THIRD SESSION
                                    RECONVENED IN
                                    WORKSHOP SESSIONS
                                    September 28, 29, 3O,
                                    October 1,2, 197O.
                                    Chicago, Illinois
                                            Vol. 5,
    Pollution of Lake Michigan
    and Its Tributary Basin





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




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

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

CONTENTS, Continued

John Chascsa                                          2289

Harold B. Olin                                        2298

A. J. Boehm                                           2304

Mrs. Paul Kaefer                                      2305

Mrs. Robert Herlocker                                 2306

James Sloss                                           2303

Michael R. Rouse                                      2309

Mrs. Maynard J. Seidraon                               2310

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


          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.


          MURRAY STEIN, Assistant Commissioner for

          Enforcement and Standards Compliance, Federal

          Water Quality Administration, U.S.  Department

          of the Interior, Washington, B.C.


          CLARENCE W. KLASSEN, Director, Illinois

          Environmental Protection Agency, Springfield,


          PERRY E. MILLER, Assistant Director, Stream

          Pollution Control Board, Indiana State Board

          of Health, Indianapolis, Indiana.


          DAVID P. CURRIE, Chairman, Illinois Pollution

          Control Board, Chicago, Illinois.



          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.


          Thomas E. Dustin, Executive Secretary,  Indiana

Division, Izaak Walton League of America, Fort Wayne,


          A. Joseph Dowd, Assistant  General  Counsel,

American Electric Power Service Corporation, Two  Broadway,

New York, New York.



           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,
           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.


          H. R. Thoke, Wisconsin Southeast Chapter of

Trout Unlimited.

          The Honorable Robert E. Mann, Chairman, Lake

Michigan and Adjoining Land Study Commission, Chicago,


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

Kalamaaoo, Michigan.

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


          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,


          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,



          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


          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,


          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.


          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,


          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.



          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.


          Mrs. Maxwell McCrohon,  Crete,  Illinois.

          Mrs. Dan Harper,  Crete,  Illinois.

          The Honorable Robert McClory,  U.  S.  House

of Representatives, Washington, D.C,

                       Murray Stein

          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


                      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'


                      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


          "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."


                      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


                   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



cc: Francis T.  Mayo
    Ralph  Purdy

       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

       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.

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

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.
                                            '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

                      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?




          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


                      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


                      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


          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


                      T. E. Dustin                  1734

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-


          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

                      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


          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


                       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


          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

          Resume of Statement for the Record by

                  JOHN £. BARDACH, Ph.D

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

                 COL. WILLIAM G. STEWART

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

                    In the Matter of


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

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.

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


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.
           (c)  A change in conditions so as to favor less
                desirable fish species such as carp and
      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.

                "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


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


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

      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


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.

Research Experience

     Sensory physiology, especially cheuical and temperature senses
of fishes:
1968-'  pilot study of effects of thermal pollution on behavior of
1957-1958:  Chemical senses in communication and social behavior of
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
                          EXHIBIT A

professional Experience and Honors

Re-introduced instruction and research in Limnology,  Iowa Lakeside
     Laboratory, 1950-1953.
Director, Bermuda Government Fisheries Research Program,  part-time,
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),
Time-coordinated behavior of fishes, senior investigator  (NSF)
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


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):

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



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,

(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

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,

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

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



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.

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


                      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


          It is time those who would use our waters for

septic tanks and stewpots prove their actions will be


          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


                      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


                      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,


                      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


                      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


          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.


                      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


                      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


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

l'£olQtt«l William Stewart
                                        ecHMMrrrce ON COMMON*
                                        WASHINGTON, D.C. 20510
           Army Corps' of Engineers"
       Imrk Street \.\ •.;.    •   '
    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. '  ••


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.


     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

     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.

     We therefore support the view that recommends no increase in temperature
of the waters of Lake Micigan.


     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

     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.


     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.

(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

(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


                      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.


                      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

                      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


                      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


          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


                      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


          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


          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


                      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


                    Mrs. J. F. Voita

of Senator Ralph Smith.


                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


                     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?


               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


                      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

                    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


                     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


                     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

                     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


                     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?


                     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


          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



                    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,




          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


                      F. Pierson

to stress a single point and to ask some extremely simple


          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.

                      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


          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


                      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

                      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

                       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


                      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


          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?




          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


                      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


          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


                      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


          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


                      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)


                      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.

                      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


                      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

                      A, Pancoe

the heat in under the 1-degree standard.

           MR. STEIN:  Are there any other comments or


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

           MR. PANCOE:  Thank you.

           (Mr. Pancoe*s presentation follows in its


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

   AGAINST VIOLENCE          _   ^     ^v          ^   NORTH  SHORE AFFILIATE

              TO THE   ""  


              TO THE


               BOX 84

                                                    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
    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



             TO THE


              BOX 84


                                                       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
      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
      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
  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
                        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

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



              TO THE


               BOX 84

    "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




              TO THE


               BOX 84
                                                                            PAGE 2
                         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
                             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



               BOX 84

         •'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-
                              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
                              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

 Table  2.   Lethal  temperatures for some Lake Michigan fishes.
STDCCICS Acclimation Temperature ' (°

Channel Catfish-

Lake Herring—

Lake Trout-'

Coho Salmon-

Yellow Perch

Gizzard Shad—


77 Summer^-/
77 Winter^
F) Lethal Temperature (fFj
feL .
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

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

Sept .



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  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.

Cons, hhl                                              November 6,  1969
Fishery .Resource Management

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)

       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.


                      Mrs. L. Botts

          MR. STEIN:  Mrs. Lee Botts.



          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


                       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


          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

                      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


                      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


                      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.


                       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

                      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


                      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


                      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

                      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


                      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.


                      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


                      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


          There is one point on which I find myself in

agreement with the power companies and their consultants


                      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


                      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

                               33rd Annual Meeting
                             University of Rliode Island

                              August 26 - 29,  1970

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

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

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

   in nutrients and the planktonic diatoms of Lake Michigan.	^^^
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
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

                             27 May,  1970
                          Fragiloria  crotonensis

                          Tabellaria  flocculoso
                          Stephanodiscus  hantzschii

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 LUDINGTON
,-ig. 2.  inshore-offshore differences in concentrations of silica, total Phosphorus and non-

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
                          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.

  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,

  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.

                                                                     	'	» 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

Tcrta] P
Dtemlved P
Particuthta P
Af, fwibigittf

MI fc
                                 NOTES  AND COMMENT
  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.

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.
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
	. 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.


                      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


          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.


                           L. Gomes




          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


                      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


                      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


          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-


          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


                      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


          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-


          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

                     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.




          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


                        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


                        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


          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.


                      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


          When I took these pictures to Earth Day programs


                      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


                      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?

                       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


          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


          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.


                      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


          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


          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


                     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


          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.

                       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


          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


          MR. CURRIE:  Miss McKee, