's 82 counties have about 5#,000



landowners as cooperators.  In recent years, assistance



has been extended not only to farmers but also to a great



variety of non-farm land users,  A major development has



been the effort by soil conservation districts to have



local units of government adopt erosion control regulations



which would reduce sedimentation by many development



activities.  Several municipalities have already adopted



such regulations and it is expected to spread.



           There may also be a move for Statewide



legislation which would require land developers of all



kinds to install proper soil and water control measures



as recommended by their local soil conservation districts.



           Data submitted by the U, S, Soil Conservation



through its "Inventory of Soil and Water Conservation Needs"



show that our job is far from completed.  Their data points



out that large quantities of soil still reach the Great



Lakes through our major river basins and that about two-



thirds of our cropland must have soil and water conservation
-------
                                                     2072
                       R. G. Hill



treatment either initially or recurring.  Nearly one



million acres of cropland are subject to severe wind



erosion.  However, we have the tools to do the job and



the organization established.



           The State Soil Conservation Committee likewise



acts for the Governor's office in processing applications



for watershed assistance under Public Law 566,  To date,



74 communities have submitted applications for Federal



watershed assistance.  Forty-eight of these applications



have been approved by the State Committee; four have been



disapproved; and twenty-two are before the Committee for



consideration.  Six watersheds have been completed and



the U, S. Soil Conservation Service informs us that 10



additional projects are now in operation.



           In order to accelerate the watershed planning



on the approved applications, the Michigan Legislature in



1970 provided funds for the State Soil Conservation



Committee of the Michigan Department of Agriculture to



employ a supplemental watershed planning party.  This move



should help accelerate the rate at which local communities



are serviced for watershed assistance.



           Inasmuch as land treatment is a basic objective



of these watershed projects, the furtherance of this program



should materially assist in reducing sedimentation pollution
-------
                                                     2073





                       R. G. Hill



which would eventually reach the Great Lakes.  Here, too,



it should be pointed out that we still have a long way to



go.  Approximately 140 watersheds have been identified as



having potential need for Public Law 566 assistance.  Many



years of effort must be expended before this volume of



work can be accomplished.



           Related to the soil and water conservation



program is the use of commercial fertilizers which may



pollute water.  Reference is especially made to nitrogen



and phosphorus.  Educational programs now being conducted



by soil conservation districts and the Cooperative



Extension Service encourage soil testing as a guide for



the proper application of commercial fertilizer.  Research



carried out in this State and in other States show that



very little phosphorus reaches our water areas by under-



ground sources.  Excessive uses of nitrogen may provide



some basis of contamination.  Here too it is becoming more



evident that the loss of these plant food minerals is



probably due more to erosion than infiltration into under-



ground water.  Our efforts to control erosion, therefore,



should also help alleviate the loss of plant nutrients



from land and the subsequent contamination of water areas.



           Another related area is the farm animal solid



waste disposal problem involving large concentrations of
-------
                                                      2074






                       R. G, Hill



farm animals.  The severity of this problem has also



been documented for your use by other agencies.  Soil



Conservation Districts are closely working with the



Agricultural Stabilization and Conservation Service and



the Uo S, Soil Conservation Service, and the Cooperative



Extension in developing and encouraging methods of properly



handling farm manures.



           Nearly 100 requests from landowners with farm



animal waste problems have been submitted to ASCS for



cost-sharing and the SCS reports servicing about 50 of



these requests.



           Pollution from this source can be severe under



a variety of conditions, but through installation of proper



surface runoff control structures and solid waste disposal



units we are confident that this problem too can be brought



under control.  Pollution control regulatory authority in



the hands of the State Water Resources Commission will also



help bring about compliance of livestock waste disposal



so that pollution from these installations will be minimal.



           Still another area in which the Department has



a responsibility which relates to the Great Lakes pollution



problem is inter-county drains.  An administrative staff



member of the Department serves as chairman of all inter-



county drainage boards.  It is recognized that properly
-------
                                                    2075





                       R. G. Hill



constructed drains reduces excessive erosion and subsequent



sedimentation of water.  Educational and information efforts



are being extended to encourage the proper engineering of



drainage projects so that ditch banks may be properly



seeded and stabilized and spoil banks treated so that



erosion will not occur and life of the drainage structure



extended.



           These are some of the major areas in which the



Michigan Department of Agriculture are involved which



directly relate to the pollution problem of the Great



Lakeso  We do not say that all problems are adequately under



control or that pollution from these sources has been



entirely stopped.  We are saying that we are confident



that the sources of agricultural pollution have been and



are being reduced and that further reduction will con-



tinually occur.  New research in some areas such as farm



waste control, pesticides, commercial fertilizer management,



and erosion control on non-farm areas are needed so that the



proper control techniques may be practically applied.



Certain regulatory legislation may be necessary to force



compliance in some areas.



           Nearly 50,000 acres of agriculture land are



being transferred to non-agricultural use each year.



There is little evidence that this transfer is being
-------
                                                    2076






                       J. F. Wilson



accomplished with careful planning or in line with any



long-time land use policy.  The time is past due for the



State in consultation with its citizens to develop a



meaningful land use policy.  The Department of Agriculture



is giving leadership in obtaining action in developing



such a policy.  A widespread information and education



program is essential in order to provide people with an



understanding of their involvement in Great Lakes



pollution problems, the corrective steps that must be



taken, and assistance that is available to correct these



problems.  We pledge our continual effort toward these



accomplishments.



           MR. STEIN:  John F. Wilson.








           STATEMENT OF JOHN F. WILSON, DIRECTOR,



           WISCONSIN ECOLOGICAL SOCIETY, GREEN BAY,



                          WISCONSIN








           MR. WILSON:  My name is John F. Wilson, and



my address is Green Bay, Wisconsin.  I am a Director of



the Wisconsin Ecological Society, and this paper repre-



sents the views of the organization and its individual



members.



           I would like to comment, before I present the
-------
                                                      2077
                       J. F. Wilson



paper that I intend to present, on some of the views and



thoughts expressed in the press this week by various



scientists and engineers that are tantamount to creating



in Lake Michigan a large, experimental tank.  And I am



appalled, quite frankly, at these suggestions made by



ostensibly responsible people.



           I would like to also ask the conferees to



seriously consider Dr. Bardach's suggestion about making



the industrial users of our environment require — or



require them to set up an environmental insurance program,



I don't know exactly who might underwrite these activities,



but I really feel that this is something we should seriously



consider.



           I would like to present some material here that



was developed in 1969 on the Fox River and in lower Green



Bay by Professors R. P, Howmiller and A. M, Beeton.



           I am very quickly just going to summarize a



few of the highlights of this report and then I am going



to make some comments on it.



           This was a study made on lower Green Bay using



the identical parameters and the exact sampling stations



and at the same time of the year that studies were made



in 1952 by some other University of Wisconsin professors.



           Now, this is an unpublished manuscript; it will
-------
                       J. F. Wilson



be published.  Basically, what it says is that Green Bay



is a relatively shallow, fertile arm of Lake Michigan,



and it describes the bay and its physical condition.



           Pollution of Green Bay and concomitant concern



have increased in recent years.  The major tributary of



the Bay, the Fox River, contributes an average of 125



milliliters per 3 seconds of grossly polluted water; D,00



content of the river water approaches zero, and it goes



into a fairly — by this time — well known expose of the



conditions on the Fox River and in lower Green Bay,



           He discusses in this paper some of the findings



in 1952,  He concludes the paper by saying — well, I will



read two paragraphs:



          "Carr and Hiltunen  (1965) documented changes in the



benthos of western Lake Erie from 1930 to 1961,  Some of



the changes observed were similar to those occurring in



Green Bay,  Oligochaeta" — sludgeworms — "and Chirono-



midae (Tendipedidae)11 — bloodworms — "increased in



abundance while Hesagenia decreased to less than 1 percent



of its former abundance.  It appears that Hexagenia



completely disappeared from the area in the years 1961-




1967 ....



           "Other changes recorded for western Lake Erie



as a whole are unlike changes observed in Green Bay0
-------
                                                    2079

                       J. F, Wilson
Gastropoda and Sphaerlidae increased substantially from
1930 to 1961 ..«.  However, in 196l, these groups and
leeches and naiad clams were rare near the major sources
of pollution; the mouths of the Maumee and Raisin Rivers
and the western side of the Detroit River mouth.  It
appears that lower and middle Green Bay are ecologically
similar to highly polluted areas of western Lake Erie but
they are more degraded than open lake areas of Erie were
in 1961.
           "The future of the Green Bay bottom fauna is
not difficult to predict if pollution of the bay, via the
Fox River, continues.  We can then expect a large abiotic
area around the river mouth.  Also, midge larvae would be
expected to decrease in abundance at stations farther
north in the lower bay.  Other groups would, of course,
continue their demise,**
           And this is basically the conclusion.  There are
some other details of it, but I am submitting the entire
report to this conference together with the various charts
that clearly document the condition of the Bay not in
196? or 1965 but in 1969.
           (The documents above referred to follow in
their entirety,)
-------
                                                             2030
  SOME CHANGES IN THE BOTTOM FAUNA OF GREEN BAY,1
           LAKE MICHIGAN FROM 1952 TO 1909
              P. Howraliler and A. M. Beeton
      ifemntng head: Changes in Green Bay Benthos
        Contribution tfo.  39, Center for Great Lakes Studies,
University of Wisconsin-Milwaukee, Milwaukee, Wisconsin 53201
-------
                                                                  20&L
                         ABSTRACT

        Bottom samples were collected In lower and middle
Green Bay In May 1989 on the same date,  at the same 27 stations,
and using the same methods as a 1952 survey.
        In 1969 there were fewer Ollgochaeta and Chlronomldae
in the vicinity of the Fox River mouth.  Elsewhere In the tower and
middle bay ollgochaetes and midge larvae were more abundant than
In 1952 but most other benthlc Invertebrates were less abundant.
        The observed changes are Interpreted as Indicative of
greater pollution and Increased eutrophlcatlon during the Intervening
17 years.
-------
                     INTRODUCTION

        Green Bay la a relatively shallow and fertile arm of Lake
Michigan (Fig. 1).  The bay has long been Important for recreational
ueea, shipping and commercial fishing.  As early as the 1880,**,
undesirable changes In the bay were recognized.  Smiley (1882)
reported that sawdust pollution was an Important factor In the decline
of the whlteflsh population la the 1870's.
        Pollution In Green Bay, and concomitant concern, hare
Increased In recent years.  The major tributary  of the bay, the Fox
Hlver, contributes an average of 125 ms/sec of grossly polluted water*
The dissolved oxygen content of the river water approaches zero
mg/Uter In summer months (Schraufnagel, et al.,  1968). Even
"pollution tolerant" benthlc Invertebrates are rarely found In the
sediments of the lower reaches (Balch, et al., 19S6; Schraufnagel,
etal., 1968).
        Water from the Fox  Elver spreads out over the lower 15*20 km
of the lower bay  (Schraufnagel,  1906) and dominates the character
of this environment.  The middle bay, from the Green Bay harbor
entrance light north to Sturgeon Bay, Is affected  by Fox River water
mainly In the eastern half where river water may account for as
much as 80% of the northward current (Modlln and Beeton, 1970)*
In this region  the major Influence of the polluted  water  appears
during the months of Ice cover (WSCWP,  1939; Schraufnagel, et al.,
-------
                                                                  20&3
                                                                  9
1968, Howmlller and Beeton, 1070) when Urge areas suffer oxygen
deficiency.
        Various public agencies have conducted chemical and biological
surveys on the bay to assess the severity and extent of pollution
(WSCWP, 1930;  Surber and Cooley, 1952; Balch,et al., 1956;
Sehraufnagel, et al., 1988).  Bottom sampling, for analysis of benthlc
Invertebrate animals, was a part of each of these studies. Surber and
Cooley (1952) compared numbers of organisms at nine of their stations
In the lover bay In May 1952 with data from nine comparably located
stations sampled during the period November 1938 to February 1939.
The Increased number  of pollution tolerant midges and ollgochaetes
led them to conclude that there was an Increase In pollution during the
intervening thirteen years.
        A later report was less pessimistic.  None of the samples
taken In 1955 (January) contained populations of sludge worms
(Ollgochaeta) In  the numbers Indicated In either the 1938*39 or the
1952 studies (Balch, et al.,  1956).  Discounting the possibility that
January samples were  not taken at a population peak, the report
concludes that "most probably, there Is a major reduction in the
numbers of these forms (Ollgochaeta)." It Is not clear why the
possibility of a winter minimum of population density was treated BO
lightly. Great reductions In numbers  of ollgochaetes may occur during
winter months (Howmlller and Beeton, 1970).
-------
                                                               206k-




                                                                4



       Howmiller and Beeton (1967) compared numbers of oligochaetes,



midge larvae, and burrowing mayflies taken at stations in the lower bay



in 1938 and 1966. In 1966,  fewer oligochaetes and midges were found in



the immediate vicinity of the river mouth but they were more abundant



in the region 5-15 km from the river mouth (Beeton 1969).  Nymphs of



the burrowing mayfly, Hexagenia, taken at  two of eight stations in 1938,



were not found in 1966.  Changes were interpreted as indicative of



increased pollution near the Fox River mouth and increased eutrophication



of the bay.



       Critical comparison of data from these past studies may be open



to question because investigators seldom visited the same stations sam-



pled in preceeding studies.   They also generally failed to sample at the



same season of the year.  Thus year to year changes in animal numbers



may be confused with normal seasonal variation in abundance.  Further-



more, these  investigators did not always use the  same apparatus and



methodology  as their predecessors.



       The present report discusses a study of changes in the benthic



fauna of Green Bay which has attempted to eliminate these three sources



of inaccuracy.





                           METHODS



       On 26 May 1969 we sampled the benthos of lower and middle



Green Bay at the stations shown in  Figure  1.  Samples were taken with



a 23x23 cm (9x9 in) Ekman  grab and screened immediately with a U.S.



 Std.  No. 30 sieve.  The residue on the sieve was preserved in 10%
-------
                                                                  2Q35
formalin.  Organisms were hand picked from the residue using low



power magnification.



       APonar grab sample was also taken at each station.  These



samples were processed in the same manner as the Ekman grab samples.



The Ponar grab samples were taken primarily for purposes not concerned



with the subject of this paper, and data from Ponar grab samples are not



compared directly with 1952 data but are simply mentioned in Table 2



to indicate that certain animal taxa did occur at stations where they were



not taken in Ekman grabs.



       These same  stations were sampled on 26 May and 27  May 1952,



exactly seventeen years earlier, by Surber and Cooley (1952).  They



used, with one exception, a 15x15  cm (6x6 in)  Ekman grab and processed



samples with a No. 30 screen.  The single exception is that a Petersen grab



was used to take their sample at station 11 which was on a hard sand bottom.





                     RESULTS AND DISCUSSION



       Aquatic oligochaete worms are commonly known as "sludge



worms" and large numbers of these animals frequently have been cited



as evidence of pollution.  In general Oligochaeta have increased in abun-



dance from 1952 to 1969 (Tables 1,2; Fig. 2).



       The only notable exception  to this generalization is in the imme-



diate vicinity of the  river mouth (Stations 1-4). This cannot be inter-



preted as a result of improved environmental conditions for there is a



similar dearth of other benthlc life in this area.
-------
                                                                   *
        Long periods of anoxia during summer months (Schraofntg«lt
et al., 1968) probably make It Impossible for healthy populations of any
animals to exist In the vicinity of the river mouth.
        Surber (1957),  after studying reports from a number of lakes,
concluded that,M. .  . an abundance of tubtflclds In excess of 100 per
square foot apparently truly represented polluted habitats." Wright
(1955) and Carr and Hlltunen (1965) used the following numbers of
ollgochaetes per square meter to designate pollution areas In western
Lake Erie; light pollution,  100*999; moderate pollution, 1000*5000|
and heavy pollution, more than 5000.   Lower Green Bay Is, by these
standards, heavily polluted (Table  2, Fig. 9).
        The middle bay (stations 11*27), according to Wright*s
standards, was only lightly polluted1* In 1952 (Table 1) but was ft*
least "moderately polluted" In 1989.
        Goodnight  and Whltley(1980), working on a mldwestern
stream, proposed .hat the relative abundance of ollgochmete worms
In the benthos should be used as  an Index of pollution. They con*
sldered the stream In "good condition" If the bottom fauna were
less than 60% OUgocfcaeta, "doubtful" If 60*80% and highly polluted
If more than 80% ollgoehaetes.  In 1952 Ollgoehaeta accounted for
an average of 66% of the beathlc  organisms In samples from statlo«a
2*10 In the lower bay.  In 1969 the average percentage of ollgochaeto*
In these samples was 85.  Thus It appears that this area has
-------
                                                                  t
deteriorated from Borne doubtful condition to a highly polluted state
In the Intervening seventeen years (Fig. 3).
         An Increased relative abundance of Ollgochaeta to more
pronounced In the middle bay.  At stations 11*27, Oltgochaeta have
Increased from an average of 23% to 64% of the total benthlc fauna la
the years 1952*1869, Thus, by the standards of Goodnight and Whltiey,
It has gone from a "good condition" to "doubtful" since 1952 (Fig.  8)*
         Surber and Cooley (1952) believed that, at the time of their
collections, the majority of the Qllgochaete fauna belonged to the tobl-
fIcld genus Llmnodrllus.  They stated that a few Tublfex also occurred
In the samples.  They recorded the naldld genera Dero and Stylarla at,
respectively, stations 2$ and 26,  and stations 12 and 26.  The 
-------
                                                                  0
In the lower bay, and Helobdella (Glos siphon! a) stagnalls in the middle
bay. The 1889 collections included Erpobdella puactata, Helobdella
atagnalts. and a fish leech (Plsclcolldae), lUlnobdella, which was
represented by the five specimens In the Ponar grab sample at £$8Hoa 5.
The fish leeches appeared very emaciated. The Glosslphonlldfte*
Oloflslphonia and Helobdella,, commonly are predacious upon snails,
ollgochaetes, and other email Invertebrates (Pennak,  1953).
punctata. now the most common leech In the bay,  apparently feeds
heavily upon ollgochaetes.  Two of fifteen specimens examined had
ollgoehaete worms in their mouths at the time of capture.  The decline
of leeches in Green Bay may have contributed to the greater success of
the Ollgochaeta.
         Snails occurred at ten stations of the 1952 survey but at oaly
two stations in 1969 (Fig. 5).  Collections in 1952 included Campoloma,
Hellsoroa, Valvata trlcarlnata, and Viviparus.  Empty shells of these
taxa now occur at many stations In the  lower and middle bay but
the only one of the four found living in our recent Green Bay colloc-
                •••s
tlons is Viviparus.  Vlylparus d(d not,  however, occur In  1909
sampling at atatlons^elng compared in this report. The snails found
at stations 13  and 15 belong to the genus Amnicola.
         Fingernail clams (Pelecypoda, Sphaerltdae), like snails, ware
much lest abundant la 1969 than In 1952 (Pig* 6).  They decreased
-------
                                                                  0
/roan an average of 16.5% of the total benthlc fauna to 3.3%.  The
species of Sphaerildae inhabiting Green Bay have not yet been deter*
mined.  As a group,  the fingernail clams are known to be less pollution
tolerant than most Ollgochaeta and many species of Chlronomldae
(Keup, Ingram andMackenthun, 1966).
        While no naiad clams (Unlonldae) were reported In 1052,
Lampallls elltquoldea was found at station 15 In 1969. This species
baa recently been found at several other stations on the sandy sub-
strates Just north of  Long Tall Point but not elsewhere In the lower
or middle bay.  The  presence of naiads generally Indicates clean
water (Carr and RUtunen, 1965).  In Green Bay It Is probably also
closely related to the nature of the substrate.  Soft muds,  common
over much of the bay, are not a suitable substrate for these large
clams.
        While the distribution of  amphlpods (Fig. 7) was very
similar In 1952 and 1969, this group seems to have been much more
abundant and to have comprised a larger proportion of the population
In the 1952 collections.  Surber and Cooley (1952) reported only
                                                  Hyalella azteca
Oammarus fasclatus from their collections. In 1969,     '    ~
occurred at stations  7, 15, 25,  and 27,' Gammarus fasclatus and
Pontoporeia afflnle at stations 11, 24 and 25; and Crangonyx at
station 27.
-------
                                                                  2090

                                                                10
        The Isopod, Asellus, occurred at too few stations to allow
generalizations concerning possible changes la abundance or dlotrl-
bution.  Widespread sampling; in the years 1966-1969 Indicates that
Asellus occurs farther south In the bay than the data In Table 3 suggest.
Cooley and Surber (1952) Identified the Isopod present  at that time as
A. communls.  Balch and co-workers (1956) recorded A* m lilt aria.
The Isopod present In 1969 was_A.  milltaris.
        The burrowing mayfly (Hexagenla)  was once quite abundant In
Green Bay.  In years past, adult Hexagenla piled up by the bushel under
electric lights In the city of Green Bay on many summer evenings
(WSCWP, 1939).  The report of 1939 (W6CWP) registered surprise at
the small numbers recovered but recorded Hexagenla nymphs In 16 of
51 samples.  At that time It occurred as far south as the vicinity of
Long  Tall Point.  Surber and Cooley (1952)  found Hexagenla only  at
station 16.  In 1955 one burrowing mayfly "wa*» ^  >d" at a station
near the mouth of the Oconto River (Baleh,  et al, 1956).  Hexagenla
was not recorded In the data of the report.  Hexagenla did not occur to
samples taken In 1969 or at any of 74 other  widespread stations sampled
by the Federal Water'Pollution Control Administration In 1967 and the
Center for Great Lakes Studies, University of Wisconsin-Milwaukee
In the years 1966*1969 (Howmlller and Beeton, 1970).  It has apparently
disappeared from Green Bay as It has from western Lake Erie (Carr
and Rlltunen, 1965; Veal and Osmond, 1968).
-------
                                                                  2091
                                                                 II
        The aquatic larvae of midges (Chlronomldae) were the second
most abundant and widespread members of the bcothlc fauna In both
1952 and 1969 (Fig. 8).  The midges decreased markedly In the vicinity
of the Fox River mouth - doubtless because of Increased pollution-
Increased numbers of midges were found at most stations north of Long
Tall Point.  However, this Increase did not equal that of the Oltgochaeta
with the result that midges decreased In relative Importance from an
average of 48 to 37% of benthlc Invertebrates In the middle bay and
from 37 to 26% for the bay as a whole. The Chlronomldae Includes many
species adapted to a wide  range of environmental conditions.  However,
as a group,  the midges display pollution tolerance  second only to the
Ollgochaeta.  Like many Ollgochaeta, the pollution tolerant midges
have an abundant supply of hemoglobin which makes them very efficient
at obtaining oxygen at the  low concentrations associated with organic
pollution, and In the profundal region of stratified  eutrophlc lakes.
        The only animals found at station 1 In 1969, Peychoda larvae.
are air breathers which are abundant In mud flats, drains,  sewage
fitters, and other habitats subject to total deoxygenatlon (Hynes I960).
Erlstalls larvae, found at station 1 In 1952,  are ecologically similar.
Both these organisms have been reported from other rivers so grossly
polluted that no normal river animals survive (Hynes, 1960).  However,
since they require contact with the surface to breathe, these cannot
hare been viable populations at depths of 18-21 ft at station 1.  These
-------
                                                                 2092
                                                                12
animals must have been carried to station 1 by the current from shallow*
water anaerobic habitats upstream.
        The common and abundant benthlc ne mat ode In Green Bay la
1969 measured about 4.5-5 mm long and 0.2 mm In diameter* An
animal this size certainly cannot be collected quantitatively when a
No. 30 screen (0.6 mm openings)  Is used and, therefore, nematodea
were not counted In our samples.  In view of the abundance and wide*
spread occur ranee of nematodes In 1989 (Table 2) It Is difficult to
believe that they occurred at only  one station In 1952 (Table 1). Perhaps
samples were  screened more vigorously and almost all nematodea
were lost.  Another possibility Is  that they were so abundant In 1960
that sufficient  numbers were retained as to be noticed.

                          CONCLUSIONS
        There were  marked changes In the bottom fauna of lower and
middle Green Bay between 1952 and 1969.  Two animal groups which
contain many eutrophlc and pollution tolerant  species, the Ollgochaeta
and the Chlronomldae,  have Increased In abundance over most of the
bay. Most other benthlc Invertebrates were less abundant la 1969
than In B 52.  These  changes suggest that the deterioration of the bay
environment, noted by previous Investigators, Is continuing.
-------
                                                                  2093
                                                               IS
        Carr and HUtunen (1065) documented changes In the benthos of
western Lake Erie from 1930 to 1961. Some of the changes observed
were similar to those occurring in Green Bay. OHgochaeta and Chlrono-
tnldae (Tendlpedldae) Increased In abundance while itexagenla decreased
to less than 1" of Us former abundance.  It appears that Hexagenia
completely disappeared fron, toe area In the years 1961-1967 (Veil and
Osmond, 1968).
        Other changes recorded for western Lake Erie as a whole art
unlike changes observed In Green Bay.  Gastropoda and Sphaerlldae
Increased substantially from 1930 tp 1961 (Carr and Hlltunen, 1965),
However, In 1961 these groups and leeches and naiad clams were rare
near the major sources of pollution; the mouths of  the Maumee and
Raisin Rivers and the western side of the Detroit River mouth,  It
appears that lower and middle Green Bay arc ecologically similar to
highly polluted areas of western Lake Erie but they are more degraded
than open lake areas of Erie were In 1961.
        The future of the Green Bay bottom fauna Is not difficult to
predict If pollution of the bay, via the Fox  River, continues.  We eaa
then expect a larger abiotic area around  the river mouth.  Also,
midge larvae would be expected to decrease In abundance at stations
farther north in the lower bay.  Other groups would, of course,
continue their demise.  The OHgochaeta, the only group which Increased
In absolute and relative abundance between 1952 and 1969, would assume
oven greater Importance In the benthlc community.
-------
                                                                 2094
                                                               14
        With the disappearance of other major groups further changes
IB the bay environment must be assessed through changes In numbers of
the Ollgochaeta and Chlronomldae and through changes In species eompo
sltlon of these groups.
        A report on the distribution of ollgochaete species in Green
Bay Is In preparation (Howmlller and Beeton,  1970). A study on the
distribution of species of Chlronomldae, a taxonomlcaUy difficult
group, Is planned for the near future.

                      ACKNOWLEDGEMENTS
        This research was supported In part by the University of
Wisconsin Sea Grant Program.
        It Is a pleasure to acknowledge the fine  service of the
personnel attached to the H/V "Mysis" and the willing help of
J. E. Gannon which made the fleldwork efficient and pleasant.
        Mr. Ratko lilstic drew the figures.
-------
                                                                2095
                     BIBLIOGRAPHY

Balch, a. F.t K. M. Mackenthun, W. M. Van Horn and T.  F. Wls-
        nlewskl. 1956.  Biological studies of the Fox Elver and
        Green Bay.  Bull. WP 102, Wisconsin Comm.  on Witter
        Pollution, 74 p., mlmeo.
Beet on, A. M.  1999.  Changes In the environment and biota of the
        Great Lakes, p.  150-187.  In_:  Eutrophlcatlon; causes,
        consequences,  correctives, proceedings of a symposium.
        National Academy of Sciences, Washington, D. C.
Brlnkhurst, H. O.  1967. Sampling the benthos.  Univ. Toronto,
        Great Lakes Institute, PR 32, 6 p. mlmeo.
Carr, J. F. andJ. K. HUtunen.  1965.  Changes In the bottom fatma
        of western Lake Erie from 1939-1961.  Llmnol. Oceanogr.,
        10: 551-569.
Flannagan, J.F., A. L. Hamilton, P. G.  Sly and W. F. Warwick.
        1969. An evaluation of twelve commonly used bentholoflcal
        sampling devices.  Unpublished manuscript, 7 p., mlmeo.
Goodnight, C. J. and L. 8. Whltley.  1960.  Ollgoehaetes as
        indicators of pollution.  Proc. 15th  Ann. Waste Conf.,
        Purdue, p. 139-142.
                             15
-------
                                                                 2096

                                                               16
Howmlller, rt. P. and A. M. Beeton.  1967.  Bottom fauna Investiga-
        tion In lower Green Bay.  Paper presented to Midwest
        Benthologlcal Soc., Carbondale, 111., unpublished manuscript,
        5 p. mlmeo.
Howmlller, R. P. and A. M. Beeton.  1970.  The ollgochaete Iauaa of
        Green Bay, Lake Michigan,  le&e presented at the 13th
        Conference on Great Lakes Research,  1 nternatlonal Association
        for Great Lakes Research, Buffalo, April 1970.
Hynes, H.  B. N. i960.  The biology of polluted waters.  Liverpool
        University Press.
Keup, L. E., W. M. Ingram and K. M. Mackenthun.  1966. The role
        of bottom-dwelling macrofauna In water pollution Investiga-
        tions.  Public Health Service Pub. No. 999-WP-38, 23 pp.
Modlln, a. and A. M. Beeton.   1970.  Current studies In Green Bay.
        Unpublished report.
Pennak, H. W.  1953.  Freshwater invertebrates of the United States.
        Ronald Press, New York.
Schraufnagel, F. H.  1966. Green Bay stream flows and currents,
        pp. 178-182. 'In; Lake Michigan pollution, governor's
        conference proceedings.
Schraufnagel, F. H.,  L. A. Montle, L. A, Leuschow, J.  Llssack,
        G. Karl and J. ft. McKersle.  1968.  Report on an Investigation
        of the pollution In the lower Fox River and Green Bay made daring
        1966 and 1967. Wls.Dept. Nat. Resources, Int. Kept., 47 p. mlmeo.
-------
                                                                 2097
                                                               if
Sly,  P.G.  1969.  Bottom sediment sampling.  Proc.  12th Conf. Great
        Lakes Res., Int. Assoc.  Great Lakes Res.: 855*870.
Smiley, C. W. 1882.  Changes in the fisheries of the Great Lakes
        during the deeade 1870*1880.  Trans. Amer. Fish. Cult.
        Assoc.,  11: 28-37.
Surber, E. W. and H. L. Cooley.  1952.  Bottom fauna studies of Green
        Bay,  Wisconsin, In relation to pollution.  U.S. Public Health
        Service, Comm. Water Pollution, 7 p. mlmeo.
Surber, E. w. 1957.  Biological criteria for the determination of lake
        pollution, pp. 164*174.  In:  Trans. 1956 seminar, H. A. Taft
        San.Engr. Cntr., U.S. Publ. Health Senr., Cincinnati, Ohio,
        W57-36.
Veal, D. M. and D. S. Osmond. 1968. Bottom fauna of the western
        basin and near-shore Canadian waters of Lake Erie.  Proc.
        llth Conf. Great Lakes Has.,  Int.  Assoc. Great Lakes R«s.i
        151*160.
Wisconsin State Committee on Water Pollution and State Board of
        Health In collaboration with the Green Bay Metropolitan
        Sewage Commission.  1939. Investigations of the pollution of
        the Fox and East Rivers and of Green Bay In the vicinity
        of the city of Green Bay.  242 p., mlmeo.
Wright, 6.  1955. Llmaologlcal survey of western Lake Erie.  U.S.
        Fish WUdl.Serv.,Spec. Scl. aept. •-Fisheries No. 139,
        341 p.
-------
                                                                       2098
Table 1.  Abundance of benthlc Invertebrates, as Individuals per square meter,
la samples taken at stations shown In Fig. 1 on 26 and 27 May 1052.
g
i
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
80
Oconto4(2i)
Oconto-202)
Ocaato-3g3)
Ocatto-4(24)
Ocoato-5(35)
Oeooto-6
-------
                                                                     2099

Table 2, Abundance of benthlc in vertebrates, as Individuals per square meter,

la samples taken at stations shown in Fig. 1 on 26 May 1960.
1
1
a
3
4
5
6
7
8
9
10
11
12
IS
14
15
16
17
18
19
20
ai
23
23
24
25
26
27

Nematoda 8
0
+
0
•f
+
•f
+
+
•»•
•#•
+
+
•f
+
+
•*>
+
+
+
+
+
•*•
+
+
+
•*•
+

Oligochaeta
0
22657
8604
7227
29292
16921
11854
4264
2008
1032
1663
822
688
918
2792
1281
1109
229
4531
2658
5354
1740
899
9770
10325
23441
10095

Leeches ||
0
0
0**
0
0
0
76
0**
19
19
0
0
0
0
0
0
0**
0
0
0
0
0
0
19
0
0
0

oo
*•.
13
eg
0
0
0
0
0
0
0
0
0
0
0**
0
19
0
19
0
0
0
0
0
0
0
0
0
"0
0
0
1
CO
I
*•*
o
0
0
0
0
0
0
38
57
631
19
172
994
268
19
1166
0
o**
0
57
0
0
0
0
0
10
0
0

AxBpMpods
0
0
0
0
0
0
0**
0
0
0
o**
0
0
0
19
0
0
0
0
0
0
0
0
57
38
0
19

(0
>— i
0
0
0
0
0
0
0
0
0
0
o**
0
0
0
0
0
0
0
0
0
0
0
0
76
38
0
0

i Other
0 gQPsychoda
38
688
440
2237
3155
1778
860
1759
76
402
1836
1644
3097
554 19 LampsUU
1128
918
707
2314
2065
803
1530
344
1300
631
1166
2275

*Nematoda were very numerous In many camples but certainly not sampled
quantitatively, hence not counted.
**Not taken in Efcman grab sample but animals la this category were recorded
from Ponar grab sample taken at the same time.
-------
                                                                   2100
                   FIGURE LEGENDS
Figure 1.  Lower and middle Green Bay, Lake Michigan, showing
        bottom sampling stations of 28 and 28 May 1952 and 23 M
        1039.
Figure 2.  Distribution and abundance of OUgochaeta In the sediments
                                                       -r
        of lower and middle Green Bay en 26 and 28 May 1932 (left)
                                                      it
        and 26 May 1889 (right).
Figure 3.  Relative abundance of OUgochaeta, as percentage of total
        bottom fauna,  In May 1952 and 1969.
Figure 4.  Distribution and abundance of leeches In lower and middle
        Green Bay In May 1952 and 1969,
Figure 5.  Distribution and abundance of snails In May 1952 and 1909.
Figure 6.  Distribution and abundance of fingernail clams In May
        1952 and 1989.
Figure 7.  Distribution and abundance of amphlpods in May 1952 and
        1969.
Figure 8.  Distribution and abundance of Chlronomldae In May
        and 1969.
-------
2101
-------
-------
2103
-------
2104
-------

-------
-------
210?
-------
-------
                                                                           2109
                              Curriculum Vitae
                         RICHARD P. HOWMILLER


Born:  9 January 1939, Milwaukee, Wisconsin

Education
  University of Wisconsin-Madison, B.S., Biological Aspects of Conservation,  1963
  University of Wisconsin-Madison, M.S., Zoology, 1966
  University of Wisconsin-Milwaukee, Zoology (limnology), PhD expected June  1971

Employment

Milwaukee Public Museum, Student Aide in Botany, part-time,  1961
Wisconsin Conservation Department, Conservation Aide II, summer 1962
SabishJr.  High School, Fond du Lac, Wisconsin, Intern Teacher, spring semester,  1965
Wisconsin State University, Stevens Point, Wisconsin, Faculty Assistant, 1965-66
National  Audubon Society,  Greenwich, Conn., Staff Naturalist,  Summer  1966
University of Wisconsin-Milwaukee,  Teaching Assistant,  1968-69

Honors
B.S. conferred with senior honors,  1963
Delta Chi Sigma, honorary science and mathematics fraternity,  1967
Phi Kappa Phi, honor society, 1969

Memberships in Scientific Societies

American Society of Limnology and Oceanography
International Association for Great Lakes  Research
Midwest  Benthological Society
Societas  Internationalis Limnologiae
Wisconsin Academy of Sciences, Arts and Letters

Papers presented before scientific societies
Fitzgerald, G.P. and R. P.  Howmiller.  1966.   Use of laboratory evaluations of
   aquatic herbicides  and algicides.  Weed Society of America.

Howmiller,  R.  P.  and G.  P.  Fitzgerald.  1966.  The use of Lemna minor L. for
   aquatic plant bio-assays.   Midwest Benthological Society.

Howmiller,  R.  P.   1966.  Duckweeds and  detergents.  Wisconsin Academy of
   Science,  Arts & Letters.

        and A. M.  Beeton.  1967. Bottom fauna investigations in lower Green Bay.
   Midwest Benthological Society.

Howmiller,  R.  P.   1969.  A cruise to the Galapagos.  Society of Sigma Xi,
   Wisconsin State University-Oshkosh.
-------
                                                                              2110
Howmiller, page 2.

Howmiller, R. P.  1969.  Limnological studies in the Galapagos Archipelago.
   Midwest Benthological Society.

Howmiller, P. P.  and A. M. Beeton.  1970.  The oligochaete fauna of Green Bay,
   Lake Michigan.  International Association for Great Lakes Research.

Howmiller, R. P.  1970.  Biological assessment of pollution and eutrophication in
   Green Bay. Wisconsin Academy of Science, Arts & Letters


Publications

Howmiller, R. P.  and A.  Weiner.  1968.  A limnological study of a mangrove lagoon
   in the Galapagos.  Ecology, 49_:  1184-1186.

Howmiller, R. P.  1969.  Studies on some inland waters of the Galapagos.  Ecology,
   50:  73-80.

Howmiller, R. P.  andW.  E. Sloey.  1969.  A horizontal water sampler for inves-
   tigation of stratified waters.  Limnol.  Oceanogr. , 14:  291-292.

Howmiller, R. P.  and K.  Dahnke.  1969.  Chemical analysis of salt from Tagus Crater
   Lake, Isabela,  Galapagos.  Limnol.Oceanogr., 14_:  602-604.

Howmiller, R. P.  and A.  M. Beeton.  1970.  The oligochaete fauna of Green Bay,
   Lake Michigan.  Submitted for publication.

Howmiller, R. P.  and A.  M. Beeton.  1970.  Some changes  in the bottom fauna of
   Green Bay, Lake Michigan, from 1952 to 1969.  Submitted for publication.
-------
                                                                           2111
                                 A. M. Beet on
                               Curriculum VLtae

Present Address: 340 Park Circle, Cedarburg, Wisconsin
Born:  August 15, 1927, Denver, Colorado
Married

Education:

 Jackson  High School, Jackson, Mich.,  graduate 1946
 Jackson  Jr. College, Jackson, Mich.,  1946- Feb.  1949
 University of Michigan, Ann Arbor,  Mich.,  Sept. 1949-Feb. 1958.
      B.S. 1952; M.S.  1954, Ph.D. 1958.

Experience
 Academic Appointments:
      University of Wisconsin-Milwaukee,  professor of zoology, Feb. 1966-present.
      University of Michigan, Research  associate in zoology, Sept. 1964-Feb. 1956;
        lecturer in civil engineering Sept.  1961-Feb.  1966.
      Wayne State University, lecturer (graduate limnology course) June 1957-
         Sept.  1961; instructor, Sept. 1956 -June 1957.
      University of Michigan, teaching fellow, Feb. 1956 -June 1956; Sept.  1954-
        June 1955; Sept.  1953-June 1954; Sept. 1952-June 1953.

 Government Service:
      U.S. Fish and Wildlife Service, Ann Arbor, Michigan (GS-3) June 1955 -
        December 1955; (GS-5) June  1956-Sept.  1956; (Fishery Biologist Res.)
        June 1957-Feb.  196G, Chief Environmental Research Program.
      Travel to India, Israel and Pakistan,  1063 and 1964, in connection with the
        Bureau's Foreign Currency (P.L.  480) program  to review fishery research
        being sponsored through this program.
      Institute for Fisheries Research. Michigan Conservation Department, June   • ;i
        1962-£ept. 1962; June 1953-Sept.  1953; June 1954-Sept.  1954.

 Consulting Appointments
      1967-69;  U.S. Army Corps  of Engineers,  Buffalo District,  New York.
        Member, Board of Consultants, on effect of Corps' dredging activities
        on pollution in the Great Lakes.
      1968-present:  Metropolitan Sanitary  District of Greater Chicago
      1968: University of Illinois.

  Academic Activities:
      Associate Director (Biology), Center for Great Lakes Studies, University
         of Wisconsin-Milwaukee, 19G6-present.
      Member, Executive Committee, Division of Biological Sciences,  University
         of \7isconsin (all-university committee) 1966-67, 1967-68.
         Member, all-university Council for Marine Studies, University of
         V/isconsin, 1967-68,  1968-69.
-------
                                                                           2112
A. M. Beeton, page 2

Honors,  Grants & Awards
University of Michigan, Lit. College scholarship,  1950-51
American Ornithology Union, student membership award, 1954
Herbert E. Boynton, graduate school scholarship, 1956.
Phi Kappa Phi
James, \V. Moffett Publication Award from U.S.  Bur.  Commercial Fisheries
    for best scientific paper publised (1968) in 1967.

U.S.  Army Corps of Engineers, Buffalo District,  Contract 1968-69 ($20,005)
       to study the effects of dredging and disposal on  the Great Lakes.
U.S.  Dept. Interior, Bureau of Commercial  Fisheries, Grant($3,700,  1968;
($7,563, 1969) to study the population dynamics of juvenile alewife and core-
       gonids of Green Bay, Lake Michigan.
National Science Foundation, Wisconsin Sea Grant Program, 1968-69, $11,400
       to study various aspects of the eutrophication of Green Bay.

Research Interests

       My major research interests have been in the behavioral physiology of
Crustacea and the eutrophication of the Great Lakes, although I have made
contributions to several aspects of the limnology of the Great Lakes (see attached
list of publications).

       Studies on photoreception in the freshwater mysid, Mysis relicta, employ-
ing behavioral methods, demonstrated the nature of spectral sensitivity, dark-
adaptation, and phototropic response in this organism  and established general
methods for similar studies of this group of organisms in the marine  as well as
the freshwater environments.   These studies have been duplicated by  other
investigators  on marine mysids.  The laboratory investigations of photoreception
and photo response of M.  relicta provided information  essential to the proper
interpretation of field data on the vertical migration of M_.  relicta in Lakes Huron
and Michigan.  This latter study showed that light "triggers" and controls their
migrations, while thermal conditions interact with and modify the influence of
light. The field data showed that as the length of day decreased following the
summer solstice, the mysids ascended progressively  earlier each evening and
descended later each morning.  Moonlight and fog influenced the time as well as
the amplitude of the vertical migrations.  The mysids  frequently  migrated through
the thermocline when first ascending,  but later at night the majority occurred in
or immediately below the thermocline.
-------
                                                                           2113
        Prior to 1959 the general opinion, was held that although the Great Lakes
 must be aging, i.e.,  undergoing eutrophicaticn, it v/as not recognized that eutro-
 phication could be demonstrated on bodies of v/ater as large as the Great Lakes.
 My study of environmental changes in Lake Erie, which was first presented at
 the meeting of the Lake Erie Fish Management Committee  in May 19GO, and sub-
 sequently published in the Transactions of the American Fisheries Society in
 1961,  presented evidence of accelerated eutrophication in this Lake. This work
 directed attention to an important aspect of Great Lakes limnology that had been
 ignored previously.   The significance of this contribution is reflected in the
 importance of studies of eutrophication in current research programs of the
 U.S. Bureau of Commercial Fisheries,  U.S.  Public Health Services, several
 universities, and other organizations.

        The results of my recent study demonstrate that several changes commonly
 associated with eutrophication in small lakes have occurred in the Great Lakes.
 These changes apparently reflect accelerated  eutrojiiication in the Great Lakes,
d ue to man's activity. Chemical data compiled from a number of sources, dating
 as early as 1854, indicate a progressive increase in the concentrations  of
 various major ions and total dissolved solids in all of the Lakes except Superior.
 The plankton has changed somewhat in Lake Michigan and the plankton,  benthos,
 and fish populations of Lake Erie are greatly different today than  those of the
 past.  An extensive area of hypolimnetic water of Lake Erie has developed low
 dissolved-oxygen concentrations in late summer v/ithin recent years.


 Professional Membership

 Phi Sigma , Beta Chapter, secretary 1954-55
 Sigma  Xi
 American Fisheries Society
 American Institute of Fishery Research Biologists
 American Society of Zoologists
 Societas Internationalis Limnologiae
 American Society of Limnology and Oceanography; Treasurer,  1962-present,
        member,  Board of Directors
 International Association for Great Lakes Research, Board of Director,
        1967 - present; Program Chairman, llth Conference on Great Lakes
        Research, May I960, Attendance - 550+.
 Midwest Benthological Society
-------
                                                     2114





                       J, F. Wilson



           MR. WILSON:  Now, I would like to make my



comments on this report.



           From the foregoing data, it is apparent that



the condition of the bay is worsening and at a rapid



rate*  Of primary concern is the fact that during this



time, the rivers emptying into the bay and the sources



of pollution on them have been under the scrutiny of the



responsible Wisconsin pollution control agency.



           Using figures compiled by the Wisconsin Depart-



ment of Natural Resources, we can make the following



comparisons on BOD and suspended solids loading of the



Fox River in a 20-year period ending in 196S.  You get



the picture here?  In other words, I am going to be dis-



cussing loading factors that have been repoted on BOD



to the Wisconsin Department of Natural Resources as



against the study that I have submitted in 1969 as to



the condition of the bay.  All right?



           In 194#, the municipal load was 23,9#0 pounds



per day of BOD»  The mill loads — paper mills altogether



in the Fox River, 2##,020 pounds per day, giving a grand



total of 312,000 pounds of BOD per day into the Fox River.



           The suspended solids load in 194# was 10,520



pounds per day.  The mill load was 101,940 pounds per day,



and the total was 112,460 pounds per day of suspended
-------
                                                     2115
                       J. F. Wilson



solids in the Fox River,



           Now, I will read the 1963 figures — this is



the end of the 20-year period.  Municipal loading, 26,714



pounds per day BOD.  The mill loading has dropped to



276,740 pounds per day — these are all admitted loadings.



It is very important to understand this:  that this is



what the mills admit to dumping.  Total, 303,454 pounds



per day.



           In 1963, suspended solids loadings — municipal



suspended solids loadings were not reported.  Mill loading



went from 101^940 pounds in 194# to 243,500 pounds per



day of suspended solids.  I can't give you a total because



the municipal suspended solids load was not reported.



           The numbers applying to the Menominee, Peshtigo,



and Oconto Rivers, while lower, show relatively the same



changes.  One might well ask, in view of what appears to



be a net reduction in BOD — admittedly a very small one —



how Professor Howmiller and Dr. Beeton were able to docu-



ment such a drastic deterioration in the condition of the



bay0



           It is interesting to examine the suspended



solids loading during this period.  The contributions



double.  Might not a clue to the problem lie herein?



           It is also instructive to understand fully the
-------
                                                      2116
                       J. F, Wilson



nature of the monitoring process, which is largely performed



by the polluters themselves and, in fact, would include the



contents of settling lagoons and basins that are regularly



discharged to the river only under extremely rare circum-



stances.  I hope that is clear:  that the settling lagoons



and basins are reported under only extremely rare circum-



stances*



           The Quirk-Lawler-Matusky study of the Fox River,



funded by the Wisconsin Department of Natural Resources,



included among its recommendations that **<,,. an economic



alternative to advanced treatment facilities would be flow



augmentation,"



           We note that Michigan's pollution control agency



has accepted this principle with regard to the huge new



Mead paper mill at Escanaba, where the proposal is to, in



times of low flow of the Escanaba River, pump water out of



Lake Michigan and introduce it upstream from the mill.



This is designed to maintain an adequate dissolved oxygen



in this critical stretch of the river.  Where, however, do



the pollutants and solids go after they are thus diluted?



Gentlemen, these measures have been proven unsatisfactory



in the past.  Why are they permitted now and accepted in



future planning?



           In April, at the Lake Michigan Conference in
-------
                                                      2117





                       J. F, Wilson



Milwaukee, I raised the question whether it was necessary



to demonstrate that a specific pollutant crossed the State



line in Green Bay before the Federal Government could



exercise its jurisdiction in those waters.  Mr. Stein



interrupted at that point to indicate that the Federal



Government viewed Green Bay as clearly within their purview.



           The question has come up again, however, and a



conflict of interpretation within and between the FWQA and



the State of Wisconsin has not been resolved.  Wisconsin



claims harbor areas and river mouths as being within the



jurisdiction of Wisconsin statute.  No one has defined how



far out into the bay these areas extend.  Unless some



clearly quantitative limit is placed on rivers and harbor



areas of influence, presumably all of Lake Michigan could



be claimed as a mixing zone for one or another State's



river or harbor.  Apparently FWQA cannot or will not act



in the Green Bay section of Lake Michigan until this



matter is decided.



           In Green Bay, on June 23, 1970, in a hearing



before the Wisconsin Department of Natural Resources,



evidence was presented indicating that the Fort Howard



Paper Company t«as now discharging some 40,000 pounds of



BOD per day and 8,000 pounds of suspended solids per day



into the Fox River as compared with their 196S loadings
-------
                                                       2118




                       Jo F. Wilson



of 32,720 pounds of BOD and 27,SgO pounds of suspended



solids per day.



           It was also brought out that they intended to



reduce their loadings through the installation of advanced



treatment facilities to 10 percent of their present con-



tribution.  Their new orders call for abatement to 25,400



pounds of BOD and 27,300 pounds of suspended solids per



day.  Why do they not call for a maximum of 4,000 pounds



of BOD and SOO pounds of suspended solids per day?  And



why, above all, did it require the citizens to pool their



money to legally force this information into the open?



Why did not the Wisconsin Department of Natural Resources



determine this information for themselves?  As yet, we



have not received a new order for this mill, although



presumably it is forthcoming*



           The joint municipal-industrial treatment plant



to be built in the city of Green Bay is designed to treat the



mill wastes from American Can and Charmin to effect a 90



percent removal.  Green Bay Packaging is constructing a



reverse-osmosis plant to remove 90 to 100 percent of their



effluent load to the Fox River.  But the State orders



trail behind the technology available.  In 1963, admitted



loadings to the Fox River from both industrial and municipal



sources totalled some 303,450 pounds of BOD per day.
-------
                                                       2119

                       J. F. Wilson
Technology permits this to be reduced to 10 percent of that
total.  The Wisconsin Department of Natural Resources is
calling for a reduction to only #7,065 pounds of BOD per
day from the paper mills, plus an additional municipal load.
           We ask that total contributions to the Fox,
Oconto, Peshtigo, Menominee and Escanaba Rivers be put
at 10 percent of their present loadings, and that the ominous
rise in suspended solids be immediately investigated at the
source.  We also request that this conference begin the
procedures necessary to establish effluent standards on
all waters affecting Lake Michigan,  We request further
that the States establish adequate and uniform monitoring
of discharges that will permit complete public surveillance of
all pollutional sources.
           And, finally, the Wisconsin Ecological Society
would like to commend the excellent report, "Physical and
Ecological Effects of Waste Heat on Lake Michigan," pre-
pared by the Great Lakes Fishery Laboratory of the Fish
and Wildlife Service of the Department of Interior.  This
is another piece of excellent work done by that able
laboratory.
           For the first time, the actual physical
process of introducing large amounts of hot water has
been described.  Rejecting the notion that the heated
-------
                                                       2120





                       J. F. Wilson



water would intermix with the entire volume of water in



the lake, and the equally simplistic view that the warm



water plumes would spread out evenly over the entire lake



and quickly evaporate, they have quite accurately delin-



eated the complex routes possible to this huge mass of



interjected hot water*



           We completely concur in the conclusion of the



report that no significant discharge of waste heat into



Lake Michigan should be permitted.  (Applause)



           MR. STEIN:  Thank you, Mr. Wilson.



           Mr0 Frangos.



           MR. FRANGOS:  Just a few quick comments,



           I recognize that much of this presentation did



not bear on the thermal question, but it is certainly



important to the well being of the lake.



           I am not sure I understand it, but I think the



best way is for me to say again — I said it at the last



conference — we have no jurisdictional problem in Wisconsin



from the State's point of view about Green Bay and the Fox



River and the tributaries to the lake.  We have included



this in all of our listings to the conferees, and we have



proceeded on a schedule that is compatible with the



overall requirements of this conference <>



           On the Fort Howard situation, I really can't
-------
                                                       2121






                       J. F, Wilson



comment, or I don't think I should at this time since this



is under advisement by our Department's legal unit.  But



Mr, Wilson is indeed correct that a decision will be forth-



coming in the near future,



           I hesitate to comment on the effectiveness of



the reverse-osmosis in the Green Bay Packaging operation



as a demonstration program, and I don't have the confidence



in the capabilities of that process at this time that Mr,



Wilson has,



           I think his points are well taken on increasing



surveillance over pollution generally in the State and



certainly on the Fox River.  The Legislature has responded



to our Agency's request for increasing our monitoring.



We have been successful in getting funds, and we will be



indeed increasing our surveillance, and we have designed



a monitoring system for the Fox River, and we hope to have



that on line within the next month,



           MR, WILSON:  Mr, Stein, may I just respond to



one point that Mr. Frangos has made?



           The hangup — if you want to put it that way —



with the jurisdictional matter is simply that when you



classify a stream as industrial cooling, you also extend



the area of influence of that stream out beyond the harbor



mouth.  Now, the actual measurement of what that harbor
-------
                                                       2122






                      J. F. Wilson



influence is, that area of influence by the harbor, the




actual mileage out into the bay, has not been defined, and




as I understand this from the highest people in the FWQA



in Chicago, there is no way that they can insist that Lake




Michigan standards be enforced in areas that you say, as



the head of the Wisconsin — your pollution control agency



— that you say are areas of influence.



          Now, does that clarify the problem?



          MR. STEIN:  We have the highest people right




to my left.



          Again, let me indicate what the situation is.



We go over this again and again and again, and I keep




quoting the same man — Oliver Wendell Holmes.  He said;




"Any bright young man can tell me what the law ought to be,



but it takes a student to know what the law is and what



we have to enforce."



          The Federal law is clear on this.  We have to



have two criteria present to have a Federal enforcement action




if we are going to proceed on Federal initiative.  The



first thing, there has to be interstate waters or navigable



waters.  I don't think that is the question here.  Then,



if we are to proceed on our own initiative for a cleanup,




whether it is under the standards provision or whether it



is under the conference provisions as we have here, we have
-------
                                                       2123
                      J. F. Wilson



to have pollution in one State endangering the health or



welfare of persons in another State.  You have to have both




of those things.



          There is an exception to this.  That is where we




have been asked to intercede in intrastate situations by a




State.  As I read this, we have been asked in here by




Governor Kerner on an intrastate situation in Illinois as



well as an interstate one.  We have never gotten a request



like that from the Governor of Wisconsin.  Therefore, Federal




jurisdiction, in Wisconsin, is limited to pollution which



is interstate as well as affecting an interstate or




navigable water.  This effectively pulls the teeth of the



whole thing in Green Bay.



          But what you have just said is exactly what we



are talking about.  First of all, Lake Michigan is supposed




to be suitable for all water uses.  Now, the point is:



What kind of an imaginary line is supposed to be drawn



across the mouth of the Fox River?  There is one, there



must be, because if there was not then obviously the water



does not qualify.




          Sir, what I want to point out is:  while there



may be an imaginary line, there is a very definite line



which is the border of Wisconsin and the neighboring State,
-------
                                                      2124
                      J. F. Wilson



and all of the waters you are talking about lie well



within the boundaries of Wisconsin, and they are



intrastate in nature.



          MR. WILSON:  They are intra?



          MR. STEIN:  Yes.



          MR. WILSON:  Oh:



          MR. STEIN:  At least the effect is within.  The



water may be interstate but the effects that you are talking



about are also all within Wisconsin — the same State upon



which the discharge that you are talking about has the



alleged causal effect.



          Now, I would like to move back, and I think I



may have misled you.  The waters are interstate but the



discharge point and the alleged damage point and the



causal connection with them all relates to points within



Wisconsin, and when that happens, our jurisdiction is



limited unless the Governor asks us in, and that hasn't



happened.



          Now, we have a proposed amendment to the Federal



law which would remove this, but the Congress hasn't acted



on that yet.



          MR. WILSON:  What is the name of that bill?  Do
-------
                                                      2125
                      J. F. Wilson



you know that offhand?



          MR. STEIN:  We can get that for you.  But the



House has not had hearings on this.  Senator Muskie's



Committee has had hearings, but we haven't had any movement



of that legislation yet.



          MR. WILSON:  All right.  I think, sir —



          MR. STEIN:  Let me continue on this.  We recognize



the problems in the law.  But I would suggest that in



those instances that you have to remedy the law or get the



request of the Governor of a State in order for us to



exercise jurisdiction, at least complaints about the



efficiencies, etc., should be directed to the places



where they can do the most good.  This forum here can just



carry this out.  But I recognize this and the Administration



recognizes this.  We can't do anything else.



          MR. WILSON:  In other words, now, if Michigan



would request some action on Green Bay, they would claim



that they were affected?



          MR. STEIN:  Well, if they said they were affected



— I never heard them say that.



          MR. WILSON:  No.  I see the problem.



          MR. STEIN:  There is another feature in the law.



If Michigan asks us, we have to go in there in a mandatory



way.  We have no option.
-------
                                                       2126
                      J. F. Wilson



          MR. WILSON:  What about if Illinois asked you?



          MR. STEIN:  What, that Green Bay affects Illinois?



          MR. WILSON:  Would that have to be contemplated?



          MR. STEIN:  Well, surely we would go in, but



they sure enough have to contemplate it.



          We get this again and again, and I know you will



be facing your citizens over and over again.  We have had



the same problem.  It can be best illustrated by our case



that is currently in progress on Lake Superior.  People



were complaining about discharges to Lake Superior from



Reserve Mining Company, which all hands agree is putting



out 67,000 tons — get that figure —a day of taconite



tailings wastes into the lake at Silver Bay, Minnesota.



They asked "Why, why, why couldn't you clean this up?



Look at all this material coming out."



          Because we didn't have an intrastate request



from Minnesota, we had to prove before we had jurisdiction



that these materials were getting over into Wisconsin and,



in fact, deteriorating water quality in Wisconsin.  We



had 30, 40,  50 miles of open lake to trace these pollutants



across or this material across — I don't think the



company considers them pollutants yet.  We had to



trace them across remarkably clean waters, and we had to
-------
                                                      212?
                       J, F, Wilson



spend a fiendish amount of money and resources to prove



that*



           Now, this is the state of the Federal law now,



and unless you people recognize that, you will have a very



difficult thing to understand.  We stand on what our juris-



diction ie<.     I know the people around the shores of Lake



Superior who talk in the same terms you do of money, people



and staff coming out, were very impatient with us in not



being able to move in within days or weeks after we entered



the case.  But this was not possible until we felt or the



Federal people felt that interstate pollution could be



demonstrated,



           MR, WILSON:  Thank you,



           MR, STEIN:  I hope this is helpful, because



we are going to run into this over and over again,



           MR, DUMELLE:  Mr, Stein, let me just ask you a



clarifying question,



           Mr, Ourrie, when he was sitting here a little



while ago, talked about the chloride situation, and we



have this allegation that some 1,500 tons of chlorides as



sodium chloride are going into the lake at Manistee ever)



day.



           Would it be necessary for us to ask Governor



Ogilvie to point this out to the Federal people in order
-------
                                                      2128






                       J. F. Wilson



to get to abatement of this discharge,  in order to show an



interstate effect? Or can we assume that Lake Michigan,



because of its mixing, will carry this  kind of a persistent



discharge all over the lake?



           MR. STEIN:  As I read the request from Governor



Kerner which, as far as I can see, is endorsed by Governor



Ogilvie, we already have this request from Illinois in



sufficient terms to give us jurisdiction over that and



investigate that and correct that if that is the problem*



           MR. DUMELLE:  Thank you.



           MR. STEIN:  This has already been done.



           May we have Mr. Winston?  Is he here?



           Vance Van Laanen?  Is he here?



           While you are coming up, Mr. Van Laanen, I would



like to take this opportunity to introduce a telegram into



the record from Carole Magnus, addressed to several of the



conferees and Mrs. Edgar Wilkinson's statement — she had



to leave — and Catherine Quigg's statement, who also had



to leave.  They have entered statements for the record.  I



would like to put those in.



           (The following telegram was received from Carole



Magnus, Secretary, Manistee County Anti-Pollution Organi-



zation .)



           "MACAPO fully supports strongest action to
-------
                                                      2129





                     Mrs. E. Wilkinson



prohibit thermal pollution.  Urge push for prejudgment,



guidelines."








             STATEMENT OF MRS. EDGAR WILKINSON,



              SOCIETY AGAINST VIOLENCE TO THE



            ENVIRONMENT, HIGHLAND PARK, ILLINOIS








           MRS* WILKINSON:  My name is Ann Wilkinson from



Highland Park, Illinois, and a member of the Society Against



Violence to the Environment,



           I am not speaking for SAVE but as a concerned



citizen and as a mother.



           I grew up in Highland Park and used to enjoy



swimming in Lake Michigan.  I have a 4-year old and I



wouldn't dare let her go in the lake in its present state.



I hope she will be able to some day.



           If there is any doubt of the effect of adding



heat to the lake from atomic powerplants or any other



sources, we should not add any heat.  We can't afford to



take a chance.



           You've seen the button, "Don't Do It in the



Lake."  I don't think that anyone — business or private



— should be allowed to put heat in the lake.
-------
                                                     2130





                     Mrs. C. T. Quigg








           STATEMENT OF MRS. CATHERINE T. QUIGG,



                   HARRINGTON, ILLINOIS








           MRS. QUIGG:  Electric utility companies to the



contrary, nuclear powerplants are not man's good neighbors.



           Existing and proposed nuclear powerplants are



designed to pour billions of gallons of heated water into



Lake Michigan each day.  The Zion plants alone will con-



tribute 2 billion gallons of heated water a day to the



lake.



           I am aware of the decline of the lake due to



pollution and I am afraid that nuclear power siting with



thermal discharges along its shore will hasten this



decline.  Not just the Zion plants but all powerplants



being built around the lake deserve our serious concern



with relation to their environmental effects.



           At the very least, we should insist that



electric companies utilize current technology such as



cooling towers and cooling ponds to prevent aquatic



damage.  Why don't we — for once and for all — dispel



three power company myths:



           1.  The myth that cooling towers cause adverse



atmospheric conditions.
-------
                                                     2131

                     Mrs. C. T. Quigg
           Investigations by the FWQA of fogging problems
from natural and draft towers presently operating in the
eastern United States refutes this position.  Reports
indicate that natural draft towers did not produce ground
level fog or drizzle under any weather conditions.  Plumes
of steam from cooling towers rarely dropped below the top
of the tower for an extended distance, and generally
dissipated within a few hundred feet of a tower.
           The FWQA report, dated September 1963, went on
to say, "In general, undesirable meteorologic effects from
towers can be prevented or controlled to a large degree
through modern design, such as effective drift eliminators
and air-flow control.  In situations where problems arise,
the area affected is limited to that immediate to the tower
installation•"
           Research on cooling towers by Eric Aynsley,
research chemical engineer, Illinois Institute of
Technology, confirms the above conclusions.  Initial
findings of his studies at the Keystone Generating Station
near Indiana, Pennsylvania, state that local fogging
problems and icing from tower plumes do not present a
problem,
           2.  The myth that cooling towers are too
costly.
-------
                                                       2132






               Hon. Gaylord Nelson,  U.S.S.



           According to recent studies,  installation of



cooling equipment to control thermal pollution from water



discharges from powerplants would add about 30 cents a



month to the average customer's electric bill,  I'll pay



that much to keep the lake alive.



           3,  The myth that cooling towers are so unsightly



the public doesn't want them.



           This is the weakest argument of all.  The choice



between unattractive cooling towers and a dead or unsightly



lake is an easy one to make,



           I recommend that we insist on alternate cooling



methods for thermal powerplants near Lake Michigan,  We



should not allow Lake Michigan to become the power



company's private waste sink at our great expense and



that of future generations,



           MR, STEIN:  Just in case you think I am out



here on my own, I have received another telegram from



another one of my bosses, which I will read into the record



now:



           "Though  the exact extent of potential damage



to Lake Michigan by the introduction of massive quantities



of waste heat is yet undetermined, there is enough evidence



to make it clear that consequences could be catastrophic.



Federal reports which have been presented to this conference
-------
                                                      2133
                     V. Van Laanen



cite the dangers and demonstrate there are at least six



reasonable and feasible alternatives to discharging heat



wastes to the lake from powerplants.  The conferees should




act immediately to establish tough standards on these



plants prohibiting the discharge of waste heat to the lake.



There is no valid reason to gamble with the future of this



priceless resource when, in fact, such a risk can be



avoided with available technology,"  Signed Senator



Gaylord Nelson,



           Mr, Van Laanen,








           STATEMENT OF VANCE VAN LAANEN, PRESIDENT,



           WISCONSIN RESOURCES CONSERVATION COUNCIL,



                      GREEN BAY, WISCONSIN








           MR, VAN LAANEN:  My name is Vance Van Laanen



and I reside in Suamico, Wisconsin,  I speak on behalf of



the Wisconsin Resource Conservation Council of which I



am President, and the newly formed Lake Michigan Federa-



tion, of which I am Chairman0



           During the past week, Mr0 John Wilson, who



represents the Wisconsin Ecological Society, and I have



concluded negotiations with the Wisconsin-Michigan and



Wisconsin Electric Power Companies in lieu of intervening
-------
                                                     2134





                     V. Van Laanen



in the licensing of their facility at Point Beach.  I know



it was earlier reported in the press that we had reached



an agreement and that is partially correct.  We had, in



fact, reached an agreement in principle*  In the wording



of that agreement, however, the principle enforcement



mechanism was to have been the Atomic Energy Commission



itself.  Subsequent discussions with AEC counsel, which



I will not quote directly, disclosed the fact that the



Commission had no intention of enforcing the agreement



even though they did agree to accept the document for



inclusion in the official docket for Point Beach unit



number one.  This original agreement had then to be



renegotiated with different enforcement mechanisms and



I believe that a portion of that document is relative



to the proceedings here.



           I have included a copy of the agreement



together with my remarks for inclusion in the record.



(See Pp. 2141-2145)



           The agreement states in part:  "The intent of



this agreement, which all of the provisions thereto are



understood to promote and establish, is to create an



obligation on the Applicants to make every reasonable



attempt to reduce all deliberately discharged radioactive



wastes from Units 1 and 2 of the Point Beach Nuclear Plant
-------
                                                      2135





                     V. Van Laanen



to zero."  And again:  "The Applicants will proceed forth-



with to obtain proposals from Westinghouse and/or other



suppliers for equipment or systems that are applicable to



the Point Beach Nuclear Plant and that would result in



reducing the discharge of radioactive substances in con-



formance with the intent of this Agreement,1*



           I firmly believe that this language, arrived at



through negotiation in good faith, firmly establishes



the principle of zero release of radioactive materials



to the environment as a technically feasible and econom-



ically practicable reality.  Further, I firmly believe that



it demonstrates an awareness on the part of the utility



industry, or at least that portion of it that is



environmentally responsible, that the general public is



not willing to settle for a lenient standard, even though



no immediate danger to health and welfare can be estab-



lished, when the technology is available, at reasonable



cost, to meet more stringent standards,  I commend the



applicants, Wisconsin-Michigan and Wisconsin Electric



Power Companies for their willingness to take this



important step in environmental protection and I strongly



urge the conferees here to require no less of the other



utilities constructing reactor generating facilities



around the lake.
-------
                                                       2136
                     V, Van Laanen



           During these same negotiations,  the question of



thermal loading of Lake Michigan came up, as you might



suspect.  The applicants asked iis to withdraw consideration



of the thermal aspects as it was not relevant, in this



situation, to the Atomic Energy Commission proceeding.  We



agreed with the applicants that Wisconsin regulations



effectively direct the consideration of thermal discharges



to this conference.  We, therefore, request of this con-



ference that it require the abatement of thermal discharges



to the full extent that is technically feasible and econom-



ically practicable, or more simply that it require the full



application of the state of the art in thermal abatement



techniques.  I would like to take a moment or two to explain



why I believe this request to be both reasonable and timely.



The fundamental issue in thermal control involves the



question of whether the utility industry, or any other,



possesses the right to contaminate the environment beyond



the limits of necessity.  The question is not technical, it



is a moral question.  I say it is not a technical question



because if you leave out all of the economic qualifiers, it



is obviously undesirable to inject large amounts of heat



into a natural cold water system.



           The traditional approach to pollution control



in this country has been defensive and negative.  This
-------
                                                       2137
                     V, Van Laanen
approach has developed over a period of many years from
an initial, basic, philosophy of using the environment to
its maximum capacity to carry away wastes.  The environment
has been thought of as having a "self-purification capacity"
that can and should be legitimately used for waste disposal.
In this way, of course, the costs of waste control and dis-
posal could be minimized, and it has been an accepted idea
that to require additional waste treatment would be to
place an unreasonable economic burden upon industry.  So long
as no obvious damage could be shown  wastes from communities
and from industry could be released to the environment
without further justification.
           It thus became the practice to establish
environmental and human protection criteria that were based
upon a concept of obvious or provable harm.  Once such
limits are established, of course, they become "dumping"
criteria, in the traditional sense that the costs of
pollution control are customarily minimized by releasing
the maximum amount of wastes that can be absorbed by the
environment without evident and obvious harm.  Quite
obviously, this approach also results in the maximum
pollution of the environment that is tolerable on a. short-
term basis.
           We now have a history of attempting to clean up
-------
                     V. Van Laanen



pollution after the damage has been done, and that procedure



is both expensive and unsatisfactory*  It leads inevitably



to an environment that is barely tolerable.



           What is required instead is a new approach to



environmental protection which is based on prevention rather



than cure.  It should no longer be necessary for those



desirous of protecting the environment to bear the burden



of proof that each and every discharge will, in fact, result



in X-amount of damage.  The burden of proof should be on the



other foot and the potential polluter should be required to



show the absolute necessity of making any releases to the



environment.  Instead of making maximum use of the environ-



ment for waste disposal, we must begin to think in terms of



the maximum protection of that environment  and the minimiz-



ing of wastes dispersed to it.  The crucial question must



become not how much waste can the environment tolerate, but



how much can be reasonably kept out?  While the concepts of



air and water quality standards have served adequately as



a beginning in pollution control, we must take the next



step and begin to place controls on the effluent discharges



where they originate.  The only supportable justification



for the release of any contaminant to the biosphere now is



the absolute demonstration of the necessity for it.



           The Fish and Wildlife Service has presented to
-------
                                                      2139
                     V. Van Laanen
this conference a clearly viable alternative to the once-
through cooling system.  It has shown that these alternatives
are technically feasible and economically practicable•
There is no question that the prohibition of  once-through
cooling is the only reasonable response by the conferees.
           Finally, I suggest that adopting stringent thermal
standards now would be not only reasonable but timely,  A
recent issue of Limnos magazine contained an excellent
article by Mr, Mayo,  In the article, he described ways for
private citizens and conservation groups to be more effective
in promoting sound environmental policies and even suggested
some excellent strategems for environmental litigation.
           Let me insert here that I agree with everything
Mr, Mayo said.  What I deplore is that he had to say it at
all!
           I suggest that the conferees here would be
shocked to pick up tomorrow's morning paper and see an
article by the Chicago Chief of Police outlining methods
for citizens of this city to preserve law and order.  In
the area of crime control, we have long passed the time
of the vigilantes.  The democratic process in the area of
pollution control, as I understand it, consists of legis-
lative acts and regulatory enforcement.  Yet everyone here
is aware of a continuing necessity for litigation on
-------
                                                       2140





                       V0 Van Laanen



environmental matters initiated by the citizen.  Although



litigation before the courts of the land is a viable



extension of the democratic process, I suggest that it indi-



cates some weakness back on the legislative and regulatory



levels.  Litigation is rapidly becoming unavailable as a



tool for the private citizen.  The costs involved are almost



prohibitive.  Conservation organizations are less and less



able to mount significant environmental actions in the courts,



but the need for such litigation has not abated.



           When the public is frustrated at the legislative



and regulatory levels, and when the courts, for economic



reasons, are no longer available, I suggest that the con-



frontation over the environment will still occur.  The



logical destination in the democratic tradition  for that



confrontation  is the street,  I personally would deplore



such a development as would most other responsible conser-



vationists, but I would remind the conferees that the



problems are severe, widespread, and increasing.  More



people are becoming aware and involved every day.  As



environmental degradation increases in intensity its



visibility factor increases exponentially.  This increase



in the visibility factor will inevitably attract the



attention of greater and greater numbers of the public,



The time for strong, purposive regulatory action is now.
-------
                                                       21U





                       V. Van Laanen



           (Following is the agreement referred to by Mr.



Van Laanen.)



                        AGREEMENT



           This agreement is entered into by and between



Wisconsin Electric Power Company and Wisconsin-Michigan



Power Company hereinafter called "Applicants" and John F,



Wilson and Vance J. Van Laanen and a number of organizations



represented by them as set forth in their petition in the



proceedings before the Atomic Energy Commission of the United



States of America under docket No. 50-266, including the



Wisconsin Ecological Society, Inc. and the Wisconsin Resources



Conservation Council, hereinafter called "Intervenors."



           Applicants have in said proceedings requested



that the Atomic Energy Commission issue them an operating



license for the Point Beach Nuclear Power Plant Unit



number one at Two Creeks, Wisconsin.  Intervenors have



petitioned the Atomic Energy Commission for leave to



intervene in such proceedings and for a public hearing in



the matter of the issuance of such requested operating license



stating as their view that it is desirable that no discharge



of radionuclides be made to the environment and that the



present state of the art is such that no radionuclides need



be discharged to the environment.



           The intent of this agreement, which all of the
-------
                                                      2U2





                       V. Van Laanen



provisions thereto are understood to promote and establish



is to create an obligation on the part of 1, the Applicants;



           To make every reasonable attempt to



           reduce all deliberately discharged radio-



           active wastes from Units 1 and 2 of the



           Point Beach Nuclear Plant to zero*



and on the part of 2, the Intervenors:



           That upon satisfactory demonstration of



           applicants* intention to meet the above



           stated obligation, to forthwith withdraw



           their petition to intervene in the pro-



           ceedings before the Atomic Energy Commis-



           sion under docket No, 50-266 and withdraw



           their request for a public hearing on the



           request of applicants for an operating



           license.



           The provisions agreed to by Applicants and



Intervenors intended to implement this agreement are as



follows:



           1.  That Intervenors will forthwith withdraw



their petition to intervene in the proceedings before the



Atomic Energy Commission under docket No, 50-266, and



withdraw their request for a public hearing on the request



of Applicants for an operating license.
-------
                                                       2143
                     V, Van Laanen
           2.  The Applicants will proceed forthwith to
obtain proposals from Westinghouse and/or other suppliers
for equipment or systems that are applicable to the Point
Beach Nuclear Plant and that would result in reducing the
discharge of radioactive substances in conformance with the
intent of this Agreement.
           The Applicants will within 60 days after receipt
of these proposals make their evaluations and place orders
for such equipment and systems.
           3.  That the following paragraph will be submitted
forthwith by Applicants to the Atomic Energy Commission with
a request that it be incorporated into and become a part of
the said operating license requested by Applicant for the
Point Beach Nuclear Plant, Unit number one at Two Creeks,
Wisconsin to wit:
           "On or before June 1, 1971» Applicants will
submit to the Atomic Energy Commission application for
modifications and/or additions to the Point Beach Nuclear
Plant Unit number one to effect such changes in the equip-
ment and/or operations that will reduce radiation exposures
and releases of radioactive materials to unrestricted areas
to as far below the limits specified in 10CFR20 as the
state of the art in the reduction of such emissions will
allow."
-------
                                                      2144
                       V, Van Laanen



           4,  That if and when the Atomic Energy Commission



grants such application for modifications Applicants will



proceed to effect the modifications as approved by the



Atomic Energy Commission according to the time schedule



approved by the Atomic Energy Commission, or, if no time



schedule is so established, within a reasonable time,



           5,  This agreement shall also apply in all



particulars to the proceedings relative to Applicants'



Point Beach Nuclear Power Plant Unit number two under



docket No, 50-301 before the Atomic Energy Commission,



           6,  In the event Applicants fail to comply with



the provisions for implementing this agreement, provision



number five (5) shall be voided, and Applicants shall not



proceed with the fuel loading of Unit two of Point Beach



Nuclear Plant, at Two Creeks, Wisconsin,



           7,  This agreement shall be enforceable by the



Atomic Energy Commission and any successor agency to the



Atomic Energy Commission and in any proper court of record



and shall be enforceable in such court through the remedy



of specific performance or injunction if the court con-



siders such remedy or remedies proper.



           This agreement shall be executed in duplicate,



one copy being retained by Applicants and one by Inter-



venors.  Provision number three (3) shall be duplicated
-------
                                                       2145
                     V, Van  Laanen




forthwith by applicant and submitted to the Atomic Energy



Commission to become part of docket No, 50-266 if rules of



the said Commission permit*



           Witness our hands and seals this 5th day of



October, 1970.



           MR. VAN LAANEN:  Thank you.  (Applause)



           MR. STEIN:  Mr. Van Laanen, thank you.



           Any comments or questions?  If not, thank you



very much, sir.



           MR. DUMELLE:  Mr. Stein, I just want to ask Mr.



Van Laanen — it is my understanding that the State of



Maryland, in issuing its permit for the Calvary Cliffs



Nuclear Plant, set the standard at 1 percent of the AEG



10CFR20 regulation, and that the State of Minnesota, I



think, will set a 2 percent value.



           Am I to understand you think that these are too



loose, and your standard would be zero for radioactive



discharges?



           MR. VAN LAANEN:  You get into an area here of



what is zero and what is essentially zero.  The Minnesota



standards, as I understand them, and the Maryland standards



are set right about at the point where the difficulty in



calibrating the measuring instruments interferes with the



ability to measure.  So you are down in the area where it
-------
                                                     2146






                       V, Van Laanen



doesn't really make much difference whether you are talking



a tenth or two-tenths or three-tenths.  I think it has been



substantially demonstrated that the state of the art — in



radiation control techniques — is well beyond the Federal



requirements for it«  And, as I say, I think that the



willingness of the Wisconsin Electric Power and Wisconsin-



Michigan Power to take on itself the extra burden of agree-



ing to provide essentially zero releases amply demonstrates



the fact that this is the case,



           I certainly don't want to criticize the Minnesota



standards or the Maryland standards,  I think they are both



very good,



           MR, DUMELLE:  What I am trying to establish isj



Are your standards tighter than theirs, as you see them?



           MR, VAN LAANEN:  Well, first of all, you are



trying to compare apples with peaches here.  I am not that



familiar with the Maryland standards.  The Minnesota stan-



dards are — by the way, those are not statewide standards,



if I am not mistaken, those Minnesota standards apply to



the — what is the name of the plant? — Monticello plant.



They are specifically designed to cover a General Electric



cooling water reactor with specific conformation at



Monticello,



           So the maximum permissible concentration factors
-------
                                                      2147
                      V. Van Laanen



for different isotopes are going to differ with that which




will be coming out at Point Beach.  If you are asking which



standards will be lower, I think that probably there will be




a smaller standard from the Point Beach Plant simply because



it is a pressurized water reactor, and you don't have the



gas emission problems that are difficult to handle that you



do with the boiling water reactor.  I do not have it



calibrated down into specific MFC's at this point.



          MR. STEIN:  Any further questions?



          This has come up.  Mr. Van Laanen, don't run off



because I have one more question.  With the background




you have demonstrated, I think this is a good time to ask




you the question that has come up and people have asked



me from time to time.  If the electric utilities demonstrate,



as you indicated in Wisconsin, before they build the plant



that they are going to get down and get into this refined



philosophic discussion of zero tolerance — and I agree



with your statements on that — of the protection of the



environment from releases of radioactive material into




the environment, how do these plants on the one hand get



so far on radiation,when on the other hand they didn't



give the same comparable assurances of protection from



discharge of heated water?
-------
                                                        2148
                      V. Van Laanen



          MR. VAN LAANEN:  Are you asking now the plan —



          MR, STEIN:   No, no, it is a philosophic point.



I am not talking, obviously, about the fossil fuel plants



because this doesn't  arise there.  But if you are dealing



with the nuclear plants and before the power industry



goes ahead with that  plant, they present full, complete,



and documented assurances — and I think they do a pretty



good job of it —



          MR. VAN LAANEN:  Yes, they do.



          MR. STEIN:   — that there won't be a nuclear dis-



charge, and they have safety devices, etc., and have taken



every precaution to protect the environment, the question



is how come the plants already have done this with



nuclear or radioactive material but they haven't done it



apparently to everyone's satisfaction with the proposed



heat discharges?  Or should the industry, before it puts



up a plant, be required to make the same kind of case,



provide the same kind of assurances and the same kind



of devices that it relates to protecting the environment



from the discharge of heat as apparently it has done in



assuring the protection from radioactive materials?
-------
                                                     2149
                     V.  Van Laanen
           MR. VAN LAANEN:  I would say absolutely, and I
think the reason why they are not is because there has been
a regulatory vacuum in that area.
           The other thing I would say is that since the
implementation of the NEPA Act I think this will probably
be done or at least done to a certain extent.  However,
you bring up another very interesting point here, in that
I do not personally see how it is possible to separate the
heat from the radioactivity or vice versa.  For the most
part, the radioisotopes which come out of the these plants
with the exceptions of the noble gases will come out ae a part
of the hot water discharge stream, and how are you going to
physically or in any other way philosophically or ideally
separate the isotopes from the waste heat in the waste
disposal stream?  I don't think it is possible.  So I think
it makes sense to do the same kind of study, the same kind
on the noble gases — environmental reassurance sort of
thing — with heat that you are doing with radioactivity
because why the sense of water discharges, you can't
separate them anyway.
           MR. STEIN:  By the way, I would thoroughly agree
with you, and I don't know if you are familiar with it, but
before these plants -- at least the thermonuclear plants —
cane on, we did have many enforcement cases involving the
-------
                                                       2150
                      V. Van Laanen




uranium mining industry in the Colorado River Basin,  and



at this time I see a lot of parallels to where we are here.



          MR. VAN LAANEN:  Yes.



          MR. STEIN:  According to the Federal investigators




and agreed upon by the State people, we went out and we




at least determined there was excessive discharges of radium




to those waters.  These plants were operating.  We got



these pushed back, back, back.  Then when the new plants




came in the assurances were given that this wouldn't



happen.  But the restrictions for emitting radiation also




applied to the existing plants.




          So in radiation this was carried on, in large



measure, into all plants  such as the thermonuclear



plants.



          But I thoroughly agree with you that the protection



of the environment is always one piece and you can't



separate this.  Any kind of emission that comes out of the




plant that may affect the environment has to be accounted



for.  I am not just referring to the power industry.  I



don't want to single them out at all, because we have



the same thing in mercury discharges.



          MR. VAN LAANEN:  Yes.



          MR. STEIN:  But it seems to me that if we have



an example of how an industry can come forward and assure
-------
                                                      2151
                      T. MacDonald


the public that it has taken all safety measures in pro-


tecting the public from radiation discharges, we might be


much farther ahead if they would provide that same kind


of assurance as to other potential hazards to the environ-


ment,


           MR. VAN LAANEN:  You may get into this if you


get a vigorous enforcement of the NEPA requirements, but


I don't know if that will be or not,


           MR, STEIN:  Thank you.


           May we have Ted MacDonald?





           STATEMENT OF TED MacDONALD, WEST


                   LAFAYETTE, INDIANA





           MR, MacDONALD:  Mr, Stein, and gentlemen of


the conference.  My name is Ted MacDonald.  My home is


in West Lafayette, Indiana,  I also own property on Lake


Michigan immediately adjacent to the Donald C, Cook


Plant at Bridgman,  I am involved in a lawsuit  at the


present time  against the Indiana and Michigan Electric


Company in company with eight of my neighbors to recover


erosion damages that have been caused by the construction
              i

of their plant.


           But I speak to you today as a private citizen
-------
                                                     2152





                      T. MacDonald



interested in preserving Lake Michigan.  I speak not only



for myself but for dozens of people I know personally from



all four States bordering the lake  and uncounted hundreds



of thousands I will never know, all of whom will need a



living Lake Michigan in the years to come, a living lake



to provide them with peace-preserving recreation, the fresh



water they need to survive, and perhaps an essential food



supply in an overcrowded world.



           And as I speak, I continue to be amazed that



after all that has transpired, a few private citizens still



must take it upon themselves to carry on such a major



portion of the fight to save the lake — and it is a real



fight.  I have the financial scars and a depleted supply



of midnight oil to prove it0  The people I speak for — and



I am in close contact with them — feel there are some



questions which need answering.  Some positive answers to



these questions must be found before further possibly



lethal doses of hot water and radioactive waste are



allowed to be administered to Lake Michigan.



           MR. STEIN:  Mr. MacDonald, just a moment, please,



           I would appreciate it if the people would not



talk in the back so the rest of the people could hear*



Thank you.



           MR. MacDONALD:  First question:  Why do power
-------
                                                      2153
                       T. MacDonald



companies regard the granting of construction permits and



operating licenses as a foregone conclusion?  What would



lead them to believe that they are safe in spending many



thousands, yes, even millions of dollars, on preconstruction



work before the necessary permits are issued?  They seem



so sure of themselves that it makes one wonder.  Just one



example of many:  At Michigan City, a powetplant  discharge



flume is already partially constructed but the permit to



complete it has not yet been approved.



           Second question:  Last March 30 at Grand Rapids,



Michigan, Senator Philip Hart conducted a hearing for the



Subcommittee on Energy, Natural Resources and the



Environment of the Committee on Commerce of the United



States Senate.  At this hearing, Senator Hart questioned



a top official of one of the power companies with regard



to comparative costs of wet and dry cooling towers.  The



power company official replied, and I quote, "Let me say



there are no nonevaporative cooling towers in the United



States.  The only experiment we are knowledgeable of in



the foreign countries have not proven very successful as



yet.  These are under study by us but there needs to be



a lot of development before they can be used."



           Whereupon, an official of the Federal Power



Commission stood up, identified himself, and reminded the
-------
                                                       2154






                       T. MacDonald



gentleman from the power company that a nonevaporative



cooling tower is now being installed in the State of Wyoming



by the Black Hills Power and Light Company.  Now, the



question is this:  Are power company officials as pitifully



ignorant of the problems they are creating and the solutions



to those problems as the foregoing example indicates, or do



they tend to play Mickey Mouse with the truth when it is to



their advantage?



           Third question:  When are State and Federal



agencies  which have power to grant power companies various



permits and licenses  going to get down to business and



protect public interests?  At the Donald C. Cook plant



in Michigan  permits for the intake outlet structures were



all set for automatic approval until the facts came out at



a hearing held only because of public demand.  As a result,



complete redesign of the structures was necessary.  Why



did the public have to hire consultants and attorneys to



show government officials they were playing brinksmanship



with the public interest?  How many other permits already



granted should be reexamined in the light of this incrim-



inating example?



           Fourth question:  Why does the power industry



continue to spend millions of dollars on advertising to



sell more electricity, while at the same time broadcasting
-------
                                                       2155

                       T. MacDonald
the dangers of impending power shortages?  A TV news program
tells the story of the recent brownout in the East,  The
sponsor of the show is a power company, and the commercial
urges us to heat our homes electrically.  How ridiculous
can this comedy of errors become?  Who can attach any
credibility to statements from people in the electric power
business when they so grossly underestimate the public
intelligence and so poorly manage their business affairs?
           Fifth question:  When is the power to grant
permits and licenses going to be shifted to State and
Federal Government agencies which have some power to
enforce such conditions and stipulations as the permits
or licenses may contain?  Such conditions and stipulations
are usually in the public interest, but it has been my
personal experience that it is up to the public to spend
a bundle of its own nontax  deductible dollars to do the
enforcing.
           Sixth question:  Why do government agencies,
particularly at the State level -- although I've seen
the Army Corps of Engineers do it, too — rely so heavily
on people hired by the power companies for scientific
information pertinent to the life or death of Lake
Michigan?  Here again it has largely been left up to the
private citizens to bring forth and pay for their own
-------
                                                       2156
                      T, MacDonald



reputable scientists to emphasize the obvious and proven



fact that there are two sides to the story*  I submit that



John Q. Public is fed up to his ears with officials who



have abdicated their responsibility to the people by



swallowing the power company story hook, line, sinker, and



contaminated bait*



           In conclusion, I submit that the public is not



to be underestimated in its determination, or in its



knowledge of the many facets of this problem.  The public



wants answers to their perfectly legitimate and logical



questions, only a few of which I have mentioned.



           If the money already spent on this fight had



been devoted to research to find answers to problems which



already were there when the whole thing started, all of



us could be attending to other important business today.



Let me suggest that we stop wasting each other's time and



money and get down to the business of finding ways to



satisfy our power needs without destroying any irreplace-



able natural resources in the process,



           I am grateful for this opportunity to speak.



Thank you very much,  (Applause)



           MR, STEIN:  Thank you, Mr, MacDonald,



           Any questions?



           MR0 DOWD:  I have one question, Mr, Chairman,
-------
                                                      2157
                      T. MacDonald
           While you are coming up with your question, I
have to do my research in this room every day, and I forget
it from one time to the next, but it always works.  May I
suggest that people who want to talk or hold conferences
get outside that exit door.  For some reason or another
when you speak against that rear wall there in the next
room, it is like an echo chamber, and your voices come
right back up here, and there are some dead spots in the
center where you can't hear it, but the noise level up
here is rather loud.  We have a lot of ante rooms available
for private conversations and caucuses just outside.
           Thank you.
           MR. DOWD:  I am Joseph Dowd, counsel for Indiana-
Michigan Electric Company.
           Mr.. MacDonald, you mentioned that a dry cooling
tower is presently under construction at a plant owned by
the Black Hills Power Company.  Do you know what the gen-
erating capacity of that plant is?
           MR. MacDONALD:  No, sir, I don't.  It is on
page 75 of that booklet you have in your hand.
           MR. DOWD:  Does it specify the generating
capacity?
           MR. MacDONALD:  No, it does not,
           MR. DOWD:  Well, that is what I was interested
-------
                                                      2153
                      T. MacDonald



in.




           MR. STEIN:  Are there any further questions or



comments?



           If not, thank you very much.



           MR. MacDONALD:  Thank you.



           MR. STEIN:  M. A. McWhinnie.



           While you are coming up, Miss McWhinnie, I do



have a clarifying statement from Mr. Sol Burstein, Senior



Vice President of Wisconsin Electric Power, which I would



like to put in the record.  Some of you may recall we had



a colloquy on the meaning of a quote from the Senate



Appropriations Committee — and I guess I started this —



and I think Mr. Burstein has clarified it0  There was a



typographical error in his report which led to my questions



and they used the word "Commission."  "Commission" was



inadvertently substituted for the word "Committee," which



makes the thing fairly clear, and we will place this in



the record because I think this is explanatory.



           (The letter above referred to follows on page




2159o)



           MR. STEIN:  And I also have a letter from John



Co Berghoff, addressed to Mr. Klassen which, without



objection, can be put into the record as if read in toto.



           (The letter above referred to follows on pages




2160-2163.)
-------
                                                           2159
WlSCOnSin EleCtriC POWER COMPANY
231 WEST MICHIGAN, MILWAUKEE, WISCONSIN 53201
                                           October  I,  1970
     Mr. Murray Stein
     Chairman
     Lake Michigan Conference
     Sherman House
     Chicago, Illinois

     Dear Mr. Stein:

                    At the conclusion of  the presentation
     of my prepared statement at  the workshop  session of
     the Lake Michigan Conference on Wednesday,  Septem-
     ber 30, you asked for a clarification  relating to the
     quotation of the Senate Appropriations Committee,
     which begins on page 15 of my statement and concludes
     on page 16.

                    As you may recall,  the  question arose
     because of the word "commission,"  which appears in
     the first line of page 16.

                    The statement has been  checked,  and I
     find that the word "Commission" was  inadvertently sub-
     stituted for the word "Committee."   The rest of the
     quotation is correct and is  taken  from the  Committee's
     report on FY 1971 funds covering appropriations for pub-
     lic works for water pollution control  and power develop-
     ment and the Atomic Energy Commission.

                    Therefore, the statement does indeed rep-
     resent the thinking of the U. S. Senate Appropriations
     Committee, in response to your question.
                                Sincerely,
     Sol Burstein               Senior Vice  President
-------
                                                             2160
JOHN C. BERGHOFF
   ATTORNEY AT LAW
 I I 5 WEST JACKSON BOULEVARD

 CHICAGO, ILLINOIS 6O8O4                                     TELEPHONE 012)431.2622

                           SEP 2 9 1970
RECEIVED
                       EWIBONMENTftL PROTECTION
                            STATE OF ILLINOIS
                                               September 28, 1970
 Mr. C. W. Klassen, Director
 Environmental Protection Agency
 State of Illinois
 535 W. Jefferson Street
 Springfield, Illinois  62706

 Dear Mr. Klassen:

                LAKE MICHIGAN FOUR-STATE  CONFERENCE

           Thank you for your letter of September 22 with respect
 to the reconvening of the Lake Michigan  Four-State Conference
 September 28 on the subject of Thermal Discharges.

           Please accept this letter as a request for permission
 to present a brief oral statement at this conference, which I
 understand will be held at the Sherman House Hotel in Chicago,
 Illinois, on Friday, October 2, 1970. We appreciate the oppor-
 tunity to make a statement in the public interest at this
 important hearing.

           With kind regards.

                                      Very truly yours,
  JCB :hk
-------
                                                                2161
                   STATEMENT OF JOHN C. BERGHOFF
                      FOUR-STATE CONFERENCE
                   THERMAL POLLUTION STANDARDS
                 CHICAGO, ILLINOIS - OCTOBER 2,  1970

          My name is John C. Berghoff.   I earn my living as
Associate General Counsel of Swift & Company.  I have spent most
of my years living near the shoreline of Lake Michigan in Illinois,
Indiana and Michigan.  I am a member of the Council of the Illinois
State Bar Association Section on Environmental Control Law.  Today^s
statement I make, however, in my individual capacity as a person who
greatly values the natural resources of this area,  particularly Lake
Michigan, and who wants to see these resources and  this lake pre-
served for the 3routh of this generation and for  generations to come.
          I have no quarrel whatsoever  with the  nation's need for
more electrical energy nor with the concept of nuclear plants to
provide this additional energy.  I do strongly object to the way
in which the pox^er companies are being  permitted to use the
nation's natural resources such as Lake Michigan as private indus-
trial waste ponds.
          The nuclear plant now under construction  with which I am
most familiar is the one being built on the lake shore at Bridgman,
Michigan - the Donald C. Cook Plant. This plant will, when
completed and if permitted to do so, draw two billion gallons of
fresh, cold, Lake Michigan water aach day, use it as a coolant in
its nuclear processing and spew it back into the lake at the end
of the day some 20 to 25 degrees warmer than when it was withdrawn.
The American Electric Power Company which has announced that this
plant will cost 400 million dollars is  not planning to spend one
-------
                                                                2162
                               -2-
single dollar to moderate this extreme elevation of temperature,
nor for that part is it planning to spend one single dollar  to
assure zero or near-zero radioactivity of the water which will be
returned to the lake.  It simply, if permitted to do so,  will  treat
Lake Michigan as its own private waste pond.
          I strongly feel that the interests  of this nation, and
more particularly of the people who live in these four states  which
form the shoreline of Lake Michigan, deserve  to have this natural
resource protected by reasonable thermal pollution criteria  adopted
by the federal and state governments involved.
          Further, it is my personal view that the top managements
of the electric power companies involved, despite the great  number
of highly-qualified and highly-paid expert witnesses whom they have
presented at this hearing, would welcome the  promulgation of tough
and uniformly enforced thermal standards.  Under our free enter-
prise system, these companies cannot be expected to take  the lead
in protecting the public interest when it clashes with the private
interests of their shareholders.  Once a determination has been
made as. to what reasonable thermal standards  are required to
protect the public interest, however, and once the appropriate
governmental agencies have adopted these standards, I am  sure
we will find the power companies conducting themselves as good
citizens in compliance therewith.
          I urge it to be the responsibility of each of the  four
states here involved and of the Federal Government to adopt
meaningful, unambiguous thermal pollution standcirds, avoiding
intricate mixing zone formulations which will only lead to costly
-------
                                                                2163
                               -3-
compliance problems and will not give the nation  and  its  citizens
what is required to preserve these resources.   You will best  serve
the interests of the conservationists and, though tney may not
admit it, the power companies as well,  by adopting and enforcing
uncomplicated, reasonable but firm thermal standards  - you will
have met the nation's need for expanding electrical energy without
permitting our national resources to be ravaged in the process.
-------
                                                     2164





                     M. A. McWhinnie



           MR. STEIN:  Would you go ahead?







           STATEMENT OF MARY ALICE McWHINNIE,



           PROFESSOR, DEPARTMENT OF BIOLOGICAL



           SCIENCES, DePAUL. UNIVERSITY, CHICAGO,



                          ILLINOIS







           DR. McWHINNIE:  I am Mary Alice McWhinnie,



Professor in the Department of Biological Sciences at



DePaul University, with an earned doctorate from



Northwestern University, and Director of the DePaul-EPRO



Ecological Study of Lake Michigan.  My credentials for



speaking to this board of conferees relates to my



professional experience in crustacean biology in study



of effects of temperature changes on invertebrate animals



in freshwater and Antarctic marine water, and to the work



in which we are engaged on Lake Michigan,



           Mr0 Chairman, and conferees, ladies and



gentlemen.  I am grateful for this opportunity to present



some views and concerns which I share with most, if not



all, present at this workshop.  I am aware of the serious



responsibility each of us accepts in such participation,



because of the unprecedented external pressure against



nuclear-powered electric generating stations which
-------
                                                     2165





                     M. A. McWhinnie



pervades into an area of knowledge in which we find our-



selves lacking in sufficient information to answer



satisfactorily all of the questions placed by the non-



scientist,  I offer that the disparity of views presented



thus far at this workshop attests to the inescapable reality



with which we are faced:  l) the necessity and commitment



to protect the environment; 2) the increases in population



density; 3) the continuing demands for available energy;



4) the intolerable slowness with which definitive knowledge



accumulates.



           Though disparities clearly exist, as judged



from the statements made at this workshop and elsewhere,



there is within these multiple views (at least) one point



of common agreement:  more study is needed and the dif-



ferences in existing and/or planned electric generating



plant sites require individual study.



           I should like to focus on what I believe led to



the development of workshops of this kind, but I will not



burden this statement with repetition of the long litany



of data available on the topic of thermal modification.



Rather will I include for the record statements prepared



for the recent hearing conducted by the Illinois Pollution



Control Board held in this city 25-26 September 1970,



With the approval of the following authors, I ask to have
-------
                                                      2166
                     M. Ao McWhinnie



entered the statements of Dr. Philip F. Gustafson —



who I understand presented his yesterday — Director of



the Great Lakes Program, Argonne National Laboratory



(See Pp. 2179-2190); Dr. Charles Collinson, Head,



Sedimentology Division, Illinois Geological Survey (See



Pp. 2191-2201); Mr. John D. Harper, Director, Environmental



Parameters Research Organization (EPRO) (See Pp. 2202-



2209); and my own, as Director of the DePaul-EPRO



Ecological Study of Lake Michigan (See Pp. 2210-2219).



           The objective of Dr. Gustafson's presentation



on "Thermal Discharges and Lake Michigan," is to illuminate



the facts of natural thermal increments as they relate to



man-induced thermal increments in Lake Michigan water.



He states that the volume of water which would be involved



in the operation of six nuclear powerplants to be in oper-



ation by 197$ "... tends to stagger the imagination and



perhaps to blur reason."  In recognizing the wide variation



in Lake Michigan water temperature, seasonally and



vertically, he questions the real meaning, and points to



the ambiguity of the term "ambient temperature,"



           Considering the long period of operation of



fossil-fuel plants at Waukegan, State Line, and Oak Creek,



he notes the lack of any profound impact on the aquatic



environment especially when compared with sewage and
-------
                                                      216?






                     M. A. McWhinnie



chemical waste outfalls.  With respect to temperature,



he shows a river water inflow to the lake which is at a



temperature 5 degrees to 19 degrees Fahrenheit greater



than the lake, and that this is near or comparable to the



thermal input to the lake from a given nuclear powerplant;



yet the former is not generally considered as "thermal



pollution,"  The advantages and the disadvantages of the



alternates to once-through cooling water are discussed



and a "field program to determine best options" is urged;



without this ",,, we will never know what reasonable



thermal standards are ,.,,"  Dr, Gustafson recommends,



in conclusion, that a plan be developed to allow present



and near-ready facilities to operate to allow for the



conduct of sound scientific investigations,



           Dr, Collinson laid emphasis upon the scant



evidence available concerning the sedimentary and chemical



composition of Lake Michigan and that data must be gained



before its original character is degraded.  He points out



that localized areas already give evidence of change,



e.g., the oxygen demand of southern Lake Michigan sediments



is approximately three-fold that of Lake Huron,  A program



to study unconsolidated sediments with respect to atmos-



pheric dispersal and surface water pollution as indicated



by trace metal accumulation was started in 19&9,  From the
-------
                                                        216$






                      M. A. McWhinnie



data thus far obtained, heavy metals appear to be accumu-



lating (10 to something more than 90 p.p.m.) as is organic



carbon.  These two categories are directly correlated and



may indicate that sediments with a high organic content may



in time have a high metal content; changes should be closely



monitored. Sediment type distribution and stratigraphy are



also being studied.  The main impression of their study



is:  "..o a very serious absence of basic scientific data



about Lake Michigan ..,*'.  "Reservations are held about the



effectiveness and correctness of any blanket temperature



standard ... at the present time."  If a thermal input is



allowed the site should be thoroughly studied before, and



monitored after operation.  MIn final analysis ... our



knowledge is so small ... and the resource so valuable ...



we would welcome the exclusion of any input ... to the



lake ...."



           The thrust of Mr. John Harper's statement is



that a mutually agreed upon moratorium be struck by the



utility companies and the regulatory agencies.  Such a



moratorium would allow adequate study of completed or



in-construction powerplants which would serve as the field



experiments whose results would lay to rest the continuing



debate prevailing in the absence of definitive information.



He further states that under such a plan, power companies
-------
                                                        2169
                       M. A. McWhinnie



must be prepared to change their cooling methods if such is



found to be necessary.



           In my own statement, I presented the findings of



several laboratories subsequent to study of "real situation"



thermal modification of the aquatic environment, as well as



in-laboratory duplications.  In a number of such published



studies no persistent biological alterations were demon-



strated.  Results were comparable for freshwater and marine



organisms as would be expected of living systems.  The



temperature preferences of some plant and animal species



were cited within this context.  The implicit limitations



of "fixed number policies" in establishing the maximum



limits of thermal increments, or fixed distances for mixing



zones, are presented just on the basis of the characteristics



of a natural environment for which data were given.  Based



on those considerations, a position, finding agreement with



most scientists, is taken that we can delay no longer in the



procurement of hard data to provide the answers needed.



           The full text of these four statements is presented



as an appendix to this one.



           Within the context of this workshop, I should



like to present some reflections on what I consider to be



the questions which lead to such, and for which we are



seeking some reasonable solutions:
-------
                                                     2170





                     M, A, McWhinnie



           !•  What is the true nature of the problem,



described to be a temperature increase in the Great Lakes



in general and Lake Michigan in particular?



           My own answer to this can be no different from



that of all persons present.  Briefly, it is a scientific



question directed at the physical, chemical, and biological



modifications that will result when one factor, in the



complex web called "nature," is varied*



           Many scientists have spoken on this subject  and



presented evidence that must be reckoned with, and some of



that evidence has not corresponded with intuitive feelings



expressed by others.



           It is necessary to state that a tone or climate



appears to have come to prevail in this workshop such that



it might be more appropriately characterized under the  title



of a trial.  In my opinion, it is unfortunate that by the



second day of this week the words "testify," "witness,"



and "cross examination" became common language.  My inter-



pretation was placed in some doubt when on Wednesday it



was stated that this meeting was to engage in a discussion;



however, my first impression persisted.  Information emerges



from both types of activities but the former deals with an



objective problem to which all seek solutions; the latter,



however, leads to impugning motives and credibility.
-------
                                                      2171






                     M. A. McWhinnie



           If science has nothing to say or to contribute



to our environmental problems, then our solutions will be



less than adequate; they shall have no more justification



than expediency; objectivity becomes  nonexistent, the



scientist will return to his laboratory and our society



will lose,



           2,  My second question could be called the first:



From what source(s) can those convened here, and all Ameri-



cans, holding diverse priorities, seek the information



essential to reasonable decisions?



           The answer must be those persons who, by virtue



of an earlier academic preference, pursued study in depth



of those disciplines called physics, chemistry, biology,



meterology, geology, and engineering — and the environment



is all of these.  These men have no special omniscience, but



in their area of competence they have knowledge, experience,



insights, and a deep curiosity to "know,"  If our judgment



of their data is influenced by the wby-linew over which



their name is given, and the persons to whom they speak in



a civil society, we fly in the face of honesty, we dis-



credit without evidence, and as a Nation we demonstrate a



schizophrenic personality, seeking the benefits and



by-products of science on the one hand as we discredit it



on the other when it does not support a fear or uncertainty
-------
                                                       2172






                       M. A. McWhinnie



which we might interpret as fact.



           If the proof of "no damage" to the environment



rests upon the user, to whom can he turn for the proof?  If he



seeks those qualified by training, by research, and by



objectivity, the latter are viewed with skepticism, if not



discredited, and the former are said to be "fighting the



issue,"



           Yet so recent as 29 September 1970, the "Chicago



Sun Times" carried an article stating that Mr, Stein said,



",.« industry <>•• and not the public ••• should prove that



its projects pose no threat to the environment or public



health,"  It is with deep concern over this conflict that I



submit the view that Lake Michigan belongs to scientists,



too.



           With a high hope to obtain answers essential to



the making of supportable decisions and acceptable to an



irate public too quick to judge and too concerned to be



silent, the DePaul-EFRO study was initiated in the field



in June 1970; a multidisciplinary study conducted by a



confederation of  10 scientists from private, public, and



governmental agencies, responsible and concerned, as are



the conferees and all participants here, to reach for



answers proportionate to the urgency of the issue.  Their



data are only now beginning to accumulate but their motives
-------
                                                        2173





                       M. A, McWhinnie



have been publicly impugned; yet they stand independent of



all vested interests, and this is well understood by all



persons on both sides of this question.



           Gentlemen of the board of conferees, if scientists



are the only appropriate segment of our society to study the



science-based issues of our environment, can they be written



off because someone doubts their motives?  If study of the



environment is not really needed, why did a conferee ask



this week, "... could any meaningful conclusions be drawn



from a one-day study ..." as it was reported by one of the



speakers?



           If lack of study is not our critical problem



why was the Kittrell report, for the FWPCA, of 1963, so



thoroughly detailed as to what had to be done that we might



"know"?  Perhaps more critical is the problem that that study



was not, to my knowledge, undertaken.  Is that part of why



the answers are not always forthcoming?



           If this was not true would we have come to be



impatient with what is increasingly called a wait-and-see



policy?  Is the character of that phrase intended to



encapsulate the view of or paraphrase scientists?  If so,



I urge that we recognize that erroneousness is insidious,



it is defeating; it is divisive in a society already fraught



with doubts, suspicions, and credibility gaps.
-------
                      M. A, McWhinnie



           3.  What will be the effect on the biota subse-



quent to thermal modification of Lake Michigan?



           Throughout this workshop, highly qualified scien-



tists have presented their own data and that published by



others; similarly, biological data have been presented in



the "white paper" of the Department of Interior,  In my own



statement of recent time, submitted herewith (See Pp. 2210-



2219) and previously this year, I too have called upon the



scientific literature.  I think I shall add little to cite



still more titles for the record.



           I should like to add another consideration with



respect to temperature effects on living systems.  May I



say first that the subtleties of the capacities of living



systems are profound and exquisite and continue to amaze



even those who have devoted their life to such studies.



Many of these subtleties pervaded the answers which Dr»



Raney offered to your questions.  He, as well as others,



could not concur with the view that plus 1°F., or plus 5°F.,




or plus 3°F., or plus anything had any significant meaning



to organisms in a dynamic system, one changing from moment



to moment to constant fluxes in the natural environment.



           If some fixed value is the maximum permissible



for cooling water entering the environment, such as plus



5°F0, or other,
-------
                                                      2175
                       M. A. McWhinnie



           a)  Is this meaningful when it is 50° plus 5°



in the same context as when it is 60° plus 5°» or 70° plus




5°?



           In terms of ease of understanding for those



unfamiliar with biological phenomena it may be.  For living



systems, and those who have some understanding of them, each



condition is dynamically different as it slides along the



temperature-response curve for each species and for each



vital function for each species.  As a consequence, such



a regulation would have less than rea] meaning in the



biosphere.



           Indeed the living systems we work to protect pass



through such oscillations in a diurnal (daily) cycle, and



more; further, those endemic to the waters we seek to



conserve live through approximately 32.5°F. to approximately



#0-#5°F. on an annual cycle.  Dr. Raney's comments on the



yellow perch which have a range from the southern States to



these latitudes are the biological evidence of the range of



tolerance and adjustment.  I hold this point as valid, even



in the light of others made by the authors of the "white



paper."  Given the opportunity to discuss this in depth,



I believe we would not find those two views so diverse;



but the requirement of "yes" and "no" answers obscures



biological realities and creates an  erroneous polarity.
-------
                                                       2176
                       Mo A. McWhinnie
 Delicately shifting biological phenomena cannot fit into
 "legal  boxes,"
            In this context, and all the nuances that it
 implies, what meaning does a fixed thermal increment have?
            b)   If plus 5°F., or other, is a fixed limit for
 natural water resources, is it for any water--water
 relatively free of high concentrations of naturally-occurring
 elements  (phosphorus, nitrogen, silicon, calcium, etc.);
'or water with some given concentration of these; or water
 deteriorated with chemical waste, with toxic  compounds,
 with phenols, cyanide, acid waste?  No single environmental
 factor  can have an uncomplemented effect.  How will a  fixed
 thermal increment cope with the phenomenon of synergism?
            May  I note that Dr. Pritchard stated that temper-
 ature does not  cause eutrophication;  rather do inorganic,
 and organic nutrients.  The verification of this may be
 evident when in late August at these  latitudes, an algal
 bloom of  enriched waters in summer declines,  while yet the
 temperature is  high or higher than previously. The decline
 in algal  growth occurring at elevated temperatures
 corresponds with the decline in nutrient due  to massive
 utilization. As the temperature then declines naturally
 into fall, another algal bloom occurs in October as a  result
 of a new  rise in nutrient and yet the temperature is lower.
-------
                                                        2177
                       M. A. McWhinnie



           Is it then temperature which causes eutrophication;



and what does a fixed thermal increment mean in this context?



           I have another concern, and it is with reluctance



that I note it, for it is "ticky-tacky," and it could be



subject to disproportionate criticism.  Under other circum-



stances, I would not speak to it, but as I noted earlier,



erroneousness is defeating and only for that reason shall I



mention it.  In the now well known "white paper," three



references cite the periodical, "Chesapeake Science,"



Volume 10, Numbers 3-4 (19&9) of that periodical was



devoted to the studies which were reported at the Second



Thermal Workshop of the U, S, International Biological




Program,  and 29 papers were given.  Of the three



references to this periodical in the "white paper," one was



to the introductory opening remarks to the workshop, and



another was to a resume,  I wonder why some of the data



presented in the other 28 of those papers  did not



find their way into the "white paper"?  I ask this question



because some of the data which I cited which show no thermal



effect were taken from that same volume and numbers).



           In conclusion, may I say the problem we are dis-



cussing is, in my judgment, scientific; it is complex in the



extreme; it cannot be resolved by debate; it must not be



confused with intuitive feelings; and, it shall not be
-------
                                                       217S





                       M. A. HcWhinnie



resolved if scientists leave the world of contemporary prob-



lems in our society.



           Rarely does the opportunity arise to attest to



your convictions and defend your profession in order to



serve the society and civilization of which you are a part.



I am grateful that you have made this possible.  Thank you,



           (The papers cited in Dr, McWhinnie's presentation



follow in their entirety,)
-------
                                                                       2179
                  Thermal  Discharges and Lake Michigan
                            P.  F.  Gustafson
                      Argonne National Laboratory
                           Argonne, Illinois
     At the present time the states bordering upon Lake Michigan and
the federal government are wrestling with the questions raised by dis-
charging waste heat into the Lake.  The deliberate release of waste
waters at temperatures above that of the Lake at the point of input is
not a new practice; it has been part and parcel of human occupation of
the land along the Lake and has increased at a rate connensurate to or
exceeding that of population growth.  1,'hat is new, however, is the fact
that the wisdom of this practice is now being questioned, and indeed
being subject to regulation by the appropriate agencies.  This ai^sticri-
ing and probing is a healthy sign, a further indication of the awareness
on the part of a growing number of citizens that our resources arc not
endless; that the natural environment - be it air, land, or water - dees
not have a limitless capacity to absorb wastes and other forms of insult
and assault.
     The matter of thermal discharges into Lake Michigan has been brcu^t
to the fore by the construction of six large nuclear power plants (a total
of ten individual reactors to be in operation by 1978) which intend to use
Lake Michigan water for condenser cooling, and discharging this water di-
rectly back into th 2 Lake.  The sheer magnitude (volume) of water involvcu,
coupled with the ri'.e in temperature over the condenser, tends_to__star/g2r
the imagination and perhaps_tq_b]_ur_reason.
-------
     About 4,600,000 gallons per minute (gpm)  or 10,000 cubic  feet per
second (cfs) will be required for cooling purposes  by the  nuclear plants
now under construction.  This figure does not  include the  Bailly nuclear
unit now being considered.  The cooling water  will  gain an average of 20.5°F
across the condenser.  Cooling water for the nuclear plants will be taken
from some distance off-shore, and in most cases from near  the  Lake better,.
Hence, the cooling water will usually be belcw the  ambient temperature of
the surface waters when it enters the plant, and as a result the tem-
perature difference between discharge water and lake surface temperature
will be significantly less than the AT across  the condenser.  The objective
of this statement is to attempt to place the cooling water discharged from
nuclear power plants in a reasonable perspective, to discuss what is known
and what is unknown concerning thermal parameters in Lake  Michigan, to ex-
plore the alternatives to direct Lake discharge, and finally,  to suggest a
course of action to answer pertinent scientific questions, to alleviate
economic and operational stress, and to provide adequate electric power to
residents of the Lake Michigan region.

Perspective

     Lake Michigan is the fifth largest body of freshwater in the world.   It
is of sufficient depth that  it is thermally stratified during the summer
(roughly May to  November), and is thermally mixed from top- to bottom each
spring and  fall.  The  primary source o~~ heating of  the Lake is  direct solar
and atmospheric  radiation, with river c.nd  surface water run-off providing a
relatively  minor additional  natural  heat  input  to the  Lake proper.  Major
-------
                                                                          2161
man-made sources of warm v/ater discharges Include industrial  discharges,
municipal sewage treatment plant effluent, and cooling water from steam
generating facilities.  The waste heat from this latter category is most
readily documented because of the rather direct relationship between
electrical output and heat loss across the condenser.  In addition, de-
tailed records of power generation make it possible to determine not only
annual heat discharge but to break it down into daily or even hourly seg-
ments.  The present electrical generating capacity situated on Lake Michigan,
                                                    *
and using Lake water for cooling, is about 8000 MWe.  Except for 75 HV.'e
which comes from the Big Rock Nuclear Plant at Charlevoix, Michigan, all
this power comes from coal- or oil-burning plants.  Older fossil fuel
plants such as these have an efficiency of about 30-35% (although fossil
fuel plants built recently achieve about 40% efficiency) for converting
heat into electrical energy.  Of the 65-70% waste energy as it were, about
15% is lost up the stack.  Thus, from the 8000 MWe from fossil fueled power
generation, there is between 17,000 and 19,000 MH of waste heat produced,
of which 13,000 to 15,000 Ml) is released to the condenser cooling water.
The present type of nuclear power reactors have a conversion efficiency of
about 33% (heat to electrical energy), and effectively (a few percent may
be lost directly to the atmosphere in tha plant) all of the waste heat  (67%)
is released to water across the condenser system.  Therefore, we see that
for each unit of electricity actually generated (per kilowatt, for example),
20-35% more heat (50% more when compared to the most modern fossil plants)
is discharged to cooling water from a nuclear plant than from a conventional
fossil-fuel installation.  It is also true that the present trend in power
 *
  3000 megawatts  electrical,  a  term  describing  generatini  capacity.
-------
                                                                          2132
plant construction is in terms of blocks  of 500 to  1000 Mite  per  generating
unit.  This means that the heat released  is concentrated  in  a  localized
area, and is somewhat more aggrevated in  the case of  nuclear plants  because
of the greater aqueous heat loss per unit of power  produced  as discussed
above.
     In terms of heating of the entire Lake, the discharge from  generating
plants makes an insignificant input.  Calculations  show  that if  none of the
heat from present power plants and those  proposed through 1978 were  to leave
the .Lake over an annual cycle, the temperature increase  would  be a few
hundredths of a degree centigrade throughout the entire  Lake.  Of course,
such a situation does not exist in nature, as there is continual heat loss
to the atmosphere by evaporation and non-evaporativs processes.   It  is also
true that the discrete thermal discharges from power plants  do not mix
throughout the entire Lake, but are essentially localized entities of warm
water.  It is because of this phenomenon of relatively restricted volumes
of warm water, present in one general location near shore, that  raises
questions about biological effects and other aspects relating to water quality.
     Except at times during fall and spring when the Lake is thermally mixed,
the temperature is not uniform throughout the Lake.  In suirmer,  the  mixed
surface layer (which may extend down to depths of 60-70 feet) is anpreciably
warmer (10-25°F) than the underlying waters.  Conversely, in the winter,
surface waters may actually be colder than those at greater depths.   Further-
more, there are variations in surface water temperatures over fairly short
distances  (less than a mile) and/or short time intervals (less than  an hour).
These variations are particularly evident near the shore, and are due to the
upwelling of cooler water, warm surface water being blown onto the shore, and
-------
                                                                          21 $3
                                                                      5

other wind and current phenomena.   These variations  make the term ambient
temperature somewhat ambiguous other than in a general  or average sense.
     As mentioned earlier, there are already a number of generating  plants
situated on Lake Michigan which draw cooling water from the Lake and return
the heated effluent to the Lake.  Three of these begin  to approximate the
generating capacity and thermal discharge of the nuclear stations now under
construction.  These larger plants now in operation  are Haukegan (1108 M'.-!e),
Oak Creek (1670 MWe). and State Line (964 MWe).  A feeling for the magnitude
and the environmental effects of thermal discharges  may be obtained  by looking
at and around these plants which have been in operation for a number of years.
The initial impression is that these plants have not had a very profound, or
obvious effect on the Lake, certainly not an adverse effect as annears to
have been the case with some other discharges such as sewage and chsmical
discharges.  Determinations of the lateral extent and the depth of the warm
water discharges (called thermal plumes in analogy to smoke plumes)  have been
made by infra-red over-flight techniques and by making direct temperature
measurements in the water.  A thermal discharge is wanner than ambient Lake
water and tends to float because it is less dense, spreading out as  it floats
in a manner dictated by wind, current, and the velocity of the discharge it-
self.  The Lake thermal plumes studied are a few feet (6-8 maximum)  thick
and have temperatures which are measurable above ambient (about 1°C) out
to a mile or so from the discharge point.  The initial  decrease in water
temperature from the outfall to the measurable edge of the plume occurs
primarily through mixing with the cooler water surrounding the plume, with
some loss directly to the atmosphere as well.  Over a matter of a day or so
-------
                                                                          2184
the bulk of the heat is lost to the atmosphere.  Other than providing  a
warmer region for swimming, and a more ice-free region of limited extent
during the winter, and occasional periods of local fog, there are no
obvious physical effects from the thermal discharge.  Biological  effects
are equally hard to discern.  Fish are noted to congregate near the outfall,
particularly in winter-time, but increased algal bloods, differences (cr
lack of) in bottom organisms and other indications of biological  change
have not been documented.  Bottom organisms probably are not truly good
indicators of the thermal situation because of the surface-floating character
of the warm water.  The fact that changes have not been documented in part
implies they are difficult to see, or are slight if not non-existant.   On
the other hand, it must be said that not a great deal of research has been
devoted to looking for thermally-induced changes.  So we are faced with a
situation in which obvious changes have not been observed, but secondary,
more subtle, effects at some distance from the point of input may take place.
     Additional information as to possible thermal effects can be obtained
from examining  stream and river plumes in the  Lake.  The prime example as
far as  Lake Michigan is concerned is the Grand River vhich has an average
flow of between 1500 and 7700 cfs depending upon the time of year.  This
compares with  the flow rates of 3260 and 3500  cfs specified for  the Ziori
and Donald C.  Cook plants, respectively.  The  Grand River is also warmer
than the average  surface temperature of  the Lake, varying from 5°" above
Lake surface temperature in March and Seotcniber to as much as  19°F in July.
During  part of the year the actual r^at  carried irto  the Lake  by the Grand
River  in BTU/day, for  example, closely approximates that which would bs
-------
                                                                         2185
                                                                      7

released from the largest nuclear plants now under construction  on the
Lake.  From March through July the Grand River dumps between 200 and  340
billion BTU/day into the Lake, whereas if run at peak capacity for 24 hours
a day the Donald C.  Cook and Zion plants would discharge 390 and 340
billion BTU/day, respectively.  It is interesting to observe that the
Grand River is not generally thought of as a source of thermal pollution.

Alternatives
     On the basis that adverse effects may be taking place now from the
presence of thermal inputs or the mode of introduction, or that such chanqes
may occur if the inputs increase, one must consider other means of disposing
of waste heat.  This can be done in several ways; through increased volume
of cooling water, diffuser systems which increase mixing, cooling ponds,
cooling towers, or combinations of these.  It is also apparent that in the
main, the summer months are the more critical time; hence, the time when
more elaborate cooling measures should be taken.  There is, of course, a
further option open and that is to not site power plants or other heat
sources along the Lake at all.  This is a solution for future siting, but
hardly helos in present circumstances.  From a strict economic sense, direct
cooling is least expensive in terms of initial investment and annual operating
costs.  It may, in fact, turn out in the end to be the most reasonable use
of a natural resource, namely the Great Lakes.
     Each of the various alternatives will be considered in terms of their
advantager, -nc1 disadvantages.
     1.  The condenser discharge could be mixed with additional water before*
entering the Lake.  This would serve to reduce the difference in temperature
-------
                                                                           2136
between the plant discharge and the Lake itself;  however,  it would not
reduce the total heat input to the Lake.  Such a  procedure involves the
expenditure of energy in pumping, and the larger  volume of relatively
high velocity water might produce both physical and biological  effects
such as scouring of the Lake bottom, or influencing fish movements.  The
advantage would be that modifications to present  facilities could be done
at or near the Lake shore in most instances, and  v/ould not require the use
of additional land.
     2.  Diffuser systems.  Multiple nozzle or aspirator systems will allow
rapid mixing with cooler surrounding water, and when spray devices are used,
direct heat loss by evaporation is achieved.  Such systems will reores&nt
sone expense, and the durability and maintenance of such devices has not
been field tested on a large scale.  I/here actual sprays are involved the
water loss from the Lake system will increase due to evaporation.
     3.  Cooling ponds.  These would require considerable land adjacent to
the plant to be used for this purpose - approximately two acres per MV.'e
is a rough figure for cooling pond size.  The  loss of water from evaporation
would be comparable to or somewhat greater than if the heat were put directly
into the Lake itself.  Confined bodies  of warm water such as this may become
algal beds, and require attention to prevent their being a source of odors.
The quality of cooling pond water will  decrease with time as solids left
behind by evaporation accumulate.
     4.  Cooling towers.  Wet or dry cooling towers for oower plants in the
500-1000 ''!We range renresent a sizable  capital investment.  The Davis-Besse
Plant in Ohio is spending $9,000,000 on cooling towers ""or a 872 MK'e facility.
They will also  consume  power in  their operation, and require nariodic maintenance,
-------
Such towers are fairly large in size, both height and base area.   Wet towers
will be more wasteful of water in that they depend heavily upon evaporation
for heat removal.  Solids left behind in evaporation must be removed, as
must slime and algal growths, usually by back-flushing into the Lake.  Such
a procedure will produce periodic inputs of concentrated chemicals into the
Lake.  The evaporation may lead to fog and icing under appropriate meteoro-
logical conditions.  Dry cooling towers do not waste water, but are limited
in their cooling abilities by the ambient air temperature as cooling is
done by exchange to the air passing over the cooling coils.  Experience with
dry towers is,limited to fairly small (200-300 MWe) installations.  In seme
locations, objections have been raised concerning the appearance of cooling
towers and their effect on the landscape.

Cornoi nations

     A combination of methods might prove most acceptable in the long run.
Direct discharge except in wsrm seasons, when cooling towers could be used,
is one possibility.  This would also avoid the fog and ice problem during
the winter months.  A cooling pond-direct discharge is also in this category.
     It should be emphasized that from the standpoint of water conservation,
direct discharge of heat in the Lake is most conservative of this resource.
As demands for Lake water increase, the diversion of water for cooling towers
and ponds may be regarded as an unacceptable use of water,

Field Program to npterrnne^ Best Options

     Two things  seem  apparent:  1.  That  demonstrable physical and/or
-------
                                                                      10
biological effects from present thermal  discharges are hard to find  on
the Great Lakes or elsewhere.   2.   There is a need for well-planned  intensive
and extensive field work to determine what effects, if any, do exist.   It
would also seem reasonable to  not  be overly restrictive on thermal discharges
in light of present observations.   In reality we will  never know what reason-
able thermal standards are until adequate field work is done, and to do this
it will be necessary to have thermal discharges to study.   Otherwise an
unwise alternate, the consequences of which are, in fact,  less clearly
understood, may be chosen.  There  are environmental costs  to be borne in
any event, and what must be done is to minimize these costs in conjunction
with their socio-economic impact.   This should be the prime objective of
regulation.  There is a conservation principle involved here related to
the conservation of energy principle.  In fact, energy is  the real culprit.
Feasible methods of steam electrical generation ara inherently limited to
maximum efficiencies of the order of 40-50%.  This means that half or n^ore of
the heat  produced must be discarded, and the name of the game is to discard
this heat in the manner least offensive to the environment or to use it
beneficially in some manner.  There is a feeling, based upon plenty of
evidence  to be sure, that whatever man does in terms of waste disposal is
probably wrong.   It is possible that in the case of heat,  discharge to Lake
Michigan  is an appropriate, and acceptable use of a natural resource.  It
remains to be  proven, however,  and  the natural caoacity of the Lake to
receive and to eliminate heat must  be determined.
     The  source of support to do  the necessary research is always a problem.
But consider the manner in which  monies are now being  spent.  For example,
the Davis-Besse nuclear plant on  Lake Erie  is qoing to spend  $9,000,000  on
-------
                                                                         2139

                                                                      11

cooling towers, plus operating and maintenance expenses annually.   This
exceeds the total amount spent annually on research in the Great Lakes
which is at all relevant to the pollution question, and greatly exceeds
the annual support of thermal research on the Great Lakes*  The ooint is
that more money could be reasonably spent to determine whether or not
cooling towers are a) necessary, and b) desirable, rather than going ahead
and building them without further consideration.  The money involved could
go a long way toward answering some of the uncertainties, without ir-
reversibly harming the Lakes, and perhaps would even save expenditures
in the long run.

Lako Mi chinan PI an

     A suggested plan for determining thermal effects and thermal capacity
is to allow present facilities, and those under construction, to operate,
but to conduct sound scientific investigations of the environmental effects
of such operation.  At present, theory is inadequate to predict the con-
sequences; only experiments v/ill do.  This doss not mean a license to operate
indefinitely in the face of evidence of deleterious effects.  If such effects
manifest themselves, corrective action must be taken.  Such a procedure could
be conducted under a Lake Michigan Environmental Agreement between the oublic
(throunh their representatives) on the one hand and thermal dischargees on
the other.  The results of field investigations should be reviewed by a
Commission composed of federal, state, and local representatives, in-
dustrial representatives, and members of the concerned public such as
-------
                                                                         2190
                                                                      12
conservation groups, environmental  committees and the like.   If the
findings indicate environmental  change, the Coraiission must  make a judg-
ment as to its seriousness and recommend that corrective action be taken
promptly, and may even recorrmend what corrective action be taken.  The
details of this approach must, of course, be worked out.  The main point is,
however, that some reasonable course be followed which does  not blindly
trade one environmental situation for another which is even  worse.
-------
                                                                         2191
            TESTIMONY FOR T1I2  ILLINOIS  POLLUTION CONTROL BOAIO

                Field Museum Chicago,  September 25  and 26

                   Thermal Standards  for  Lake  Michigan

                            Charles Collinson
                    Illinois State Geological  Survey,
          Coordinator for Geological  Research  in Lake  Michigan


          The  Illinois State Geological Survey has  long had an interest

in. Lake Michigan, going back ir-ore than  75 years to  the days of Levci'ett,

whose works arc still standard descriptions  for the lake region,  and

extending up through the tine  of M. 1.1.  Leighton and J. Karton L'rctz,

whose works bring us up to the present  day.  The Lake  researches  01

those years wore studies of the historical lake,  however,  and consisted

mainly of descriptions of the  physical  aspects of the  lake shores,  the

beach ridges, wave terraces and outlet  drains.   These  studied have

provided us with a knowledge of the history  of the  lake and v/ivn  it a.i

appreciation of the unique resource that  the 13,000 year old glacial la'.ie

represents.  On the other hand, such  studies did not produce the  kir.c o-

basic information our growing  lakcshore population  now requires.

          Last year,  in exa:,:ining information  sources  about the living

lake, our staff concluded that  the lake- sediments have received scant

attention as far as seuir.ientary and che.viical composition are concerned

and th;.t time is running out for the  gathering of data before the

origin.;.! character of glacial  Lake Michigan  has been scriou<;iy degraded.

Localized areas already are undergoing  environmental changes—large

populations of sludge-worms nourished  oy organic nutrients  disc.-.argec.

iii'co the lake have bcon found  in bottom sediments along the porin.ote.'

of the iL.outhfiVi. half of the lake (A;djral  'u'ater Pol] ution  Control

Ad.i.ini^tratio.-i, 106o,  Lake Michigan Uaiin Report, physical and chei.v-cul
-------
                                                                          2192





                                                                     2.







quality conditions).  In addition, surface water  run-off,  atmospheric




fall-out and industrial discharges appear to  have contributed significant




amounts of chemical trace elements to  the southern Lake Michigan Basin




(Figure 1:  Illinois State Geological  Survey  Environmental Geology




Notes 30 and 32, 1S70).  The overall result is  that the oxygen demand




of the southern Lake Michigan sediments  is about  three times that of




Lake Huron, indicating considerable organic enrichment (Benton, 193S,




Univ. Wisconsin, Milwaukee, Contribution No.  7).




          In response to the need for  more information on these conditions,




the State Geological Survey, in  cooperation with  Prof. Harry V. Leland




of the University of Illinois Department of Civil Engineering, began




an extensive examination of uncor.solidated sediments in the southern lake




basin.  Sampling was begun in mid-year 1959 from  research vessels of




the University of Michigan Great Lakes Research Division and "che Bureau




of Commercial Fisheries.  Lazer  use was  made  of samples taken off




Y/aukegan and Zion by Professors  Mc'.V'hinnie and Murphy from BePaul University,




samples furnished by the Federal Water Pollution  Control Administration,




and samples taken from a private vessel.




          The program has t\vo objectives.  Dr.  Leland and his associates




in the University are determining the  extent  of atmospheric dispersal




and surface water pollution in the lake  and particularly that which




can be measured in  tanas of trace metal  concentrations.  In the analyticaJ




chcmi::try laboratories oi the Gcolo/i~«j. ourvey this study has been




cxtcr.dcci to include analyses for xho major elements and minor constituents:




alu:.:i:u;m, silicon,  iron, calcium, magnesium,  potassium, sodix::.;, inorganic




carbon, organic carbon., titamu:.., :.:ai:,.\inc:3o,  mercury,  phosphorus a:...!




Sijlphur .  Trac<.v e) i...,or.ts doi crr.ir.cd arc-  boroa,  bury 1 li;:..i, bvo,...;-.o,




cadii.ii...i, cub.ilt, clii'oiaiiiiii, copper, lanthauui'i, nickel,  load, sc.iadiu..i,
-------
                                                                                           2193
   wise
Wouregan
                                                          05   ,30  20  Z5
                                                             KILOMETERS
                     J  Q
                     -J I '-
     Pi£.  1 -  Vopc~rj-i3hy of tho Ir.'.re  fleer, soutr.crn Lake :achi^an.  Contour-s ropro
               depth in i"cet boiov  ;:.ca,i low-v-a-tor- l^vol  (5'/6.8 feet).  Contourir.^ is
               based en U.S. /ov.y Corp.-, of ^rcir.car^ L:.J:o  Survey District  churts.

     Takcp. fron i-'i^.  2,  l.S.G.S.  ;.:iv.'.:'o:i.  Coo] .  :;otu No.  30.
-------
                                                                            2194
var.adiuia, zinc, arsenic and mercury.




           In. the clay analysis  laboratories,  the sample fraction of less




than a micron size clay and the  clay  mineral composition are determined.




Already one report, Illinois State Geological Survey Environmental




Geology Note 32, has been produced on distribution of chemical constituents




in the lake iloor sediments.




           Little has been known of the extent of accumulation of in-




organic elements in the lake floor sediments,  especially so for the toxic




metals:  lead, copper, chromium,  cadmium,  arsenic and mercury.  This is




where our chemical studies boar  directly on the problem of standards for thermal




input into Lake Michigan.  These early stages of chemical research have




shown (I.G.S. Environmental Geology Note 32, 1970) that lead, bromine,




zir.e, nickel, arsenic, mercury and chromium have accumulated and probably




are still accumulating in the upper few centimeters of lake floor sediments.




Concentrations, which reach levels ranging from 10 to more than 90 parts




per million, correlate directly  with  the organic carbon content of the sedi-




ments and somewhat less directly with the less than 2 micron size clay




fraction in the sediment  (Figure 2) .   T.-.is fraction constitutes as much as




50'7o. of the sediment in some areas of  the lake floor.  Thus it appears that




sediments with high organic content  in time will also be high in toxic




metals.




           Although it is speculative at this stage, because v.e do not




'.'.::o;: the source of the organic matter, the point to be made- in this




respect is that local increases  in productivity of algae and ether




plankton duo  to local temperature •..".creases could possibly cau.,o co.icon-




ir^tior... oi' partJculatc organic  c.-r-jon th.. , might fix sig; ificn/.t U:..,V.:,V-L-;




o..'  iG.x-c v.-li . ..;::tt,.  V.-.c-rc  tk<_-L;«j  ooou;' -.'. tl.o :;naiiov; \;a i.ort, o^" the l^ko,




"i.i'iuy could '.o  oi'  t,x.nou.y  concern.
-------
                                         2195
                          c
                          C"
                         -s
                          tr
                          Z

                          o
                          cr
\
 \
   \
-------
                                                                          2196
           Additionally, inasmuch as we  do not  know the procedures




whereby the metals beco.v.e fixed by  the scdirr.er.ts,  we should closely




follow any changes in  the lake that might  significantly increase the




bioniass and should study in  detail  the conditions  existing before any




thermal or other  input is considered and then continuously r.cr.itor the




area for signs of significant changes  in water quality, plant ar.d ar.irral




communities, and  sediment composition.




           Coequal with the  geochcr.dcal  studies of the Survey has btsn




a coupreher.oive program for  napping sediments of the lake fleer and




describing the stratigraphic sequence, composition and thickness of




sediments under the  lake  (Figures 3,4).   The cores, which range fro:.




3 to 20 feet in length, penetrate the  soft lacustrine clays, sands an>a




silts and occasionally encounter the underlying glacial till that occurs




over most of the  southern lake basin.  These studies have provided great




quantities of new data and  unexpected  discoveries.  For exa-pie, the




lacustrine units  are of special  interest in that their water center.:




ranges betv/een 90 and  2007o  of dry weight (Figure 5).  In addition, they




are thixotropic,  that  is without bearing strength when disturbsc, but




otherwise appearing  solid.   These sediments range up to 30 or -10 feet




in thickness and  cover :nore than a  thousand square rr.ilcs of la::a floor.




Their mineralogy, chemistry,  age and stratigraphy are only no-.; being-




detailed.  Their  role, if any, as reservoirs of sublake water should ~u




taken into account in  any lake water or  heat budget.




           In brief, the main impression gained fro:.! our st-c.lc-s is -..:at




there is a very  serious absence  o.J  basic .icicntific data abo'.t Lake




Michigan, vl.at uuat be  gathered  if ve  aru to effectively r.ch^.vc- ar.d




)..a^.ntain the good healtn  ar.d co/.'cii.ac.c; u.-r.oJalnc-JS o^ ~ho la.:^.
-------
                                                                                        2197
H a '.I
o°'i  Woukcqon
         o j:; •  .;. • •;:::•;  Sheboygan
                           South Hoven
        , -J |	— _.  Carm:
         <-• i—

'    ,    , LJ • —-r—- -
    I    i 	 i.
                                            Scnc on beeches
                                            Soft, dork grey to brown  scr.o/ s..t to
                                               sand,  end gravel

                                            Dark  groy silty clay v/ith  bicck ieds cr-
                                               mottling;  more compact  tn",  V.coke
                                               Wcmoer
                                             Dcrk brownish gray day;  c  few
                                               and sorne biack mottling
                      Reddish brown clay
                             Wilrnsite Sec •   DcrK groy  clcy  v/ifh  sorr-.e  o ::••.  ^ea;
                                             Reddish  brown cloy
                       Reddish grey  cloy
                      Sond,  scndy  pebbly c!cy,  s..r,  c.ic
                         Pvjbble  conglomerore
             u;.a ,1-lyin.s .,C'UU:iCi\i '^a.ic  ;-:j..\..: ."..
-------
                                     2198
a,.,. 4
                                       ^ O
                                       o o
-------
                                                                                           2199
                       GRAIN SIZE (%)
    CLAY MINERALS
(Relotive o&unaonce based on
   diffraction effects)
CALCITE/OOLOMlTE

    RATIO
                                                                              NONCLAY MINERALS

                                                                       s
                                                                       %
                                                                                          g
                                                                                       B E ii
100    ISO
                                      IOOJO O20JO4O10607O8O5OIOO
                                                               1056 76 1 A3 2
                 ?ig.  5 - Grain  size and mineralogy  of core 145.


                 Taken  from Fig.  4,  I.S.G.S.  Environ. Gool. Noto No.  30.
-------
                  Surface sediments on the bottom


                        of Lake Michigan
                                                                2200
   v,V."'^V~
   ."•  r'r\ ^   \ \
LAKE •   •  V \ \ \ \
FCR.-IST *.  Aj \ \ \  \ :

   ^       \\\  \
   V.      \ \ \  \
   - 4 , -  	\ \ -•	
      V      \.^
             Vx •

      L.X-'.    ' ^
         \
 \
~\
           V
            s
/'
              \
                       *fj
                                          . ' * \-:\'J b.f FALO
-------
                                                                     2201



                                                                   5.






         "Here arc our specific views on thermal  input  standards  for  the




lake:




          We have reservations about the effectiveness  and  correctness




     of any blanket temperature standard that mieht be  imposed  at the




     present time.  Among other things,  lake water,  temperature,  current




     velocity and direction,  turbulence,  wind force and direction,  as




     well as the wind exposure of the facilities,  rainfall,  lake  depth,




     bottom, topography,  bottom sediments and the  biota  are  all  elements




     that will control the effect of thermal input and  distribution.




     Because of the large number of these seasonal,  daily,  even hourly




     variables, which are different for  each input site,  each site should




     be considered and controlled as a separate entity.




          If input to the lake is allowed,  then we recommend that each




     site be thoroughly studied before construction and closely monitored




     thereafter, not only for temperature levels,  but for effect  on.the




     various components of the lakes. Various scientific,  governmental




     and private organizations could combine to accomplish  such studies




     much as is now being done in the Waukegan-Zion area.




          In final analysis,  however, our knowledge of  the  lake is still




     so small and the value of the lake  resource  so valuable in terms




     of its use for hundreds  of future years,  we  would  welcome  the




     exclusion of input of any kind to the lake that does not equal or




     exceed the optimum conditions now existing in the  lake.
-------
                                                        2202
     TESTIMONY OF JOHN D. HARPER, DIRECTOR




ENVIRONMENTAL PARAMETERS RESEARCH ORGANIZATION




                 SUBMITTED TO




LAKE MICHIGAN ENFORCEMENT CONFERENCE WORKSHOP




               CHICAGO, ILLINOIS




       SEPTEMBER 28 THROUGH OCTOBER 2, 1970




       FOR INCORPORATION INTO THE RECORD
             PREVIOUSLY SUBMITTED TO




       ILLINOIS POLLUTION CONTROL BOARD




                SEPTEMBER 25, 1970
-------
                                                                                  2203
                           TESTIMONY OF JOHN D.  HARPER
                                    BEFORE THE
                        ILLINOIS POLLUTION CONTROL BOARD
                                    FIELD MUSEUM
                                  CHICAGO,  ILLINOIS
                               SEPTEMBER 25 AND 26, 1970
Mr. Chairman,  Members of the Board,  Ladies and Gentlemen:

My name is John D. Harper.  I reside in Hanover Tov/nship, Cook County, Illinois.  My

education and training is in engineering, both civil ond mechanical.  I  am a Director of a

non-profit Illinois foundation known as Environmental Parameters Research Organization, or

by its acronym, EPRO.  EPRO's chief function is the scientific investigation of problem areas

in our society.  EPRO is funded by private contributions and foundation  grants and derives

no part of its income from vested interests, either pro or con,  on the subject matter under

investigation.  For example, the EPRO program for an ecological study of Lake Michigan's

western shore between Waukegan and Kenosha is not funded in any part  by either the power

companies or governmental, federal, state or local, regulatory agencies.


In a publication entitled, Water Pollution Problems of Lake Michigan and Tributaries,

January,  1968, issued by the Department of Interior, FWPCA, Great Lakes Region, a

recommendation was made on page 66 as follows:

                "14.  A special investigation be made of the effects which the
                installation of large power plants, both  fossil-fueled and nuclear,
                have on Lake Michigan; this investigation to include studies of
                benthic fauna, radioactivity, water temperature, heat diffusion
                and lake  currents.!l

At the four state conference on pollution of Lake Michigan and its tributary basin held

January 31 through February 7, 1968, the conferees recommended the formation of a
-------
                                          -2-
special committee on nuclear discharges and thermal pollution aspects of nuclear power

reactors.  This committee, chaired by F.W.  Kittrell, did its work and reported to the second

session of the four state conference on February 25,  1969, with several  recommendations,

two of which I would like to point out at this time:

             "6.  FWPCA coordinate a comprehensive study of the effects on
             water quality and aquatic life  of thermal wastes from a large
             nuclear power plant on Lake Michigan,  with attention to various
             methods of cooling water dispersion.

             7. FWPCA coordinate a study of the effects on water quality and
             uses of radioactive wastes from a large nuclear power plant on
             Lake Michigan, with especial  attention  to the concentration of
             radionuclides in aquatic life."

In the fall of 1969 I inquired of the then FWPCA, now FWQA, what action was intended

commensurate with the recommendations of the Kittrell committee.  It was my understanding

that because of budgetary considerations, the recommendations to study the pre-operational

ond post-operational site of a nuclear power generating facility could not  be undertaken to

the extent recommended  by Kittrell's committee.  Recognizing that it would be imperative

to have data obtained in-situ upon which to evaluate  the impact of a nuclear power

generating facility on the local environment, several  scientists and other individuals

including myself formed a group to initiate and conduct a multiparameter ecological study

of the western shore of Lake Michigan centering about Zion, Illinois.


In the publication,  Physical and Ecological  Effects of Waste Heat on Lake Michigan,

issued by the U.S. Department of Interior, Fish and Wildlife Service, September, 1970,

it is stated on page one:
-------
                                                                                      2205
                                          -3-


          "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 needed now; since it is not
          available, however,  interim standards must be set for Lake
          Michigan on the basis of existing knowledge."

On page 91 of the same report the concluding recommendation ?s:

          "11.  On the basis of the above points, it is  concluded for
          ecological reasons that  no significant discharge of waste heat
          into Lake Michigan should be permitted."

I agree with these two statements  as I  do with most of the material presented in the report.

As is so often the case, when decisions must be  made effecting the utilization of any of the
          •
Great  Lakes, be it Lake Michigan,  Lakes  Huron,  Superior, Erie or Ontario, the decisions are

based upon little, if any,  knowledge that  we possess of these lakes concerning their biological,

chemical, physical,  geological and meteorological characteristics. The scientific research

activities in the Great Lakes, and now let us confine ourselves to Lake Michigan,  have been

minimal in the last three or four decades and practically non-existent before that.  Some

educational institutions bordering Lake Michigan namely University of Michigan, University

of Wisconsin at Madison and at its Milwaukee campus,  and DePaul University in Chicago,

have recognized that in depth multiparameter scientific studies of Lake Michigan are

imperative if answers are to be  found for the many questions confronting us today.


One of the major reasons why research in Lake Michigan and the other Great Lakes is so

far behind similar oceanographic research  in the saiine waters in the Atlantic, Pacific and

other oceans of the world is the unique fact that the Great  Lakes  have no military application.
-------
                                         -4-                                           2206










No submarines are permitted to operate in the Great Lakes by treaty with our neighbor




to the north. Those submarines that are in the Great Lakes have their propellers removed




and are strictly for training purposes  in the former Corn Belt Fleet of the U.S. Naval Reserve.




Now it  may seem odd that the lack of military application to the Great Lakes would be a




factor in our present limited knowledge of these bodies of water, but when  you  realize




that a great preponderance of the data collected in saline waters is to determine the




conductivity and temperature of the water for the express purpose of plotting the transmission




and propagation of underwater sound waves which in turn has a great bearing on underwater




military capabilities, it becomes obvious that with no need for this data in  the  Great Lakes




because of the absence of submarines,  the basic data we need,  along with all the attendant




biological,  chemical  and physical data that is simultaneously obtained, is  lacking.  Now




there have been scientific cruises on Lake Michigan conducted by the University of




Michigan on their ships and conducted by the University of Wisconsin on ships of convenience,




usually  the Ludington car ferries.  DePaul University has availed itself of the opportunity




of using a research vessel that is operated by EPRO for the purposes of graduate instruction




in the aquatic sciences and for biological research and surveys of existing pelagic and benthic




life.  In the context of a complete over-all picture of Lake Michigan, it is necessary, it is




imperative, that research activities in the lake be conducted continuously throughout the




year at  innumerable vertical  and horizontal stations.  This one shot, one observation




approach as has been conducted by so many of us can be  disasterious if as we find,




extrapolations are made on the data  presented involving a host of complex  issues such as that




which is before  this Board today.  I would liken the data from the present state of Lake




Michigan research, if I may, to information sent by the wife here  in Chicago of a Gl in




Viet Nam who  has written that the temperature was 92 degrees in Chicago  in mid-September,
-------
                                         -5-







1970.  The Gl's buddy may have received a letter from his family also in Chicago a few




days prior or later that indicated the temperature  was 47 degrees.  The picture they have so




far removed from the scene, as far removed from the conditions in the lake as we are now,




seem vastly different and would be confusing.  While the data that has been collected to




date is of extreme value, it is all we have; and it is necessary to obtain considerably more




before the momentous decisions effecting regulatory agencies, such as this Board, can be




enacted with the degree of certitude so necessary on such  complex issues.







The major reason there is a dearth of information about the lakes is that funding sources are




practically non-existent.  The Sea Grant Universities  of the University of Michigan and




University of Wisconsin have some small funds  that can be earmarked for activities in the




lake.  Other universities, including DePaul, that have evidenced interest are hampered




by budgetary considerations that preclude a viable effort  in the lake. If no funds are going




to be available, which has been the case to date, then we shall continue to be ignorant




of the many complexities that we should bs aware of when decisions effecting all of us,




such as the siting of once through cooling water power plants, must be made.  I respectfully




urge the Board to do everything in its power to make available the means whereby institutions




desiring to conduct  studies of Lake Michigan are adequately funded.







Some regulatory agencies occasionally engage in  water and bottom sampling for the purpose




of determining existing criteria as it relates to their operations.  This is to be commended




and encouraged,  and it is hoped the data that  is obtained  is made available to all wishing




to utilize  it. One factor that influences the frequency of  sampling is the capabilities of




the watercraft the agency utilizes to take the samples. Lake  Michigan, as you gentlemen




are well aware of, is moody and reacts quickly to changing meteorological conditions.
-------
                                                                                       2208




                                          -6-







It is often said by the foreign flag seamen that they prefer the North Atlantic to our




Great Lakes at their worst.  The combination of storms and squalls can impart heavy




damage on shore-site facilities, underwater construction and ships and boats on station




in the lake.  Very seldom can a 16 ft.  outboard be used in Lake Michigan as  it could




in the Des Plaines River for limnological studies.  Even a 30 footer in the lake must take




all precautions because of the rough sea situation that can occur. EPRO employs  a 54 ft.




steel hulled vessel and will have in operation next year a 100 ft. research vessel for the




purpose of greater capability in the lake on a more consistent basis.  The ship time operating




cost on the lakes  for research purposes approximates that in dollar value of those research




or oceanographic vessels operating on the oceans. For those agencies that are oriented




along the lines of a 16 ft. outboard doing all the  work for them, this can be quite shocking.




To conclude now, gentlemen, I would  like to emphasize that considerable additional




research is needed in Lake Michigan now and that the funding to conduct this research must




be obtained if the questions  we are being asked today about the eutrophication  of the lake are




to be intelligently answered so that we may  wisely utilize and preserve this great  natural resource .




The position of myself and the organization I represent is that at the present we do not have




enough  knowledge on what impact the  introduction of heated cooling water from nuclear or




fossil-fueled plants will have on the lake's biota  and chemical  and  physical characteristics.




Without sufficient data upon which to base  an educated appraisal of the situation, I  suggest




ihat  a Moratorium, voluntarily accepted by  the power companies and the regulatory  agencies,




be immediately established on once through  cooling water power plants, be they nuclear or




fossil fueled.  It should be agreed between  the pcrties that those generating stations  now
-------
                                                                                      2209





                                             -7-








nearing completion or completed employing the once through cooling water system should




be permitted to operate contingent upon the establishment of provisions to modify deleterious




effects if they become  evident, that application for construction of once through cooling




water type plants be  suspended and/or modified to comply with future regulations to be




promulgated after the investigations of existing once through cooling water facilities




are fully known.  This  Moratorium on future once through cooling water type electrical




power generating stations should satisfy reasonable men that all efforts are being made to




serve society with both ecological and economic consideration.
-------
                               TESTIMONY                         2210

         HEARING ON PROPOSED THERMAL STANDARDS FOR LAKE MICHIGAN

                     ILLINOIS POLLUTION CONTROL BOARD
                            Chicago,  Illinois
                            25,  26, September
                                   1970

                 Mr. Richard J. Kissel, Hearing Officer

     I am Mary Alice McWhinnie, professor in the Department of

Biological Sciences at De Paul University in Chicago, and Director

of the De Paul-EPRO Ecological Study of Lake Michigan.  My credentials

for speaking to this Board relates to my professional experience in

crustacean biology in study of effects of temperature changes on

invertebrate animals in fresh water and Antarctic marine water, and

to the work we are engaged in on Lake Michigan.

     Mr. Chairman.  I am pleased to respond to the need for infor-

mation on the complex topic of the ecological influences of industrial

use of water resources in general, and Lake Michigan in particular.

I believe that the need is high, first because of the long term plar.s

which call for the use of lake water by the rapidly expanding devel-

opment of nuclear powered electric generating stations, and second,

because of the unprecedented concern for environmental quality.

The plans for the future are increasingly well known but, for co-

herence of presentation I shall briefly restate them here.  In an

AEC report of June, 1970 it was stated that:

       16 nuclear plants were operable at that time,
                                             producing,   5,073,700 !-"•
       54                were in construction,
                                            to produce,  43,755,90C ;~.
       34                were planned,      to produce,  32,591,OCC I-~
        8                were in earlier stages of
                             planning,      to produce,   7,539,000 }7.

       giving a total of 113 plants within the U.S.,
                    to reach an expected production of  ,  89,010,6^ C }7.

       100 of these are in the eastern one-half of our country ar.d
-------
                                                                    2211
all are expected to be in operation by 1978.  As of September, 1970

a longer term projection was published by the U.S. Department of the

Interior under the colloquial term of a 'white paper1, wherein the

predictions were confined to Lake Michigan.  The values cited there

were derived principally from a report by Acres (1970) and represent

the sum of both 'fossil-fuel plants and nuclear powered plants.  It

is realistic to treat the two types of plants together since heat,

the topic of these hearings, is a common by-product of any electric

generating station.  Briefly, assuming, a) no change in stations

planned; b) no change or improvement in technology throughout that

time; c) no increased efficiency in energy production or utilization

between 1968 and 2000, the growth in electric power production and

heat loss have been estimated to be:
                             1968           2000         Increase
      Kilowatts (at       7,600,000      73^500,000      9.6 fold
       full capacity)

      Energy loss as          29.85          414.67     13.8 fold
       heat (billions,
       BTU's/hr.)

     Other sources of heat addition to Lake Michigan are negligible

in contrast.  However, whatever its source, the question we are asking

is, "what are the ecological consequences of heat addition to Lake

Michigan, and what are our alternatives concerning policy and standards"?

It has been recorded in many places that the present state of knowledge

on the environment and the complex interdigitation of physical,

climatic, chemical and biotic characteristics is too poorly under-

stood to state, with certitude, what the effect of thermal additions

will be on the ecosystem and that only a thorough ecological study of

an area to be influences, will provide the information essential to

knowing whether such technological developments can be borne by the
-------
                                                                    2212





environment.  Alternate views hold that in.'terms of the possible effect



of such heat additions (based on the projected growth), caution directs



that an upper limit on thermal increment be set or, that no increment



should be allowed.  These views have taken the form of three proposals



which, in general, state that use of natural water shall not increase



its' temperature, more than • 5 F (or 3 F) above  'natural ambient1 terr.p-



erature; it shall not exceed S5°F (29.4 C) or, it shall not exceed



37°F (2.8°C) to 77°F  (25°C)  depending upon the season, or, that heat



at any level shall not be added to a natural body of v/ater.



     I have at least a limited appreciation of the need for, and the



responsibility of, regulatory policies to protect our environment.



However, within the context of existing data I do not believe that



we are in a position to justify a fixed value, such as these are, as



a consequence of the variables with which we are faced.  I am aware



of the fact that such a statement as this provides no support or



assistance to policy making bodies;  I appreciate that a degree of



risk prevails when delays are encouraged in the interest of establish-



ing securities against environmental deterioration.  I ain  further



aware of the most difficult of truths relative to seeking  'best



estimates' concerning the development of policies; namely, that



one who is  concerned about thermal dangers can cite published scientific



data which indicate that certain selected species of organisms have



been shown in laboratory study  (or field) to have upper lethal temp-



erature values which will be reached with waste heat  addition;



contrariwise, others recognize such a possibility but take a more



moderate view, and can also cite publi: hed scientific data which show



that certain selected species are taken  to their biological optimum



when provided a warmer environment.  Each is right, each is honest,




each is scientific and each is supporting his  views to the best of
-------
                                                                2213
existing knowledge; they differ in their intuitive sense and their



disparity reflects the presently unacceptable reality that we do



not have definitive information which will provide the solid plat-



form of knowledge upon which reasonable and realistic policies



should be based.  In this context I should like to present some data



which of necessity y$ selected, but that which will hopefully place



in balance the perspective of persons who have the responsibility to



deal with this problem.



     The following unpublished temperature data have been derived



from Lake Michigan in the vicinity of Waukegan and Zion, Illinois



during the summer of 1970:



             Vertical Water Temperatures (6 July 1970)
         CDT
Waukegan
Sta.S 52
(0945)
16.5°(61.4°F)
16.4
15.5
15.4
15.3
15.0
Vertical Water
Zion
Sta.£ 1
(1115)
16.3°
16.2
16.0
15.5
14. 8
14.5
Temperatures (30

Sta.= 7
(1530)
17.0°(62.'6°?)
17.1
16.4
15.9
14.5
12.9
June 1970) (132
                                 Waukeaan
Sta. if 50
17.2
15.6
15.3
14.0



Sta.i 51
16.7
16.0
14. 8
14.6
14.0
11.2

Sta.£ 52
16.7
16.5

15.8
14.6
14.4
14.3
Sta. 2 53
18.2


15.1
14.3
14.2
14.0
Sta.= 55
19.4
16.2.

14.0
13.5
13.2
13.1
-------
Waukegan
Sta.£ 51
20.2
20.0
19.4
18.9
17.4
15.2
Sta.S 52
20.9
20.9
19.4
19.2
16.5
14.0
Sta.# 53
21.0
21.0
23.0
19.4
18.6

                                                                      2214


                Vertical Water Temperatures (24 Aug. 1970)

                                  Waukegan

  ta.a 50    Sta.S 51    Sta.g 52    Sta.jt 53    Sta.S 54    Sta.3 55

  21.3         20.2        20.9        21.0        21.2        21.6
  20.6         20.0        20.9        21.0        21.2        21.6
  22.2
                                                   20.8        21.2
                                                   19.8        20.0
                                                   18.4        18.4
                                                   16.4        15.6

     These values have been given to indicate that:

      - a policy limiting thermal incremontc u_> less thafy,  "a 1-degree

Fahrenheit rise over natural water temperatures at the point of dis-

charge" , caTinot in my opinion be achieved since, in practice, most,

ifhot all, uses of water result in some thermal increment,  if for

no other reason, residence within the facility using the water;

      - a policy limiting thermal increments to + 3°F  (1.6 C) or

•f5 F  (2.8 C) must also qualify under what solar heat input level,

or at what tine of day?, or at what point in space .(and 'I understand

'at the outfall1)?,.and under what current  (and wind) conditions?

        a policy limiting a thermal increment to a mixing zone whose

length or radius is 5280 Ft. or less does not reckon with currents

and/or wind action; there are some data which suggest that under

certain wind conditions a  'tongue1 of warmed water may extend 2-3

miles in what is apparently a narrow band along a shoreline  current;

this will in all probability apply to any body of water warmed by

any means.

     At this point  I  am concerned that these points  can lead to the

notion that, "about nothing can we be sure", and further, that due

to the complexity of  physical  factors we  cannot reach a realistic  and

practica-ble standard with  respect to thermal modification  of  the

aquatic environment.  While there is some  truth to  this I dofnot see
-------
                                                                   2215

the disabling objections to be unsurir.ountable.  I do see them to be

significant in their call for study and, in their call for a reluctance

to specify a numerical limit with respect to any environmental para-

meter with our present state of understanding, in particular, " x°F "

or, " x ft. " for a mixing zone.

     It can be legitimately asked, how can a biologist view that which

is more widely held as an environmental threat, with such seeming

insensitivity?  In answer, may I offer:

       -  I do have reasonable concern for thermal increments in the
          aquatic environment;

       -  I do recognize that the environment has a finite "carrying
          capacity" for chemical and physical additions or variations;
          I am in full agreement with Sorce (1969) that while a hear
          dissipating source may raise the temperature of a receiving
          body of water only a few degrees within a limited area frcrr.
          the discharge canal, an accumulation of heated effluent frcr.
          many sources could prove disasterous over many r.iies.  Thus,
          the projected increase in number of sources using Lake
          Michigan water in the next 30 years could prove to be
          ecologically critical.  The limit of heated effluer.-s which
          an ecosystem can endure without adversely altering ics
          biological balance can only be determined by a total ecoicgical
          study of an area.

       -  I do recognize that biotic communities respond differentially
          to variations in physical or chemical qualities in -heir
          environment.  This notion has been fundamental ro the principle
          of succession as evidenced in ecological systems;  seme ds-a
          I have presented for fish can be cited again,

                      Fish Species          Temperature Preference

                   Carp                        32°C   (89.6°F)
                    (Cyprinus carpio)
                   Perch                       24 C   (75.2°F)
                    (Pc^rcji f lave scons)
                   White Fish                  13°C   (55.4°F)
                    (Coregonus cluooaformis)

          I am aware of the direct effect of temperature on natural
          phenomena and thus on biological systems; I recognize that
          temperature increases are often employed to increase
          biological actjvity.
-------
                                                                     2216


           I am convinced that while highly controlled laboratory
           physiological studies on particular plants,animals and
           microorganisms have contributed significantly to cur
           understanding, that we cannot extrapolate these findings
           directly to the natural environment; these tv;o approaches
           complement each other, —  they are not a substitute for
           each other.

     With these and other considerations I should like to cite sorr.e

data which bear on this subject.

     In a study of benthic fresh water protozoa, Cairns  (1969) has

reported that small gradual increases in temperature have no effect

on the protozoan community of the Savannah and Potamac Rivers; this

conclusion prevails after 9 years of a study still underway.  The

temperature increase was downstream of a heated water discharge ar.d

the water temperature was "a few  C over ambient".  On the other hand

Cairns had previously shown  (1968) that a sudden temperature shock

caused major changes in the number of species present.   The differences

between  'chronic' and  'acute1 temperature changes are well known and

apply generally to all species of organisms.  In the 1969 study a

temperature shift of 20°C to 35°C  (ca. 95°F) within 10 minutes and

sustained for 6 days showed an increase in protozoan species on the

sixth day after an immediate decline from 26 to 7 species apparently

surviving.  In another- similar experiment where the experimental

temperature was shifted abruptly  from 21°C  (69.8°F) to 31°C  (87.8°F)

the number of species fell from  34 to 21 and within 32 hours had

returned to the initial value though  the temperature regime lasted

three days.  Shock effects such  as these are not likely  to occur in

nature and thus the effect on species diversity would also be  less.

In any case these data indicate  no effect on a protozoan community.
-------
                                                                  2217
At an earlier time  (1956) this author showed that different terr.p-
erature levels did influence the relative predominance of algal

groups, e.g., diatoms were the predominant types at 20°C  (63 F)
                                                 o       o
and below; green algae were predominant at ca. 33 C  (91.4 F) while
blue green algae developed maximally at 40°C  (104 F) ; this pher.oner.cn

has been called competitive exclusion and relates to the earlier

reference I made to succession of biotic communities as enviror.-er.zai
conditions shift in any aspect.

     Benthic marine molluscs (mussels) and fishes were shown to be

more .sensitive to temperature increases  (Pearce, 1969) and, while
the commercial mussels had somewhat different tolerances to ter.p-

erature depending upon their point of origin  (intertidal or lirtoral)
     o       n
at 24 C (75.2 F) abnormalities appeared  (attachment, clustering, ezc.).
However, their southward range was a region of  26.7 C  (ca.  73.5 F)

indicating perhaps tolerances developed in larval  life  not  capable

of adjustment in adult life.  In this same study starfish ar.d  snail
                                                   o      o
feeding activity declined at temperatures above 20 C  (63 F).

Nauman and Cory  (1969) studied benthic animals  by  way of test  panels

placed at the intake and outfall of the Chalk Point, Md. fossil-fuel

plant in the Patuxent River.  The temperature difference be-ween

intake and outfall was approximately 6.3°C  (ca. 11.5 F).  Ccr.p arisen

of the animal populations showed a 3-fold increase in biomass  at  the
outfall relative to the intake with little or no change in  species

composition between the two.  The epifauna represented  considerable

diversity including some 25 species from 8 major   animal groups

(including nemertean worms, flntworms, annelid  worms, arr.phipods,

bryozoans, anemones, clams, protochordatos, and a  variety of

crustaceans).  The temperature range of the effluent, seasonally,

varied from ca.  10°C  (50°F) to 37°C  (98.G°F) arid production '..-as
-------
                                                                     221S
based on dry weight.  Species diversity, a ratio of number of species

present to the total number of individuals present, did differ between

the two points and was generally higher at the outfall.  Some species

disappeared at the effluent at certain seasons but were found in

abundance just outside of the effluent canal  (thermal preference/

gradient).  An increase in size of barnacles occurred at the outfall

and higher production occurred there even with fewer species present

(ca. 3-fold greater than at the intake).  Summarily, in the epifaunal

community there were differences in species number  (more, though

some species disappeared at certain months), total number (more),

biornass production  (more),and species size (greater) as a consequence

of a thermal increment.  During the warmest months  (July, August)

fewer species were present at the outfall.

     Barnett and Hardy  (1969) in a summary report of marine ber.zhic

clams  (Tellina tenuis) studied a coastal environment  (Scotland) for

four years before a heated discharge appeared in the environment ar.d

for five years after.  They report that there were  large seasonal

fluctuations in Tellina but that none of the  changes were attributable

no warm water effects.  Conversely, Tellina grew more  rapidly in the

post-effluent years with the greatest difference being in young stages
                           /L. ^Y^'^^O^X^o
and there was no evidence of*tne spawning  characteristics between, the

two studies  (pre-,  and post-).  Kowever, the  snail  Xassarius rericulatus

while  not different in population density, showed  thinner shells than

others in the species range which were  not influenced  by the thermal

increment.  Advanced breeding and egg hatching occurred  for  a species

cf snail, 'a copepod and amphipod in the vicinity of the  thermal i:is-

charge.  These species  are irrtertidal;  no  effects  were observed in

sub-tidal bottom communities.
-------
                                                              2219


     The scientific literature is available for anyone to obtain

examples of this kind.  As I noted earlier, scientists have, and

probably will continue to present, examples that place emphasis

on various aspects of biotic responses to changes in environmental

temperature.  Despite this, regulatory agencies are unable  to set

realistic and meaningful limits concerning the use of natural

water resources for excess thermal discharges, —- because  we lack

an understanding of the carrying capacity of them.  As time passes

and more uses are planned for water sources we must cease to be in

this position and, in my judgement, only hard data will make that

possible.

                              Literature CjLted  (in sequence presented)

U.S. AEC  News Release, Vol. 1  June, 1970

U.S. Dept. of Interior, Fish and Wild Life Service  (September, 1970)
     Physical and Ecological Effects of Waste Heat on Lake  Michigan

Acres, H. G., Lts. 1970  Thermal inputs to the Great Lakes  1968-2000.
     Inland Waters Branch, Department of Energy, Mines, and Reservoirs
     Canada Centre for Inland Waters.  Niagra Falls, Ontario.

Unpublished Data, from De Paul-EPRO Project: Ecological Study of Lake
     Michigan.   (Data available from the Director)

Sorge, E.V. 1969  The status of thermal discharges east to  the
     Mississippi River.  Chesapeake Sci. 10:131-138.

Cairns, J., Jr.  1969  The response of freshwater protozoan commun-
     ities to heated waste waters.  Chesapeake Sci. 10_:171-lc5.

Cairns, J., Jr.  1968  Rate of species diversity restoration follow-
     ing stress in protozoan communities.  Univ. Kansas Sci. Bull. _£:':
     209-224.

Cairns, J., Jr.  1956  Effects of increased temperature on  aquatic
     organisms.  Indust. Waster. .1:150-152.

Pearce, J.B.  1969  Thermal addition and the benthos, Cape  Cod Canal.
     Chesapeake Sci. X£:227-233.

Nauman, J. W., and R. L. Cory 1969  Thermal additions and epifaun:!
     organisms at Chalk Point, Maryland.  Chesapeake Sci. XO : 2LS--21 i .

Barnett, P.R.O., and B.L.S. Hardy  1969  The effects of tempcratur ;
     on the benthos near the Hunt orston generating station, ficotlr...c.
     Chesapeake ScJ. 30:255-256.
-------
                                                       2220





                       M« A* McWhinnie



           MR. STEIN:  Thank you,  Professor McWhinnie.



(Applause)



           Are there any comments  or questions?



           MR8 JETTERQLF:  Tes.



           Dr. McWhinnie, I believe you are speaking strictly



as a scientist who has been working in plume areas, and lest



there be any doubt, could you cite some of the sources  of the



funds, the money that enables you to do this work?



           DR. McWHINNIE:  There is a moment every day  when I



grow facetious and I never know when it is going to hit.



But let me say that  a year ago, the Environmental Parameters



Research Organization was founded and incorporated within



the State of Illinois as a not-for-profit organization  about



which I knew almost nothing.  Only later did I come to  know



about it.  And I learned that its director and founder  did,



in fact, on his own obtain from a proprietary interest  of



his funds that would go into this non-proprietary organiza-



tion.



           Perhaps like any power company or any other  such



group, he reached out to try and find scientists who might



have a commitment to the environment, and thus he did come



upon some of us, and the program was worked on through



last winter and it was initiated in the field last springs



           But the funds were rather limited, and I regret
-------
                                                       2221






                       M. A. McWhinnie



to say that in my own inimitable fashion I went screaming



to the president of the university and said, "I have to have



money.1*  And, as everyone here would know, if you don't



request it a year ahead of time, and if you don't get it



written into the budget, there isn't any.



           But somehow in his own commitment, which was



demonstrated when, as chairman of the department of biologi-



cal sciences in the early sixties, he held the first



privately sponsored water pollution conference in Illinois



— and I am delighted to say that Mr. Murray Stein was its



luncheon speaker in 1962 — I am not sure he remembers —



but, in any case, that man is now president and he brightened



my life and gave me a little money and we are once again at



the edge of those funds.



           I have two choices.  Let us not be so foolish as



to think that those of us who undertake such a project as



this are not attracted to those upon whom the press of



information  is the greatest. You call them power companies.



           Yes indeed, ladies and gentlemen, they have



attempted in, I believe, their own motivation to finance



this; they have tried to give us money.  I am grateful



for a typewriter and a carbon copy.  For anyone present,



we can demonstrate that in a state of destitution we had



the guts to say, "I am sorry <>  I can't take your money."
-------
                                                        2222






                     M. A. McWhinnie



          And, as the president said to me recently when




I said, "You know, I have these people on the payroll and



I don't have any money."




          He said, "We will try and find it someplace."



          How unfair is an American public that demands



that the burden of proof is on the user, and they deny the




scientist the right to use those moneys?  But this is where



we have been put and given an infinite commitment to the




objective reality of truth, I should say, "By God, we will



do it."  And I don't know where the money will come from.



          MR. STEIN:  Do you have any other questions?



          Miss McWhinnie, I appreciate your statement, but



let's go over some of your points here.



          As you know I am a lawyer.  I know I have met



many old friends among the legal profession attending



during this week, as well as a lot of new ones.  As



lawyers always do we have listened to the jargon of the



scientists and I have no quarrel with it; I appreciate it.



I think your paper is couched in those terms. But when




you talk about the discussion and use terms such as



"testimony," "witness," "cross examination" — and I



think I have allowed questioning to approach that because



it seems that is what the people want to do inasmuch as



in the profession that is the way they conduct their




business — I think you have to recognize that we were
-------
                                                        2223
                      M. A. McWhinnie



employing the jargon of the lawyers and that is how we



do our business.



          This was in no way a trial.  This was a workshop



and a discussion.  However, the participants in this



workshop were lawyers — lawyers by long training and by



long experience.  They didn't shed their personalities when



they came in here as the scientists didn't shed theirs, and



we have to expect that.



          So I think in that sense those terms got into



this, but no testimony was given under oath.  We permitted



the witnesses latitude in question.  We didn't require proper



foundation or we didn't require the technical rules of



evidence.  I really do think that we all understood the



rules under which we were working here.



          So I wouldn't place too much credence on this.



I think we have an amalgam here of both the legal jargon



and argot and the scientific jargon.  I have no preference



for either, but I think everyone has to do his own thing



and say it his own way if we are going to try to achieve



an accommodation in these matters.



          DR. McWHINNIE:  May I —



          MR. STEIN:  Yes.



          DR. McWHINNIE:  I would only caution that we do



not drive the wedge against the credibility of scientists
-------
                                                       2224




                       M. A. McWhinnie




 across this  land.  Today did we not hear a Representative



 use  an expression "paid mercenary experts"?  This has deep



 impact,



           MR,  STEIN:  Professor McWhinnie, if you are



 sensitive to that — and I appreciate you might be — we



 lawyers get  called that all of the time and this is, I think,



 a  price you  pay,



           DR,  McWHINNIE:  That is the price I would not pay



'when, in fact,  funds might have been available to carry on



 a  study that this Agency needs carried on,



           MR,  STEIN:  Well, I think you are talking about —



 the  funds is another matter.  As a matter of fact, I don't



 know the details of that at all,  I really don't,



           DR,  McWHINNIE:  No, no, no.  My point is:  Do not



 put  us out of credibility.  The American people need every



 segment of society.



           MR.  STEIN:  Surely.



           DR.  McWHINNIE:  But already there is such doubt



 cast upon the scientists that his data will convince no one,



           MR,  STEIN:  It may.  But here is the point.  We



 don't have a plutonian elite running our socity,  Tou may



 probably from your point of view point up those disciplines



 that — that we have to get the answers.  We can't get them



 from "legal  boxes."  I don't believe we ever have  "legal
-------
                                                       2225





                      M. A. McWhinnie



boxes" for those disciplines — physics, chemistry, biology,



meteorology, geology, engineering and the environment.



It would be nice, and I know you think it would be



nice to have this.  But I think we have heard from the public



here, and long ago, as Clemenceau said, "War is too important



to be left to the generals."  I think we have heard that the



public feels that the environment is too important to be



left to the scientists, the public officials and the lawyers.



(Applause)  That is why they are here.  We have to face



this.



          Now, the hotel is signaling, and we will be out



in a few moments.



          Now, the other point I think is that the lawyers



have a way of looking for the truth, too.  It may not be



scientific truth, but it is the kind of truth as proven



by our society that can arrive at an accommodation within



our form of government where we can move forward to the



next step.



          Truth in the abstract is always a problem.  I



am not talking about that.  But I am talking about truth



in the sense that when we have divergence such as we



have here it may be the great seamy part of society, but



that is the miserable job that we lawyers have in trying to



get all of these elements together — trying to get to the



truth as best we possibly can, groping toward it as expertly as
-------
                                                       2226





                       M, A. McWhinnie



we can  tt  come up with a conclusion so all parties know



the rules  and we can at least hopefully move forward.



           Now, I recognize that from many philosophic or



scientific points of view you may not consider this the



ideal way to move,




           DR. McWHINNIE:  I do not have any grief with



lawyers, if it is true — and I think that this is a science-



based problem — but then we must not close the door on



the scientist; we need his answers just like we need the



lawyer's answers,



           MR, STEIN:  That is true.  But, ma'am, if we are



faced with the situation — I am reminded of Senator Hart's



telegram, and I don't think he said much different,  I just



raise this as a question that you pointed out as a conclu-



sion, but I will get to that in a moment.



           The point that Senator Hart raised was, in view



of the fact that we are dealing with a complex scientific



problem  where every answer is not yet in,     should we not



employ the technique that we have employed many times in our



society in getting some kind of change, either to society



or our environment, by using the principle of burden of



proof?  And that is what he suggested, and I certainly have



not talked to Senator Hart about this.  We have been having



enough discussions about mercury and heavy metals to get
-------
                                                       222?
                       M. A. McWhinnie




into other issues lately.  But I think his telegram



seemed to me to get to the same point that I was making,



and I think Attorney General Scott made the same point.



Maybe this is the point that comes from our professional back-



ground, and when you get a complicated situation like that the



way you take the first step is to fix the burden of proof



and let the parties who are responsible come forward with the



scientific evidence or any evidence which will cause you to



move*



           DR. McWHINNIE;  I agree.  But when the burden is



upon them  do not deny them the only group who might be able



to provide it.  And I regret that distinguished scientists



this week — one a member of the National Academy of Sciences



to which neither you nor I are good enough to be so named —



was not even allowed to scientifically answer the charges



against his work because he had gone home.  And this is not



common in my community.  Scientists speak freely to each



other.  They don't get put into "legal boxes," so that they



cannot reach each other.  This is all I seek.



           MR. STEIN:  Oh, we have another rule in the law,



and that is — and I guess we have to do this — what we do



is give people an opportunity to be heard, and that is just



an opportunity.  If they are not here and don't avail them-



selves of it, what can anyone do?  The hall is open.  The
-------
                                                        2223






                       M» A. McWhinnie



notice is out.  You have to show up in order to be heard,



and if you leave, that is your privilege, but there is no



way that we can chain a man here when we are not exercising



subpoena power*



           DR. McWHINNIE:  Whatever was the mechanism I do



not know.  But I think those questions should have been placed



to those scientists by those who later stated them at the



time that it was fresh in the mind of the conferee and fresh



in the mind of the participant,



           MR. STEIN:  I have one last point, and I hope you



won't take this too personally.  But you talked about some



"ticky-tacky" point on quotes from a "white paper" where part



of the information was put in and part not.  I believe you



were here for most of the week.  I believe you have talked



before public bodies in the past 15 or 20 years — congres-



sional committees and many other public bodies — and yet



what do I find?  When you criticize the "white paper" — and



I am not commenting on your criticism of leaving something



out and putting something in — and from the precis I find



— after you have probably heard my views all week and



remember me possibly from 1962 — that I get a quote that



you attribute to me from a newspaper.



           DR. McWHINNIE:  Oh, please, sir, this I would not



do.  Please read the text —
-------
                                                       2229
                      M. A. McWhinnie



          MR. STEIN:  Yes, I read it.



          DR. McWHINNIE:  ~ in which it was stated what



Mr. Stein said because I, too, have deep concern for the



accuracy of the press.



          MR. STEIN:  I have no concern, I repeat, I



have no concern about the accuracy of the press.  I want



to say here that these concerns I hear about the press



not reporting things right is not a fair criticism.  I



find we get fair reporting practically all of the time.



          But, Professor McWhinnie, the question here is



that if we are seeking the truth, I would prefer to go to



your work that I have heard of, or your statement or your



verbatim testimony than use any quote in the paper.



However, I might rely on that paper as an expression of your



view.



          DR. McWHINNIE:  I must not speak clearly.  That



quotation is only to emphasize the position that I think



has been taken — "The burden of proof is upon the user."



It is known everywhere.  It is even said of Mr. Stein in the



Chicago Sun Times.  Now, if this is true, don't close the



door.



          MR. STEIN:  Again, let me make my position



clear, because I don't think this is what I said.  I raised



the question for the conferees.  I didn't come to a judgment,
-------
                                                       2230
                      M.  A.  McWhinnie



I raised the question to  the conferees.   They have to



make this judgment; I have not come to the conclusion



but I am raising the question with them.   This is the



essential point of this conference.  One  of the major



issues I hope to speak about.in the executive session



is:  Is the way to handle this through the burden of



proof?  If it is, on whom should that burden of proof



be?  Should it be on the  Government, or on industry,



or a city which wants to  use a natural resource?  This



is a judgment that they are  going to have to make.



          Now, I don't even  know whether they want to take



this approach, but I have framed this question again and



again.  I say independently  a lot of other people have



come forward with the same kind of question.  All I



ask is that I think this is  a legitimate matter for the



conferees to consider, to see if they want to adopt that



approach.  I have by no means said that I endorse at this



point the burden of proof rests on anyone or is the avenue



through which we will handle this case.



          DR. McWHINNIE:   May I just —



          MR. STEIN:  Just go ahead.



          DR. McWHINNIE:   I don't care upon whom the burden



of proof depends; either side will need scientists.
-------
                                                      2231





                      M. A. McWhinnie



           MR. STEIN:  Thank you,



           I think we are all agreed.  We are both agreed



on that.



           Now, are there any questions?



           MR.  OLIN:  My name is Harold Olin.  I am not



a scientist, and I am not a lawyer; I am an architect, and



I am proud to say I am a conservationist.



           I would like to cross-examine this witness with



your permission, but it will be brief.



           MR. STEIN:  Well, let me tell you —



           MR, OLIN:  It will be brief, sir.



           MR. STEIN:  Well, you know we have to be out



of this room.



           MR. OLIN:  Okay.  Can you state categorically



from a scientific point of view that the 40 or 50 billion



B.t.u.^per hour which are being dumped into the lake at



the moment are not damaging to the lake ecology?



           DR. McWHINNIE:  No, sir, I cannot.  May I ask



you a question?



           MR, OLIN:  As soon as I am finished with you.



Thank you.



           MR. STEIN:  Pardon, sir,  I am afraid —



           MR. OLIN:  I only have one other question, sir.



           MR. STEIN:  All right.  Go ahead.  I am not sure
-------
                                                       2232






                      M. A. McWhinnie



how much there will be,



           MR. OLIN:  How long do you think it would take



to get consensus in the scientific community that it is or



is not damaging?  How many years?



           DR. McWHINNIE:  I would say we do not seek



consensus, we seek evidence.  I would further say that 2



years annual cycle multidisciplinary study preoperational



is essential; 3, 10 postoperational.



           MR. OLIN:  Possibly 15?



           MR. STEIN:  I am sorry.  You can continue this;



we just have to give up the room.



           MR. OLIN:  Thank you.



           MR. STEIN:  I will tell you where the next



room is, and you can have the floor.  We will reconvene in



about 15 minutes in the Randolph Room.  You can find the



Randolph Room on the lower level.  Take the entrance down-



stairs through the College Inn Arcade on the main level, and



we are all set up in the Randolph Room, and we will reconvene.



           (Short recess.)



           MR. STEIN:  We will reconvene, if we may.



           I don't know — Professor McWhinnie, do you want



to get up again?  I think if any questions are going to be



asked, I am going to ask the person on the floor to get



near Mrs. Hall, of course, and speak loudly.
-------
                                                      2232a
                       M. A. McWhinnie



           MR. OLIN:  I have one final question.  You have



indicated that you could not state categorically that the



heat is not damaging to the lake<>



           You have also indicated that it would take some-



where between 12 and 15 years in order to do an exhaustive



study — scientific study, of course, and I am just wonder-



ing whether you are proposing that we continue our current



practices in the interim.



           DR. McWHINNIE:  May I ask a question?  Given that



what you say is true, the answer is no.



           MRo OLIN:  What are you saying I said?  I am



basing my questions on what you said, Professor McWhinnie,



not on what I said.



           DR. McWHINNIE:  Under the moment of confusion,



would you resay what it is?



           MR. OLIN:  Certainly.  My first question was:



Can you state categorically that the 40 or 50 billion B.t.u.*s



per hour which we are currently dumping into the lake are



not damaging to the ecology of the lake?  And if I might



remind you of your answer, your answer was that you could



not state categorically that it is not damaging.



           My second question to you was:  How long would



it take to get scientific consensus on whether the heat



discharges into the lake are damaging or not?  And you said
-------
                                                       2233




                         M. A. McWhinnie



that it would take an initial 2-year study and perhaps a



10-year study after that.



           And ray third question to you now, based on your



two earlier responses, is:  Do you propose that we continue



the same current practice of dumping all of the heat from



industries and from powerplants, municipal treatment plants,



into the lake while these studies are being performed?



           DR. McWHINNIE:  With respect to the first, we do



not know.  We have information on which we make reasonable



judgments.



           I would ask you:  Would you not expect to see



deterioration due to heat increments at the Waukegan plant



after 40 years of operation?  May I ask if you would be kind



enough to try and answer that?  Would you expect this?



           MR. OLIN:  May I suggest that you haven't answered



my third question and you are posing a question to me?  I



will be glad to answer but, you see, I am not a scientist;



I am only an architect and an observer.



           MR. STEIN:  I am sorry.  Again, I am going to



have to act like a nasty old lawyer.



           MR. OLIN:  I would like the record to show that



Professor McWhinnie has not answered my third question.



           MR. STEIN:  The record will show what you said.



           Now, what I am going to have to ask is that you
-------
                                                        2234





                     M. A. McWhinnie



handle one question at a time.



           MR. OLIN:  Which I did.



           MR. STEIN:  J.ust ask one question at a time.



           Do you have a question to ask or a comment to make



to Professor McWhinnie?



           MR. OLIN:  The question was:  Do you propose that



we continue our current practice while these exhaustive



studies are being made by the scientific community which



might take, as you have indicated, anywhere from 10 to 12



or 15 years?  That is my question.  You have a choice.



           DR. McWHINNIE:  May I correct your 10 to 12 years



or 15?  I said 2 years before, 2 or 3; or $ or 10 afterwards.



You only added up the last numbers.  And there is a danger



in this.



           It is my own plan and that of all of this



confederation of scientists that surely we shall have



supportable information 2 years, quote, preoperative; 3,



postoperative.  But we are not satisfied with an interim



answer.



           I would like to remind you that that lake does



belong to the scientists also who share the concerns of



everyone here.  As a consequence, we will continue our studies



when the public has long since gotten tired, but we will



continue.  For that you have your 12 to 15 years; not for
-------
                                                      2235





                       M. A. McWhinnie



an answer to the public,



           MR. OLIN:  Professor McWhinnie, I am not clear



on what your specific recommendation to the conferees is



with respect to a thermal standard, and that is exactly



what I am trying to get to.  These gentlemen are here to



find out what you and the scientific community ought to be



doing about a problem which exists now, in the view of many



of your colleagues.  And somehow your specific recommendation



to me at least is lost in all of the scientific rhetoric.



What is it you specifically recommend to these gentlemen



here?



           DR. McWHINNIE:  In answer to that, I included in



my testimony — Mr. Stein, sometimes called a statement —



the position expressed by implication by Dr. Gustafson,



by explicit wording by Mr. Harper.  Let us, before debate



defeats us, recommend a moratorium, but let us have an



experiment and, thus, my recommendation  would be in this



category within the options open to this board of conferees



but significantly also look at what the States of Michigan



and Illinois have recommended and, of course, the third



alternate, the Federal Government.



           Based upon the probability, not the possibility



— anything is possible — it is indeed possible that when



I step out of this room, I shall be trampled to death by a
-------
                                                      2236





                      M. A. McWhinnie



team of elephants, but I don't think it is very probable.



Within the world of probability, I believe, that with the



information that we have, the recommendation from the



State of Illinois, does not bode badly for Lake Michigan,



and with a moratorium we can come to provide the answers



that are needed when the moratorium would be left,



           MR, OLIN:  What do you mean by a moratorium?



A moratorium on standards or a moratorium on thermal dis-



charges, Professor?



           DR. McWHINNIE:  A moratorium with respect to the



number of plants to be placed on Lake Michigan,



           MR, OLIN:  Is it your recommendation, then, that



we should hold the status quo and not permit any additional



plants on Lake Michigan?



           DR0 McWHINNIE:  I would feel that the plants



that are^or are in construction,would provide us the



experiment we need,  I would leave it to this board of



conferees to make the decision, quote,"how manyJ'Mhow soon?"



           MR, OLIN:  Thank you,



           MR, STEIN:  Are there any other comments or



questions?



           MR, READ:  My name is Herbert Read,



           Your comments about a number such as plus 5 on



top of 50 or on top of 70 interests me0  As I understand
-------
                                                      2237






                       M, A, McWhinnie



you, your number — a plus 5 may be acceptable under certain



circumstances but a plus 1 or plus 2 may not be acceptable



under other circumstances, is that correct?



           DR, McWHINNIE:  You, too, must be a lawyer,



           Do not read what isn't there,  I am saying that



it is unrealistic to say plus anything, and I carefully



kept indicating "or, etc."  If, by example, I can use one



number, it is only an example, and, thus, the plus 5 or



the plus 1, or the plus 3»  I am saying it is unrealistic



within the context of oscillating temperatures in an envir-



onment, variability in organism adaptation, they face from



32 to #5 every year anyway.  What kind of sense could this



board offer to prove the reasonableness of why they said



plus something?



           MR, READ:  All right.  In other words, since



there seems to be no consensus of plus 1 or plus 5 or plus



10, either over 50 or 60 or 70, would you say the only



way that we could be sure of anything is plus zero?



           DR. McWHINNIE:  If you are afraid of the



possible, and you have no interest in the probable, plus



zero, you are required to ask for,  I face what is probable,



           MR, READ:  All right.  In dealing with proba-



bilities, then, can you come up with any number — here again



dealing with probabilities — can you come up with any number
-------
                                                       223S





                      M, A. McWhinnie



that these gentlemen should consider?



           DR. McWHINNIE:  I have indicated that I believe



reasonableness is represented by what the State of Illinois



has been attempting to do.



           MR. READ:  Now, is that a number question here?



           DR, McWHINNIE:  I think this is a maximum #5 at



any time.



           MR. READs  I am from Indiana so I am not familiar



with the Illinois situation.



           MR. STEIN:  Mr. Currie.



           MR. CURRIE:  If I may clarify that just a bit.



There is an existing 85-degree standard in Lake Michigan



water quality standards adopted by the State of Illinois.



There is in addition a requirement that cumulative temper-



ature changes be not more than 5 degrees from the ambient



temperature, and that not more than 2 degrees difference be



permitted within any given hour.  There are presently for



consideration before the Illinois Pollution Board two



proposals to change those standards, and the State of



Illinois has not so far either through my board or through



Mr. Klassen's agency proposed any thermal standard for this



conference.



           MR. READ:  All right*  In view of the explanation



here, the State of Illinois, under the explanation that was
-------
                                                      2239





                      M. A. McWhinnie



just given, did de"al with figures, and government agencies



do have to ultimately deal with figures.



           We had a figure plus 5 mentioned, plus 2, under



certain other circumstances.  Then, is that the figure that



you think that we could live with dealing with the proba-



bilities?



           DR. McWHINNIE:  Dealing with the probabilities, I



would say that I think we could live with considerably more



than plus 5*



           MR. READ:  Well, then, what?



           DR<» McWHINNIE:  I am sorry, sir, I will not name



a number.  There is no data that would support me.



           MR. READ:  Would you say that in the absence of



data the safest thing to do, then, would be plus zero?



           DR. McWHINNIE:  I don't like to take that kind of



logic to its ridiculous extreme0  But in the absence of



certainty that I am not going to be killed on the street,



I should stay in bed in the morning.  On these grounds,



forgive me, but based upon the existing data, I would



suggest that plus 5 is restrictive; 80 to #5 is realistic,



in the receiving body.  In those areas where plants are



presently operated — operating — because I must emphasize



the Waukegan fossil fuel plant has been operated for 40



years, and I am not supposed to speak until I have data ——
-------
                                                       2240





                     M. A. McWhinnie



but I can say this to you:  that through 3 months of intensive



effort this summer, I am sorry, we ain't got the evidence to



support the position of concern which you show*  I show con-



cern but I will not react to that which is possible.



           MR, READ:  All right.  So I want to state that at



least I was able to obtain a statement of your position.



I have been trying to determine what that was, and thank you



very much.



           MR. STEIN:  Yes.



           MR. COMEY:  David Comey.



           Miss McWhinnie, I am not a lawyer, so donft worry



about my cross-examining you.  I used to be an attorney



though.



           You spoke about the difficulty of finding funds



to conduct thermal research on Lake Michigan.



           DR. McWHINNIE:  Only as for funds so you under-



stand where I stand.



           MR. COMEY:  Well, I was in a similar position last



year, and had to turn down a very interesting  6 -figure



contract to do a thermal pollution study near Chicago because



the government agency that was funding it had some restric-



tions about publication which we didn't feel were consistent



with academic freedom, so we turned it down.  So I think on



the moral level at least I can come into this conference
-------
                                                       2241





                       M. A, McWhinnie



with some sort of basis of perhaps equal with you.



           The problem that I have is that I am basically



concerned now with the public reaction, and you talked in



your presentation this afternoon about capacities of the



lake.  Now, I think really this is what the public is



objecting to and I would like to ask you —



           DR. McWHINNIE:  Excuse me, before you go on.  I



did not speak about the capacities of the lake.  I did speak



about the capacities of living organisms, and I think the



record will show that.



           MR. COMET:  All right.  Could I extend that a



little bit further?  Do you believe there are such things



as assimilative capacities to natural bodies of water for



distinction of pollutants?



           DR. McWHINNIE:  I love the expression.  Presented



in the National Water Pollution Conference papers of I960



in which the, quote,. "Purifying Powers of a River, etc.,



etc., etc." — yes, I do believe in this.  I would be a



fool to fly in the face of evidence that the living world



is in dynamic equilibrium with its environment, and it will



oxidize out, and it will take that which is organically



useless, return it to a usable form for plant life, and the



cycle goes on and on, and this was so ably pointed out



then.  The only problem is, our inputs are now too close,
-------
                                                        2242






                     M. A. McWhinnie



and we get so that the normal biological processes cannot



carry on to completion what once they could, given the time.



           MR. COMEI:  You, I gather from previous statements



before this in the Illinois Pollution Board feel that field



studies are far preferable to laboratory studies.



           DR. McWHINNIE:  They are essential.



           MR. COMET:  Let me ask you this:  Would you be



willing to conduct a controlled experiment on injecting



cyanide, lead, mercury, or other pollutants of this sort



not in a controlled laboratory situation but measuring



rather large amounts of them out into Lake Michigan in order



to determine exactly what the effect on the biota would be?



           DR. McWHINNIE:  I am deeply concerned over the



constant analogies which don't fit together.



           You cannot ask of a living system a question in



the physical word, called thermal, and use as a fair example



a toxic compound.  This abuses knowledge.



           MR. COMEY:  Well, I would extend the abuse a little



further,  I would say that if a graduate student came to you



with funds proposing to measure a capacity.such as the



following:  Exactly how many rapes per hour a woman could



tolerate; you would turn that down, and advise his graduate



advisor.  Similarly you would turn down any biological



experiment on children with respect to how many beatings
-------
                                                        2243





                       M. A. McWhinnie



per hour they could take,



           I think what the public is saying is:  We are not



interested in measuring parts per million of pollutants or



B,t.u.'s per hour; if the technology exists, we want it all



out.  And that is what they are saying,



           DR. McWHINNIE:  I understand their question.



           I would like to know why you started to call it



thermal pollution.  You made a decision.  I am not prepared



to make it.



           Earlier at this conference, Mr. Stein speaking



with some speaker — I have forgotten — asked: "Are you



turning to the possibility of enhancement?" And the reply



was, "Yes."  And I wonder why we don't see two sides of every



coin.



           Who started the word "pollution"?  Could they not



have restricted it to thermal modification?1* Why has the



decision been made?  But it has.



           MR, COMEY:  Well, I believe that when I first



began hearing the term in the middle 1960's, it was in indus-



trial magazines such as Chemical and Engineering News,



Nucleonics News attempted to change it in about 196$ to



thermal environment' but scientists changed it instead.



           Well, I am concerned about the attitude that



you have expressed, and I think that, very frankly, if this
-------
                                                       2244






                       M, A. McWhinnie




thermal conference is unable to remember something of this




question and to adopt the idea of the zero standard,  the




public is going to be very disappointed.  As a matter of




fact, in Mike Royko's column the other night he talked




about a rather interesting gentleman in King County he




called Fox, who has been very carefully setting up outfalls




and covering over caps of smokestacks.




          His most recent exploit was to dump in an



aluminum company the 50-gallon excrement that came out




of their outfall.  And I am afraid that the public may



view this thermal enforcement conference as a test case




and if in several months nothing has come forward, I am



afraid the Foxes may multiply.



          DR. McWHINNIE:  May I speak to that?



          The public should not be so ready to decide that



this scientist or that one or the other one  who cannot



concur with them because of knowledge  J-s their enemy.



Let the public further know that I loved that lake long




before they did.




          MR. COMEY:  But you also made the very patroniz-




ing remark —



          DR. McWHINNIE:  Let me finish.  When the public



takes it into its own hands to step beyond the normal course



of events and hand it into the hands of our leaders who
-------
                                                      2245
                      M. A. McWhinnie



shall not act highhandedly, it shall be those who contribute



to the anarchic  breakdown of a country I live in and love.



Let it be remembered that lake belongs to us.  Our concern



is not different from yours.  Our experience may help us



reach a solution that you too want.  But don't you outdo



us with your anarchy.  (Applause)



          MR. PETERSEN:  I think, Mr. Chairman, at the risk



of interrupting, we have been here for sometime.  May I



please suggest that this not be a colloquy of questions that



are going to be asked.  Let the questions be asked not



speeches from the floor.



          MR. STEIN:  Sir, the other night I was here very



late and let only largely representatives of the power



companies proceed in their own manner.



          I think the admonition is well taken.  But the



point is that in a workshop such as this we have to



remember that where we don't have professionals asking



the questions, they have to do this irrespective of their



personalities.



          I asked you to be brief.  If you can I think



this would help because I think Mr. Petersen has made an



excellent suggestion.  And while philosophically, morally,



and emotionally I agree with him thoroughly, I don't think



in the exercise of my official capacity I can really enforce
-------
                                                       22^6






                        M.  A.  McWhinnie



it.




           MR. COMET:  I would only finish the comment I



tried to make before, and that was that I did regard your



statement that the scientists  would be there after 15 years



caring about the lake when the public had long gone back to



its fun, games and dancers.  I find that a very patronizing



remark.



           DR. McWHINNIE:  I do not mean it to be so.  I



regret that you have taken that interpretation.



           MR. STEIN:  Are there any further comments or



questions?



           If not, thank you very much, Professor



McWhinnie.



           DR. McWHINNIE:  I am sorry for the time.



           MR. STEIN:  It wasn't you.



           Now, we have several people here who have filed



statements.



           Ted Falls, President of the Porter County



Chapter, Izaak Walton League,  had to leave and will submit



a statement next week.  (See Pp.  2345-2349)



           Mr0 Seymour Altman, Commissioner, Highland



Park Environmental Control Commission.  (See Pp. 2248-2249)



           Mrs. Bieker, Indiana Division Board, American



Association of University Women.   (See P. 2250)
-------
                                                       2247




                     Mrs. S. Troy



           And Mrs. Robert McKimpton, Independent Citizens'



Water Pollution Research, Inc., Hammond, Indiana.  (See




Pp. 2251-2254)



           They have all submitted statements for the record



and without objection they will be entered into the record



as if read.



           Now, I have a job as an administrator as well as



doing this, and sometimes I recognize the force and the



reluctance of the scientific community to come up with a



figure or a definite answer on something.  But when they



come in for the grants for a project, they sure want a



definite answer from me on what the figures are, and the



money they are going to get before they start.



           John Berghoff,  Is he here?



           Mrs. Jack M. Troy.








           STATEMENT OF SYLVIA TROY, PRESIDENT,



           SAVE THE DUNES COUNCIL, MUNSTER, INDIANA








           MRS, TROY:  I am Sylvia Troy, President of the



Save the Dunes Council, a conservation group of 3,000



members, formed in 1952 to establish and protect the Indiana



Dunes National Lakeshoree



           It will be bitterly ironic if after all the years




(Continued on P. 2255)
-------
                                                         ARCHITECT  S

                                              ALTMAN-SAICHEK ASSOC.
                                                         300 W WASHINGTON ST
                                                         CHICAGO, ILLINOIS

October 2, 1970                                          PHONE       726-8,15
Federal Water Quality Administration
Great Lakes Region
Department of the Interior
Chicago, Illinois

Gentlemen:

I am Seymour Altman.  I appear here as a representative of the City of Highland
Park Environmental Control Commission.  I am also a co-chairman of an en-
vironmental organization, the Society Against Violence to the  Environment, as
well as,  an individual --a resident of a community bordering Lake Michigan  and
in close proximity to the  proposed Zion Atomic Energy Power Plant.

We have sat through these days of bearings, with increasing disquietude, as
industry has paraded forth an impressive array of very sincere,  technicians and
engineers --to show us that it is impossible to prove that adding enormous
amounts of heat, albeit dutifully diluted, to our Lake will harm the Lake's en-
vironment.  We are not certain whether we should be horrified by this nightmare,
or whether we are to laugh grimly and treat this as some satirical,  existentialist
theatrical production.  Apparently they would have us all believe that the burden
of proof is on the public -- that we must risk further pollution of the Lake now and
in the future.

Gentlemen,  this summer the residents of Highland Park were made aware of the
effects of past pollution of our Lake based on the  same premise.   Our beaches were
closed for swimming.  This  came as a shock to people who  had always considered
that they could enjoy the privileges inherent in living in a community on a Lake.

The closing of the beaches, in itself was a worthwhile symptom of the dangers to
which our natural surroundings are exposed.  We have become increasingly aware
of the confluence of pollutants in our area.   Add to this pollution large amounts of
heat -- what do we get?  What is the cynergistic  effect  on the Lake and on us?

Industry would have us believe that the only way to find the  answer is to "try it
and see. "  We have been through that one before.  Look where it got us.
-------
                                                                        2249
                                    - 2 -
The simple/and logical answer is this:  nothing more in the way of additives which
might change the Lake is to be allowed to be introduced into Lake Michigan.  This
Lake belongs to the people.  As such it is our responsibility to protect it and safe-
guard it. If someone wishes to use it -- they must show, beyond any doubt, that
they will not harm it or us.  Till such a time, it is our prerogative, and our duty,
to prohibit their transgression of our rights.
SA: s s s
^4w^wxW%
eymour Altman
-------
                                                                2250
         AMERICAN ASSOCIATION OF UNIVERSITY WOMEN
                        Indiana Stale Division

                        October 2 1970

                                      1154 Ridge Road, Munster In
                                                         46321

Lake Michigan Enforcement Conference
Sherman House
Clark and Randolph Sts
Chicago, Illinois

Gentlemen:

The Indiana Division of the American Association of University
Women wishes to go on record in support of the Department of
Interior's criteria for protecting Lake Michigan waters against
thermal pollution.  This department has shown the most informed
interest in protecting the environment in the public good and
would be the best informed and dependable in guarding conditions.

We have waited too long for this Conference to bring forth a clear
protective policy. We have waited too long for our own state of
Indiana to enforce what standards we already have or to support a
strengthening of the criteria concerning lake water quality.  We
see no bright hope in the states surrounding the lake agreeing on
a set of standards that would be to their mutual advantage and
equal enforceability.

We hope therefore that the regional Directed of the Federal Water
Quality Administration will officially designate the Secretary of
the Interior and his department as the federal authority estab-
lishing federal standards.  We w ould recognize that they w ould be
pressured by heavily weighted vested interests who would gain by
freedom to misuse the lake.  The Department of Interior has demon-
strated that they are capable of acting in the over-all public
good and we favor their firm stand on criteria that would not
permit lessening quality of the lake water.
                                      Yours sincerely
                                      rs. L. W. Bieker
                                     Division Board
                                     Indiana Division
                                     AAUW
-------
                                                   2251
  F3D3IIAL I7AT3R QUALITY
          HEAD'
     Chicago,  Illinois
      October  2.,  1970
         prepared by
i;-:D3Pi::.D3i;T cims^s1  WATER
  PCILUIIC." .13S3A.CH,  lire.
 7515 I:ew Hampshire Avenue
 Hanrnond, Indiana     45323
 area code -  ?19   344-1590
-------
                                                           2252
                       I.JI.J.J *. J. ~-i* *X -I.J
                                > 737^ •>'""T
                                    ' >
                                      ** ,
                    751 C -~ew Hampshire Avenue
                    Hammond, Indiana    45323
                    area code - 219  344-1590

     The i:;Tr,?i2L.D2i:ir ciriz"-.:^1 ;;Arz^ POLLuric.: ^s?2Aiicn,  i:.c.  is
s unique non-profit organization in that  it was  created  for ir.ore
than one purpose.  \s its iia.no indicates, one of our  primary pur-
poses is to sample and analyse waters, both public and private,
and to demonstrate the conditions of those waters.  Another pur-
pose of our corporation is to keep the public aware of the condi-
tions of waters sampled and analyzed.  A  third purpose which ex-
cludes I.O.'./.F.n. , Inc. from being strictly an analytical corpor-
ation is our efforts to work for more stringent  anti-pollutior.
statutes and regulations as a result of our studies and  research.
     .lepre Rents tiven of our corporation have coine in  contact with
and dealt with governmental agencies such as the Indiana  Stream
Pollution Control Board, the Federal .Jater duality Administration,
the Indians State Board of Health, the lake County Board  of Health,
and the Army Torps of llii^ineers.  In each instance in dealing with
each of these agencies, we have found an  awareness of the sever-
ity of the present pollution problem?.  In each  instance  in deal-
ing with each of  these agencies, we have  also found ineffectiveness,
evasiveness and. lack of direction.
     For example, in thn statr of Indiana, the legislature has
established the authority for the creation of the Indiana Stream
Pollution Control Board, its powers and regulation of enforcement
-------
                                                               2253
                               o
                                  2
in statutes 68-517 through 58-543 inclusive.  These statutes allow
the. SPCB to establish and enforce stringent criteria and control
of these criteria, but the SPCB has not done so.  The SPCB has,
instead, adopted weak and inconsistent criteria and regulations.
These criteria include Lake Michigan open water, Lake Michigan
shore water, Lake Michigan inner harbor basin, Indiana Harbor Can-
al, Grand Calumet River, Little Calumet ?%iver flowing into Illi-
nois, and Wolf Lake.  The criteria for these interstate waters
were requested  and approved by the Department of Interior.  r,o
samples to be used for proof of a violation by any entity can be
from effluent discharges, but must be fro:n the body of v/ater it-
self after dilution; but no stipulation in given as to what con-
stitutes a dilution or mixing zone*  The substances included in
the criteria for thses interstate waters varies so that not all the
same substances appear in all criteria lists.
     It has been proven that industries, municipalities and indi-
viduals have not and will not atterapt to reverse their polluting
d£e to social conscience.  The only solution, therefore, is
strength in the federal, and subsequently state, agencies respon-
sible for controlling, regulating and enforcing anti-pollution
regulations.  The government is the only possible means through
which the pollution crisis in our country can be solved.  Study
commissions, conferences and meetings of all types have proven
to be mere dead ends from which very little positive action
emits.
-------
                                                                2254
     Public dissatisfaction grows  stronger  day  by  day with tha



ineffectual handling of our deteriorating environment,   The



governasntal agencies, especially  the F>ro.\, must begin immediately



to act with :.:ore authority.  Compromise end ineffectual gestures



must coar.e.  The 7:r^. must require compliance by the states in



stiffling the progressive deterioration of  our  water and air.



Ignorance is no longer a valid excuse.  The health and welfare of



this country's people is now a necessary priority.



     ihe .Tetter of t her r:\al. pollution is just another in the long



list of pollution sources.  The ?:~^A has the opportunity and the



power to bs It this source before it is allo"-?er  to  become another



mfjor p o1luUant„



     It is for these reasons stated that i::D2?3;-,DS.-.T Cini-^S1



TAiZ-L POLLUTIC.: "^iSIA^K, I'/C. recommends to the "acretary of



Interior that the ther.;>?l criteria be removed free the 2nforce-



::.er;t Conference ar;d pl?ccd directly in the  authority of the Feder-



al :/ater ?;jality -.dninistration ap sn agency of the Department of



Interior.
-------
                                                       2255





                     Mrs. S. Troy



we labored to secure the National Lakeshore, its 13 miles



of beaches will not be usable by the public — and that is



a very real concern.  The beaches farther west in Indiana



— at Whiting and Hammond — have already been closed to



public use*



           All of Northern Indiana Public Service Company's



major electric generating facilities are on the shores of



Lake Michigan, despite the fact that the company services



the entire northern third of the State,  They presently



have three plants and propose to build three more — a total



of six utility plants — on a 30-mile span of Lake Michigan



shoreline and five of those plants border land dedicated to



public recreational usec



           At the proposed Michigan City plant at the eastern



end of the Indiana Dunes National Lakeshore, #75»000 gallons of



heated water per minute (heated to a maximum of 25 degrees



above lake temperature in winter, though the company refers



to a 14-degree rise, when 14 degrees is the average



temperature) will be discharged adjacent to sewage effluent



coming from Trail Creek in Michigan City,



           •,• Slide o••



           I do have a slide, a map of the Indiana Dunes



National Lakeshore,  Harold, would you mind indicating



where that Michigan City plant is?  The areas in white are
-------
                                                      2256






                     Mrs, S. Troy



the designated areas of the lakeshore.



           The currents here move in a  westerly direction



along the shore and this area has been  designated for



intensive public beach use.  The shoreline erosion in this



area is particularly acute.  According  to the Army Corps



of Engineers figures, the erosion rate  is 9 feet of shore-



line per year and is due primarily to the Michigan City



harbor breakwater which  disturbs the natural littoral



drift.  More than 300 lots are underwater and over a mile



of road has been washed away in the past year.  The heated



utilities discharge moving along the shore will most



certainly melt or soften the natural ice barrier formed



along the shore which normally acts as  a protective shield



to the ravaging winter and spring storms, aggravating and



accentuating an already critical erosion problem.



           At the western end of the lakeshore, the Bailly



nuclear plant is being proposed.  Here, the vast amounts



of heated water, trapped by the Bethlehem landfill and



joined by the chemical wastes of the Bailly coal-burning



plant and other wastes from Burns Harbor will be forced



to move in an easterly direction and have a similar melting



effect on the protective ice ridges along the shoreline,



thereby creating further erosion and pollution problems,



           I would like to counter the statistical
-------
                                                        2257
                     Mrs. S. Troy



contortions of the power industry who are attempting to



prove that dumping of vast quantities of heat will not be



harmful to the lake — they even have the effrontery to



assert that it may be beneficial — with the evidence of



what is happening to Lake Michigan,



           Here is algae collected from the east end of



Beverly Shores in the Indiana Dunes National Lakeshore near



the Michigan City plant of Northern Indiana Public Service



Company.  This is a recent development and proof of the



acceleration of the eutrophication process.  Each year



there is more and more of it along the shore.



           Have industry scientists explored the synergistic



effects of waste heat in shallow water already heavily



contaminated with chemical and sewage effluent?  Would



the electric power industry be willing to post a bond of



several million dollars or perhaps a billion dollars to



support their assertions that heat will not adversely



affect the fishing industry or recreation potential of



the lake or deteriorate its quality or disturb its biota?



           What is the credibility record of the industries



along the Lake Michigan shores?  What is the credibility



record of the utilities at the southern end of the lake?



Twenty years ago when my husband practiced medicine in



Whiting, Indiana, and phoned Commonwealth Edison Company
-------
                                                       225S





                     Mr s<> So Troy



State Line Generating Plant to complain about the air



pollution, the officials came to see him and assured him



that every possible measure was being taken to clean up



their stacks.  Last week, finally, the city of Chicago



sued Commonwealth Edison for violations,  NIPSCO's promises



on their Bailly plant were never kept.  The dirt plumes



are visible 10 miles away.



           Lake Michigan would normally have a life span



of 25,000 more years.  Responsible biologists say the lake



may be dead in 15 years if we continue on our present



course.  And is industry heeding this warning?  No,  They



are pursuing the same destructive, mindless, short-sighted



policies and they now propose to use Lake Michigan as a



heat sink as well.  The quality of Lake Michigan has not



improved since 196 5»  In fact, it may have deterioratedo



           Here is the record of Indiana industries since



the passage of the Clean Water Act,  U, S. Steel Gary Works



has actually increased daily discharges of oil.  In 1965,



they discharged 54,000 pounds of oil daily.  Now, 5 years



later, supposedly with enforcement procedures under way



they have actually increased their discharges to 67,317



pounds of oil daily and they dump 306,7$1 thousand pounds



of suspended solids as well.



           Inland Steel Company discharged 23,791 pounds
-------
                                                       2259
                     Mrs. S. Troy



of oil and 103,617 pounds of suspended solids.



           The figures for Youngstown Sheet and Tube Company



is 11,000 pounds of oil and 46,000 pounds of solids.



           Perry Miller of the Indiana Stream Pollution



Control Board, ever an apologist for industry, is quoted



by Chicago Daily News, August k, 1970, as admitting industry



is still discharging large quantities of oil but says



"... these are large facilities and large bodies of water."



Ten years ago Blucher Poole refused to be concerned about



possible wastes from Burns Harbor.



           It is no surprise that the industries and



utilities prefer Indiana State standards and State enforce-



ment and object vigorously to Federal interference.



           The record of the Indiana Stream Pollution



Control Board in reversing water pollution trends in the



State is abysmal (with the exception of some recent



actions).  The conditions of the Grand Calumet and Little



Calumet Rivers are as deplorable as ever.  Lack of staff



and an antiquated and politically controlled judicial



system also hamper them.  Governor Whitcomb has not acted



to request the State L egislature for maximum funding to



quality available Federal grants to build needed municipal



sewage treatment plants.



           Industries prefer to locate in Indiana where they
-------
                                                        2260






                     Mrs. S* Troy



can manipulate and control the local and State regulatory



agencies*  The extent of air and water pollution in the



Calumet region, despite the Federal Clean Air Act and Clean



Water Act in 1965, despite local and State laws, is a



National scandal and the record of the local and State



anti pollution  agencies ought to be investigated.



           There is an increased awareness by the public



of the threat to Lake Michigan as evidenced by the growth



and proliferation of conservation groups in Indiana and



the attendance of over 1,000 people at the public hearing



on the proposed Michigan City NIPSCO plant.  We are prepared



to take legal action, if necessary, against the State Water



Pollution Control Board for failure to protect the public



interest.



           We wish to applaud the courage and integrity of



the Federal Water Quality Administration and the Department



of Interior in taking a firm and unequivocal position



against thermal discharges into Lake Michigan.  The feasi-



bility of alternate methods of cooling with costs that



will not be excessive to the public offer no excuse to



the utilities for not acting immediately to use this



technology.  Utilities' threats of blackouts and brownouts



is reprehensible.  Indeed it reflects their lack of



efficiency and organization.  They prefer to put the blame
-------
                                                       2261





                      A. J. 0'Conor



on the conservationists,



           A vigorous approach is necessary if we are to



save the lake.



           May we urge the State of Indiana to finally come



into the Twentieth Century and approve the thermal criteria



as requested by the Department of Interior.



           Thank you,  (Applause)



           MR, STEIN:  Thank you, Mrs, Troy,



           Any questions or comments?



           If not, thank you very much, Mrs, Troy,



           Andrew 0'Conor,








           STATEMENT OF ANDREW J. 0'CONOR, ATTORNEY,



           OF THE FIRM OF BERRY AND 0'CONOR, OTTAWA,



                          ILLINOIS








           MR, 0*CONOR:  Mr. Stein, members of the conference,



ladies and gentlemen.  My name is Andrew O1Conor.  I  am an



attorney, for better or for worse, from Ottawa, Illinois,



LaSalle County, which is located approximately 100 miles



southwest of where you are sitting,



           I am here on behalf of a group known as the



Brookfield Township Land Committee; the Illinois Agricultural



Association, a group of approximately 190,000 members; the
-------
                                                        2262





                     A.  J,  O1Conor



Illinois National Farmers Organization;  the  Illinois  Farmers



Union; the Fox River Valley Community Action Council, which



consists of twelve locals of the United  Auto Workers  from



Streater to Woodstock,  Illinois; and we  are  here  to present



our position which to many of you may seem to be  totally



unrelated to the thermal pollution of Lake Michigan,



           Actually we are here because  of what we think



is an attempt to avoid thermal pollution of  Lake  Michigan



by the Commonwealth Edison Company, which company services



part of the territory which I represent.



           The relationship is direct and is caused by



their attempt to avoid violating the thermal differential



regulation which has been propounded by  the  Department of



Interior, as I understand it,  since 196#, and which affects



the Illinois River, which is a Federal navigable  stream,



and which receives into it the Chicago River, waters  from



Lake Michigan, and the confluence of the Fox or the Kankakee



and DesPlaines Rivers to form the Illinois River in our



part of the State,



           MR, STEIN:  This is outside the conference area,



isn't it?



           MR, 0'CONOR:   Well, I think it is, Mr. Stein,



and in deference to you I did talk to Mr, Wright, and I don't



intend to really go beyond this except to — from Washington
-------
                                                      2263





                     A. J. 0'Conor



— and I did suggest that perhaps it was outside the con-



ference area, but he asked me to come anyway.  This was by



telephone on Thursday, and I don't — Joseph Wright — I



don't attempt to presume on the time of the committee and



I will make it very short.



           MR, STEIN:  Yes, because I think if you have a



legitimate problem — and I don't doubt you do — this is



clearly the wrong place to take this up because we have



absolutely no jurisdiction in that area nor are we direct-



ing it there,



           MR. 0'CONOR:  Well, I think we have this message,



if I can put it this way:  We have appreciated and do



appreciate all of the information we have received here



about the feasibility of the alternate means of cooling



for thermal powerplants'.     I would suggest that they are



equally as applicable to our problem which consists of the



Commonwealth Edison wanting to take 7,000 acres of prime



farmland instead of taking 7>000 acres of idle, marginal,



unproductive land, and we feel that the information put



out by the Department of Interior on these alternate



methods of cooling, such as the towers, etc,, etc,, are



equally solving of our problems as they are for the



utilities around Lake Michigan0



           The third and perhaps most important part of our
-------
                                                       2264
                      A. J. 0'Conor



message — and this I mention to you gentlemen and to the



people who are here from the various power companies —



I think if you feel that by removing these powerplants from




the Lake Michigan shores to an inland site, and thereby at



least appear to temporarily solve the thermal pollution of



our lakes, you have solved the problem, you are wrong,



because you will run into just as vigorous opposition



from land-based groups such as I represent unless the




selection of the site is compatible with the land use and



the land sought to be taken, in terms of what is good land



as opposed to poor land.  And I would like to just make




that point for the conference.  I think that is important.



          MR. STEIN:  By the way, 1 think I agree with



you.  I think the way our Federal law is now, if it were



ever true in the past, that industry could go from one



place to another and avoid tight regulations, it doesn't



apply today.  I am not just referring to the power industry,



because as many industries know — and I am not sure how



well they like to see me — they find wherever they go in



the country, there I am.




          MR. 0'CONOR:  Right, and this is precisely



our problem.  (Laughter)  Not you, particularly, but I



mean wherever the power companies go, that is our problem.




I didn't mean that in reference to you.
-------
                                                      2265






                       A. Jo 0'Conor




           We do feel, though, that before you relocate —




and you take this home — there is a lot more to just



relocating away from Lake Michigan or any of the Great



Lakes than simply picking out a site and looking at it




from an economic standpoint — that is from the company's




economic standpoint and thinking then that because you have




the supposed power of condemnation that all of the people



who are interested in this good land are going to surrender.




They are not going to do it, and there is going to be some




regulations, truly some ground rules laid out about land



use in relation to utilities in the future,




           MR, STEIN:  Thank you very much,



           MR, 0'CONOR:  Thank you.




           (The following document was submitted for



inclusion in the record by Mr, O1Conor,)
-------
                                                              2266

               LET'S TELL IT LIKE IT IS!

     In view of the confusion about and distortion of the
Brookfield Township Land Committee's true position in relation
to the Commonwealth Edison project, we herewith submit oui
position and the reasons therefor.   This  position and the
points supporting it has remained constant and unchanged since
the original announcement of the project  in the spring of  1970.
     1.  Apparently some persons are under the impression  we
desire to force Commonwealth Edison Company to leave this  area
entirely.  Such is not the case nor has it ever been the case.
We do desire and insist, however, that Commonwealth Edison Com-
pany not use the prime farm land which it now seeks but rather
locate the plant and its facilities upon  idle, unproductive,
or marginal farm land, of which there are thousands of acres in
this area, both within and without  LaSalle County.  In this
regard, the original plan of Commonwealth Edison use was to a
considerably smaller tract of land  (5600  acres) than that  now
sought and which land was located directly along the south bank
of the Illinois River south of Seneca and three miles north of
the proposed site.  Several thousand acres still remain in this
general area which we believe could still be used for the  same
purpose and which could include a cooling lake.  Despite the
assertions of Commonwealth Edison Company that it can not  use
this type of land, engineering advices indicate otherwise.   Full
engineering plans were and are drawn for  this original site.
The land taken at Dresden, both for the first nuclear plant as
well as for the second nuclear plant, is  for the main part
highly marginal, unproductive land.  The  same poor land quality
and characteristics prevail in large part in the Lake Kincade
area and we are informed the same marginal quality of land is
-------
                                                             2267
 sought to be taken in the Cordova, Illinois area near the
 Quad-Cities.  The Brookfield Township Land Committee acknowledges
 the need for additional electrical energy.  This statement has
 been made repeatedly to Commonwealth Edison Company and to the
 public generally.  We are, however, unalterably opposed to the
 taking of prime farm land for the present proposed site and
 further oppose ^ropoood future similar takings of prime and good
                t<    1.1
 farm land, which must be taken according to the utility industry
 press releases, literature and projections.  If this is so,
 why was the poor quality of land taken at Dresden, Cordova and
 Kincade?  On the contrary, there is in fact available to the
 utility industry literally tens of thousands of acres of idle,
 unused and unproductive land which can, through modern engineer-
 ing techniques, be adapted to and for the construction of the
 nuclear energy plants and facilities.  Since the initial Common-
 wealth Edison Company announcement was made in early spring, the
 Commonwealth Edison Company has repeatedly stated that "its
 studies" and "its engineering research" indicate that none of
 the tens of thousands of acres of idle, unproductive lands in
 this area or, in fact,  throughout all of Illinois - which they
 have allegedly reviewed and surveyed - are adaptable or useable
 for nuclear energy plant sites.  This we deny.  Repeatedly, our
 group, through its attorney and its various representatives,
 has asked the Commonwealth Edison engineers to release and reveal
 all of their so-called in depth engineering studies and data to
 permit us and our engineers to analyze such data and research.
 Not once has Commonwealth Edison as yet responded to such a
 request.  We again challenge them ago MI to here and now release
 this information immediately so that we and all who are inter-
 ested in the agricultural industry might have an adequate and
 fair opportunity to thoroughly analyze and inquire into the
Commonwealth Edison studies.  The only answer we have received
-------
                                                             2268
from Commonwealth Edison engineers when such requests  have  been
made is "we are sorry, we can not release this information  at
this time.  Eventually you will receive it".  Eventually, why
not now?  We ask you, Commonwealth Edison,  to play fair with
us and all of the agricultural industry and release all of  your
studies immediately!   Actually most of the Illinois Valley area
from a point immediately west of Seneca on through west of  LaSalle
and Peru is all served by the Illinois Power Company.   It is a
known fact that the electric power sought to be generated at
the Brookfield site will not be used here but will be  transmitted
to the City of Chicago and the Cook County area.   We have no fear
that Commonwealth Edison will leave this area if they  are re-
quired to put this plant on idle, less productive ground.
Commonwealth Edison has every intention of being in on the
"economic kill" of this valley when it develops.
     2.  About the suggested job loss to this community:  If
this plant is removed to the original site proposed for it  by
Commonwealth Edison, to-wit, some three miles north of the
Brookfield site or to some other site in this area, no jobs
will be lost.  Obviously, the jobs will still be there and
the economy of this community will in no wise be effected.
Persons regularly travel many miles daily to their regular
places of employment, i.e., Caterpillar-Aurora, Caterpillar-Joliet,
to Owens-Illinois at Streator from Ottawa,  and from Libbey-
Owens-Ford at Ottawa from Streator, etc.  Moreover, there might
well be more jobs created should Commonwealth Edison Company
abandon the cooling lake project and invoke one of the several
alternatives available to them as suggested by the Department
of the Interior of the United States Government,  to-wit:
          A.  Dry cooling towers,
          B.  Wet cooling towers, or
          C.  Spray canals.
-------
                                                             2269
While Commonwealth Edison has only casually referred to these
alternatives, they do exist and, in fact, are successfully in
use in dozens of places, not only in the United States but
throughout the world.  They have proven satisfactory and are
constantly being constructed in lieu of and in preference to
cooling lakes.
     Cooling ponds are objectionable in the following major
particulars:
          A.  Cooling ponds by their very nature have a low
heat transfer rate and thereby require large surface areas -
they have been considered by numerous engineering authorities
to be impractical.
          B.  The quality of cooling pond waters will decrease
with time as solids left behind by evaporation accumulate.
          C.  Cooling ponds by the nature of their construction
concentrate dissolved solids.
          t.  Cooling ponds further collect impurities since
large surfaces are open to the atmosphere.
     The primary reason for cooling ponds ±a because they are one
of the cheapest and least expensive methods of water cooling.
Any environmental contribution is purely secondary and incidental
to their primary purpose and use.
     3.  Much is said about tax loss.  Actually, there would be
not tsx loss but a tax revenue gain if Commonwealth Edison were
to build on the idle or marginal land,  three miles to the north
of the proposed site or were to build on idle, marginal land
located elsewhere in LaSalle County.  Remember Commonwealth
Edison also owns large acreage in the Utica area.   Much of this
acreage is idle and unproductive.
     Should Commonwealth Edison build on marginal land:
-------
                                                            2270
          A.  The new plant and plant site would be located on
marginal land now producing very little tax revenue, and this
in turn would become high tax revenue producing land.
          B.  The present highly productive and highly taxed
prime farm land in Brookfield Township would still be available
for present and future taxation and would continue to contribute
its regular tax share.
     4.  About the right of condemnation or the taking of the
land:  We have been advised by many of the land owners and tenants
that certain of the Commonwealth Edison land agents have indi-
cated that the company has the absolute right of condemnation
and that if the land owners and tenants do not agree to the
prices and propositions presently being offered by Commonwealth,
they will receive less at some future condemnation hearing date
than the prices and propositions now proposed.  Such statements
are absolutely false.  Neither the Commonwealth Edison Company
nor any utility in Illinois, has the absolute right of condemna-
tion.  The Illinois Public Utilities Act, under which Common-
wealth Edison must file its application for a Certificate of
Convenience and Necessity, requires the concurrent action of
the petitioning public utility and the Commerce Commission to
vest the power of eminent domain.  Commonwealth Edison does not
have the right of eminent domain under this act until and unless
the Commission issues its certificate finding that the public
convenience and necessity exists for the facility.  Before any
action is taken by the Commission extensive public hearings
must be held under the law and will be held before the Illinois
Commerce   Commission.  If adverse to the Brookfield Group, the
decision will be taken through the entire appellate court
system of Illinois for adjudication.  The final determination
of whether or not the power of condemnation, in fact, will be
granted is at least two or more years away and possibly
-------
                                                            2271
 considerably longer.  For authority that Commonwealth Edison
 does not have the power of condemnation, we refer you to the
 case of Central Illinois Electric & Gas Co. v. Scully, 161 N.E.2d
 304, at page 307, wherein the Supreme Court of Illinois (195S)
 recited as follows:
     "The necessity for the improvement requiring condemnation
     and the manner of its construction are for the consideration
     of the condemnor, subject to the decision of the commission
     as to convenience and necessity.  The condemning petitioner
     does not have the right of eminent domain until the
     commission issues its certificate".
 We challenge Commonwealth Edison and its counsel to contradict
 this holding of law announced by the Illinois Supreme Court in
 the above case and which law governs today.  Commonwealth Edison
 has been totally silent on this point.  Don't be mislead by
 statements to the contrary!
     5.  The effect of deep wells on the surrounding territories
 not taken:  Commonwealth Edison admits it must sink numerous
 deep wells in the area to supply the pure water needed for steam
 generating purposes.  Tens of thousands of gallons of pure
 water will be needed twenty-four hours every day, 365 days a
 year.  This fact is not in dispute and is conceded by Common-
 wealth Edison.  The present average well depth in Brookfield
 Township is now approximately 600 feet.  Water is consistently
 and regularly available at this level to Brookfield Township
 residents for all purposes.  Commonwealth Edison says it will
 take water from deep well veins.  All well enough!  In recent
 years industries locating near Ottawa and Seneca who likewise
 take extremely high gallonages of water daily from deep vein
 levels made the same statement before sinking their wells.
Ask the farm and city residents who live in northwest Ottawa
 and beyond in the country, as well as in the Village of Seneca,
Manlius Township and parts of Grundy County, what happened to
 their relatively shallow depth wells once industries started
-------
                                                            2272
tapping the deep vein wells in these areas.  You've guessed
it!  Their wells went dry.  Consider also the disastrous
effect on raising livestock, to say nothing of human needs
should this occur!  Commonwealth has been totally silent on
this point.
     6.  The effect of the site and its facilities upon drainage
in Brookfield TownsKip:  The area proposed to be taken presently
contains approximately forty percent of the total tiling systems
of the entire Brookfield Township area; Commonwealth Edison Com-
pany personnel have stated unequivocally that all drainage tiles
proceeding through this area will be permanently cut and termina-
ted; that the number of tiles proceeding through this territory
is, in fact, unknown both as to quality and quantity and that
for a long time subsequent to the installation of this project
there will be a severe and substantial backing up of under-
ground drain waters and permanent flooding of lands not to be
taken but presently under cultivation surrounding the perimeter
of the proposed site.  Without question this constitutes a serious
and permanent threat to approximately an additional 2,000-3,000
acres of land adjoining the perimeter of the site proposed to
be taken.  Based upon competent engineering advice, this committee
believes that regardless- of the technological efforts made by
Commonwealth Edison Company, it is both an engineering and
physical impossibility to keep the entirety of the perimeter
of 2,000-3,000 acres from being permanently flooded and destroyed
for cultivation to a greater or lesser extent.  Commonwealth
Edison has been totally silent on this subject.
     7.  About Lake Brookfield:  Again much has been said regard-
ing the recreational and conservational value of the proposed
Lake Brookfield.  We invite you to examine and consider just
what Lake Brookfield will consist of.  Firstly, it will average
about 10 feet in depth.  It will average 95 degrees water
-------
                                                             2273
temperature.  It will be filled with whole,  "live",untreated
Illinois River water.  The Illinois River water contains a
high percentage of human and industrial sewage particulate
as well as a high brine content despite treatment processing.
The Illinois River further contains a high content of phosphate
and nitrates.  Lake Brookfield will have a system of channels
separated by numerous dykes which will protrude above water.
We are advised Lake Brookfield will not be a solid uninterrupted
mass of water from one shore line to another in any direction.
It will resemble water canals as in strip mine diggings.  Lake
Brookfield will evaporate an estimated 96,000 tons of pure
water every 24 hour period at an average annual water temperature
of 95 degrees - guess what will be left after normal evaporative
losses have been added to the high heat induced losses?  Right -
you guessed it!
     How recently have you enjoyed a refreshing swim in the
           water
Illinois Rivex/?  How recently have you enjoyed fishing in the
Illinois River, plus the further pleasure of eating the clean,
wholesome fish you have caught?  How recently have you enjoyed
the delightful aroma from the Illinois River?  How recently
have you noticed the green algae scum that forms on both the
Illinois and Fox Rivers' during the summer months when the water
                                                  "lake"
reaches a warm temperature point?  Bear in mind this/water will
be totally untreated and will average approximately 95 degrees
annually.
     In this connection,  it is interesting to note a letter
recently written by Mr. Thomas G. Ayers,  President of Common-
wealth Edison,  under date of July 31, 1970 to Mr.  Daniel N.
Beal,  Cashier of the Verona Exchange Bank,  Verona, Illinois,
wherein he states and we quote him directly:
-------
                                                            2274
     n	 The original water to fill this lake will come
     from the Illinois River and the daily evaporative loss
     will be made up from the river.
     Because the Illinois River is biologically impure, we
     are not sure at this point what level of aquatic life
     the lake will be able to support	"
     And what about Lake Kincade which Lake Brookfield is
supposed to duplicate?  Lake Kincade is fed by three natural
pollution-free water courses.  It was formed as a result of a
dam on Clear Creek about a mile upstream from the south fork
of the Sangamon River.  It has an average depth of 	 feet.
Because of its low pollution content, it is able to support
aquatic life.  However, at certain low water seasons of the
year there are extensive mud flats adjoining the perimeter of
Lake Kincade which prevent people from reaching any of the
waters thereof.  The average annual temperature of the water
of Lake Kincade we are told is 45 degrees to 50 degrees because
Lake Kincade receives the discharge waters from the Commonwealth
Edison Kincade power station which is FOSSIL FUELED AND NOT
NUCLEAR FUELED.  Fossil fueled plants discharge about 50$
less heat per kilowatt than nuclear power plants. The two
lakes are in no way comparable.
     8.  About the alternatives-to a cooling lake:  Commonwealth
Edison as well as all utilities have been aware for years about
cooling towers, both wet and dry, as well as spray canals.  The
United States Government, through the Department of Interior,
recommends the use of dry cooling towers or spray canals.  We
would be pleased to hear from Commonwealth in this regard.  It
is a known fact that cooling towers require no fan operating
power, occupy a fraction only of the ground space required for
cooling lakes, reduces hot and cold water piping costs, generate
no noise, and discharge their steam or vapor at a high level.
-------
                                                             2275
We  quote  from "Cooling Tower Newsletter", Number 4, issued
April, 1968,  published by Research-Cottrell, Inc., Harmon
Cooling Tower Division,  P. 0. Box 750, Bound Brook, New Jersey,
as  follows:
      "For extremely large installations such as power generating
      stations, natural draft towers should be considered.  These
      have significantly  higher initial cost than mechanical
      draft units, but they require no fan operating power,
      they occupy substantially less ground space, they reduce
      hot  and  cold water  piping costs, and they offer minimum
      maintenance over a  long service life.  In addition, they
      generate no noise,  and also discharge the steam plume at
      a significantly higher elevation, thus eliminating the
      problems of low level fog and drift."
      9.   Commonwealth Edison claims there will be little or no
fog arising from Lake Brookfield during cooler or cold weather.
You don't have to be an  engineer to appreciate the fog potential
Lake  Brookfield will contribute for many miles to the surrounding
territory.  Based upon engineering advices serious air pollu-
tion  conditions may arise throughout the year which will effect
a substantial number of  lands and acreages within a several
                 ~'.-r                               >»H
mile  distance of said lake site, causing fog, mist /general air
pollution, and all of which will further effect and produce
abnormal  weather conditions, thus possibly adversely effecting
the cultivation of large areas surrounding the proposed lake
site.  None of these points have ever been discussed by Common-
wealth Edison Company.
    10.  Regarding the economic loss to the community:  The
entirety of the 7,040 acres proposed to be taken, with the excep-
tion of the area taken for easements for roads and natural water-
ways,  is highly productive and superior farm land,  is rated
as Number 1 or prime farm land for eighty percent thereof, and
rated as Number 2 or good farm land for twenty percent thereof;
that the records and statistics of production of farm products
of all kinds,  including livestock,  grain,  and allother farm
items produced by this agricultural community approximates one
-------
                                                            2276
and one-half to two million dollars worth of retail value annuallyJ
the value of all products and services consumed and purchased  by
the Brookfield Township group, as a direct result of the agricul-
tural and retail economy produced by this area approximates
$700,000 annually.
     The area proposed to be taken directly produces approxi-
mately 700,000 bushels of feed grain annually, together with
2,000 head of livestock annually, all for public consumption.
It is a fact that food shortages can and do repeatedly develop
throughout the world and that the present rate of soybean and
corn consumption on both the national and international market
has soared to thirty to forty percent within the last six months
alone to say nothing of the serious corn blight loss problem we
are now faced with.  The actual feed grain reserves of this
country do not constitute in excess of one yearfs supply as
dictated by the needs of the national economy and will be further
shortened and reduced according to some agronomists.
     That annually more than one million acres of land are now
taken out of production in this country due to developments of
one sort of another, i.e., highways, house and building con-
struction, and the like; that our populatipn continues to
expand and soar and is looked upon as one of the grave issues
not only for the present but in the future as well; highly
productive andsuperior producing Number 1 farm land should
not be taken out of permanent production when other totally non-
productive and idle lands available by the thousands of acres
can and could be utilized for nuclear energy site facilities.
ONCE THIS LAND IS TAKEN IT WILL BE TOTALLY AND PERMANENTLY
REMOVED FROM PRODUCTION FOREVERMORE AND WILL, IN FACT, MOREOVER
PERMANENTLY ADVERSELY EFFECT A SUBSTANTIAL ADDITIONAL ACREAGE
SURROUNDING AND ADJOINING THE SITE.
-------
                                                            2277
    11.  Just what kind of land is Commonwealth Edison proposing
to take in Brookfield Township?  Much has been said about the
average or inferior type of land proposed to be taken.  Nothing
could be further from the truth.  Of all of the 7,000 acres
proposed to be taken not one acre is in the soil bank.  Approxi-
mately      acres is in what is known as the Federal Farm Program.
This program is entirely distinct and separate and is formed
for totally different purposes.  This is a year to year program
and is designed to balance supply and demand and to keep in
reserve a sufficient acreage for future food needs of this
country.  This reserve, which has long been a factor in American
agriculture, is no different from the electrical energy reserve
Commonwealth Edison hopes to acquire for electric energy users.
It is simply a sensible way of controlling highly productive farm
land and has long been recognized by agricultural experts as a
method of insuring adequate food supply for the nation:' at all
times.
     60% of the land proposed to be taken is classified as
Number 1 farm land by the United States Department of Agriculture.
Number 1 farm land is defined as land which will raise a minimum
of 125 bushels of corn per acre with an expenditure of not to
exceed $20.00 per acre for fertilizer, and would raise a mini-
mum of 40 bushels of soybeans per acre.  The remaining 2Q% of
the land proposed to be taken is classified as Number 2 farm
land by the United States Department of Agriculture.   Number 2
farm land is defined as land which will produce not less than
100 bushels of corn, with an expenditure of not to exceed $20.00
per acre for fertilizer,  and produce not less than 35 bushels
of soybeans per acre.
     To remove all doubt  on this point we are indebted to Mr.
Truman Esmond,  a local realtor for many years,  and who has
-------
                                                             2278
been the chief architect and representative of Commonweaxth

Edison in attempting to acquire the land in question.   In an

interview with Kr. Esmond taken on February 26, 1970 by Joan

Hustis of the Daily Times under the lead title "Huge Land

Acquisition Proposal Under Study", Mr. Esmond had this to say

about the character and quality of the land he and the other

land representatives of Commonwealth Edison now dispute:

     "About 7,000 acres, or almost 11 sections, of "prime
     farm land" are involved in the proposal, according to
     TrumarT Esmond, the local realtor representing the
     corporation."



             LET'S TELL IT LIKE IT IS I

Who is for the Brookfield Group?  To name a few:

          The First Presbyterian Church of Grand Ridge, Illinois,
          United Methodist Church of Ransom, Illinois,
          Brookfield Presbyterian Church of Marseilles, Illinois,
          St. Mary's Roman Catholic Church of Grand Rapids Township,
          St. Patrick's Roman Catholic Church of Ransom, Illinois,
          Illinois National Farmers Organization,
          Illinois Farmers Union
          Fox River Valley Community Action Council, consisting
             of United Auto Workers Locals 145, 184} 285,
             872, 881, 904, 922, 954, 1030, 1088, 1175 and
             1615, consisting of 8,000 members in locals from
             Woodstock to Streator, Illinois,
          First National Bank of Grand Ridge, Illinois,
          Cooperative Grain & Supply Co.,
          Laurence Gage, Ruth Gage, Michael Kennedy, Velma
             Kennedy, Max Ugolini, Coleen Ugolini, Charles
             O'Laughlin, Geraldine O'Laughlin, John Looft,
             Cyrus Trowbridge, John Ryan, Louise Ryan, Paul
             Ryan, Cyril Ryan, Helen Ryan, Joseph Heaton,
             Mabel Heaton, Larry Heaton, William Heaton,
             Jerome Heaton, Roy Spaulding, Robert Gage,
             Doris Gage, William Ross, Lois Ross,
          Plus an additional 5,000 people who have signed our
             petitions in the last 90 days.

                        Respectfully submitted,

                        BROOKFIELD TOWNSHIP LAND COMMITTEE

                        By  Ruth Gage, Laurence Gage
                            Mary Ann Muffler, Donald Muffler
                            Jean Widman, Mark Vvidman,  Jr.
                            Michael Kennedy, Velma Kennedy
                            Max Ugolini, Coleen Ugolini
                            William Ross, Lois Ross
                            John Looft, Ruth Widman, and
                            Robert Widraan, Co-Chairmen


             KEEP THE FIELDS IN BROOKFIELD/
-------
                                                                    2279
ILLINOIS COMMERCE COMMISSION,
          On its own motion

          vs.

COMMONWEALTH EDISON COMPANY POWER
COMPANY, CENTRAL ILLINOIS UNION
ELECTRIC COMPANY, ILLINOIS PUBLIC
SERVICE COMPANY, CENTRAL ILLINOIS
LIGHT COMPANY, IOWA-ILLINOIS GAS
& ELECTRIC COMPANY, ELECTRIC ENERGY
INC., INTERSTATE POWER CO., MT.
CAEMEL PUBLIC UTILITY COMPANY,
PEOPLES GAS LIGHT & COKE COMPANY,
and NORTHERN ILLINOIS GAS COMPANY.

Investigation of Air Pollution in
the State of Illinois so far as
Illinois Public Utilities are
involved.
                                                       ^
                                                          ;«/'
        55321
PETITION TO INTERVENE
     Now comes the First Presbyterian Church of Grand Ridge, Illinois,

United Methodist Church of Ransom, Illinois, Brookfield Presbyterian

Church of Marseilles, Illinois, St. Mary's Roman Catholic Church of

Grand Rapids Township, LaSalle County, Illinois, St. Patrick's Roman

Catholic Church of Ransom, Illinois, Illinois National Farmers

Organization, Illinois Farmers Union, Fox River Valley Community

Action Council, consisting of United Auto Workers Locals 145, 184»

2#5, 872, BBl, 904, 922, 954, 1030, 1083, 1175, and 1615, First

National Bank of Grand Ridge, Illinois, Cooperative Grain & Supply

Co., Laurence Gage, Ruth Gage, Caroline Whittaker, George Whittaker,

Lillian Briner, Henry Briner, Gladys Hallowell, Clifford Hallowell,

Michael Kennedy, Velma Kennedy, Kathryn Fleming, Margaret Carey, Max

Ugolini, John Kennedy, Helen Kennedy, Stacia Hynds, Hugh Killelea,

Mary Danaher, Charles O'Laughlin, Geraldine O'Laughlin, James Kennedy,

John Budach, William Bieneman, George Looft, John Looft, Cyrus Trow-

bridge, Walter Chrest, George Chrest, Florence Marsh, Dominic Ugolini,

Arlene Ugolini, Ronald Briner, Caroline Briner, Emmet Kennedy,

Margaret Kennedy, Edwin Morrow, Donald Muffler, Mary Ann Muffler,
-------
                                                                    2280
John Ryan, Louise Ryan, Paul Ryan, Cyril Ryan,  Helen Ryan, Robert
Carey, Emmett Moran, Carrie Moran, Joseph Heaton,  Mabel Heaton,
Larry Heaton, William Heaton, Jerome Heaton,  Roy Spaulding,
Ronald Frye, Rose Frye, Luella Beacher, Mildred Myers, Thomas
James, Benoit Hallett, Marjorie Hallett, John Feidler, Nancy
Feidler, Margaret Kennedy, Robert Gage, Doris Gage, David B.edeker,
Darlene Bedeker, Raymond Bedexer, Elizabeth Bedeker, Carrie Lou
Cleve, Forrest Cleave, Caroline Gage, Melva Gage,  Edward Caputo,
Venita Caputo, William Ross, Lois Ross, Kenneth Edwards, Parnell
Maier, Anna Maier, Elmer Maier, Felicia Maier and Orel Logsdon,
by Berry & O1Conor, their attorneys, and petitions this Commission
for leave to intervene in the instant proceeding and in support
of their position, allege as follows:
     1.  The various petitioners above named and described are
landowners, tenants and other persons, religious and lay organi-
zations and groups either residing within or residing closely
without and on the perimeter of the territory proposed to be taken
by Commonwealth Edison Company of Chicago, Illinois for a nuclear
energy generating plant site in Brookfield Township, LaSalle
County, Illinois.  All of said persons, corporations, organizations
and groups have organized to promote and maintain the present and
long-standing environmental quality of agricultural and environ-
mental life which has prevailed in Brookfield Township, LaSalle
County, Illinois since its development as a highly productive and
highly valuable farm community and center for over 100 years last
past.   These petitioners represent to the Illinois Commerce
Commission that they will all be subjected to a permanent and
total change in environmental land use and development both within
and without -the area effected if the taking of said land is per-
mitted, for the following reasons:
-------
                                                                    2281
     A.  The entirety of the 7,040 acres proposed to be taken with
the exception of the area taken for easements for roads and natural
waterways for highly productive and superior farm land is rated
as Number 1 or prime farm land for eighty percent thereof, and
rated as Number 2 or good farm land for twenty percent thereof;
that the records and statistics of production of farm products
of all kinds including livestock, grain, and all other farm items
produced by this agricultural community approximates one and one-
half to two million dollars worth of retail value annually; that
the value of all products and services consumed and purchased by
the above persons, organizations, and entities, all of whom are
from the Brookfield Township community, as a direct result of the
agricultural and retail economy produced by this area approximates
$700,000.00(f«ven h"n*;rf?   annually.
            thousand dollars;
     That the area proposed to be taken directly produces approxi-
mately 700,000 bushels of feed grain annually, together with  2,000
head of livestock annually, all for public consumption.  That it
is a fact that food shortages can and do repeatedly develop
throughout the world and that the present rate of soybean and
corn consumption on both the national and international market
has soared thirty to forty percent within the last six months alone.
That the actual feed grain reserves of this country do not consti-
tute in excess of one year's supply as dictated by the needs of
the national economy.
     That annually more than one million acres of land are now taken
out of production in this country due to developments of one sort
or another, i.e., highways, house and building construction, and
the like; that our population continues to expand and soar and
is looked upon as one of the grave issues not only for the present
but in the future as well; that highly productive and superior
producing Number 1 farm land should not be taken out of permanent
-------
                                                                      2282
 production when other totally non-productive and idle lands
 available by the thousands of acres can and could be utilized
 for nuclear energy site facilities; that once this land is taken
 it will be totally and permanently removed from production for-
 evermore and will in fact adversely effect a substantial additional
 acreage surrounding and adjoining the site.
      B.  That immediately to the north and adjoining this property
 lies approximately 5,000 acres of rough, unproductive land, a
 large portion of which is already owned by Commonwealth Edison
 Company; that this land is,  in fact, available to the Commonwealth
Edison Company and its availability as an alternate site should be
 considered and inquired into in depth by the Illinois Commerce
 Commission in connection with its general inquiry into this sub-
 ject matter.
      That to date hereof the Commonwealth Edison Company has refused
 to. reveal its engineering data or studies as to the feasibility of
 developing this alternate site or any other alternate site, except
 by general statements indicating increased costs would ensue but
 without divulging any particulars.   It is the opinion of these
 petitioners, based upon competent engineering consultation and
 advice, that in fact, the 5,000 acre tract adjoining to the north
 could be equally utilized and developed for identical atomic
energy producing purposes; that the 5,000 acres of rough, unpro-
 ductive land to the north produces little or no agricultural
 products, is largely idle, and could well be utilized as an
 energy producing site; that a visual inspection and comparison
 Of the two areas clearly reveals a total and complete distinction
 in soil fertility and productive capacity and quality.
      C,  That the area proposed to be taken presently contains
 approximately forty percent of the total tiling systems of the
 entire Brookfield Township area; that Commonwealth Edison Company
-------
                                                                    2283
personnel have stated unequivocally that all drainage tiles pro-
ceeding through this area will be permanently cut and terminated;
that the number of tiles proceeding through this territory is. in
fact, unknown both as to quality and quantity and that for a long
time subsequent to the installation of this project there will
be a severe and substantial backing up of underground drain waters
and permanent flooding of lands not to be taken but presently under
cultivation surrounding the perimeter of the proposed site.   That
this constitutes a serious and permanent threat to approximately
an additional 2,000 acres of land adjoining the perimeter of the
site proposed to be taken.   That based upon competent engineering
advice, these petitioners believe that regardless of the technological
efforts made by Commonwealth Edison Company, it is both an engineer-
ing and physical impossibility to keep the entirety of the perimeter
of 2,000 acres from being permanently flooded and destroyed for
cultivation to a greater or lesser extent.
     D.   That these petitioners have further been informed that
the surface of the lake area will constitute approximately 4»500
acres; that the temperature of the water being emptied into this
lake, after cooling the generators to be located on the proposed
site, will vary between 70 and 110 degrees; that by reason thereof
these petitioners state, based upon competent advice and counsel,
that serious air pollution conditions may arise throughout the
year which will effect a substantial number of lands and acreages
within a several mile distance of said lake site, causing fog,
mist, general air pollution, and will further effect and produce
abnormal weather conditions, thus, adversely effecting the cul-
tivation of large areas surrounding the proposed lake site.
     E.  That these petitioners further state that the Common-
wealth Edison Company proposes to take from the Illinois River
tens of thousands of water a day and that this water, which
-------
                                                                  2284
contains a substantial percentage of salt and sewage,  will be
pumped into the proposed lake in the middle of the farm community
of Brookfield Township.   That engineering estimates indicate some
60,COO tons of water will evaporate daily from this lake site and
that since mainly clean water will evaporate, the brine and sludge
particles pumped from the Illinois River will remain behind and
settle in the lake; that by reason thereof opprobrious odors may
well result and that further the environmental quality of the lake
will be seriously reduced and hampered due to the resulting sludge
and brine condition.
     F.  That to supplement the water supply to be taken from the
Illinois River, the Commonwealth Edison Company intends to put
down numerous deep wells to pump thousands of gallons of water a
day from the basic water table underlying all of Brookfield Town-
ship; that although the Commonwealth Edison Company proposes to
draw water from a deeper level than that presently serving Brook-
field Township, repeated similar deep well drawings heretofore
carried out by other industries in other parts of LaSalle County
have conclusively shown that the current water levels used for
general consumption by the public of this area located at 300 to
500 to SOO feet sublevel in these other areas have been greatly
effected and depreciated by such other deep level -withdrawals of
*-">ter.   That, accordingly, these petitioners believe the value
of the remaining land will be greatly reduced throughout all of
the township despite precautions and engineering techniques
Commonwealth Edison Company might introduce as to this factor.
     2.  These petitioners further state that, in their opinion and
based upon competent engineering advice, it is technically possible
for Commonwealth Edison Company to locate their proposed nuclear
-------
                                                                      2285
 generating site upon and within the 5>000 acres of rough and
 unproductive land located immediately north of the proposed site
 or upon other unproductive lands located elsewhere in the State
 of Illinois and thereby significantly and totally remove all of
 the  environmental loss which must and will ensue to the Brookfield
 Community if the Commonwealth Edison Company is permitted to ob-
 tain the proposed site.
     3.  The Illinois Commerce Commission has the responsibility
 and  power to protect the public safety and environmental welfare
 by ordering the Commonwealth Edison Company to remove and relocate
 its  proposed site to either the site immediately north and which
 is presently available to it or to some other site within the
 State of Illinois; that, in fact, the Commonwealth Edison Company
 has  used lands of extremely inferior value, being those located
 in Christian County, Illinois for their electrical generating
 site near Kincade, Illinois; that further, in fact; the land
 heretofore used and presently being used by Commonwealth Edison
 Company at its Dresden, Illinois plant located outside of Morris,
 Illinois, is inferior land and of extremely poor quality, none
 of which is in any way productive or comparable with the Brookfield
 Township properties proposed to be taken; that, in addition, the
 site proposed to be used by Commonwealth Edison Company for its
plant located near the Quad-Cities, at Cordova, Illinois consists
of very sandy type soil and is of thin and marginal quality and
productiveness.   That, in addition, to the rough site located to
the north and presently available to Commonwealth Edison Company,
there are literally thousands of acres of rough and unproductive
land located throughout the State of Illinois upon which all of
such proposed site  could be located.   These petitioners state
that current costs of transmission are no longer a factor as
witness the Kincade plant and Quad-Cities plant, independent
-------
                                                                     2286
engineering counsel also confirms this.   Accordingly,  there is
available to Commonwealth Edison Company a multitude of sites
which should be considered and inquired  into by the Illinois
Commerce Commission.
     4-  These petitioners further state, based upon the literature
available to them and published by the utility industry, that it is
the proposal, not only of Commonwealth Edison Company, but of other
utilities to install throughout all of northern Illinois plant
sites located upon similar land and that presumably 7,000 to 10,000
to 12,000 acres of farm land comparable  to that proposed to be
taken will be needed for each site.  That, accordingly, the pro-
posed Brookfield Township taking is indeed significant and will
set a precedent not only for this particular area but for the
entire State of Illinois and these petitioners respectfully and
urgently request the members of this Commission to make full and
due inquiry in all particulars and thus  meet its responsibility
to these petitioners and to the public.
     WHEREFORE, these petitioners request leave to intervene in
this proceedings and to be treated as parties to this proceeding
and ask the Commission to grant the following relief:
          A.  To order Commonwealth Edison Company to utilize
existing technology to the maximum feasible extent in relocating
its proposed nuclear energy site upon unproductive and unfertile
land lying idle and having no agricultural value, and
          B.  That the Illinois Commerce Commission expand its
inquiry on its own motion under and within its investigative
docket to include all activities of all  Illinois utilities which
might create or cause deleterious effects upon or to agricultural
and all other environmental land uses as the same are subjected
to utility uses from time to-time.
-------
                                                                      2287
          C.  Require the Commonwealth Edison Company to show
that it has exhausted all reasonable and proper alternatives to
the proposed Brookfield site.
          D.  That it deny to the Commonwealth Edison Company any
use whatsoever of the proposed Brookfield site for nuclear energy
generating purposes.
          E.  To grant such other relief as will protect the health,
safety, agricultural and ecological environment of the Brookfield
Township area and the citizens thereof.

                                 Respectfully submitted,
                                 BERRY & 0*CONOR,
                                 Attorneys for Petitioners,
STATE OF ILLINOIS  )
                   )  ss.
COUNTY OF LASALLE  )                      VERIFICATION
     ANDREW J. 0*CONOR, being first duly sworn upon oath, deposes
and states that he has read the foregoing petition by him sub-
scribed and that the matters therein alleged are true and correct
to the best of his information and belief.
                                         Andrew J< 0'Conor
Subscribed and sworn to before me
this  /f**-   day of August, 1970.
,*<>
Not
        otary Public.
BERRY & OfCONOR
Attorneys for Petitioners
130 East Madison Street
Ottawa, Illinois
Telephone: (&L5) 434-6206
-------
                                                      22&B





                        D. D. Comey



           MR. STEIN:  I have a statement from an old friend



of the conferees, I guess, John Chascsa, Lake Erie Cleanup



Committee, and I would like to put it in the record as if



read without objection.



           (The statement above referred to follows on



Pp. 2239-2290.)



           MR. STEIN:  Do we have Frederick M. Brown?



           David D. Comey?  He was here before.  There



he is.








           STATEMENT OF DAVID D. COMET, DIRECTOR,



           ENVIRONMENTAL RESEARCH, BUSINESSMEN FOR



           THE PUBLIC INTEREST, CHICAGO, ILLINOIS








           MR. COMEY:  Mr. Stein, a funny thing happened to



me on the way to the conference.  A couple of weeks ago I



wrote to Mr. Klassen and asked if I could appear today,



and I didn't get an answer from him.  But yesterday his



secretary called my secretary and said that I should be



prepared to testify at 9:30 a.m., Tuesday, October 6, and



I find when I come here today that, alas, we are not



scheduled.



           So since I have taken so much time already today,



I would like with your permission to submit a written
-------
                                                                         2239
                                             September 23, 1970
Lake Michigan Snforcercent Conference
Sherman House
100 tfest Randolph 3treet
Chicago, Illinois

Attentipns  Chairman, Murray otein, Chief iinforceaent Officer
            Interior's Federal .Vater Duality Administration

Dear i'ir. 3tein:

It is indeed encouraging to learn that all types of Pollution are being
investigated by your Coraraittee.

'.Ve have, on many occasions, heard that one type of waste after  another
is responsible for the condition of our Lakes, Hivers and  streams.   In
some instances we have condemned the use of our waters  ar>  durapAn-^
grounds or hiding places for unwanted waste sewa/je, rofuse and  hot  water
from large Industries,  However, it took our President, Hichard .•;.  Nixon
to open our eyes to the serious dangers involved in permitting  Thermal
Pollution to further complicate our Snvironaental problems.  3o, if
Hiscayne Uay can Beccrae a living mass of Algae interspersed  with dead
and dying marine and bird life, this could and would  crente  a  very
nauseating stench in the area,  (which by the way is the location of
our Southern «hite House, it inn't  used much, but  it  i« th-ire.) You
can im'.r^ino what could ha j?p«n  to Lake Michigan,  Lake  Srie or for that
•natter  any  of  our  inland  Lakss.  La're Michigan  is  the moat vulnerable
 though,  and  then Lake  -Srie.

Lake  Michigan  from Muskegon to -'^»ry,  Indiana,  and  then on to Chicago
is (as  you  km--")  the  natural pocket with no pl^ca for the water to  flow.
This  area has  for  many years received all sorts of wnste, it has been
 the cause of many  illnesses, much fish and wild fowl rnort slity, and
 could become a hot bed of mora of  the same,  if permission to use Lake
 Michigan ware  granted to cool industrial or municipal hot water.

 Why must the general Public have to accept the loss of the use of  a
 Public Lake,  Stream or River,  and be ex ected to pick up  the tab for
 cleaning up the mess when it becomes too unbearable?

 There are,  as  you have pointed out, many ways to cool and purify water
 and there are some that have not even been considered.
-------
                                                                       2290
page 2
Mr. M. otein
Sept. 23, 1970
Perhaps the state of Michigan's Fisheries Departaent are expecting to
use the warmer water to escalate the growth of the Coho that is being
planted by them, or perhaps this is a good way to get a ready cookad
meal*

Seriously, the Lake Krie Cleanup Committee supports your stand on pro-
hibiting the use of our Lakes as a depository of Thermal Pollution, or
any other form.

Knowing the area around Ludington, I would suggest that these combined
systems be used - such as an inland cooling Pond with spray and return
canals for re-use in the plant or into the Lake.

Due to unforseen circumstances I am unable to attend this conference,
but would Like to take this opportunity to voice the opinion of the
Lake Srie Cleanup Committee, and the Monroe County Hod and Gun Club ,
and to thank you for this presentation.

for a better Environmental tomorrow, I remain.
                                             Sincerely,-,
                                             John Chascsa, President
                                           ./Lake Srie Cleanup Committee, Inc.
ec:   Conferees:
Illinois Environmental Protection Agency,
Wisconsin Department of Natural Resources,
Indiana Stream Pollution Control Soard,
Michigan Water Resources Commission
-------
                                                      2291





                        D. D. Comey



statement to be entered into the record at a later time«



           MR. STEIN:  Can you get that in next week?



           MR. COMEY:  I will get it to you by Tuesday.



           MR. STEIN:  It will be included in the record.



           MR. COMEY:  Thank .you very much.



           MR. HARPER:  Mr. Stein, since this gentleman —



           MR. STEIN:  Come on up here.  We can't hear you.



           MR. HARPER:  I am John D. Harper, and I would



like to know what this gentleman's testimony will relate



to next week.  I want to know if I am going to be missing



anything as to what particular line of thought he has on



this.  I wonder if he could just very briefly — since he



has previously expressed himself — if he could very



briefly just encapsulate a couple of his views.  Would you



be kind enough to do this?  This is with your permission.



           MR. STEIN:  Oh, surely, he can respond to this



if he wishes.



           MR. FETTEROLF:  May I ask who Mr. Comey



represents ?



           MR. COMEY: I am representing Campaign Against



Environmental Violence, a Chicago not-for-profit corpora-



tion organized in April 1969.



           MR. STEIN:  I guess I might have read that.



           Do you want to respond or not?
-------
                                                     2292





                        D. D. Comey



           MR. HARPER:  I can appreciate that off the cuff



it may be difficult, but it would be appreciated if you



could just encapsulate somewhat briefly your views while



we are all present.



           MR. COMEY:  Well, briefly what I was going to



talk about, Mr. Harper, was that it is my feeling that the



time for research and for study is past.  I think — I won't



say is past, but with respect to setting a thermal criterion



for Lake Michigan, at the present time, I think it is past.



           I think that at the present moment the Federal



paper which was presented last week to the public ought to



be supported by the four other conferees, and I hope that



if they see their way to supporting that, this entire issue



will be resolved before the enforcement conference wends



its way through the ISO-day procedure.



           MR. HARPER:  I concur with you and I have indi-



cated in testimony I too support this.  I support this on



the basis of the last conclusion  for ecological reasons,



and I am sure you do.  I think we are all people of good



intent.  For ecological reasons we support this.  But for



ecological reasons we should not be in this auditorium.



The carbon monoxide level here right now may be 9 or 10;



the permissible level is 13 p.p.m.  So,"for ecological



reasons "does not always govern, and I just make this point,
-------
                                                      2293





                       D. D. Comey



that we live in a society that is a rather magalopolis



from Milwaukee to Gary, and you must take into context



a number of these factors if we are going to present to



the board all of the testimony for the past week or 10 days,



          I am glad to have your view.  I agree with you



wholeheartedly.  For ecological reasons we should stop the



heat — for ecological reasons.  Something I am far more



concerned with is the chemical degradation, but ecological



reasons do not always govern.  It is unfortunate but that



is the way of life.  I didn't mean to —



          MR. COMEI:  There is probably one other thing



that I shall point out in my written statement, and that



is that based on all of the industry projections — and



these were brought out in the Federal paper — the number



two paper on the alternatives to thermal discharge — the



incremental cost of providing alternatives of cooling are



very small.



          Now, the Federal paper chose to use busbar costs.



I think that is somewhat unfortunate because the public is



not aware that the percent increase in busbar costs is



considerably higher than in the incremental cost to the con-



sumer.  Normally busbar costs are about 21 percent of power



charges.  So that even assuming that the 9 percent



for just cooling towers is the busbar incremental cost,



this would represent less than a 2 percent additonal cost,
-------
                                                       2294
                      D. D. Gomey



and that on the average house-holder's bill it would be



approximately 24 cents a month.  Now, for a quarter, if



we save Lake Michigan —



          MR. HARPER:  For a quarter, I am sure, for a



dollar even.  But if you put this off on the American public



what are they going to do?  What has the experience been in



the proliferation of trash?  We are no better.



          But for a quarter — and what is before the



board here now is the determination to come up with either



a standard or some means that is consistent with the needs



of society and the people that vote, and these people have



in mind that, "Oh, it is all right; let the American public



pay another 25 cents.H  As you say, it may not set too well.



 It is unfortunate but it may not.



          So we are in agreement there, and I am glad to



have your views.  I think the value of this whole confer-



ence is the diversity of opinion, and as long as we have



this forum, it is essential.  I think that this board — if



I might just proselytize a little — Mr. Stein has shown



remarkable objectivity to me — not to me personally but



to the diversity of views.  How these gentlemen can sit



through a week of this is beyond me.  We are drawing to a



conclusion now, fortunately, I would imagine.



          I think that the point  is well taken, but I
-------
                                                      2295





                        D. D. Comey



would just like to emphasize the ecological reasons do not



always govern, unfortunately.  The pristine purity of Lake



Michigan can never be restored to the time that Kinsey was



first living on its shores,



           MR, COMEY:  Mr, Stein, may I be permitted to



ask you one question?



           MR, STEIN:  Tes,  Is the colloquy completed?



           MR, HARPER:  Yes, thank you,



           MR, STEIN:  Go ahead,



           MR, COMEY:  Supposing by December the other four



conferees from the States are unable to agree upon any



standard or criterion for thermal discharges to Lake



Michigan?  Is it possible for the Secretary of Interior



upon recommendation of the Federal Water Quality Adminis-



tration and other constituent bodies with the Department



of Interior to lift the thermal criterion out of the



enforcement conference and set Federal standards?



           MR, STEIN:  Well, whenever you ask a question



of a person in the field you get the same kind of problem



we had when we asked Professor McWhinnie something in her



field.



           One, I would    suppose that — because of my



past experience with these conferees,   and I have been



working with these States for a long, long time —
-------
                                                      2296
                         D.  D.  Comey



we are going to come to an agreement, and I am very confident



that we will.



           The remarkable thing about our process of govern-



ment or this process is, untidy as it may seem to many, we



can resolve problems and come up with solutions even though



we can't agree on philosophy, professional discipline,



jargon, or what we think is the right way to express some-



thing.



           However, we have two operations here:  One, we



have an enforcement conference; and, two, we have a standard-



setting procedure.  If we adopt the standard-setting pro-



cedure and we hold a Federal standard-setting conference,



we have to give notice; we have to put that out.  We will



have to give the States six months to protest, and it is



all built into the law.  That is a rather time-consuming



process.



           MR. COMEY:  You are talking about the ISO-day



procedure?



           MR. STEIN:  No, I am not talking — as I say,



the law is very complicated.  If we would set a Federal



standard, we hold the conference with the State, have all



you people in again, make another record, and then we set



a Federal standard.  Then we publish that in the Federal



Register — first, we publish it before we go out, then we
-------
                                                     2297





                        D. D. Comey



publish it again.  Then we give the State six months to file



a disagreement.  Then if they do, we have a hearing.  We



are in a process like that with Iowa thermal standards,



among other things, and that is taking quite a time.



           I think if I sensed the feeling of the four



States here as well as the Federal Government, we recognize



the urgency of this problem and except as a last resort we



will not permit ourselves to embark on a confrontation



course between State Government and Federal Government which,



by virtue of the time consideration, that is built into our



statute, would place a resolution of this problem maybe a



year off.



           So I think we are all going to make a valiant



effort to try to solve this by negotiation and discussion



through this conference technique.  Otherwise if we go the



other way, it is at least going to be probably a year away



before we can promulgate a Federal standard which should



stand up, assuming that it is not modified in any way by the



procedures that we have to go through in between.



           MR, COMEY:  So I take it that what you are



saying is that this will be solved far sooner than the



one year that would be necessary under the other



procedure,



           MR, STEIN:  I am always optimistic.  That is why
-------
                                                     22 9S





                        H. B. Olin



I am here, and that is why we go into the night*  There



isn't a place we won't go, nor a place or something we



won't sit through, and patiently sit through, all of the



evidence to try to cut that time down.  If we wanted to



sit on our bureaucratic doubts and just act the way we are



authorized to act under the law, sure we can kick these



procedures off, but it will take a long, long time before



you would get a resolution,  I think this is the best way



and the fastest way,  I would like to give it a chance,



           MR. COMEY:  Thank you,



           MR, STEIN:  May we have Harold B, Olin?








           STATEMENT OF HAROLD B. OLIN, AIA,



           MEMBER, BOARD OF DIRECTORS, LAKE



           MICHIGAN REGION PLANNING COUNCIL,



                  CHICAGO, ILLINOIS








           MR. OLIN:  Mr0 Chairman, members of the con-



ference, ladies and gentlemen,  I am appearing today on



behalf of the Lake Michigan Region Planning Council, a



4-State planning organization sponsored by the American



Institute of Architects Chapters of the States of Wisconsin,



Illinois, Indiana, and Michigan.  It is the objective of



the organization to study resource problems from a
-------
                                                     2299






                        H. B. Olin



regional point of view and recommend courses of action to



governmental units and agencies.



           The shores of Lake Michigan are ringed with a



deadly necklace of some thirty power generating plants and



a multitude of industrial plants spewing their waste



effluent into the lake in ever-increasing amounts*  Power-



plants alone in 1963 were dumping almost 30 billion B.t.u.Afe



per hour of waste heat into the lake and the total for all



industries and sewage treatment plants is over 40 billion



B.t.ufeper hour.  By the year 2000 these figures are



expected to increase almost 11-fold to431 billion B.t.u.Vs



per hour.



           Department of Interior and independent scientific



studies document the devastating effect of these thermal



discharges into the lake.  Professor John Bardach of the



University of Michigan, whom you heard earlier today also



testified recently at several hearings on powerplants as



follows:



           "One electrical generating plant will have some



adverse effect and several of them would exacerbate



conditions in a more than additive manner, due to the



prevailing hydrographic conditions set forth below0



           vSome scientists believe that heated water



remains on the surface and quickly loses heat to the
-------
                                                     2300
                        H. B. Olin



atmosphere rather than to the water.  However, present



knowledge of water-air heat exchange and heat exchange



between water masses in the regions of Lake Michigan to be



affected is incomplete as there is not available informa-



tion on all possible weather conditions such as patterns



along the shore under which these exchanges would take place,



Nevertheless, and especially if there are a dozen electri-



cal generating plants along the shoreline and if the



currents flow along this shore as they are indicated to



do, long-term adverse effects of heating the shallow water



are likely to occur and eutrophication is likely to be



accelerated,"



           The First Annual Report of the Council on



Environmental Quality states the problem in different



words but with the same thrust.  It also highlights the



need to curtail thermal discharges, and I quote:



           "Waste heat is one of the most serious emerging



sources of water pollution.  The electric power industry,



which currently discharges over #0 percent of all the



thermal heat into the Nation's waters, doubles its capacity



every decade.  The trend toward larger, nuclear plants,



which creates 50 percent more thermal pollution in water



per unit of power than fossil-fuel plants, could result



in damage to aquatic systems, if it is not controlled.
-------
                                                     2301






                        H. B. Olin



With the tremendous thermal pollution potential of



projected power production, it is fortunate that waste



heat from electric generating plants can be adequately



controlled.  Waste heat and thermal pollution can be



reduced by improving the efficiency of the plants; by



making productive use of heat; and by the use of cooling



towers, cooling ponds, or spray ponds."



           Recognizing the need for additional power to



serve the needs of a burgeoning economy, the Council's



report recommends a National power policy based on broad



based regional criteria of sound planning and environ-



mental protection, which we heartily endorse.  The Coun-



cil's report says:



           "For example, the need for a National energy



policy is clear.  As the demand for power increases



rapidly, new power facilities have to be built.  Power-



plants will pollute the air with oxides of sulfur and



nitrogen, the water with heat, and the landscape with



mammoth towers and obtrusive power lines."



           In his message to Congress transmitting the



report of the Council, President Nixon emphasized:



           "Unless we arrest the depredations that have



been inflicted so carelessly on our natural systems —



which exist in an intricate set of balances — we face
-------
                                                        2302






                        H. B. Olin



the prospect of ecological disaster ....



           "Natural systems are generally 'closed systems.



Energy is transformed into vegetation, vegetation into animal



life, and the latter returns to the air and soil to be



recycled once again.  Man, on the other hand, has developed



'open* systems — ending all too often in an open sewer or an



open dump.



           "We can no longer afford the indiscriminate waste



of our natural resources; neither should we accept as



inevitable the mounting costs of waste removal.  We must



move increasingly toward closed systems that recycle what



now are considered wastes back into useful and productive



purposes.  This poses a major challenge — and a major



opportunity — for private industry."



           The concept of closed systems endorsed by



President nixon implies not just minimal discharges, but



zero discharges into the lake.  We support that stand and



urge this conference to adopt a standard which would



prohibit any thermal additions to the lake from any



source.



           Thank you.



           I have a personal remark at this point.  I am



reminded of a statement made by a knowledgeable observer



about a year ago, who pointed out that Lake Michigan, and
-------
                                                       2303
                        H. B. Olin
especially the southern tip of it, is very much like a
pus-filled appendix on the "bowel of civilization."  I
myself could use simpler terms to describe the same
phenomena but in any case I want to point out that the
patient is critically ill and surgery is needed immediately
and I urge the conferees to take appropriate action — very
drastic action — as soon as possible.
           Thank you.
           MR. STEIN:  Thank you, Mr. Olin.
           Are there any comments or questions?
           If not, thank you very much, sir.
           I have a statement I would like to put in the
record as if read from A. J. Boehm, Executive Vice Presi-
dent of American Fishing Tackle Manufacturers Association.
           (The letter above referred to follows on P.
2304.)
           MR. STEIN:  I think we called on these names
before.
           Mrs. Paul Kaefer.
           (The following statement was submitted to be
entered into the record as if read.)
-------
                                                        CENTRAL 6-0565 • AREA CODE 312

                                                                        2304
AMERICAN FISHING TACKLE MANUFACTURERS ASSOCIATION
                      20 NORTH WACKER DRIVE • SUITE  20M


                           CHICAGO, ILLINOIS 60606

                             October 2, 1970
        Mr.  Murray Stein, Chairman
        Lake Michigan Environment Conference
        Sherman House
        Chicago, Illinois
        Statement of A. J. Boehm,  Executive Vice President
        American Fishing Tackle Manufacturers Association

        Over the past four days much has been said pro and  con about
        heated water from atomic power plants damaging Lake Michi-
        gan.  We do not propose to  reiterate these arguments; rather,
        we desire to have the records show that this Association sup-
        ports the U.S. Government's proposed maximum of  one degree
        heat rise in waste water discharged into the Lake from power
        generating sources.

        Also, we would like to speak for the fisherman. Approximately
        25 per cent of the 30-some  million people who live in the four
        states surrounding Lake Michigan are fishermen.  As fishermen,
        they violently oppose taking any risk that may jeopardize the fish,
        their  sport, and also as a food supply.

        The public is aroused and rightfully deeply concerned.  The public
        is not of a mind or mood to accept any tinkering with their natural
        resources.  The public is not objecting to any increased costs for
        the installation of cooling facilities at generating plants.  The pub-
        lic has learned that it is much easier to prevent pollution before
        it starts than it is to stop it after it has begun.  Lake Erie is cer-
        tainly an example.

        True conservationists who  have studied the deterioration of our
        environment recognize the  need for caution. Their  watchword is
        "When in doubt,  don't".
                                    Signed
                                                   A. >J.  Soehm
                                              Executive Vice President
-------
                                                       2305


                       Mrs. P. Kaefer



           STATEMENT OF MRS. PAUL KAEFEE, CITIZEN,

                       NORTHBROOK, ILLINOIS



           MRS. KAEFER:  My name is Mrs. Paul Kaefer.  I

live at 3921 Oak Avenue, Northbrook, Illinois.

           As a citizen I feel that the lake is my resource.
                                                       A
When I use it I have a responsibility to not abuse it.  All

citizens, utilities, and industries have this responsibility,

None of us must interfere with the nature of the lake.  I

ask you to set standards that would permit no heat to go

into the lake.

           In this age of space travel and other technical

achievements, it is imperative that utilities and industries

use such technological knowledge and devise methods so that

no heat enter the lake.

           I have a family to return to and my responsibili-

ties do not permit me to stay past 11:30.  I came at 9:30.

           I want my testimony entered into the record.

           MR. STEIN:  Mrs. Robert Herlocker.
-------
                                                      2306






                      Mrs. R, Herlocker








           STATEMENT OF MRS. ROBERT D. HERLOCKER,



           CALUMET AREA BRANCH, AMERICAN ASSOCIATION



           OF UNIVERSITY WOMEN, MUNSTER, INDIANA








           MRS. HERLOCKER:  My name is Mrs. Robert D0 Her-



locker of Luast^r, Indiana.  I am representing the  Calumet



Area Branch of the American Association of University Women.



           The thermal standard proposed by the Department



of the Interior gives us a ray of hope that man will have



the intelligence to take action in time to avert disaster,.



           We do not ask, we do not request, we do not urge,



we demand that the States adopt the recommended standard.



           Most of our members live in Indiana in  the



Calumet region.  In efforts to do something to clean up



our environment, we encounter nothing but excuses  and buck-



passing between the State and local agencies:



           "We don't have the manpower to do the job."



           "fcfe don't have the monitoring equipment."



           "We don't have the money."



           "These things take time."



           "The laws aren't strong enough."



           "Industry has a timetable."



           We say to you now, and I address myself primarily
-------
                                                      2307
                     Mrs. R. Herlocker


«, the Indiana representatives, all y.u need is the «isdom,


               Q«H the backbone to accept these recommenda-
the integrity, ana ™

                   ou are net servants of the Republican


                    ~aMr *rty, <»r of industry; you are
 Party,  of the Democratic


 servants of the people
                     -_  said:  "To every thing there is a
            Ecclesiar

                   ^o every purpose under heaven."  This

  season,  and  a tiff

                 .fill your purpose in the public interest.

  is the time to
               fEIN:  Thank you, Mrs. Herlocker.
             MF

              MILLER:  I only have one comment.


            * all my time in public service if there is


           know it is that I am a servant.  I always have

    one  tr
        ilways will be.


          MRS. HERLOCKER:  And you tell them in Indianapolis


     .blic is after you and they have got to do something.


          MR. STEIN:  Thank you, Mrs. Herlocker.


          May we have H, R. Thoke?   Is H. R. Thoke here?


          Mrs. Winston?


          Mer. Berghoff?


          Mr. James Sloss?  (See P.  230S)


          Mr. Michael R. Rouse?  (See P. 2309}


          Mrs. Maynard J. Seidmon?   (See P. 2310)


          Mrs. Lyman Barr?  (See P.  2311)


          Mr. Aaron Wolff?  (See P.  2312)
-------
        JAV1ES SLOSS
       SOS SKOKIE LANE
     GLENCOE, ILLINOIS SOO55
      U
rta
                       RECEIVED
                          SEP28S70
                                  ,,- r
                        i
-------
I           \  I
           \1
                                        (
                                              0
-------

-------
                                                      2307

                     Mrs. R. Herlocker
to the Indiana representatives,  all you need is the  wisdom,
the integrity, and the backbone  to accept  these recommenda-
tions.  Remember, you are not servants of  the Republican
Party, of the Democratic Party,  or of industry; you  are
servants of the people.
           Ecclesiastes said: "To every thing there is  a
season, and a time to every purpose under  heaven."  This
is the time to fulfill your purpose in the public  interest.
           MR. STEIN:  Thank you,  Mrs. Herlocker.
           MR. MILLER:  I only have one comment.
           In all my time in public service if there is
one thing I know it is that I am a servant.  I always have
been and always will be.
           MRS. HERLOCKER:  And  you tell them in Indianapolis
the public is after you and they have got  to do something.
           MR. STEIN:  Thank you,  Mrs. Herlocker.
           May we have H0 R. Thoke?  Is H. R. Thoke  here?
           Mrs. Winston?
           Mer. Berghoff?
           Mr. James Sloss?  (See  P. 230#)
           Mr. Michael R. Rouse?  (See P.  2309)
           Mrs. Maynard J. Seidmon?  (See  P. 2310)
           Mrs. Lyman Barr?  (See  P. 2311)
           Mr. Aaron Wolff?  (See  P. 2312)
-------
                                  2303
    JAMES SLO55
  EOS 5KDKIE LANE
GLENCDE, ILLINOIS BOO52
                     RECEIVED
                    ENVIRONMENTAL Pf.CTECHDft AGi^Ci
                        STATE Oril'JSKS
-------
                                                   2309
              uv                       RECEIVED
                  '~VN  _-A  /    '
 I . t^t t>c w -^ w* dt&Jc- fciM-^tt c csW |A £WN tc       g^p 2 9 1970
          '                            — StSS ""
. G&A

                                     : e( 4 &
                                   It
                            C ^.-t
                 x    u           . ili ^^i LJ , at
                       - C C cuJ^C;a- l^c^Xxi-^
                        '-^^^^t«,<^- ^^>^t^
                                .  Vt ^ t    ^
-------
                                                2310
MRS. MAYNARD J. SEIDMON
            1064 SKOKIE RIDGE DRIVE, GLENCO£, ILLINOIS 60022
                  ,  _  RECEIVED
                           SEP 28 1970
                                     l~~4.^ ^£*<
           XJU,  .XU-A^

-------
                                                      2311


           (The following letter, dated September 25, 1970,

from Mrs. Lyman Barr, 1005 Wade Street, Highland Park,

Illinois 60035» was received by the Environmental Protection

Agency, State of Illinois, on September 23, 1970, and was

submitted for inclusion in the record.)



           Mr. Clarence Klassen
           Illinois Environmental Protection Agency
           535 W. Jefferson Street
           Springfield, Illinois 62703

           Dear Sir:

           I feel it is of the utmost importance that

           the k-State Enforcement Conference on Lake

           Michigan Pollution should adopt the strictest

           possible standard in respect to thermal

           pollution — that announced by the Department

           of the Interior.  I urge you to do everything

           you possibly can to bring this about.

                             Yours truly,

                             (Signed)

                             Lucy M. Barr
-------
SEP 2 8 1910
                                                                     2312
                            AARON S. WOLFF
                             II SOUTH LA SAULE STREET                    AREA CODE 312
                               CHICAGO 6O6O3                    FRANKLIN 2-5461
          ,\ r '
          l!" '•""
                                       September 24,  1970
         Mr.  Clarence Klassen
         Illinois Environmental  Protection Agency
         535  West Jefferson Street
         Springfield,  Illinois   62706

         Dear Mr. Klassen:

                   Since you are head of the Illinois
         Environmental Protection Agency,  I strongly urge that
         you  do all in your power to avoid thermal pollution of
         Lake Michigan.  At the  forthcoming Federal-State
         Enforcement Conference  on pollution of Lake Michigan,
         I  certainly hope that you will  push for adoption of the
         strictest standard under consideration.  This would be
         that of the Department  of the Interior which would
         sanction only the minimum possible waste heat to be
         discharged into Lake Michigan or a 1° F. rise over
         ambient at the point of discharge, whichever is less.

                                       Very truly yours,
                                       Aaron S.  Wolff


         ASW:sf
-------
                                                       2313
                    Closing Remarks - Mr, Stein



           MR. STEIN:  I guess that is all the people's



names I have.



           Now, does anyone who hasn't been called feel that



they want to say something now, because we are going to



close?



           If not, I would like to thank a lot of you for



bearing with us.  I know some of you have stayed with us



all week, and I think we have amassed quite a record.



           There is one thing I would like to say for this



process, and I have always been proud of this in a way.



           I think we have a document here in the transcript



of this conference which is going to be invaluable.  I find



when we finish these things that the researchers, the planners,



the analysts through the years  in going for hard information



that they can use  constantly turn to these transcripts.



           Now, again, the pride I have is this:   If



Government — I don't know, maybe industry is a little bit



wealthier — but if the Government were to amass this kind



of thing through the other processes that they have in



grants or contracts, I will bet that this would cost about



a half a million dollars — what we have here.



           We got this and a good portion of this has been



a contribution to the public good, and we couldn't have



gotten it without the volunteer action of the citizens,
-------
                                                     2314





                   Closing Remarks - Mr,  Stein



the municipalities, the industries, the State Government,



concerned.  And certainly all of these groups have brought



in scientists, consultants, other interests that one would



have been beyond the capacity of the Government alone —



any government — to assemble, and certainly beyond our



budgetary capacity.



           That is one of the great things about these



democratic institutions—that we have drawn on the kind of



talent  and the considered statements that we could draw



on for the past week, and we were able,without  I think



getting really out of hand  from the standpoint of a



disciplinary way,to have a cross-examining of ideas and



questioning as far as we could,



           I think you all must appreciate that this is



a very difficult thing to do, because we have people from



disparate backgrounds, disciplines, and ways of doing



business coming here.  These conferences are a lot easier



to handle when we just have the conferees asking questions,



or you have a much easier job if you just have lawyers



arguing back and forth or questioning back and forth or



presenting evidence under their rules — at least what



we think are rules — or if you have biologists or you



have engineers or architects who know how to operate,



           I think the wonderful thing is that we could
-------
                                                      2315





                 Closing Remarks - Mr» Stein



hold a meeting like this and get all of the people with



different backgrounds and different disciplines to focus



on the problem, and I think that the people who have been



here — I would say about 99»44 percent of the material put



in was germane — germane to the problem, and that also is



wonderful.  You may not have agreed with it, but it was



what someone thought we should know about the problem.



           Now, I have this to suggest to the conferees,



and I don't want anyone to think this is a suggestion that



I haven't floated around for the past day to see what its



acceptance would be.



           In view of the complexity of the matter, I would



ask that the conferees go back to digest this material,



caucus and advise with their technical staffs, as I will.



I know next week a lot of us are committed to be in Boston



where the Water Pollution Control Federation is holding its



meeting and we are going to need the week anyway.



           I would suggest possibly the week after that, I



would ask the conferees — and I would like to keep this



meeting as small as possible, if we can, for participants,



because we are going to try to come out with an agreement



and a program — that the conferees meet with their views



and their proposals, and we sit down and try to come up



with conclusions and recommendations which we can present.
-------
                                                     2316






                 Closing Remarks - Mr.  Stein



           I would urge the conferees to get together with



their neighboring States, Federal representatives, and



others, caucus as much as you like, and I think the more



caucusing you do before you get there,  the better off we



are going to be, whether you do it in Boston or over long



distance telephone, or any other place  .     I am optimistic



that we will be able to arrive at a conclusion when we



meet, say, the week after next.  But if we can't, at least



see how many areas of agreement we can sign off on, and



whether there are any areas that we have to put off because



we can't come to an agreement.



           There is just one more thing.  This problem is



on us.  I don't think it is going to go away,  I don't think



it is going to wait, and I don't think — while I haven't



made a poll, I don't think the public is going to wait



very long for an answer.



           I want to again thank you people.  Right now the



ball is on this side of the net.  The Federal and State



officials have got it right in their court, and I think



we will have to move from there.



           Do any of the conferees —



           MR. CURRIE:  Yes, Mr. Chairman.



           I would like to introduce into the record a



letter which I sent to Secretary Hickel on September 17>
-------
                                                       2317
               Closing Remarks - Mr, Stein




making certain suggestions for the format of future pro-



ceedings in the conference, among other things suggesting



that the conference publish an agenda in advance so that



we know what we are to discuss at our meetings; in addition



that conferees and expert witnesses be asked to supply



reports in advance so that we have time to understand them;



and among other things reconvene the conference every three



months 0



           And I would like to make that suggestion now,



Mr. Chairman, that we meet again in three months after we



have solved, if we have solved, this thermal pollution



question, in order to consider other pollution problems



that are equally pressing,



           MR, STEIN:  We will consider all those sug-



gestions and, I think, without objection, that letter will



appear in the record,



           (The letter referred to above follows on Pages



231S-2320.)
-------
                                                                  2316
                           STATE OF ILLINOIS

                OOLLUTIOM carvrrROL. BOARD
                       189 WEST MADISON STREET
                       CHICAGO. ILLINOIS 6O6O2              _
                                                           TEL. No.
                                                         312-793-3620
                                   September 17,  1970


Secretary Walter J. Hickel
U. S. Department of the Interior
Washington, D. C. 20242

Dear Mr. Secretary:

     On September 28 the Lake Michigan Enforcement Conference  will
reconvene in Chicago for a five day "workshop"  session.   The Illinois
Pollution Control Board is the agency charced with statutory respon-
sibility for the adoption of water quality and  effluent  standards.
In view of the Conference's concern with state  regulation as well
as with the collection of information, Mr. Clarence Klassen, Director
of the Illinois Environmental Protection Agency,  has written to the
Conference Chairman, Mr. Murray Stein, requesting that the Illinois
Pollution Control Board be designated an official participant, in
the Conference.

     In anticipation of our designation as a participant in the Con-
ference I am listina below some proposals designed to  make the Con-
ference a better vehicle to accomplish its purpose	to  save Lake
Michigan.  Conies of this letter are being sent, to other parties in
order that they may have sufficient time to comment or endorse these
proposals if they wish.

     The Council on Environmental Quality in its first Annual Environ-
mental Quality Report to President : ixon has criticized  water pollution
control enforcement conferences and recommends  new legislation.  The
proposals listed below will make the coming Enforcement  Conference
and future sessions more democratic and more responsive  to public
interest as well as better directed toward Lake Michigan's specific
problems.

     The following proposals which can be put into effect without
new legislation are offered:

       1.  Publish an agenda for the Conference immediately.
           The notice of the Conference is not  clear as  to
           whether the Conference will deal only with  the
           proposed thermal pollution standard  or with all
           pollution matters affecting Lake Michigan.

       2.  Require that all reports by parties  to the  Con-
           ference and by expert witnesses be submitted  in
           writing in advance to the Great Lakes Regional
           Office of the Federal Water Quality  Administration,
           there to be made available for public inspection.
-------
                                                                  2319
                                 -2-
Secretary Walter J. Hickel
September 17,  1970
           In past Conference sessions,  voluminous and detailed
           reports have been presented with no time for the
           conferees or the public to thoroughly review them.
           Comments and questions would be much more meaningful
           if advance copies are required.

           Permit questioning of witnesses and agency represen-
           tatives by the public where new information can be
           gained.  This procedure is followed by our Board
           in its public hearinqs, and it would serve to make
           the Conference more democratic and more informative.

           Reconvene the Conference every three months until
           December 31, 1972.  Every State has already sub-
           mitted seven checkpoint dates for all construction
           required by listed polluters.  Frequent and public
           checks on adherence to these dates will be necessary
           in order to avoid the excessive time slippage en-
           countered in the Lake Erie Conference.

           Publish within three months a comprehensive waste
           inventory for Lake Michigan to be prepared by FWQA
           with the assistance of tne States.  A Chicago Daily
           News story of August 3, 1970 based upon FV.'OA data
           argues that 51.3 tons of oil and 223.2 tons of
           suspended solids are now being discharged into Lake
           Michigan every day by just three Indiana industries.
           No one knows the total amount of oil, solids, phenols,
           chlorides, and other significant pollutants going into
           Lake Michigan every day.  Yet this information is
           easily obtainable through the States and merely needs
           to be compiled.   It would serve to identify the major
           problems and major sources.

           Identify, with FV7QA assistance, all significant pollu-
           ters affecting Lake Michigan and not presently listed
           by the State of location as coming under the Conference
           jurisdiction.  Four industries in the Manistee, Michigan
           area are said to discharge almost 1,500 tons of salt
           to Lake Michigan daily and yet are not under the Con-
           ference purview.  We evidently cannot let each State
           be the judge of what constitutes "significant" pollu-
           tion of Lake Michigan,  It is most important that
           pollution discharges to tributaries of the Lake be
           included and controlled.
-------
                                                                   2320

                               -3-
Secretary Walter J. Hickel
September 17, 1970
           Accelerate the deadline for phosphorus removal at
           municipal and industrial sewage treatment plants
           from Decert\ber 31, 1972 to December 31, 1971.
           Phosphorus renoval technology is well known and
           can be installed at any stage of any existing sex^age
           treatment plant, and reinstalled in a plant expan-
           sion.  If phosphorus removal is indeed the key to
           Lake Michigan's survival then we must keep as much
           phosphorus out as soon as we can.
                                   Very truly yours,
                                   David P. Currie
                                   Chairman
           DPC: jb
           CC:  Board Members
                Mr. Clarence Klassen
                Ass't. Secty. Carl Klein
                Comm. David D. Dominick
                Asst. Comm. Murray Stein
                Mr. Francis T. Mayo
                Mr. Ralph Purdy
                Mr. Thomas Frangos
                Mr. Blucher Poole
-------
                                                      2321





                Closing Remarks - Mr0 Stein



           MR. SHELDRICK:  Michael Sheldrick, McGraw-Hill.



           Can you tell us where the meeting will be, and I



assume — am I correct in assuming that it will be an



executive session?  Where, what time, pertinent details?



           MR. STEIN:  We haven't decided on a place yet



and I generally don't decide on a place until I confer with



the conferees and the people back in Washington. But this



will be made known to you, and the kind of meeting we will



have will be determined by the conferees.  It will be an



executive session.



           MR. SHELDRICK:  Can you give us the date



perhaps?



           MR, STEIN:  No, I can't.



           MR. SHELDRIGK:  Other than a week.



           MR. STEIN:  No, again, we have all been away



from the office for a week.



           Let me just go off the record here.



           (Discussion off the record.)



           MR. STEIN:  Back on the record.



           The putting together of a 4-State conference



with Federal officials, given the pulse and the mandatory



appearances of these people, is something that we have to



work out.  We have always worked them out in the past, but



I don't think that until these people, who have been away
-------
                                                       2322
                Closing Remarks - Mr» Stein



from their offices, could get back and touch base that we



can set that up now,



           MR, SHELDRICKs  Did I hear you right when I



thought you said that you were hoping to meet the week



after next?



           MR. STEIN:  That is right.  That is what I was



hoping for,



           MR. FETTEROLF:  Mr, Stein, did you make a



decision that it would be an executive session?



           MR. STEIN:  WeHl, yes, in the terms — you



know what we mean by executive session?  Only the conferees



will speak.  I can't say yet whether it would be open or



closed.



           MR, FRANGOS:  Mr. Stein, just in response to



Mr. Currie's suggestions on meeting, I believe that you



also have a request or a suggestion from the State of



Michigan concerning the frequency of meetings and, as you



point out, this does take a considerable amount of time,



and it drains not only our own capability but our staff's



capability.



           Perhaps rather than increasing the frequency



to every three months we might be able to devise a better



communication system so that these conferees know what is



going on in each of these States, and then indeed if there
-------
                                                       2323
                Closing Remarks - Mr. Stein



are some questions, we can meet, but my own feeling is



that three months is awfully soon.



           MR. STEIN:  Sir, I would prefer at this stage —



I know Mr. Currie has made some suggestions.  I said if it



is agreeable.  I think we should hold those off because



I know a discussion on these — I know the conferees and



other people have had experience here, and they have many,



many differing views on the mechanism of holding the



conference, and they run the entire gamut.  I know repre-



sentatives of other States have quite different views, and



I think another place is the place to discuss procedure



which is only of interest to another bureaucrat rather



than here at this time.



           So I would like to set that off for a little



while.  We will discuss it when we hippopotami get



together by ourselves.



           Are there any other comments or questions?



Again, I would like to thank you for coming and the workshop



stands adjourned.



           (The conference adjourned at 5:5^ p.m.)








           (The following documents and communications



were received following the conclusion of the conference



for incorporation in the record.)
-------
                                                                              2324
   "~ "    T°:  C. 7. Kl?ssen,  -Technical Secretary, Illinois  Sanitary
                ,ifjter Board,  6l6 State Of i ice Building, Springfield.  111.
                S r\nf. *
SEP 281970 62706.'
f* SOtaiENTftL FKOttCTiOH ftiiiu*
           We, the undersigned,  believe that It is both technically and
           economically feasible for industry to aeet the  proposed  Federal
           Water Quality  Administration's temperature standards  of  a one
           degree P uaxlmua  teipersture i,ncre.ise of all  -raters returned
           to Lstke Michigan.   Thus,  we urge ths adoption of  these  standards
           in the state of Illinois.
                                                   Hespectfully,

                                                   Concerned Citizens
                                                                            rf)
                                                                     o
           V/ K> TMLsJ.* j
                                                   ;^   <{;'> ..\>/^J . t'f/IJS
              -
-------
                                                                  2325
                                          379 Jacks on Ave,
                                          GJencoe, 111. 60022
                                          Sept. 24, 1970

Mr. O.W, Klassen                                     .   ~ vl
Director                                                "  ":
Environmental Protection Agency               ,. ., • ,"•""}
c/o Illinois Sanitary Water Board                   '> s1
1717 W. Taylor                                       T
Chicago, Illinois                             ' f ; " ^rr ;fe    t
                                                    , i>?:.'rt f EH!»:
Dear Mr. Klassen:
     Thank you yery much for keeping me informed  on the Septem-
ber 28-October 2 Workshop of the Lake Michigan  Conference.
     The Glencoe League of" Women Voters will not  be testifying
at these workshop sessions, but I understand that the Lake  Mich-
igan Interleague Group plans to speak on thermal  pollution  stan-
dards.  I am very interested in the subject matter to be  dis-
cussed, as I have personally studied thermal pollution  problems
and standard-setting questions.  However, our League has  nox
yet completed a formal study and consensus position and is
therefore unable to testify.
     I plan to attend at least two of the sessions; and I hope
to be able to thank you personally for so considerately offering
our League time on the agenda and keeping us up to ,date on  the
content of the Workshop sessions.
                                             Very  truly yours
                                           ' Mrs.  Richard Schnadlg
                                             Action Chairman
                                             Glencoe LWV
-------
                                                                       2326
                                                                               - V?
                                             Orchard Lane
                                         Benton Harbor, Michigan Ii9022
                                         September 21, 19?0
Mr. Murray Stein, Chairman
Federal-State Enforcement Conference on Pollution of Lake 1,'d.chigan
Federal Water Quality Administration
Room U10
33 East Congress Parkway
Chicago, Illinois 6060£

Dear Mr. Stein:

         Your announcement of August 31 of  a ivorkshop for presentation
of viewpoints on pollution of Lake Michigan has been received,

         Speaking as a private citizen '.vhose water  supply and many
recreational pleasures come from Lake Michigan, I am opposed to the
siting of any nuclear power plants on the shores of Lake I£ichigan.
In terms of the risk of radioactivity and thermal pollution nresentad
by these plants, the benefits of siting on  Lake Michigan are inadequate,
particularly since alternate sitings are technologically feasible
and economically -within reach.  A more complete statement asking a ban
on placement of nuclear reactors on lake Michigan is presented  in ray-
letter to Governor William Milliken of my home state of Fdchigan, a
copy of -which is attached.

         If it be -within the scope of the format of the workshop, I
would ask that this letter, as well as the  attached letter  to Governor
MLlliken, be read into the record on September 28 or 29, days listed
as dealing with problems of Public Utilities,

         Thank you for your consideration of this request.

                                         Very trulv yours,
                                         W. D.  HDHR,  P.E.
cc: Mr. Francis T. Mayo
      FlYQA, Chicago
-------
                                                                          2327
                                     152 Orchard Lane
                                     flenton Harbor, Michigan U9022
                                     July  X,  1970
Governor William Milliken
Office of the Governor
State of Michigan
Lansing, Michigan W903

Dear Governor Millikeni

       This letter is to request that you and your administration
actively seek a ban on nuclear reactors on the shores of lake Michigan.

Background

       The hearings in progress at Kalamazoo by the AEG Licensing
Board with regard to the provisional operating license for the
Palisades Plant of Consumers Power Company have produced indication
that the AEG will seek or consent to oversee water quality effects
of nuclear reactors, including thermal effects*  The passage of laws
by the Congress of the United States in 1969 and 1?70, namely, the
Federal Water Quality Act, and the National Environmental Protection
Act, require both a broader interpretation of the Atomic Energy Act
than the AEC has previously been willing to assume and active steps
by the A3C to enhance the environment.

       With the A3C about to enter juriadiction formerly held by the
Department of Interior and the several states, a new opportunity
arises to control our environment*  Concise leadership on the part
of the State of Michigan, due primarily to our central location and
important dependence on the Great Lakes, can be greatly rewarding
for decades and centuries to come.

Specific Technical

       Elimination of thermal effects by use of cooling towers,
and prohibition of discharging radioactive liquid waste* to the lake
as an operational practice, may well come from AEG activities*
These raoves are inadequate to protect Lake Michigan*

       The naxiaiua accident involving a nuclear reactor on the shore
of Lake Michigan is to picture it chopped into small bits and dumped
into the lake.  This accident, however remote the possibility, would
be unpleasant to Michigan.  The 100-year holdup time of Lake Michigan
would mean elimination of the resort and farming industries for
decades. . The source of drinkingwater for millions of people would
be contaminated.  The radioactivity passing through the Great Lakes
and the St. Lawrence River would imperil millions more.

Boonomic

       If the alternative were EITHER nuclear reactors OR no
electricity, this letter would not be written.  But in truth, the
-------
                                                                          2328
                              - 2 -

Governor William MilUken                            July 1, 1970
economic tradeoff involved in this matter has not been discussed,
let alone decided in a dispassionate Banner.  And an economic tradeoff
does exist*  tticlear reactors sited on Lake Michigan get cheap cooling
water.  Non-evaporative cooling towers, which would permit the plants
to be sited in inland regions of low population density, add to the
cost of plant investment*  The question involves "How much?" and
"Is it worth it?"  A Maryland report on the Calvert Cliffs plant
presents estimates of $28 million and $itO million for additional plant
investment on a base plant size of $200 million*  Estimating plant
investaent increase at 20$ for non-evaporative cooling towers, and
recognizing that the cost of producing electricity is a minor fraction
of the "delivered*1 charge to the consumer, the added cost to the
public would be less than 1D% on the electric bill*

Evaluation

       TKe evaluation requires the tradeoff of leas-than-lD^ on the
electric bill, known and regular, against the cost (colossal) of an
event of unpredictable rarity (gross disintegration of a nuclear
reactor)*  Considering the unique properties of Lake Michigan, true
wisdom requires us to choose the course of accepting the nominal
increase in exchange for preventing the rare possibility of catastrophe
to the lake.

Practical Present

       It is tny request that you, as Governor of this state, take
the leadership in the administration of state government by undertaking
steps that will produce a ban on nuclear reactors on Lake Michigan.
In consort with the AEG, the Department of Interior, and the governmental
units of the other states fronting on Lake Michigan, this ban should
be worked out with dispatch.

                                    Very truly yours.
                                    W. D. MOHR, P.E.


    General Distribution
-------
                                                                                       2329
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-------
                                                                           2330
                                       October 8,  1970
                                       11653 N. Wauwatosa Road ?6 W.
                                       Mequon, Wisconsin 53092

Mr. Francis W. Mayo,
Regional Administrator
Federal Water Quality Administration
33 W. Congress Street
Chicago, Illinois

Dear Siri

My- understanding, according~io-Krs» Rheta Pierre, .Secy,  to Murray Stein^  is

that the written statements may be submitted for the Official Record  of The

Lake Michigan Enforcement Conference, Chicago for  one week,  following the close

of oral presentations, Friday, October 2, 1970„


I would please request incorpoation of the enclosed letter into the official

record, which indicates very recent "happenings?* as the  licensing of  Point

Beach, on Oct. 6th by AEC.


I would appreciate receiving a. copy of the Lake Superior 1970 Enforcement Con-

ference proceedings,  I received copy of the Oct 1, 19&9 proceedings  today,  and

have already Underscored the text through to Page  24-9*
                               CONSERVATIONALLT YOURS,
-------
                                                                                   2331
                    LAKE  MICHIGAN  ENFORCEMENT
                                 CONFERENCE


 It was my understanding that the thermal decree  of  1  degree was  enforced as  such,

 though* still in question and "still negotiable".   It would have been comforting if

 it would not be the burden of the public to "defend"  same, for 1  day,  while power

 companies (by coincidence had their  convention in Chicago simultaneously with their

 presentation dayso».Monday,  Tues.  Wed,  9-28-29-30)  One  can only guess the impact of

 expense paid testimony,by experts, versus presentations  by citizens,laboriously and

 expensively establishing their own private environmental data libraries,  subscribing

 on their own to outga'-geo'usly expensive  scientific periodicals and publications,

 without benefit of  a federal agency  repository for  scientific research (research.

 grants paid for through taxes  and oft with FtfQA  funds.)

 Since  the newly created Environmental Protection Agency  wviich became  effective Oct.

 Ihjftddjybut had a 60 day "grace" period, requested by  the President, just  in time to

 LICENSE POINT BEACH NEUCLEAR PLANT at Two Harbors on  October 6th, 1970, Tuesday. So

 things weren't in Limbot  In effect,  while FWQA  incites  and excites the engineering

 debate of the century, negotiating under  corporate & political pressure, buying jus.t

 enough time for  a' fox to his piece de resistance.   (EPA  includes FWQA., NAPCA, Bur.

 Solid Waste Mgmt, Bur .Water Hygiene & Environmental Radiation protection functions

 of AEC  & p^esticide registration of USDA.) All this, under direct control of the

 President (to whom  all things are  negotiable). (As if corporate structure hasnft always

 known political pressurepointsj

 Please  refer to FWPCA bulletin of  Sept. 1969 "HEAT CAN HURT - Better Water for America"

 indicating research being carried on at the Natl, Water Quality Laboratory at Duluth

 (I've toured same & don't remember the project)  &  reference to research at the Natl.

Marine Water Quality Lab., W. Kinsington, R,  I.   WET wasn't the benefit of this research

 introduced to advocate the Public's and Taxpayer's  re-vested interest?
-------
                                                                                    2332

                                       2.


 I refer for your research 'people  (if you are not already aware of the article,)

 "Thermal Pollution & Adquatic Life by John R. Clark, in Scientific American, March 1969.

 I have dozens  of papers  from scientific journals, and 1-| inches of articles clipped

 out of newspapers, touting public interest and concern. It is suffice to say, that

 inasmuch as you are charged  with  the responsibility to protect  our public waterways,

 (fron whatever deleterious matters, and affects from whatever source) regardless of

 political  and  corporate  pressure, 'from WHATEVER source, for whatsoever reason, do so,

 forthrightly and with integrity.

 Given the  foresight to, predict, even with 100$ total inaccuracy, in FAVOR OF the

 total  environment and the citizens of the Great Lakes Basin Region,  it' would be a far

 wiser  error, than with hindsight, in retrospect 50 years hence, to discover that our

 beautifully precious Lake Michigan (& Superior) have attained the dubious distinction

 of becoming another errie "Erie" becaused you "chanced it".

 Stick by your l^F thermal decision, let technology & cryogenics manipulate the means,

 and dedicate yourselves  immediately to pesticides, phosphates, chemicals etc. Since

 the Bureau of the Budget regulates your questionairre activities from Industry, do not,

 in the name of  justice,  thwart pollution evidence, from whatever state or source, by

 keeping it from the printed  record.

When will  the DETERGENT  industry, PETROLEUM & CHEMICAL cartels be confronted, as was

 Reserve Mining  in the L. Superior Enforcement Conference?
                                                                  ^
Please keep in mind a. potential *xium...THE QUALITY OF OUR ENVIROlMSllT IS NOT NEGOTIABLE.
                                                              J^VA
                                            ( ConservationaJJttp'jcd^rs , )
                                                          \*  ^Cv
                                            GRACE
                                            11653
                                            Mequoh,
Member of Natl. & Milwavucee Audubon Society (Bdard) & L'eglslativertbtee for
     Audubon Society Natl. Convention - 1971 - K
     Wisconsin Resource Conservation Council     League
     Milwaukee River Restoration Council         -Save LakevWiperior Association
     Citizens Natural Resource Association       Wise. Acade'my of Science, Arts & Letters
                 National Wildlife Federation - 1970 Conservation Summit, Estes Park, Colo.
-------
                                                                        2333
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-------
                                                                     2334
                                                 September 28,  1970
Mr. Murry Stein, Conference Chairman
Thermal Pollution Workshop
Sherman House
100 West Randolph Street
Chicago, Illinois

Dear Mr. Stein:

Enclosed you will find a copy of the Michigan State Chamber of Commerce's
Policy on Thermal Effects which was adopted by our Board of Directors
on January 21, 1970,

Ptease enter this into the proceedings of the Department of Interior's Thermal
Pollution Workshop currently underway in Chicago.
Sincerely,
George P. Graff,
Manager, Natural Resources

GPG/sfc

Enclosure

cc: Francis T. Mayo x
    Ralph Purdy
-------
                                                                               2335

          MICHIGAN STATE CHAMBER POLICY ON THERMAL EFFECTS
       The Michigan State Chamber of Commerce has long recognized the need to
        and enhance the quality of the environment in the State of Michigan.- Cooperative
efforts of both the public and private sectors are necessary to effectively promote this
objective.


       The Waters of the State of Michigan are an important segment of the environ-
ment and should be so respected.  The potential effects of thermal discharges to these
waters are not fully understood.  However, it is known that in some instances these
effects are detrimental to legitimate uses, while in other instances they are beneficial.


       Recognizing that there  are many,needs and objectives  in society, and that they
cannot all be satisfied in their entirety, the State Chamber strongly recommends that
the Michigan Water Management Program, with particular reference to thermal effects,
be guided by the following principles:


       1.  That no single set of regulations is adaptable to all  situations.

       2.  That the management program provide for beneficial water  uses, with joint
consideration of alternative costs to society and the objective of preserving  environmen-
tal quality.

       3.  That water quality  standards regarding thermal effects adopted by the State
are consistent with the water use management program which  recognizes the needs of
our society and further that Michigan industry will comply with all state standards.

       4.  That any use which has potential of causing significant environmental effects
be carefully monitored to determine theo extent of any effects and the possible need for
corrective action.

       5.  That prompt corrective action be taken whenever effects detrimental to
legitimate uses are detected.

       6.  That thermal effects research be promoted in an effort to obtain sound data
from which intelligent judgments can be based regarding thermal discharges.
       The State Chamber commends the responsible State agency's accomplishment?
in the area of water quality control and pledges its continuing support and coopera-
tion in efforts to provide an improved environment and high quality water in the State
of Michigan.
-------
                                               2336
             F. SCAMMON BARRY
               611 HUNTER RD.
              BLENVIEW, ILLINOIS
                            Sept. 27,1970
Francis T. Mayo, Dir.
Regional Office, US Dept. of the Interior
Federal Water Duality Adm.
33 East Congress Pkwy Hm 4-10
Chicago, 111. 60605
Dear Mr. Mayo:

              I urge you to use all of your
influence to get the 4-state Enforcement
Conference on Pollution of Lake Michigan
to adopt the strictest standard under
consideration for thermal pollution.  I
believe that is the standard announced by
the Dept. of the Interior.
             This opinion states: "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 rise over ambient at
the point of discharge.  This will preclude
fche need for mixing zones."
                              ^
            lours truly,

          /F. Scammon Barry
-------
                                                            2337
  September  28,  1970

  Mr.  Francis  P.  Mayo
  Director,  Great Lakes  Regional Office
  IT. S. Dept.  of Interior
  Federal Water  Quality  Administration
  33 E. Congress Expressway  Room lilO
  Chicago, Illinois   6o6o5

  Dear Mr. Mayo:

  I would like to voice  my  support  for the  establish-
  ment of strict standards  controlling heat discharges
  into Lake  Michigan and other waterways0   There  should
  be no difference in waterway and  discharged water
  temperature  that cannot be  attributed to  error  in
  measurement.

  It is time to  take  decisive action.  Caution must be
  exercised  now.   It will be  easier to ease restrictions
  in light of  future  findings than  it  will  be to  view
  useless bodies  of water and wish  there had been more
  foresight.

  Yc/urs truly,
C,' .'" f ^ *«,
  E. M. Davey
-------
                                                              233S
                                   September 26, 1970

Kr. "Francis T. Kayo
U.S. Dept. of the Interior
Federal Water Quality Administration
33 E. Congress
Chicago, 111.  60605

Dear Sir:

I am a member of and dissentient from the Committee on Lake
Kichigan Pollution.  I have several comments on heating of
the lake .

1.  The bad effects of heating are not now proved.  The hot
water discharge from Waukegan steam plant of Commonwealth
Edison has made good fishing for years.  Likewise, the waters
of the warm Carribean have good fishing.

2.  The real problem faced is what to do about Lake Lichigan
when we think the heat discharge may have deleterious effects.
These effects must be balanced with the effects of a shortage
of electricity.

3.  Ecology is important;  so is justice.  It is not just to
have several government bodies approve the Zion nuclear plant,
and then demand that L'dison spend more millions than planned.
This is particularly the case when the alternative heat exchange
to the atmosphere has unknown effects, also.

4.  The proposed standard of the Dept. of Interior that will
prohibit heat discharges of more than 1° above ambient is
absurd.  It would prohibit swimming.  It would prohibit small
motors.  It would prohibit dumping a thtnblefull of boiling water.
It would permit the discharge from Zion nuclear station as long
ss Edison spent uoney on more puraps to push thru a larger volume
of water.  If there is any kind of limit, it should be stated
in btu's per minute, or other units of power,  .and it should
not apply in the -.'inter.

                               Yours very truly,
                                   nobert Dover
                                   917 Chestnut Ave .
                                   V/ilmette, 111.  60091
copy:
James ;jriffith
     . on L. I ich. irollution
-------
                                                                 2339
                 PETIT, SAFEBLADE, LITTLEJOHN & GLASS

                            ATTORNEYS AT LAW

 ~T,«=   -r.-,                   HARRIS BANK BUILDING
ADELOR J. PETIT, JR.                                             ADELOR J. PETIT (1892-1951)
JOHN A.SAFESLADE                 I" WEST MONROE STREET
WILLIAM L.LITTLEJOHN                  CHICAGO 6O6O3
BRADLEY M. GLASS
EDWARD ATLAS                                                    AREA CODE 312
DAVID C. FALLS                                                     726-IO25
JAMES P. MSCARTHY, JR.                                                263-3O6O
ROY E.OLIN
  OF COUNSEL
September 30, 1970
       Clarence  Klassen
       111.  Environmental  Protection Agency
       535 West  Jefferson  Street
       Springfield,  Illinois  62706

       Murray Stein,  Conference Chairman
       Federal Water  Pollution Control
        Administration
       Department of  the Interior
       Washington, D.  C.  20242

       Francis T. Mayo, Director, Great Lakes
        Regional Office
       U.  S. Department of the Interior
       Federal Water  Quality Administration
       33  East Congress Parkway, Room 410
       Chicago,  Illinois  60605

       Gentlemen:

                  I am taking the occasion of this week's Enforcement
       Conference on  pollution of Jiake_Mi.chj.ganL to register with you
       my  deep concern for the need to establish and enforce strict
       thermal pollution standards.

                  Commonwealth Edison has been quoted as urging reten-
       tion  of Illinois' present standards (permitting a water temper-
       ature increase of up to 5°)  on the ground no evidence exists
       proving conclusively that heated water discharges will adversely
       affect the Lake.

                  I  disagree with this approach.  In this matter, so
       directly  affecting  the public interest, the evidence must prove
       conclusively  that such discharges will not adversely affect the
       Lake.  Our Lake belongs to the people.  It cannot be replaced.
-------
                                                          2340
Page Two
Clarence Klassen
Murray Stein
Francis T. Mayo
September 30, 1970
No harm must come to this  priceless  resource.  Whatever legi-
timate doubts exist regarding  the  safety of discharging waste
heat into Lake Michigan must be  resolved in favor of the over-
riding public interest.

           Accordingly, I  wish to  pledge my support for the pre-
viously stated position of the U.  S. Department of the Interior
that:  "The minimum possible waste heat shall be added to the
waters in Lake Michigan.  In no  event will heat discharges be
permitted to exceed 1° F.  rise over  ambient at the point of dis-
charge."
                          Yours  very  truly,
Gl
                                        fa. Mb**-—
                          Bradley M.  Glass, Republican Candidate
                          for  Representative  in the General
                          Assembly, First District
BMG/ak
-------
                   MRS. LYMAN BARR
                   1005 WADE STREET
              HIGHLAND PARK, ILLINOIS 60033
                                                            2341
%.
              £$JL   0 o b o v
-------
                                                                     2342
  Mr.  Francis T. Mayo
  Re?io---il Dlroot.Tr Federal Water Quality Control Administration
  55 E-  O-v-e-js parkway
    iouyj, Illinois
  Dear Mr. Mayo:

                 DO NOT PLUNGE US INTO  HOT WATER!

                        THERMAL POLLUTION
                              is th'j
  deleterious change in the normal tenporaturs of water caused by
  the  discharg-3 cf Kn-jte heat.

       THE RISK OF TAMPERING WITH THE  LAKE MAY CAUSE THESE DISASTROUS
  EFFEC1S,

       1. Fill fish
       2- Sp.= ad the aging or eutrophiCation (decrease the oxygen) process
  of the  le
-------
                                                                         2343
He I e n Ku toj ov
5493 Cornel I
Chicago, IL

Karel Wo Ifson
5210 Dorchester
Ch icago, IL

Mr.  & Mrs. R. V. Wee lew
5429 South Harper
Chicago, IL 60615

Diehl Cohen
1357 E. Park Place
Chicago, IL

Brian Dosch
5403 Wood I awn
Chicago, IL

Bruce Fischer
1414 E. 59th St.
Chicago, IL

Nancy Stetton
5950 Dorchester
Chicago, IL

Jean Spencer
5201 South Cornel I
Chicago,  IL

Mrs. Seals Sayles
1337 Beechwood Boulevard
Pittsburgh, PA  15217

Marc Kaplan
5112 Hyde Park
Chicago,  IL

A I i ce Ru bov i ts
4940 East  End Avenue
Chicago,  IL 60615

Wei  I and F. Buchanan
5555 Blackstone
Chicago,  IL

John D. Alexander
6219 S. Chapel
Chicago,  IL
Evelyn C. Trugran
1606 E. Hyde Park
Chicago, IL

Joyce A. Solomon
1410 S. Rockdale Place
Chicago, IL 60615

Harvey Mantel
1005 E. 60th Street
Chicago, IL 60637

J. Albrechs
1462 E. Park Place
Chicago, IL 60637
K. Majewaki
5314 Cornel I  A
Chicago, IL

Diane Broadbart
5824 Kimbark
Ch icago, IL

Paula Foster
5749 Dorchester
Chicago, IL

Marjorie Feren
5738 Blackstone
Chicago, IL

Pam EmiI
5450 East View Park
Chicago, IL 60615

Helen Bergstrom
5405'S. Wood I awn
Chicago, IL

Judith A. Baer
5345 S. Ellis Ave.
Chicago, IL

Pamela H. Pearson
5541 1/2 Wood I awn
Chicago, IL 60637

Ann Palkovich
5824 S. Kimbark
Chicago, IL

Mary Kay O'Brien
5824 S. Kimbark
Chicago, IL 60637
-------
                                                                       2344
Eric Anderberg
4821 South El I is
Chicago, IL 60615

Robert E. Mann
5539 S. Horner
Chicago, IL 60637
-------
DEDICATED
                       THE   PRESERVATION  OF   OUTDOOR
        2345
AMERICA
                        9?aafe Walton league  of  America
                      PORTER COUNTY CHAPTER, CHESTERTON INDIANA 46304
To:  Federal Conference  on Lake Michigan and Its Tributary Basin,
     Federal ¥ater  Pollution Control Administration,
     October 2,  1970

Submitted by: Ted  Falls, Pres., Porter County Chapter,  Izaak Walton League,
              Wheeler,  Indiana  Ij6393.
Gentlemen:

I would like to offer  these  observations on some of the papers presented to the
Conference this past few days, to stand on their own merits and without further
qualifying myself.   I  must take personal responsibility for the technical matter
here presented, but my Chapter stands committed to the position I 'state.

My first reference  is  to the discussion of the value of Dr. Peter  J.  Colby's
labotatory work on  the effect of temperature on the time for hatching eggs of
one species of whitefish.  Dr. John C. Ayres has condemned this work  in a widely
published paper, and made reference to this position in his talk before this
Conference.  "Evidently, nature knew something important that did  not bear in the
laboratory-tank experiments, but what was it?" he wrote.  "Patently,  laboratory-
tank biology was not what was going on in that warm-water plume."  A  remarkably
strong effort was made, in the questioning following Dr. Colby's presentation to
this Conference, to discredit his work as inapplicable to actual Lake conditions.

There was an important point to Dr. Colby's work that was not brought out in the
discussion.  So long as temperature remains within certain boundaries, the
fundamental process of germination responds to temperature so as to increase the
rate of germination as temperature increases above the lower boundary, then
decreases as the upper boundary is approached.  The relationship of temperature
and time is non-linear. A study of the temperature effect on a particular
species in the laboratory will permit the determination of a temperature-time
constant for each temperature, provided that all other factors are controlled to
duplicate the conditions in  nature.  In a field application of laboratory
findings, two things will be verified:  tha applicability of the temperature-time
constant, and the precision  by which the other conditions of nature were dupli-
cated.

To discover the values in a  curve it is necessary to measure at least four points.
preferably five, if the curve is always rising, or always falling.  It is of the
utmost importance to learn if Dr. Colby used this technique.  In fact, the curve
he studied rises to a  peak as temperature increases, then falls as it approaches
the upper limit of  temperature.  With this in mind, Dr. Colby evaluated nine
points in a 12 deg. C  range.  This gave him, in essence, five points  for each
-------
                                                                                2346
FCET5R COTKTY CHA-FTBR. I2AAK WALTCK LEAGUE	Sheet 2.

direction.  His result was a continuity of the temperature-time constant useful
for field application.

Nature sums the temperature-time constants through the succession of temperature
changes, producing a hatch when the sum reaches its proper point.  Every farmer,
and most students of biology are aware of the occurrence of early and late crops
in different years due to the vagaries of weather, and correctly recognize the
importance of temperature in this effect on the many functions of plant and
cold-blooded animal growth.  Mien Dr. Colby turned to the field, it became necess-
ary to measure the succession of temperatures in order to sum the temperature-time
constants he found in the laboratory, which he did.  The 98$ precision he claims
is an achievement of the first order:  a 90^ precision would be highly credible,
and useful in future predictions.

\'e are able to observe the temperature-time effect in many phases of plant and
cold-blooded animal growth.  The phenomenon has been discussed in scientific
literature for two or three generations.  For many years it has been roughly
approximated in the mean annual temperature of the region.  Hence, the northern
boundary of the growth of wild palmettos in the Carolines has been related to an
isotherm stated to a tenth of a degree, soil conditions being equal; and the
development of these plants increases southward as the mean annual temperature
increases.  Spanish moss grows wild at the southern tip of few Jersey along the
coast due to the warming effect of the Gulf Stream, far north of its normal
habitat:  the mean annual temperature indicates a suitable sum of the temperature-
time constant within the boundaries required by this plant.

"•Dach species has its own temperature-time constant and boundaries.  When nature
has established a regular succession of temperature changes, with only minor
variations from year to year, various species will become established according
to their adaptation and adaptability.  The fact that there are local, natural '
temperature changes of the waters of undisturbed Lake Michigan is irrelevant:
these are normal for each season, and are repeated year by year.  They are
within the boundaries tolerated by the species that have become established.
.Jhen the temperature-time summation and the temperature boundaries are changed,
there will be changes in response of established species; and as the factors
change progressively there will be changes in the species present.

It is obvious, with a cursory inspection of the shoreline of Lake Michigan, that
the present undisturbed Lake is at the lower boundary for growth of certain
alqae.  A mile away from the present Michigan Citjr power plant there is a growth
of algae on piles and rocks that has appeared in the last ten years, and was
never there before.  That there is a probable increase of temperature is confirmed
by several statements to this conference, reporting the results of careful studies.
The vigor of the growth of algae increases as the power plant is approached, and
is rank close to the outfall where the temperature-time summation is greatest.
It is true that there is a discharge of nutrients from the Michigan City sewage
disposal plant ofl Trail Oreek, and from the nitrates formed in the combustion
chamber of the power plant.  ~"e would expect the dispersal of the nutrients into
the outer waters of the Lake to be much slower than the dissipation of the heat,
favoring a more uniform growth of algae along the shore if heat were not an
effective factor.

I hold that Lr. A^-res is greatly mistaken to attack the validity of the work of
Lr. Colby, and that he has failed to take into account directions for study that
are of the greatest importance in evaluating the impact of huge quantities of
heat on Lake Michigan.

There are certain characteristics of a plume that seem to be ignored or not
realized in most of the discussion of this Conference.  The water of the plume
-------
                                                                                2347

PCRT3R COUCTY CHAPTER. IZAAK  •ffiLTOy L5AGIT	Sheet ;.

moves through it at a relatively rapid pace, disappearing eventually in the body
of water in the Lake.  The plume is persistent. Tor it is continuously supplied.
The plume wanders over a fixed area greater than that of the plume itself, in a
slow march as it is affected byi currents.

The rapid rate of flow within the plume has a direct effect upon the water-borne
planckton and nymph stages that might be caught within it.  These forms do not
have the means of locomotion to move out of it with any rapidity.  Such as may
survive the heat shock of the passage through the condensers do not have time to
increase before they are swept into other waters in the Lake, where they join
their fellows.  The question of eventual survival, having withstood the condenser
shock, is an easy one to answer, for a sample can be taken almost without contam-
ination by unshocked individuals from the surrounding water.  These can be studied
in the laboratory tank under optimum conditions, comparing them with samples from
the surrounding Lake as a control.  In the papers giver. I missed a comparison of
samples from the condenser discharge and from the area close before the intake,
to show the immediate effect of heat shock,

I would like to quote from the article by Er. John C. Ayres entitled "Remarks On
Thermal Pollution In The Great Lakes", a passage in the Position Paper distributed
by MPSCO in August and subsequently:  In the plume "there was no cloud of excess
algae in the warm water and no aquatic insects emerged for mating flights into
air that was too cold to let them fly".  Er. Ayres forgets, or chooses to ignore,
the fact that the temperat\ire-time constant summation for the tine to pass
through the plume is very nearly zero in the division cycle of algae and in the
life cycle of aquatic insects.

The persistence of the plume is another matter, affecting all the fixed life
forms that it can reach.  In this category are the forms of algae that grow
attached to stationary objects, and the fish eggs attached to the bottom or to
debris locked to the bottom.  These are subject to shorter or longer exposure to
temperature from the plume, responding to the temperature-time constant and the
boundaries.  The effect is very real, and under certain conditions must be
deleterious.

The wandering of the plume negates the conclusions based on the concept that the
plume is a fixed body, and gives us a key for an analysis by which we can predict
the effect with some accuracy.  Since the response of fixed life forms is the
summation of the temperature-time constants, the analysis of a plume should be a
mapping of the area over which it will flow in the course of time, taking into
account the temperature-time factor.  This will show the true area affected by
the plume:  heat-sensitive pictures of a plume at any instant are deceptive.

In Dr. Donald W. Pritchard1 s paper, the concept of the plume in Case IV is very
attractive on first consideration.  There are several controversial points,
however.  J'o doubt Er. Pritchard made sure that there is enough energy in the
stream at the outlet to create the turbulence that is the key to the reduction of
temperature that he predicts.  This is the essential factor in his proposal.

It is important to picture the nature of turbulence to evaluate this proposal.
There seem to be several conditions of flow in a tvirbulent fluid body:  vortices
of great and small dimensions;  sheets of varying thickness and shape, and of
short duration;  and pencils of odd shape of cross-section and varying dimension
and persistence, all forming and reforming progressively outward from the source.
One can see the process in slow motion in cigarfctte smoke floating in a shaft of
sunlight in an apparently still room:  in a space of such large dimensions there
is turbulence even though we are not aware of it by the feel on our skin.  In the
case that Er. Pritchard sets up, turbulence will be rapid and massive.
-------
                                                                                2348
PCRTSR COUNTY CHAPTER. IZAAK mLTON LEAGUE	Sheet h_.

In turbulent water, the laws of heat interchange will still apply.  Bodies of
water will interchange heat as they are mixed, assuming the median temperature,
just as in the mixing of cups of water in the Hi&h School laboratory.  This
means that there will be a temperature gradient from the discharge stream
outward, just as in any plume, considering temperature measurement with ordinary
instruments that average the condition in the medium in which they are immersed.
An instrument capable of instant response, fixed in a flowing plume, would show
a rapidly fluctuating temperature as the various vortices, sheets and pencils
pass by.  The range of the temperature fluctuations would decrease as the
instrument is moved outward from the initial stream.

In this turbulent body planckton entrained in the original stream will be caught
in the turbulence as the stream "peels off".  Mostly, they will follow the
bodies of water involved in the process of dispersion, suffering such temperature
change as might occur in the mixing process.  Some will transfer directly from
warm water to cooler water adjacent, perhaps a temperature shock.  Further, all
planckton entrained in the cool water drawn into the turbulence will in their turn
be subjected to a sharp temperature change as their water is mixed with the
warmer water from the initial stream.  This temperature change will be graded
according to the temperatures involved.  Some of it will be extreme.  All in all,
it seems that more destruction of planckton will occur in Case IV than in any
other proposal.  Unfortunately, the case is offered to justify the highest
temperature discharge of any of the several methods.

Dr. Pritchard is quite correct to predict that the highest temperature to reach
the surface will be materially reduced from the temperature a£ the discharge point.
The average temperature of the plume at the surface will be much less than that
of a flume spreading the hot water over the surface.  The consequence of this is
that heat dispersion to the atmosphere by radiation and evaporation will be
reduced:  a greater quantity will be retained in the Lake.  In turn, the
summation of the temperature-time constant will be effective over a greater area
of the Lake.

Further, turbulence is induced over 360 degrees of the section normal to the
direction of the originating stream.  This means that heat will reach the bottom
of the Lake as well as the top.  This will affect any plant or animal life that
might inhabit the area.

From the consideration of the heat effects of Case IV, we cannot accept the
proposal as a likely solution of the heat problem in Lake Michigan.

In our personal experience we have learned that there is more chance that an
unforeseen gimmick will destroy an attractive idea than that the idea will be
successful.  With this in mind, we have scanned a number of possible side effects
that might develop in the application of Case IV.  Two need to be examined.  There
is a possibility that a hydraulic jump will form near the end of the jet of hot
water before it is entirely dissipated.  It can be avoided by controlling the
velocity of the discharge:  it could very well be that the planned velocity will
not be of a value to produce the condition.  More likely is the possibility that
the discharge from the pipe will produce a rip.  Both will be a hazard to small
power boats that will want to use the area.  Theseaand other problems can be
resolved by a model study.

We are intrigued with certain aspects of the economy of power production.  The
heat discarded by a power plant is money, as was remarked this week.  Looking
at this cursorily, a fossil fuel power plant with a revenue of ?;!?00 million
annually for the sale of electric power is discarding a potential market value of
$563 million or more, and spending money to do it, if electric power is truly
competitive with other forms.  For a   l^OO million annual revenue from nuclear
-------
                                                                                2349

PCRTSR COOMTY CHAPTER. IZAAK WkLTOK LEAGUE	Sheet 5.

nuclear power, the value of the power discarded becomes more than $1 billion ann-
ually.  These values must not be confused with the actual cost of the power
discarded, which, of .course, is much lower but still formidible.  In either case
the gold vein is worth prospecting.  The electric companies have been peculiarly
reluctant to develop and market by-products.  Revenues from the discarded heat
amounting to only 20f? of the above figures will support a heavy investment in
research and plant.

T.Je believe that the ultimate development of power companies will be to locate in
the center of an industrial park, surrounded by heat consuming industries,
or other heat consuming activities requiring space.  With proper planning there
will be the necessity for a relatively small dry cooling tower to balance the
demand for heat with the demand for electric power.  By locating on a lake shore
a power company is reducing its areafor this option by half;  located on the lake
shore between a large public park and a high level residential community, the
option is barred entirely.

Considering that the evidence is clear that heat degrades Lake Michigan in more
than a small degree, and that the increase in generation of electric power, coupled
with the additional heat discarded by industry will approach and exceed the
tolerance of nature;  and considering also that the proposals offered for the
control of heat disposal are inadequate, we take- the position that it is correct
to limit all discharge of water to a. delta T of 1 degree.  We think that industries
that cannot meet this specification should locate elsewhere.  We feel very keenly
that Lake Michigan is of the greatest value as we found it, and that it should
be preserved.
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                                                              2350



   AMERICAN  ELECTRIC POWER Service Corporation
                          2 Broadway, New York, N. Y. 10004
                          •(212) 422-4800

                            October 8, 1970
To The Conferees
The Lake Michigan Enforcement Conference
Mr. Murray Stein, Chairman
Mr. David Currie
Mr. Thomas Frangos
Dr. F. T. Mayo
Mr. Perry Miller
Mr. Ralph. Purdy

Gentlemen:

          At the conclusion of the Workshop Session of the
Lake Michigan Enforcement Conference, on Friday, October 2,
you heard discussion of a vital point that-needs further
consideration.  This was the dialogue on who should bear
the responsibility for measuring the effects of warm water
discharges.  Chairman Murray Stein and Dr. M. A. McWhinney
set forth only part of the problem.  In this matter, as an
observer of the five days of your Workshop, I would like to
present additional comments.

          The bearing of responsibility should be recognized
for two purposes - for enforcement, and for support of a
permit of use.  For an enforcement action, many states have
laws  that require that the enforcement agency must obtain
and present the technical evidence used to judge and convict
a  violation.  For the use of a resource such as a public
water, many states insert into permits for withdrawal or for
discharge, the requirement that the user must obtain and
submit suitable observations to determine whether or not he
is doing harm by the specified use; and these states reserve
the right to withdraw or revise the permit if harm is found.
In the discussion between Chairman Stein and Dr. McWhinney,
there may have been some confusion as to which type of
responsibility was to be borne by whom.
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                       -£-                 J.U/0//U

                                                              2351

          Certainly, the federal agencies and the state
agencies should collect and present evidence used for any
enforcement action.  In addition, they should maintain a
degree of observation sufficient to verify the conclusions
offered by the user from his own studies.

          It should be required that the user of a resource
bear the burden or the responsibility of supporting sufficient
evaluation and research to, show that no harm is done by his
use.  This evaluation and research should be according to
advance plans that have been approved by the agency that is
authorized to permit the use.

          It is often to the benefit of the whole community
to have a third-party evaluation - a citizens group that is
free of the possible biases of the permit issuer and the
permit recipient.

          The type of study or research and the processes
of decision are often confused.  Should these be investiga-
tions using all of those scientific disciplines that should
be applied?  Should the validity of judgments of these
scientific studies be subject to legal review?  Or, should
the rule of "the street people", the pressure of hysteria,
replace such deliberative actions?  Last week, we heard
intimations of unlawful actions if the governmental agencies
did not move quickly and to the satisfaction of the "street
people."

          Should the scientists be considered as capable of
maintaining objectivity without regard to the source of their
financial support?  We have heard a great deal of talk suggest-
ing that any scientist who accepts support from an electric
utility is bound to find biased data in his studies, and to
give dishonest conclusions.  We have heard this claimed even
in cases where the utility paid no money directly to the
scientist but only had a contract v/ith his university.
Such a financial contamination process could be applied to
other scientists from the same university - even to those
who have expressed contrary conclusions.

          If the utility will contaminate any scientist whose
university accepts a research contract with the utility, and
if the utility will contaminate any scientist who works more
directly for the user, how can the utility find out the
truth?  And,-how can it obtain evidence showing whether or
not it does harm by its use?
-------
                    -j-             lu/o/yu

                                                             2352


          If financial support is a basis for disqualification
of scientists, how can either side of a dispute present expert
testimony?  Will only the expert testimony of third parties be
allowed?

          Chairman Stein and Dr. McWhinney touched on a little
of this, in their noteworthy discussion in Chicago.

          In many cases today, the electric utility is required
to support elaborate research by experts who were approved in
advance by the responsible agencies.  Then, the work done by
these experts is checked by various of the government experts.
This process is yielding a vast amount of honest information
on the effects of warm discharges.  This process should be
continued - and even expanded.
                              Very truly yours,
                              T. A. Miskimen
                                Senior Engineer
TAM/fkr
-------
                                                         2353
                MRS. MAXWELL MCCROHON
                 ROUTE i. STUENKEL ROAD  September 30, 1970
                  CRETE, ILLINOIS 6O4I7
Dear >ir. l-layo;

Please be  vigorous in opposing any installations
alon% our  lakeshores v;hich discharge ^ater heated
more than  one decree over the normal lake
temperature.

I am also  disturbed about the improper land use
which accounts  for industries situating on
disappearing scenic and recreational v/aterfronta^es
which are  already  inadaquate to the bur^eonin^;
metropolitan populations.

By denying the  nrivala^e to private companies to
make use of the lakeshores tnere will be more
impetus to findin,;; adaquate alternatives.

Thank-you  very  much for your kind attention.

                 Very truly yours,
-------
                    ->^-                        2354

DAN HARPER -BOX £t©, ROUTE 3, CRETE, ILLINOIS

                                           6 * y • 7
   ui.s. 07
                                      L ?-


                                        ~
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-------
ROBERT McCLORY
 12TH . '(STRICT. ILLINOIS

JUDICIARY COMMITTEE

   SUBCOM MITTEESi
    ANTITRUST
  SUBMERGED LANDS
I.S. INTERPARLIAMENTARY
  UNION DELEGATION
                                                                                  2355
Congre&S of tfje 33niteb
              of Eepresentattoe
                  , 33.C.  20515
      ROOM 426
CANNON HOUSE OFFICE BUILDING
    (202) 225-52Z1


    DISTRICT OFFICE:
   POST OFFICE BUILDING
 326 NORTH GENESEE STREET
 WAUKEGAN, ILLINOIS 60085
    (3U) 336-4554
                                      September  9,  1970
          The Honorable Carl Klein            >-A
          Assistant Secretary of Interior
          Department of Interior
          Washington, D. C.

          Dear Mr. Secretary:

          It has come to my attention that  conferences  will be held in
          Chicago from September 28 through October  2  to consider a new
          Federal policy directed against Thermal Pollution of the waters
          of Lake Michigan.  At the time of the  application for authority
          to erect the nuclear power plant  for Commonwealth Edison at
          Zion, Illinois (in my Congressional District)  1 called attention
          to the need for careful study and resolution  o*f the Thermal
          Pollution problem.

          Notwithstanding the Commerce Department and AEC approval of this
          application, the various charges  persist  that a dangerous level of
          heated waters will be discharged  into  the  Lake with possible adverse
          effect on marine life and other appropriate uses of the Lake waters.
          While it would appear to be most  unreasonable at this juncture to
          impose new standards which were not anticipated by Commonwealth
          Edison Company at the time its nuclear generating project was initiated,
          I feel it is entirely appropriate to require  that company to utilize
          such technology as may reduce to  a minimum the heat which may be in-
          volved with effluents from its nuclear generating plant.  It is my
          further hope that your hearings may lead  to  information or research
          which can eliminate thermal pollution  entirely.

          I regret that 1 will be unable to attend  your conferences personally.
          However, 1 hope to have a representative  present and that I may sub-
          sequently receive a report of the conferences which you have arranged.
                                             Robert McClory,  M.C.
          RMcC/gc
          cc:  The Hon. Clarence W. Klassen,  Director,  111.  Environmental Protection
              Agency.
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33     ^
                                                                                     2356
                                      JAMES 5LO5S


                                    EOS SKOKIE LANE


                                GLENCOE, ILLINOIS 6DD22





                                 v 35   y j.  Z-6-  ^7o
                                 Ln,***-,*- *s* >
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-------
                                                                     2357
MRS. MAYNARD J. SEIDMON
                  1064 SKOKIE RIDGE DRIVE, GLENCOE, ILLINOIS 60022
-------
                                                             2358
                    AARON  S. WOLFF
                     M SOUTH LASALLE STREET                   AREA CQDE 3|2

                       CHICAGO 6O6O3                    FRANKLIN a-5481
                              September 24, 1970
Mr. Murray Stein, Conference Chairman
Federal Water Pollution Control Administration
Department of the Interior
Washington, D. C.  20242

Dear Mr. Stein:

          Since you are Conference Chairman of the
Federal Water Pollution Control Administration, I
strongly urge that you do all in your power to avoid
thermal pollution of Lake Michigan.  At the forthcoming
Federal-State Enforcement Conference on pollution of
Lake Michigan, I certainly hope that you will push for
adoption of the strictest standard under consideration.
This would be that of the Department of the Interior
which would sanction only the minimum possible waste
heat to be discharged into Lake Michigan or a 1° F.
rise over ambient at the point of discharge, whichever
is less.

                              Very truly yours,
                              Aaron S. Wolf]


ASW:sf
-------
                                                          2359
                    AARON S. WOLFF
                    II SOUTH LA SALLE STREET                   AREA CODE 312

                       CHICAGO 6O6O3                    FRANKLIN
                              September 25, 1970
Mr. Francis T. Mayo, Director
Great Lakes Regional Office
U. S. Department of the Interior
Federal Water Quality Administration
33 East Congress Parkway - Room 410
Chicago, Illinois  60605

Dear Mr. Mayo:

          Since you are the Director of the Great Lakes
Regional Office, I strongly urge that you do all in your
power to avoid thermal pollution of Lake Michigan.  At
the forthcoming Federal-State Enforcement Conference on
pollution of Lake Michigan, I certainly hope that you
will push for adoption of the strictest standard under
consideration.  This would be that of the Department of
the Interior which would sanction only the minimum pos-
sible waste heat to be discharged into Lake Michigan or
a 1° F. rise over ambient at the point of discharge,
whichever is less.

                              Very truly yours,
                              Aaron S. Wolff


ASWtsf
-------
                                       2360
     MRS. LYMAN BARR
     1005 WADE STREET
HIGHLAND PARK, ILLINOIS 60035
                 ^ &*jfc*$  GU/Hv
               S^AAjLlA/L^.--
-------
                                      2361
            F. SCAMMON BARRY. M. D.
                1761 RIVER DRIVE
               GLENVIEW, ILLINOIS
                    —      Sept. 27,1970
                  GL. 1-5353

Mr. Murray Stein, Chmn.
Federal Water Pollution Control Adm.
Dept. of the Interior
Washington, D.C. 20242
Dear Mr. Stein:
               I urge you to use all
of your influence to get the 4-state
Enforcement Conference on Pollution ©f
Jake Michigan to adopt the strictest
standard under consideration for thermal
pollution.  I believe this is the stand-
ard announced by the Dept. of the
Interior.
              This opinion states:
"the minimum possible waste hear shall
be added to the waters of Lake Michigan.
In tho event will heat discharges be
permitted to exceed a 1 degree rise over
ambient at the point of discharge.  This
will preclude the need for mixing soneA."
                                  3
               F. ScamMon Barry
-------
                                                                               2362
                                            Lake St. Clair Anti-Pollution League
                                            P. 0. Box 63
                                            St. Clair Shores, Michigan  ^080
Mr. Murray Stein
Chairman
Lake Michigan Enforcement Conference
c/o FW/QA
33 E. Congress Parkway
Room *HO
Chicago, Illinois  60605

Dear Mr. Stein:

We wish to thank you for this opportunity to express our views regarding thermal
pollution of Lake Michigan. As you may know the pollution of our lakes, rivers,
and oceans is of primary concern to our group.

It is our contention that pollution in any form is detrimental to the health and
well being of the citizens of this country and the world, and is becoming quite
acute. The argument that only a small amount of hot water will be dumped into
Lake Michigan will not, so to speak, hold water. This pollution added to all the
other pollutants that are being dumped into the lake will only make the problem
worse. As noted in the Clean Water News , thermal pollution will, according to
a report from the U.S. Department of the Interior, have a significant adverse
ecological effect on the lake.

We feel therefore that thermal discharge into Lake Michigan should not be
condoned or allowed. As there are cooling systems available which will apparently
work and are feasible to use, we feel adequate cooling systems should be
made manditory for water cooling before dumping into the lake. Careful site
selection surveys should be made to prevent other potentially dangerous
ecological changes from occuring.

Thank you again for this opportunity.
-------
T -S-Ol
D
        V\.  *
                                                                                2363
                             . .OLLxfi t^£-ii.v  oJL .'t
-------
                                                           2364
September 28, 1970

Mr. Murray Stein
Conference Chairman
Federal Water Pollution Control Adm.
Dept. of the Interior
Washington, D. C.  2021*2

x>ear Mr. Stein:

I would like to voice my support for the establish-
ment of strict standards controlling heat discharges
into Lake Michigan and other waterways.  There should
be no difference in waterway and discharged water
temperature that cannot be attributed to error in
 measurement.

It is time to take decisive action.  Caution must
be exercised now.  It is easier to ease restrictions
in light of future findings than it is to view useless
bodies of water and wish there had been more foresight.

 Tours truly,

E. M'. Davey  '
-------
2365
-------
                                                                    2366
                                Summary
            Preli.tmin.ary Report on Sanitary Sewerage System
                and Water Pollution Control Facilities
                           Whiting^ Indiana

         - Russell, Schubert, Hanilton and Associates,, lac,,, Indianapolis
     1»  Existing  (a)  Dry weather flow to Haramoad for treatment with
                        effluent discharge to Grand Calumet River west
                        to Illinois Waterway o

                   (b)  Combined sewer overflow  (intermittent) to Lake
                        Michigan,-  Storm water pumping station discharge
                        to Lake Michigan,

     2.  Proposed  (a)  Plan A & B - Dry weather flow to Hammond :, storm
                        water disinfected and discharged to Lake Michigan -,

                   (b)  Plans C9 D and E  • All flow treated and discharged
                        to Lake Michigan with alternate for discharge to
                        Indiana Harbor Carialo
     Plan A and B  •• $7 s (A 3, 000 and $75022,000,, respectively
     Flan C, D and E - $6,2^1,0009 $63,360^000 and $5,338,,0005 respectively
     Alternates for discharge to Indiana Harbor Canal $260,000 to  $380^000

DiEcu3sj.pn

Whiting is served by a coinbined sewer system,,  Tlie dry weather wastevater
flov, from the City of Whiting is discharged to the Hamnond Sanitary District
at the Robertadale pumping station for treatment by Hammond <>  This procedure
has been in effect since the late 40 ''s*  An overflow a-c one point  in the
Whiting sower system near -ohe Lake discharges to the Lake -when the lift
station malfunctions or when the newer dovmstream from the lift  station is
surcharged,,  Whiting also maintains a storm water pijmping station  near the
Robertsdale pumping station*  At times of runoff fyom rainfall,  storm water
is discharged to Lake Michigan.

     The Implesnentation plan of the Water Qualj.ty Standards required Whiting
to prov5.de treatment and disinfection of sewage snd storm water  overflow  on.
or before the end of 1970,  When it became obvious that the City would not
aeet this schedule ^ the Board scheduled acci issued an administrative order
to provide the necessary facilities <•• the final order which was  issued on
July 21 ,, X970j provided for completion of a project to provide for treatment
and disinfection of sewage and storm water overflow by May I, 19?lc  The
order also recommended that Whiting continue to pump its wastewater to ttie
Hammond Sanitary District <-
-------
                                    .?„                                 2366-A

         Suiatiaty
,
      ^f.d^'-r^^l.  - Tae, preliminary report. which was received on September 8
.i.9?Uj,Tiraf '  copy rfccuivsd Augus. 14-1  provides information on 5 plans  aad
recommends  Plan E as IL^ most  Favor able .

      i,   Flans A  arid B. which  ai^e essentially the same, provide for  separation
          of th-i sewer system with discharge of wastewater to Hammond and
          disinfection of storm va'-e-r with discharge to LaJkf Michigan.   The
          acawx separation construe'! ion coat is estimated to be in excess of
          $3.,cto»,ooo.,

      -?.,   Plans C_ D, rir.d E propxse minor  improvements to the, sewer system* a
          3  raga aeti.T'atv>d slodge-'.ype ^reatsient plant and a 30 sag storm water
          dttt,«5ntion bdsiri., with provision  for treatment of storm water  at the
          rate of  I mgd prior T>o discharge of effluent, to Lakt Michigan «
          \JLternat«;£ are indicated for  tertiary treatment at an estimated cor.t
          of $500,000 and discharge of  the effluent to the Indiana Harbor
          Canal in lltr.u of" to Lake Michigan.
Comnifcnts
         Sufficient  detai.'t is nut provided  on the proposed treatment  facility
         arid tertiary treatment undur plans C, D? and S to determine  whether
         or not  the  cost estisaatt is feasible-.

         Sufficitnt  data are not provided on stor.ro water runoff to assure  that
         a  3^ fl^S storage basin is adequate  to retain all fltsws with treatment
         capability  of only 1 mgd above  dry weathar flo\v\-

         Cost, data is rot provide-;} on estimat&c! operation and maintenance  <*ost»
         in oi-dtT to cuapartj the annual  cost to Whiting if it built its  own
         plant vi th  «:h*: cost of continuing  to discharge to Hammond „

         Ko i/ifonnation is provided on the  feasibility of utilizing the  sewer
         piitns and detention basins a.&. proposed under plans C8 B,, &nd E  with
         dlsertargt- to haraaorid on a scheduled basis rather than construction --f
         a V*«rrt- b
     '>   Th<;  repcrt con-,tjaree thfc (.-onstrucTioft ctjst only of Plan E with  th«
         Construction cost and Li"eatHK-nt  charge by H
         TVi'.'f«  4iC  inccnsistsncie-^- and  obvious errors in the report,  so  th«t a
         proper i-, valuation of all uspecf;s  Is  not  possible.

         Tbt  proposal by Whaling to provide  its own trt5at.nH.-nf provide*  for
         dirfect discharge T-O fch<; Laku or via  the  Indiana Harbor Canal,.   Whit'. ".;''
         plat.i r>n ,

             on  - Thar  i hf  proposal, fcr construction  of  a  treatment pl*nt
         and dischargf-  v,o LA\«:  Michigan or a trib^rtary thereto no-v be
OKHer;;;
9/30/70
-------
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                                                                      2367
-------
—^±:^
    mbol.
    The filing time shown
        32)UUMA170
M «KAt®3  AS ?1F WAUKESHA «1S 2 *07AC1T

HURRAY STEIN
   CARE LAKE MICHIGAN ENFtRCEWEUT CONFERENCE  SHERMAN HOUSE CHGO
 FAVOR STAN1 AGAINST WATER POLUTION.  AM OWNER OF 10N1S IN CONSUMERS

 POWER ENV1ROMENT  MOST  IMPORTANT
    MRS 1ETTY PRIEBE
   SF120KR2-65)
-------
Klfits. DAN HARPER-BOX 216, ROUTE3, CRETE, ILLINOIS
                                               2367
                   O.C. ic ;i:i <—  .
                           c-1  t  W^  s
             ,

                         ,,
                        J  -
-------
   CLASS OF SERVICE ^
  This is a fast message
  unless Us defected char-
  acter is indicated by the
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TELEGRAM
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      The filing time shown in the date line on domestic telegrams is 1OCAI TIME at point of origin. Time of receipt is tOCAL TIME at point of destination
                                                                       CT  2   AM  9   17
                                                                               2368
 SNA003 <32>
-------
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 This is a fast message
 unless its deferred char-
 acter is indicated by the
 proper symbol.
S.          ^
                         STE
                               TELEGRAM
S
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 DL=Day Letter
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 LT «*mernat'onal
w  Letter Telegram ^
      The filing tune shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination
                                                         m     3  AM 9  [7
 W MWAS23  EM NL P» < EX  MILWAUKEE MIS  i                          2

                                                                  SN
CHAIRMAN MURRAY STEIN, ILY 75
   FEIL WATER PtLLUTItN  CtNTR«L A1VINISTRATIVE HEARING
   SHERMAN H«USE CHGt
 WE URGE YtUR CtNTlNUEl  EFFtRT T« SET  STAN1AX1S FtR LAKE MICHIGAN
 AT THE TtLERAlLE LIMIT  *F WE PERCENT THERMAL AllITItN  AB»VE
 WATER TEMPERATURE ACC«R»ING  Tt SECRETARY  tF THE INTERIOR WALTER
 HICKEL STATEMENT. WE THE  GENERAL PU1LIC MAY NfT IE V«CAL 1UT
 YfU HAVE  »UR FULL SUPPiRT.  HAPPY NEW  YEAR BEAR MR STEIN T«
 Y«U AN1 YOURS


   STAFF «F VIRGINIAS 1EAUTY  SALfN 49< EAST SILVER SPRING ELEANfRE
 GRACE MANAGER.

SF1201(R2-65)
-------
CLASS OF SERVICE
This is a fast message
unless its deferred char-
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proper symbol.
\\7 1L1 CV 1
WJcoJL
TERN UNION
TELEGRAM

' SYMBOLS ^
DL = Day Letter
NL=Night Letter
^ ^Letter Telegram^
The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination
1970 OCT 2- AM 9 I?
2370
 SNA992 (25)(10)MC®3i                                           SN
 M SB A003 SV NL ft SHEBWGAN VIS »CT 1
  MURKY STEIN
   SHE1MAN HtUSE CHGt
  THE SMEBtYGAN CHAPTER tF THE IZAAK WALT«N LEAGUE tF AMERICA
 AN1 THE SHEBtYGAN CHAPTER MEMBERS SERVING AS OFFICERS ANB BIRECTtRS
 9 THE STATE LEAGUE HARBLY ENBtRSE THAT THE WATER TERMPERATURE
 INCREASES BY NUCLEAR PtiER PLANT LtCATEB tN LAKE MICHIGAN BE
 HELB Tt tNE BEGREE THE STATE LEAGUE IS REPRESENTEB BY
 MEMBERS ANB THE SHEBtYGAN CHAPTER BY 215 MEMBERS
   E K B«RN PRESIBENT*
SF1201(R2-65)
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 N           /"
STERN
      TELEGRAM
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  ^International
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      The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination
 SNA00J
 M WSA043  JB PB ASV STEVENS POINT WIS 2  1100A CBT
 MURRY STEIN,  SHERMAN HOUSE
   CHGO
 THE CITIZENS NATURAL RESOURCES ASSOCIATION OF WISCONSIN  STRONGLY
 SUPPORT SECRETARY HICKELS  STANBARB OF ONE BEGREE INCREASE IN
 WATER TEMPERATURE FROM  ATOMIC POWER PLANTS
   F « 1AUMGARTNER PRESIBENT CNRA
 (1130).
                                               2371
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LT =
                                                                 .International
                                                                 Letter Telegram
     The filing time shown in the date line on domestic telegrams is LOCAL TIME at point of origin. Time of receipt is LOCAL TIME at point of destination
SNA005 <33M15)MBOf3 CL065
CC SNAOQ4 BY PBC 5 EXTRA SN CHICAGO ILL 2 >OSA CBT      1970 OCT 2
MURRAY STEIN, CHAIRMAN, CARE SHERMAN HOUSE

-------
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WESTERN  UNION
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                                                                        V.
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T -T- ^international
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 SNAOOg (07)(05)CTBO?2 WJ019
 W SNB002 HH GOVT PBB SN WASINGTON  1C  2  1©43A EBT                 2373
 K'URRAY STEIN                                              SN
   SHERMAN HOUSE HOTEL CLARK ANB RANDOLPH ST  CHGO
 BEAR MR STEIN*
       IT IS MY  UNBERSTANBING THAT THE  FWQA WILL BE .CONCLUBING
 AN ENFORCEMENT  CONFERENCE TOBAY CONCERNING THE POLLUTION  PROBLEMS
 OF LAKE MICHIGAN ANB THAT THE MAJOR PROBLEM  ON THE  AGENBA MILL
 BE THAT OF THERMAL POLLUTION FROM POWER  PLANTS.
       WHEREAS THE SCIENTIFIC EVIBENCE  REGARBING THIS  PROBLEM
 IS ABMITTEBLY INCONCLUSIVE, IT IS MY HOPE THAT IT WILL  BE REGARBEB
 AS SUFFICIENT TO PERMIT AGREEMENT ON A SPECIJIC THERMAL STANBARB
 FOR ALL PLANTS  ON THE LAKE. ANY SUCH STANBARB WILL .NCESbSARILY
 BE AN IMPERFECT APPROXIMATION OF WHAT  IS NEEBEB.  YET  IT WOULB
 APPEAR NONETHELESS TO BE AN IMPROVEMENT  OVER THE  CURRENT  SYSTEM
 IN WHICH BIFFERENT PLANTS ARE HELB  TO  BIFFERENT STANBARBS OF
SF120I(R2-66)

-------
                                                                  2374
                                    i^aafe Walton league of America
                                                INCORPORATED
                                      DEFENDERS OF SOIL. WOODS, WATERS AND WILDLIFE
DIVISION
Of FICFRs
Sept l'!70--Sept 1971


\\OMFV-) VI'
919 Uc>* 4Vh -We.
Gary. Indiana
46408
PRESIDENT
Wajne Stapf
1 i34 E Raymond
plamfield, Indiana
46\w
sOU'lHWEST VP
RR3, Box 233
Maitmbulle, Ind.
4bl51
SECRETARY
Mrs. Barbara Rux
1613 Washington
Michigan City, Indiana
46360
NORTHEAST VP
260 Manchester Ave.
Wab,ish, Indiana
46992
TREASURER
Gale S Atwood
3625 Lincoln St
Gary, Indiana
46408
E CENTRAL VP
416 W. Foster
Kokomo. Indiana
46901
W CENTRAL & lfat VP
George Leedy
RR2, Box 47
Plamfield, Indiana
46168
NORTHWEST VP
5808 E. 10th Ave
Gary. Indiana
46403
                              EXECUTIVE SFCKLFARY
                                           las E Dustm. 1802 Chapman Rd , Huntertown, Ind 46748 . Ph. 219-637-6264
October 2, 1970
To:  Federal Water Quality Administration
Statement of:
E. Eugene Minney, President
Interchapter Council
Indiana Division, Izaak Walton League of America
  228 N. Raymond
  Griffith, Indiana
Gentlemen:
I am E. Eugene Minney, president of the Interchapter Council, an
association of Izaak Walton League Chapters in the three northwestern
counties of Indiana—Lake, Porter and LaPorte.  These are also the
Lake Michigan counties of our state, so we know you will appreciate
our exceptional interest  in this Lake Michigan Enforcement Conference.

In our region of the state are approximately 1200 of Indiana's League
membership, the vast majority of whan see Lake Michigan almost daily,
and use it recreationally many times each year—for swimming, boating,
fishing, and simply enjoying the change of pace which the Indiana dunes'
region uniquely provides.

We commend the Department of the Interior for recommending a 1°F limit
for temperature elevation in Lake Michigan.  We would like to observe
that there has been a good deal of utility propaganda flowing from this
Conference, most of it, we suspect, for public consumption in far off
places, and not especially for the edification of the Conference.

Perhaps some of the officials of the four Lake Michigan states may feel
you have been overly restrictive in recommending a virtual zero-tolerance
for Lake Michigan thermal pollution.  We don't think so, and we fully and
without qualification endorse that recommendation.

If in recommending that tolerance you mean to tell the utilities to move
off our Lake Michigan shoreline, and to design inland plant capacity with
completely self-contained pollution control systems, then our endorse-
ment is just that much stronger.  Because that is what we think they should
do also.

The utilities have made much point about choosing between more electricity

-------
Page 2.
                                                                  2374-A
and the maintenance of high environmental quality.  We don't think this is
a choice they should be able to make.  Lake Michigan does not belong
to the utilities; it belongs to all of the people, and we are all
entitled to it in an unimpaired condition.

The utilities have produced nothing at all to suggest that their thermal
effluents will be harmless to Lake Michigan.  And a great deal of expert
testimony and documentation suggests that it will be very harmful indeed.

It is not gur burden to prove that their activity will further destroy
Lake Michigan.  We are not dealing in :the_ir estate; they are dealing in
ours.  And this is a distinction the public and its agencies have not
made very well in the past.  Other than a lone biologist who seems
willing to be quoted by the utilities—and whose views have been contra-
dicted by other more independent experts—there is no basis at all for
allowing any more utilities to discharge warm water to Lake Michigan.

It would be maddness on our part—raw maddness—to bet the life of Lake
Michigan on the say-so of one or two company-retained biologists, who have
at very least the appearance of conflict of interest.  If our Federal
or state agencies allow so much as one more utility or any other industrial
installation to add its pipe to the lake, to discharge anything warmer or
of poorer quality than natural lake water, then such Enforcement Confer-
ences as this one will no longer have a shred of credibility.

We have not rolled back the wave of pollution here in the past five or
six years.  The very best that can be said is that the lake is getting
worse at a slower rate.  This is because neither the people nor their
governments at various levels have stood firmly enough.  We have rational-
ized and equivocated.

Let me point out just one evidence of the grave environmental injustice
the utilities are expecting all of us to absorb.  The National Water
Resources Council has predicted an immense increase in water needs by
the year 2020.  Water development agencies are more than pleased to flash
these gross figures around, in order to stimulate public support for the
billions of dollars it will take to provide that water.  But what the
people DON'T realize is that while municipal, agricultural and industrial
interests account for a relatively modest part of this increased need,
it is the utilities which account for MORE THAN 50% OF THE ENTIRE INCREASE;
and that is for cooling steam generating plants.  The immense cost of pro-
viding that water is to be borne by the public.  Why should WE pay for
their hot water pollution, and then face them again in an iron ring around
Lake Michigan—polluting our water, graying our skies, and uglifying our
shorelines.

It is long overdue for a reckoning and a re-balancing of these environ-
mental books.  The utilities scream to the people of this land that they
must double their capacity every 10 years to stay abreast of demand; then
they go forth and create that demand.  They ominously forecast blackouts

-------
Page 3.                                                           2374-B
and brownouts when their 19th Century methods of operation are questioned.
But if such methods are calculated to pave the way for a new permissive-
ness toward untreated high-sulphur fuels or a free hand in thermally
polluting Lake Michigan, those methods will fail.

The fact is that in environmental engineering the utilities have done
a miserable job, born of regional monopolies and other exclusivities.
It is too bad we haven't yet come up with a way to put the utilities in
the cauldron of competitive economics the way the rest our society has
to operate.  At this time,  we can't buy somebody else's product if we
don't want NIPSCO's.

But if we can criticize the utilities—and they have much of it coming—
it is also up to all of us to help them make the transition from laissaz
faire environmentalist!! to ecological environmentalist!!.  They are right
when they say the cost will be great.  They are wrong when they fail to
begin creating the atmosphere in which the cost will be acceptable.  They
are wrong when they oppose every effort to tighten anti-pollution laws;
and they have done this, at every hearing in the state of Indiana, where
our representatives consistently testify for better conditions.

If the utilities cannot support the clean water and air proposals that
Interior and H,E.W. have been making, we would think the least they could
do is to relax their fight against these efforts.  By following such
a course, their position in requiring all of us to help with the costs
would be quite understandable and defensible.  Their present position
can only lead to the conclusion that their primary interest is in corpor-
ate profit, not public service.  They apparently see themselves apart
from the rest of us, instead as a member of the same team.

We will have to recognize our share of the cost burden, but the utilities
will have to recognize that the environment they are polluting is not
theirs to pollute, but ours—everybody's—to enjoy and live in harmony
with.

On September 20, the Indiana Division of the Izaak Walton League—with
the full support of our northwestern chapters, adopted a 10-point proposed
policy for Lake Michigan.  It accompanies the testimony of our state
executive secretary, and I will not reiterate it here.

But we feel that policy could be the start of the kind of new attitude
toward Lake Michigan which can begin to produce results.  Whether some
of its points need changing, or other points added, it recognizes Lake
Michigan as an  integral environmental unit.  Our generation MUST stop
seeing Lake Michigan as an estate that can be chipped away piece at a time.
It must be seen as a whole, and we must soon decide what kinds of activities
are acceptable  in its context, and what types are unacceptable.  ANY more
thermal pollution must be judged unacceptable.  And 100% effluent standards
must be the next goal we set.  If are serious—genuinely serious—about
saving Lake Michigan, then there are no real alternatives to such a policy.

-------
                                                 2375
' i -v    v
            vi/\
                           ''
--<>\^-'+'^~
/J
                                          i  / ^  ~T~
                                        a^j" -U^-L -dL&'
      ^

-------
2375-/?

-------
                                                       Oct.  3,  1970


Mr. Murry Stein,
Federal Yfater Quality Administration,
Department of the Interior,
'.Washington, B.C.

Dear Mr. Stela*

                      I found the following telegram awaiting  me  when
I returned home from the Lake Michigan Enforcement  Conference  - Octe  2nd.
I -was sorry that I did not have it in time to  include it  in the statements
made that day - but would like to have you enter  it into  the records  -

         Telegram -

              "Regret I am unable to leave "Washington to  attend the
         meeting to be held  in connection with standards  to prevent
         the further pollution of Lake Michigan on  October  2nd at
         the Sherman House0
               Wholeheartedly support a program to  make certain that
         no significant heat be allowed to enter  the lake from Nuclear
         Plants.  As my activities in the past have demonstrated,
         particularly as they apply to halting the  dumping  of  dredgings
         into the Lake by the Corps of Engineers, reflects  my  deep
         concern with the problem of pollution not  only of  Lake Michigan
         but all the Great Lakes.  Please feel free to call upon  me at
         any time if I can be of assistance in my capacity  as  an
         Illinois Congressman in pursuit of efforts to improve ecological
         conditions."

                                   Congressman Harold R.  Collier
                                       10th District - Illinois


                       Do hope something constructive and positive comes
out of that meeting - to assure the safety of  the Lake,,   The loss of  it
would be a major catastrophy for millions of peoplel

                                       Sincerely,      _^
              The time to take action  is nowll
 MRS. J. F. VOITA
 229 North Taylor Ave.
 Oak Park, Illinois 60302

-------
State of  Wisconsin  \  DEPARTMENT OF  NATURAL RESOURCES
                                                                        L. P. Voigt
                                                                         Secretary


                           October 8, 1970                    MADISON, WISCONSIN 53701
     Mr.  'Murray Stein
     Assistant Commissioner
     Federal Water Quality Administration
     Department of the Interior
     Washington, D. C.  20242
     Dear Mr. Stein:

          Enclosed is a copy of a statement of the Wisconsin Wild
     Life Federation submitted by Mr. Les Woerpel of Mosinee,
     Wisconsin.

          I would appreciate your including this statement  in  the
     record of the workshop sessions of the Lake Michigan Enforcement
     Conference.

                                    Very truly yours,
                                    Division of Environmental  Protection
                                    Thomas G. Frangos
                                    Administrator
     Enc.

-------
                      Wisconsin   Wildlife   Federation
                                          Affiliated with

                                  National Wildlife Federation


                             Post Office Box 7, AAosinee, Wisconsin 54455
                                                               September 30, 1970

STATEMENT TO BE ENTERED IN THE  CONFERENCE IN THE MATTER OF POLLUTION OF LAKE MICHIGAN.


     The Wisconsin Wildlife Federation would  like, first of all, to express it's
approval of the United states Department  of  Interior's proposed regulation not
to allow waste heat discharges  into  Lake  Michigan to exceed one degree Fahrenheit
rise over ambient at the point  of  discharge.

     The question of thermal  pollution must be decided now, because, if a tight
limit is to be kept on heat discharges into the lake the pattern of building
future plants will be affected, and  it may be equally as economical to build
plants in other locations than  on  the  shores of ready water supplies.  If Power
plants are permitted to discharge waste heated waters into the lake the precedent
will have been set for future concentrations of these plants around the lake.
If allowed to dump heated wastes more  leniently the time will surely come when
the orders will have to be tightened up,  and it will be next to impossible to
secure compliance with desired  waste heat discharge goals.

     Regarding Industrial and Municipal discharges of wastes into Lake Michigan
or any of its tributaries, the  Wisconsin  Wildlife Federation has long been on
record that they should be mitigated and  stopped as soon as is humanely possible.
No material progress in cleaning up  these waters can be made with a lienient
attitude toward polluters, whether of  private or governmental origin.  An example
is the doubling of the solid  waste load in the Wisconsin River over the past ten
years, a period when everyone thought  great effors were being exerted to cut the
amounts of such wastes being  discharged into the river.  We therefore urge that
every effort be made by the various  state pollution agencies and the Department
of Interior to set standards  which can realistically attain a goal  of lower
discharges into the waters of Lake Michigan and its tributaries in a reasonable
period of time,  And that the goal not  be reduced percentages of waste from a
plant or municipality, but reduced total discharge regardless of expansion of
operations.
                   Signed,
                           Les Woerpel, Secretary
                           Wisconsin wildlife Federation.

-------
                               STATF OF ILLINOIS


                   ENVIRONMENTAL  PROTECTION  AGENCY
                                                          SPRINGFIELD,  ILLINOIS  62706

                               October  9,  1970                AREA 217 ' 525-6580
Mr. Murray Stein
Conference Chairman
Lake Michigan  Enforcement Conference
United States  Department of the Interior
Federal Water  Pollution Control Administration
Washington, D.C.  20242

Dear Chairman  Stein:

     The authors  of the enclosed letters were unable to be present at  the

September 28 - October 2 Workshop relative  to the question of thermal  discharge

into Lake Michigan.  They therefore would like to have these letters made a part

of the official  record of the Workshop.



                                                  Sincerely,
                                                  C.W. Klassen,
                                                  D i rector
Ends.
                            THE NEW ILLINOIS
                                    imodato

-------
bOA 2rar, nuU i t Jfr, CHt 1t,

                                     <"<"//7

n
  ,  I*
  ,,
                    RECEIVED
                      -v^'f-1- pr.oTECT!:;j. AGCNCY
                        TATE orra'-!:io:3

-------
                MRS. MAXWELL MCCROHON
                 ROUTE I. STUENKEU ROAD
                  CRETE. ILLINOIS 6o4i7   September 30,  1970
Dear Mr. Klassen;

Hopefully you will  support  Open  Lands  and all  the
environmental organizations which  oppose  the
discharge of heated water into Lake Michigan and
propose a standard  of discharge  no higher than
1 decree at the point of emtrdssion of  heated water.

The effects of heated water are  not known at this
time. V/e can no longer afford to pursue traditional
practices which have accounted for the cesspool
conditions affecting our inland  waters.

Thank-you for your  attention.

                 Very truly yours,
                                EiVED
                             OCT  51970
                               rrj. PROTECTION AGENCY
                             STATE OF

-------
    6 \J '3 I *•>
p. SCAMMON BARRY, M. D.
    I7SI RIVER DRIVE

                     Sept. 2?
              ,„
»               OLKNVIBV.miNOl.
 SIM       -
 Clarence Klassen, 111. Environement
    Protection Agency
 535 W. Hefferson St.
 Springfield, 111. 62706

 Dear Mr. Klassen:  I urge you to use all
 of your influence to get the 4— state
 Enf6rcement Conference on Pollution of
 Lake Michigan to adopt the strictest
 standard under consideration for thermal
 pollution.  I believe this is the standard
 announced by the Dept. of the Interior.

                   This opinion states:
 "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 rise over ambient at
 the point of discharge."

                   Thank you. for your attention.
                   Yours truly,
                   P. Scammon Barry

-------
            NINETY-FIRST CONGRESS
                 _

         EDWARD A. GARMATZ, MD., CHAIRMAN

LEONOR K. (MRS. JOHN P.) SULLIVAN, MO. WILLIAM S. MAILLIARD, CALIF.
FRANK M. CLARK, PA.
THOMAS L. ASHLEY, OHIO
JOHN D. DINGELL, MICH.
ALTON LENNON, N.C.
THOMAS N. DOWNING, VA.
JAMES A. BYRNE, PA.
PAULO. ROGERS. FLA.
FRANK A. STUBBLEF1ELD, KY,
JOSEPH E. KARTH, MINN.
WILLIAM D. HATHAWAY, MAINE
WALTER B. JONES, N.C.
RICHARD T. HANNA, CALIF.
ROBERT L. LEGGETT, CALIF.
MICHAEL A. FEIGHAN. OHIO
FRANK ANNUNZIO, ILL.
SPEEDY O. LONG, LA.
MARIO BIAGGI, N.Y.
                      THOMAS M. PELLY, WASH.
                      CHARLES A, MOSHER, OHIO
                      JAMES R. GROVER, JR., N.Y.
                      HASTINGS KEITH, MASS.
                      G. ROBERT WATKINS, PA.
                      HENRY C. SCHADEBERO, WIS.
                      JOHN DELLENBACK, OREG.
                      HOWARD W. POLLOCK, ALASKA
          GEORGE A. OOODLING, PA.
          WILLIAM G. BRAY. IND.
          PAUL N. MC CLOSKEY. JR., CALIF.
          LOUIS PREY, JR.. FLA.
          JACK H. MC DONALD, MICH.
                                                                    ROBERT J. ABLES
                                                                    CHIEF COUNSEL
                                                                   ROBERT J. MCELROY
                                                                     CHIEF CLERK
                                       {jETOttttttlttCC Olt
                                        _-^  ,    V.
                                       5$t&tUTC 31X0
                             *0<"«
                                                         %)tmst ©ffice JBuilbins
                                                      i, B.C.  20515

                                                October 12,
Honorable Walter J.  Hickel
Secretary
Department  of  the Interior
Washington,  D.  C.

Dear Mr. Secretary:

          I  wish to  bring to the attention of your agency  certain
matters with regard  to the Four State  Lake Michigan Enforcement
Conference  dealing particularly with waste heat emissions  into
Lake Michigan.

          It is my wish that this  communication be included  in
that record  and that it be carefully  considered by you in  con-
nection with actions to be taken on heat emissions into Lake
Michigan.

          I  would call to your attention your responsibilities
under Public Law 660, as amended,  dealing with different forms of
pollution,  including heat emissions.   In addition to this,  I would
very forcefully direct your attention  to the Environmental  Policy
Act of 1969  which imposes upon you the duty to interpret your
fundamental  statutory and regulatory authority and responsibilities
so as to assure a clean, wholesome and desirable environment.

          Your  agency is even required under Section 103 of  the
Environmental  Policy Act to submit statements as to how you  pro-
pose to bring your regulatory and  statutory authority into  con-
formity therewith, and upon failure to be able so to do, to  report
to the Congress advising this body of  how your statutory powers,
duties and  authorities should be changed to come into conformity
with the policy statement of the Environmental Policy Act.

          Pollution  of the Great Lakes system is a major aesthetic,
conservation,  environment and resource problem.  Lake Michigan is
perhaps the  most endangered of all the Great Lakes because  of the

-------
                             - 2 -
low level of flow into that Lake and the long time that pollutants
of different kinds remain there before being carried out by flow
of water.  Massive heat emissions of the kind contemplated by the
chain of thermonuclear and conventional generating plants around
its shores not only will be a major source of pollution, but will
constitute forces bringing about significant changes in the ecology
and environment of the Lake.  In addition to this, massive heat
emissions will increase the effect and hazard of other pollutants
dumped into the Lake by industry and cities.

          It is my understanding that most of the operators and
those associated with the nuclear and conventional generating
plants which have appeared before your agency have given you to
understand that the choice is between heat pollution and no plant.

          I wish to bring to your attention that this is not the
choice, but that there are a number of alternative methods whereby
the emission of heat into the Lake may be reduced or avoided
altogether.  Cooling towers, settling ponds, holding basins and
dilution of the water by pumping of extremely cold waters from the
depths of the Lake are all available to the users in addition to a
number of other technologically and economically feasible devices.

          I specifically call to your attention the fact that the
National Science Foundation has made a significant grant to Scripts
Marine Laboratory in California to study pumping of water from
extremely deep levels to be used both for cooling and dilution of
cooling returns so as to restore the water to temperature approxi-
mating that of the surface levels of the recipient water body.

          I wish you to know of my strong feelings on this matter,
and I sign this letter as Chairman of the Subcommittee having
jurisdiction over the Environmental Policy Act, which I would have
you know imposes a far higher lej«»±-«f responsibility on you than
many of the witnesses appearing before you have had you believe.
                                  John D.  Dingell. Chairmant
                                  Subcommittee on Fisheries
                                  and Wildlife Conservation

-------
                                                     Oct.  13, 1970


Mr, Murray Stein,
Federal Water Quality Administration
Department of the Interior,
Washington, D.C.

Dear Mr, Stein:

                     On the last day  of  the  Lake  Michigan Enforcement
Conference (October 2, 1970), mention was made  of the fact that
additional statements would be accepted  for  the records,  if mailed to
you during the following three or  four weeks.

                     There is so much I  would like to say in this
regard - much of it already said by other excellent speakers that day -
and yet I would like to add my part to all the  opinions expressed.  I
thought it could probably be best  said by a  letter I recently wrote to
Mr. Donald C. Cook of the American Electric  Power Company, for whom the
Nuclear Plant at Bridgman, Michigan has  been named.  And  so - am
enclosing a copy of the letter, together with the enclosures I sent to
him - all of which are relevant to this  matter.

                      Please consider these  copies as my  statement.

                                 Thanking you for this opportunity to
help in the matter of trying to save  Lake Michigan for future generation si

                                       Sincerely,
   MRS. J. F. VOITA
   229 North Taylor Ave.
   Oak Park, Illinois 60302

-------
          Copy to - ftr.  f»10aa
                    wr«  ;ioaal r,tt«ad^ijo« all three d*-yt of fch« hn^ri (-; i«
 to  the iftllsados --tomie -sorgy Hl«nts -  hold la Salaraazoo roe&atly,  IM only ^lonned  on
 »tt»rKti:i{* tho seseic-.is the first day, bat fotiad them aa ifeaoinmti.if; that It srfta im-
 possible to stay away,
                                       y-u to Juaw -was  that 1 was doll-htsci with the
•asy yo« oc/wlaofoM t.*» ma^ti-tg » ye»-sr opwjj-ratadednsBs  throughout • ec«J y«;r ^irana
ir. »rfi»t I felt tae tho  right 'c . ~. wlu si" '»  of tba rao;rfci;sg»   For, swrel^', as you eul<2,
f^ero  i»r-*> setters that nrarie.* fUrthar co.it; idaruti it  bofors ths> permit  oo-.ld be
i^^pueti.  •..•«» so ia to be  *»t a turni.'ig polat in the history of btonie «3n-jri*yt wh«n vt»
med to -dve nore  CDAsid^mtion to th»  tot»l imp«iet  an  the savirojiaeiat,  wiich its so
important for th-s ruturn of out o«j-mtry»  purely iss need elaotrioity smd  aauelear B
ew«Bi to bfi the u.ie?wr,  but thnr^ u.ro -flays th»t c^jr air f«»d w\t-ar oun be protected sad
xvo n«n»d to 9R^»i»i8o this to th© fNllwat ia devels^jiHg this oar osarirorwjntal or i s^a wo b«gia.d«^ fco foro« us
      to a ;aoro r«»tlG«ui  ii» tho n*»r future &a Sipj.>roaoh to the resional, aatir«ial 'ad
            Q intermti->r;s*l pjManing of  pO"*«r pl'yst siting thut will ooasidor
                 bftsfe will iicluda eavlrmMasitital effects such a* than**.! «C'£«ets oa
          r s?y3ttjns, fair  pollution problems BS det«rmi"ic<} by reci!>-ig-l
          itl  :s fxod populati.'M daasities,  thatlo.;s &ad ja^ay  othor factors that ar« ncrt now ooiitrRl oon»
               'se in the  aiti'v; of poiior plants, aot to ;«»jntiai the plsuitd::^ of
      raore ir,^;jimttiv©  tn^rfy syat«ns •  * . . » Local th«riafil effects ar«i  a nueh
      <;ror.J;»r ~>robl9;i «ixl arr- alroiidy noWc^blo,   -*e will  havo to Disperse the hoat
      pro^.'ueo*! -»orH eJ'r^fiilly,  Curfcaial,; if in are coinj; to uae our energy to continue
      to hoawfit {!au» »a*3  not harm hi» or his anvirtajwoat, we will h&vo t;>  / ivc fw
      grodtor oo.mideratlon to th*» wiisag«JKont of whftt le now our -?»ste lios-t.  I boll >w
      tMs «r-a bo d-»i« by better slta planning, funti Tdth th» pro^r us® of now »ad
                 olijig tf9chnolof;i«o, such as ooo'i-ig toworo  - of bot;i th*>  wot und dry
           ty - hol<)i ^ po/-M3a, oanals, c«d  other aotnotis."
                         So - 1 fe^)9/
      n  is r^sRiasd an July :ilst.  I hfjpe to bo pr*»"-«nt -o*ki  v*vnt to tii^nk v
         y for ,yo-r o?'rort8 in t/-.!a ar.ttor, fta«l for yc^u*

-------
              Copies to - Secretary he ear              Ur, #ranois T» myo
                          Senator idmurd amide        Oov, '«aa» G. adl liken
                          Senator Philip »rt          Michigan j*pt«, of Natural Useources
                          secretary waiter J. liiekel   Carl L. Kloin
                          Donald C, Cook               Br, Glenn aeaborg

                                                      July 9, 1970
Col, Jaraee T* Ifoite, Jr.
Amy Corps of Ssfceineers,
?, 0. BOX 1027
Detroit, Mich.  48231

Dear Col, Whlt«t

                       !*st week my husband And X visited the nor completed inf orafttion
end Visitor e' Center at th« Donald C, Cock Nuclear flwit, Brtdg»m, Michigan,  There
X learned you havw not yet granted the permits for the proposed temporary harbor, or
for the installation of the pipes for the "cooling qyeteW,  You oan believe X HAS very
thankful to le&rn this fact.

                       &ee*ntly 1 have attended several hearings which have been jaoat
in tore sting, -jjd which X believe represent a turning poiat ir, the environmental nrot«o>
tlon story, which will influence what is to b* dona in the future to stop pollution tu
all its forma*
                       Fir at * the I**ke MiohJ^n 'nforoenent Conference, held in Chicago
on Jfey 7th, established tho fact that th» i'epartraent of the Interior thought it advis-
able to set a new standard in rogard to tharraftl pollution, as followoi  "The
         isaat« heat chall b» added to the waters of Lake Michigan,  Xa no oireaat trill
heat disoharges b* poraittod to ejco»«d 1 degree F* over aabiant at tho point of discharge,
This Trtll preolude th» ae«d for mixing semes*"  X undsratiand that the four states border-
iag on Lake Michigan are now eoneideriag this net? standard, to put it oa a working basis,

                        Second • the abating held ia Balaoasoo, tiiohig&n on Jttne 23,
24 and 25, in \-zhlcJt the ^Socdo  aorgy Coenisai >n oaoduetod & hearing In regard to grant<»
lag a prorisi >oal oporating license to the Consumers Power Company for the opening of Its
BOW ooopletad falisadas ftoolear Pl^at,  Four eaviroi^wntal groups, joitied by the sierra
Glob, together with aersral lasers i^to gaim their sendees vithoat pay, brwght ia enough
evldanoe that Mr* 'jam Jeasoh of the ^tonio Safety and Licensing Board adjoined the tasotiag
after three days of testinooy, sineo he beoarae co-nrl^ced there were too nany issues to be
resolved, requiriisf, furthnr InforavblJa on all types of possible pollution connected with
the operation of the plant*  Therefore ho called for & reoess, without issuing &ny permit,
askine that further data be presontod by all parties involved - the hoarlng then to be
reconvened oa July 21st,  The deciding factor in all this, it se4nat«v«^r the final outoos-« of this Atonic .nor^y
Coanission hearing is, it will also be pertinent to the Done Id C, (took Plant, and we wot
to be sure that the necessary changes in their plans are considered notr*

                        Just this morning ia the news report, *e learned that president
Hlxon has organised a new Federal SBvlronmantal Protection Agency, that -will hnve coo-
plete charge of all Hatters pertaining to the protection of the enviromant.  With all
these new agencies and laws beinf, sot up, it eeoas to us that the Ansy Corps of 'Acineere
should not grant any permits to the Donald C* Cook Pleat at the present; tisw, awaiting
the new standards that will inevitably be set to govern the development of nuclear
energy.  You sorely wo-;ld be doing the Indiana and Michigan hleotric Coop&ny a real ser-
vice cy delaying the granting of these per nit a, so that they will aUoB no costly nistokes
that will later have to be rectified.

                         Wli do hope you will add the Aray Corps of engineers to the list
of organisations who are now actively concerned in all fonts of pollution - and assure you
•ns will greatly qpprooiate your efforts in this regard.

                                                       Sincerely,

-------
Copies to - Senator Philip A. Hart
Michigan %tor Resources Commiseioi.
Mr, Donald C. Cook, Pres. fan. Power Co,
Col. James T. White , Army Corps
July 9, 1970
GOT. 'to. G, Mil liken,
State of Michigan, Lansing, Mioh. 48926

">ar Gov. Millikent

Ifey I preface my remarks by saying that for the past thirty-three years we
have been spending our summers in Michigan . and have come to feel that it ranks above most
any state in the union for sheer beauty and enjoyable features. We have adopted it as our
favorite place to be - and in the very near future hope to make it our permanent home*
Heedless to say, it is the big lake itself that is the most appealing aspect of our lor*
for Michigan and we are very rauoh disturbed by what has been going on in recent months to
undermine this moot ealient and important natural resource*

Ju.rt two wsaks ago I attended a three day hearing at Kalaraaeoo, in which the
Consumers power Company was seeking a license to operate its now completed mlisades Nuclear
Plant, Zt was a most interesting and surprising meeting in the fact that the Atomic Energy
Commission completely reversed its thoughts that it -was not concerned with the thermal
pollution that would result in the heated water to be introduced into the Lake at 28 degrees P.
As you are aware, I am sure, the meeting was adjourned, without the granting of the permit,
in order that more avidonce and factu*l material be produced by all parties concerned -
to be reconvened on July 21 et. There is no way to predict what the outcome will be - but at
least we conservationists feel there is hope}

Now - what I am moat concerned about is that during this moating the fact
wae constantly brought out that the state of Michigan has set no standards in regard to
Lake Michigan* Your attorney general (or it might have been someone who represented him)
gave evidence to this fact and could promise nothing in the way of future regulations*
This is hard to believe in the face of the fact of how important the Lake is to the entire
state in ways that wot Id take pages to enumerate. Via cannot understand the reason for this
- and do hope that in the near future steps will be taken to correct the matter - which is the
reason I am calling it to your attention*

I am sure you are aware of the importance of this matter, when the Department
of the Interior proposad t. limit of no more than one degree rise at the outfall of each
plant. As I understand it* this propos&l must be acted upon by a conference of the four
states involved. Hay v* say, we are hopeful that the state of Michigan will fulfill its
obligation in this matter, setting a state standard as nearly in accordance with this propo-
sal as is pfaotio&lly possible. If this happens, our confidence in the leadership of this
glorious state will be renewed and intensified*

May I suggest that before you and your colleagues come to any definite
conclusion that you look carefully into the regulations set forth in two acts passed by
Congress since April 1, 1970 - both the National Environmental Policy and the Wter Quality
Act, It was facts brought out in regard to these two recent Congressional acts that caused
the Atomic Energy Conmlssion Licensing Board to look further into the matters involved and to
continue the abovo .mentioned hearing at a later date*

The Palisades Plant was designed and built, meeting the standards (or lack
of standards) - and now it is ready to begin operations - and so far cannot obtain the license
to do so. It surely is not fair to the Consumers Power Company or to the Indiana & Michigan
Power Company to plan their facilities under conditions like this. Our sumitwr home is just
a mile south of tho Donald C. Cook Nuclear Plant under construction. They at the present
time are endeavoring to get a permit to introduce heated vt&t&r into the Lake at 21 degrees P.,
and •".£ far as I know the Army Corps of Engineers have not as yet issued the license, What
must be hold it up is the uncertainty as to the laws of the state of Michigan,
1-0 vdll ^ea*ly appreciate your efforts to rectify this situation, keeping
in mind that nothing should be permitted that would in any way cause the deterioration of
Lake Michigan.

Sincerely*

-------
                                                                   14, 1070

Hr» Dem 3d C.  Coda,  Pro aidant,
•fiaoriofta !il@etrlo  power Cor^jfiay, Iae«,
2 Broodisay, Hew  York, 1«Y,  lOOQ-i

Dear ISr. Cooki

                  Ifc tea bean soae time ainoe \» hssve been if} eaetnunioafeion.  So sa»fe
hag happened in  just  the past few weeks - and thore  Is so EJEWA to talk about, 1
knew  *or0 to begin,   Since you hwe b«sa kSnd enough to giro attention to
letters to yo>»,  1  am  again taking the opportunity to talk with you about
first, I tjonltl  like  to toll you about the pl««aitro t» fed  on s reocsat  r&Jay
of beiar: guests of the Indiana and MiehlfWj i^ver Congmny  at your recently atoned
Cook 'tableo? Crater,  Kr.   Pruolasffiiller sent all of us Sa  the aroa a letter oi* JL
tioo a«J M-ay todt atl?nnte/;o of the opportuaivy to l«an» what is boiii^ doas ^«Jd of tho
progress thp.t heta bean a&de.  The Center surely is aw aro<oe-iisrsl gats, uafl tho l**na»
aoaplng is b««utiful --JKI so 4ppronriut« to the OT$!tnt ot i'-aliaaaeo P&rk,
Two moat tmoxp^ct'X?  rteTBlojnonts hnvs cons out of  these
                  (1)  The propoaal that "in no erent tdll hf«t tfi0cjj*.r§os be
to 9-XSG9& 1 dsgr3«  F, rise over asibiont at the point of disohftf ge, thus precludlr'K
need for alxlng  *«9o»''»  • this beiag propoaed by  ti» Bepartrneafc of tSto interior,  AS I
under cfearstl it, the  ftair  statoe bordering on lutea  Miohigan ore now to the process  of
ew&luofei&ij tl\ia  proposal In the hojw of arriving  at a worJaable solatii,n, 1« dstemlning
jusS vAat hiss  safe, porsisiagabla tessgjeratur* ahould  be for water returned to the?
fhls -sdll in oil probability tftk® R,t lo^st tfljt to nine nusjths to aoooaallah,  So  -
     huvr to «ait to  SB© whut oorasg of
                  (2} Tho a0otia^ at Kalomaaoo, oo£id«otad by a .:;o4^rfl o.? tfoe  taaie
          t,  in  regard to thfj grtuit'ng of a liconee to op-Tat© to the Congisaers i*£r «r
         for  its now ocrapleted plaint at faliaadea  - prodtwxx* a moot aaaapeetod  txtaujt -
a complete rsvcreal of a sfciiatl"tho .Atonic '-acrcy  ConRlaaiiin has t«*4sea la the gnot,   AS
t«Rs sfcatfld by tJwt Board wipwatgdly at t:« opoaiag of the meeting* it oae act otaioeraoij
with the probl*«3 of "'tharaal pollution'1 - but at  the end of tiro© dayo a reoesa \iaa
oallod so that  further srlrionoe ootild be brought  in by ail parties oc.'soeriio^,   I ea
onolosing a  oow«sap«rr report -wtfdoh covors fcfk> throo day hearrLig -mito adeqnatoly« but
wish to  aay  furtbar, that tho latter who gpvo bis oervieas without ohairge, pros««i*-,Gd his
oese for the esnaarrotioa Sf*s£>« in a brilliant manor, les^i.iG no doubts thut  tte racozatly
passed Congressional Acts (both Sho -wriromonrtal Art anfl the  *ktor  ^ii-lity Act)
a ooajjl:-te review of Btanelards thnt hsw» boon f®lt adot^uate Ln the past,  AJ-d  so, ae
sfcatoS above, tho haRring ^as recessed after three days, to 00 reooiWsjaiod CM July
I ho;>e to be present at ttot tine,
                   With the above la mind, yfca oan toMgl-ie ho-,? aurpris-^ %afl
TW all *«re to learn that th» Angy Corps of  an^iaews just within the aasfc week ma
granted tho t"X> panaits *loh i««pe boinc oo:ite8to<< by rarity grow^a aw? iixlivlduftle !.•« this
area . In i-Js®  face of th* fact that so wuoh  is developi:is &!»>?,, tsio lino Just at tMs
       It aeeras to en thi« is wost shorU-oi^hted  at a tins vjh>?n ncn7 ofcf -.^fiJTc' s &re in the

-------
                                   - 2 .


process of being set * aad before all the evidence it in,  For* surely, i&at happen*
at the aeettng la Ealaaajjoo aext mek all! apply to the Donald C. Cook Plant as well,

                A* I an sure you are aware, president Utxon le at present setting up
a a*w InnriroasMotal Protect Icn Agency, dravrlng the mt.Jor eleraonte of pollution fighting
agencies under one unfcrella, for a concerted battle to clean up the nation' 9 air and
water,  Sorely this aew a^eacy will bo above the Anqr Corps. if it is to be effective at
all* and at last the long history of horrible instances of envlranaozital deterioration,
which has rightfully bean pluoed At tha doorstep of the Corps, will be brought to an end.

                2 ftj* asking that you give consideration to the copies of letters X have
written to various concerned people - especially to the letter to Hr, tea Jeneoh, la
nhfteh I how> quoted frca a roeeat speech by Or* Glenn Seaborg, which bringe out th»
fast that be too is baooatne «m*re that new standards i»v« to be set, as fppiied to
atonic energy, to protest the enviroas»nt«

                Then •> there is the article about new plans to u*9 the hot water
of Suolear Plants * a study being eoadooted at the Oak Kidge flational l«tbore.tary *
                                t
whioh  show that new and oongtructire mays are being earisioas4 for the use of «mat is
now "wast,® heat1**

                X know you do feel that there trill be ao ham to the take by adding heated
water.  But from all the eridttwe I htvre heard* there is «wmh fooling «ad knowledge to
the ooatrary.  The Open Unds Project (entirely funded by oonoerasd buainass aea and
individual aitisens) begpn in a siall «ay, being interested ia preserving the eaviroaoent
in  the Ghioago area, KM now, just irtthia the last few troek's, extending their aotivitiu*
and o'MCernfl to the satire Lake Michigan area, including all four states bordering on
its shores, «o that with this larger organization they oaa becows more effective ia
their efforts*  they are t»ry «wh oonoerned with the thenaal pollution aad are putting
all their  efforts and  wiantlfio toowledgs to work to stop it.
                As you aight r«iaeaA>er, m haye spent over thirty euoraers on the late
in this area (Just & Mile south of the Cook Plant) sad I have seen the iafee constantly
deteriorate,  '** now hnw algae most of the tine * ss-wthinc t^t ttas onJmown a few
years ago - all due to the aisttae of the l^e» by industries ^ad isunicipeJLiti@s over a
long period of tins*  So, the adding of "heated wator" is <& real danger* especially a»
it is ridded to tho pollution that already ia present in leJco Miohi^o*  Dr» Ayros hiaeolf
admitted at the open hearing in Bridgpitt this spring that there would be algae in the
immediate vicinity of the Pl&nt and whan pressed for <*a anewor as to hotr far, as said it
wiltf probabl;; cover & adle or two eftoh T»y.  This is terrifying to us who are within
that vicinity, but also for w^ny others mho coma to the beaches for relaxation and
reoroation,  Ia the past two sunasrs ne havw had days wh0a the algae «ag so severe us
had to stay eaay from the lake until the condition iiaproved*  .« would read ia tie
paper - ^Donuld C. Cook, president of /werioaa Fo*r Company, has node the decision to

-------
• 8 -

|»~farther * that
«A.th all that has been happening in the past few wok* * all the reeest f ladlnge anA
rrriead theorise that has been of concern in high place** from President Nixon on daw
through the various bureaus ftnd ocnaisaions ia the goveraasnt - you will proceed aoro
tloety end with aore thought in *11 thcdt is being pltMtasd for the Donald C, Cook Plant*

X do hope that sone tin* tie Right aeet* As X told you in a previous
letter, X had the pleasure of nesting several of your toy sen from the Hew York sjrea,
«*xan they were present at the publis hearing at Brldg«a» this spring - and so &» hoping
that in sosao future visit in our area, it ndght be ny privilege to meet end talk with
you* You are cordially invited to be a gn^st in our hotae in Oanewoodl, on the l
-------
An article from "The Rational Enquirer*
1BW PLOT WILL USE HOT WATER WASTE CF NUCLEAR PLANTS TO HEAT AND
coca. CITIES
Instead of polluting lakes and streams and klll& g fish by the thousands
as it does today, the hot water expelled from nuclear power plants could be of vast
benefit to nankind, a noted atomic eeientict says*

It oeuld be used to heat and eool entire cities, maintain huge greenhouses
for food crops, and even help solve other pollution problems such as waste disposal.

This is the picture painted by Sanu&l E. Beall, head of the Nuclear Reactor
Division at Oak Ridge national laboratory in Oak Ridge* lean, Beall says much of the
energy generated by atomic reactors is lost in the water used for cooling then. By
utilising this wasted power, he told The Qdqulrer, industry eould turn a potential
environmental ft aaster into a blessing*

With this in mind, he noted, a new division of Beologiaal Sciences has
been set up at the Oak Ridge National Laboratory to search for ways to turn the
liabilities ef nuclear energy into assets* "A large eity could be heated and cooled
with the throw-away heat from nuclear plants, and it could be done more cheaply than
with electricity", Beall said, B» explained that the hot water could be piped into
the city and used to operate heating and refrigeration equipment*

The hot water could also be used to heat giant greenhouses, thus creating
additional food supplies stt to feed entire cities, Beall suggested* "With a constant
flow of hot water, temperatures and humidities could be regulated in greenhouses to
greatly increase the productivity of existing acreage* By using the land All year round
for three separate crops, one acre of land under such a greenhouse could produce up
to 600,000 Ibs. of tomatoes, for example - or 10 times ae much as an average outdoor
acre."

The otherwise wasted heat from nuclear reactors eould also be used to
evaporate waste water in sewers, Beall said. Then the purified water produced by
the evaporation eould be recycled into water treatment plants for human consumption
- without costly purification procedures*

A team of 60 scientists, headed by Dr. Stanley Auerbaoh, will work in
the now Ecological Sciences Division at the Oak Ridge National Laboratory. Their
findings will be used in planning all types of industries in order to provide maximum
benefits with a T^M""* of environmental pollution*
-------
H J DUNSMORE
DIRECTOR-ENVIRONMENTAL CONTROL
October 26, 1970
Mr. Murray Stein
Conference Chairman
Federal Water Pollution
Control Administration
Washington, D. C. 20242

Dear Mr. Stein:

Third Session - Federal Conference
on Lake Michigan and its Tributary Basin

United States Steel Corporation wishes to have the following
statement included in the official record of the Workshops on Lake
Michigan held in Chicago, Illinois, on September 28 - October 2, 1970:

Three plants of United States Steel Corporation, namely,
South Works , Gary and Waukegan Works , are located on the shores of Lake
Michigan and would be directly affected by standards limiting temperature
in the waste water discharges from these plants.

Although the temperature and volume of these discharges are
substantially lower than those of the power industry, a requirement of
recirculation or other closed system method to control heat would present
substantial problems to United States Steel Corporation as well as , we
expect, to all other industry.

The general tenor of the scientific testimony at the Conference
indicated the lack of substantial knowledge of the present and future
effects of thermal discharges to Lake Michigan, but that significant
study programs on the question are in progress. In light of this we
recommend maintaining the existing standards until such time as these
studies and others demonstrate the nature and extent of needed change,
if any.
Very truly yours,
HJDrujw
-------
AMERICAN ELECTRIC POWER Service Corporation
2 Broadway, New York, N. Y. 10004
(212) 422-4800

October 2?, 1970
To The Conferees
The Lake Michigan Enforcement Conference
Mr. Murray Stein, Chairman
Mr. David Currie
Mr. Thomas Frangos
Dr. F. T. Mayo
Mr. Perry Miller
Mr. Ralph Purdy

Gentlemen:

At the Workshop Session of the Lake Michigan
Enforcement Conference on September 28 - October 2, there
was some discussion of the thermal bar. The "White Paper",
Physical and Ecological Effects of Waste Heat on Lake
Michigan, based much of its argument on the occurrence of
substantial, long-period build-up of temperature and of
chemical concentrations behind a barrier at the "thermal
bar" that prevented mixing. Attached is a discussion of
this concept prepared by Dr. John C. Ayers.
TAM/fkr
(attachment)
Very truly yours,
T. A. Miskimen
-------
Comments on the Thermal Bar as a Barrier to Mixing

John C. Ayers

The concept that the thermal bar is a real physical barrier to horizontal

transport and mixing appears to have had its origin in misinterpretation or in

misapplication of the conclusions in the papers of Rodgers (1965, 1966, 1968).

As I read these background papers I find Rodgers to be writing very cautiously;

the strongest statement that I find in these papers is in his 1966 paper where

he says on p. 371: "In the case of Lake Ontario there appears to be some

validity to the concept of the thermal bar as a barrier." It should be noted

that the wording is: 'appears to be some validity'; this is no statement that

the thermal bar is a barrier.

The first bald statement that the thermal bar is a barrier to horizontal

mixing and transport is in the' publication "Lake Currents" (Lake Michigan Basin)

by the FWPCA, Great Lakes Region, Chicago, Illinois, November 1967. In this

publication there is a strange drift from a sensible discussion of the annual

temperature regime of Lake Michigan on pages 19 through 21 (in which it is

pointed out that in spring the thermal bar as described by Rodgers may develop),

to a firm conclusion on p. 353 which says: "Thermal barrier conditions during

the fall, winter, and spring period limit the outward extent of the effective

mixing volume. This factor appears to be responsible for unusual solids build-

up in the nearshore waters during this period."

It appears that the latter conclusion has been picked up by the USBCF in

the preparation of their "White Paper" and that it has been the basis for their

definition of an inshore zone that does not mix with the rest of the lake.

In view of the FWPCA's conclusion that unusual solids build-ups occur in

the nearshore waters in fall, winter, and spring, it is proper to test their
-------
-2-
hypothesis by examining available independent data for evidence of unusual

solids build-ups. The suitable long-term data available are those of the water-

treatment plants on the perimeter of Lake Michigan. These plants draw their

water from the very same nearshore waters in which FWPCA found or postulated

unusual solids build-ups. If the thermal barrier conditions in fall, winter,

and spring do limit outward mixing, the records of the water-treatment plants

should show higher levels of "solids" in those seasons. Indeed, if the thermal

barrier condition is continuous throughout the fall, winter, and spring seasons

(as the FWPCA implies) the record of "solids" in the nearshore waters should

begin to rise in fall, continue to rise in winter, and reach a maximum sometime

in spring before "spring storms destroy the thermal bar."

I have examined the available records of longer-term conservative (not

influenced by biological activity) "solids" at Michigan City, Indiana; at Gary,

Indiana; at Milwaukee, Wisconsin, The results are presented as annual graphs

of the available "solids" parameters in Figures 1 through 4.

Figure 1 presents the results of samplings by the State of Indiana for

specific conductivity a"t the Michigan City water plant for the years 1957-1967

inclusive. There is a small rise in specific conductivity in the months March

through May which may or may not be significant, but certainly there is no sub-

stantial rise in this "solid" beginning in fall, continuing through the winter,

and culminating in a maximum in spring.

Figure 2 gives the levels of chlorides (as chlorine) in the Michigan City

intake records for the years 1957-1967 inclusive. The graph shows no difference

in chlorine in the nearshore water from year's beginning to year's end. That

the contribution of chlorine from the early-spring melt-off of road salt is not

detected by the local water plant indicates that there was substantial escapage
-------
-3-
to the open lake and that the spring thermal bar at Michigan City was not

operating as a collector of pollutants.

Figure 3 shows the annual distribution of total dissolved solids at Gary,

Indiana, for the period October 1959-September 1962 inclusive. Levels of IDS

in January, February, and March are slightly higher than for the rest of the

year, but there is no evidence of a rise beginning in the fall, continuing

through the winter, and culminating in a maximum in spring.

Figure 4 depicts the year-round condition of total dissolved solids at the

Milwaukee, Wisconsin, water plant from August 1960 through September 1962.

Here the data show no change from year's beginning to year's end. There is no

evidence of a collection of "solids" behind a thermal barrier in any part of the

year.

In summary, the independent data available with which to test the FWPCA

hypothesis that thermal barrier conditions in fall, winter, and spring collect

unusual levels of "solids", do not support the FWPCA hypothesis.

References

Rodgers, G. K. 1965. The thermal bar in the Laurentian Great Lakes, pp. 358-363
in Proc. 8th Conf. on Great Lakes Research. Univ. of Michigan, Ann Arbor.

Rodgers, G. K. 1966. The thermal bar in Lake Ontario, spring 1965 and winter
1965-66. pp. 369-374 in Proc. 9th Conf. on Great Lakes Research. Univ. of
Michigan, Ann Arbor.

Rodgers, G. K. 1968. Heat advection within Lake Ontario in spring and surface
water transparency associated with the thermal bar. pp. 480-486 in Proc.
llth Conf. on Great Lakes Research. Internat. Assoc. Great Lakes Res.
Ann Arbor, Michigan.
-------
SPECIFIC CONDUCTIVITY (^mhos/cm)
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-------
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-------
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
L. P. Voigt
Secretary

November k} 1970 MA.OISON, WISCONSIN 53701
Mr. Murray Stein
Assistant Commissioner for Enforcement
Federal Water Quality Administration
Department of the Interior
Washington, D. C. 2021*2
Dear Murray:

Attached is a copy of a statement from Senator Proxmire which
he wishes to have entered into the record of the Thermal Pollution
Workshop of the Lake Michigan Enforcement Conference.

Could you take care of this, please?

Very truly yours,
D. J. Mackie
Assistant Secretary
DJM:dgb
Attach.
-------
. ' i, ,',, V. X , CHAIRMAN
i--Q._i iG, MO.
u.^ I G. .'.CC^..t_Aw, PA.
UIA,- i>. Wi-.N/ L-,. N.J.
J. cROC.C J3, Ti-.vJS.
IJL, --• C. CO.N.'.c.LL, JR., N.Y.
HIO
EXECUTJVC D,fi£CTO«
JOINT ECONOMIC
(CREATED PURSUANT TO sec. sU) o;-- PUSLJC LAW ac*, TSTH CONGRESS)
WASHINGTON, D.c. 20510
JOHN jiW- s,yi/V', AUA.
J. VV. Klju'-rtlGHT, AKK.
HcHMAN E. TALMAOGL, GA.
STUART SYMINGTON, MO.
ADRAHAM IVlJllCOrF, CONN.
JACOB X. JAVITS, N.V.
JrtCK MILLAR, IOWA
LEN B, JORDAN, IDAHO
CHARLES H. PERCY. ILL..

JAMES W. KNOWLES,
DIRECTOR OF RESEARCH
October 23, 1970
, L. P. Voigc, Secretary
P.O. Box 4-5
Wisconsin 53
Znclosed you v<-lll Tina my stater,i3n'i prepared for the
record, of the Lcike i.llcn:'.3'an Pollution Conferance. The subject
of uhe statement, as you know, is ther.aal pollution and
i;o r.ach for your cooperation in this ratter.
-------
Statement by Senator William Proxmire

WASTE HEAT AND LAKE MICHIGAN

Waste heat is rapidly becoming one of this nation's most

serious sources of water pollution. In order to solve the problems

associated with waste heat, we must fully understand its causes, effects

and controls.

Tremendous amounts of water are used each year by industries

for cooling purposes. In fact, according to the Federal Water Quality

Administration (FWQA), almost one-half of all water used in the United

States is utilized for cooling and condensing by the power and manufacturing

industries. In I$6k, this amounted to about 50 trillion gallons.

How Thermal Pollution Can Affect Lake Michigan

The potential for serious ecological damage to our nation's water

resources as a result of the discharge of industrial waste heat is readily-

apparent when we examine Lake Michigan.

Although more research is needed on the ecological effects of waste

heat, the evidence gathered to date substantially demonstrates the adverse

effects of thermal pollution. Let me describe two of these effects in relation

to Lake Michigan.

First, waste heat can speed eutrophication — the process by which

a lake chokes itself to death. The rate of eutrophication is controlled

primarily by nutrient supply and water temperature. In Lake Michigan, indica-

tions are that nutrients in the inshore waters are approaching levels commonly

found in the central basin of Lake Erie. Lake Michigan inshore waters receive

a substantial and increasing load of nutrients in the form of nitrogen,
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phosphorus, and other fertilizing agents from domestic effluents and

agricultural run-off. If nutrients are not sufficiently controlled, the

inshore waters of Lake Michigan will attain conditions of algae pro-

duction similar to those in Lake Erie. When these conditions are reached,

temperature becomes a very important factor. HLue-green algae, which are

especially responsive to higher temperatures, will increase in direct

proportion to temperature increases. The process of eutrophication will

be well on its way. Lake Michigan will begin to choke itself to death.

Second, evidence gathered to date also demonstrates the adverse

effects of thermal pollution on the fish life of the lake. The role of

temperature is an important one in the growth, survival and abundance of

fish in any water environment. All available information indicates that

each fish has specific thermal tolerances. These thermal tolerances vary

from life stage to life stage. When the limits are exceeded the organism

functions at reduced efficiency and may ultimately die.

As the U.S. Pish and Wildlife Service has pointed out, the timing

of natural events is essential for the perpetuation of Lake Michigan coldwater

aquatic life. Any waste heat influence which would interfere with this

natural timing places the survival of this aquatic life in jeopardy. Evidence

indicates that only slightly elevated temperatures may be critical in the

life history stages of Lake Michigan species.

Power Needs and Thermal Pollution

Each year this nation's power needs have increased. The public

has demanded greater and greater amounts of electric power. And, as a

result, power industries have been called on to produce the needed quantities

of electricity.
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The increasing demands for power over the past decade has meant

increasing amounts of waste heat to be disposed of. Thermal pollution

has been a direct result, then, of the public's demand for greater amounts

of electric power.

In view of the fact that the electric power industry accounts

for about 80 percent of all cooling water used in this country, the best

single index of thermal pollution potential lies in projecting future power

production.

POWER PRODUCTION

The demand for power has increased steadily since the turn of

the century. For the past 30 years, power generation has increased at a

rate of 7.2 percent annually, virtually doubling every 10 years. This has

necessitated a doubling of electric power facilities each decade. This

trend is expected to continue, and possibly accelerate, through 2000.

The following table prepared by the FWQA indicates the amounts

of electrical power used in certain past years as well as projected national

requirements through 1985:

U.S. Electric Power — Past Use, Future Requirements

Year Billion KWH

1912 11.6
I960 753
1965 1,060
1970 1,503
1975 2,022
1980 2,75^
1985 3,639

Power is usually generated by hydro- or steam-electric plants,

with the latter process requiring cooling water for waste heat removal.
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There are few sites remaining today for hydro-electric stations, so the

power industry must depend more and more on thermal power generation to

meet future needs. Presently, thermal plants produce approximately 80 percent

of the electricity in the United States. Predictions indicate this figure

may reach 92 percent by the year 2000, when two-thirds of the plants may

operate on nuclear fuel. Thus, thermal plants will continue to gain a

larger portion of a steadily increasing market for power. Waste heat

production will increase proportionally, which in turn reflects the

increase in waste heat disposal that we must accomodate.

The waste heat output from manufacturing industries, such as the

chemical, petroleum and paper industries, will also increase in the coming

years. The cooling facility needs of these industries are expected to

increase at a ^.5 percent annual rate, compared to the 7*2 percent annual

increase expected by the power industry.

Lake Michigan Power Production

As with the rest of the nation, power demands have increased in the

Lake Michigan area. In fact, it is predicted that more power facilities

will be installed in the Northeast and Midwest in future years than in any

other section of the United States. Nowhere are these plans for expansion

more apparent than on Lake Michigan. And, as a result, waste heat effluents

from the power industries along Lake Michigan will increase.

According to a study recently completed by the Department of Interior,

the doubling of power capacity each decade means that the Lake Michigan

megawatt capacity will increase at a geometric rate. Cooling water require-

ments will also increase at a similar rate (almost fourteenfold). Heat
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addition from steel and municipal sources is expected to increase by

63 percent by the year 2000. In total, it is estimated that waste heat

addition to Lake Michigan from these sources will increase from 1*0 billion

Btu's in 1968 to about ^31 Btu's in 2000. Thus, at the predicted rate of

increase, the amount of waste heat dumped into Lake Michigan by 2000 will

be 10 times larger than it is today.

In light of the environmental affects of thermal pollution which

I mentioned earlier, it is obvious something must be done to control the

massive amounts of waste heat that are predicted for the future.

Waste Heat Limitations

In its first annual report, issued last August, the President's

Council on Environmental Quality stated:

A strong and consistent Federal policy
should be developed to control thermal
pollution. Criteria should be upgraded to
assure prompt and successful negotiations
with the States on water quality limits from
thermal pollution...

I fully support this recommendation by the Council. It
is in the public interest to upgrade water quality standards now.

If we wait too long, correcting the ecological damage caused

by thermal pollution may be extremely difficult, if not impossible.

According to the FW^A, the adoption of alternative cooling

systems to control heat waste discharges would be economically feasible.

The increased costs of the monthly bill associated with adopting alterna-

tive cooling systems, based upon an average family electric bill of

$9«^ a month, would be:
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wet mechanical draft tower .....

wet natural draft tower

cooling pond

spray canals

dry mechanical draft tower

dry natural draft tower 9^

Conclusion

Waste heat discharges can be harmful. It is within our

power to control these discharges. And it is economically feasible

for us to do so. I hope that the federal government, working in

cooperation with the states, can act on this without further delay.

* U. S. GOVERNMENT PRINTING OFFICE : 1971 O - 422-409 (Vol. 5)
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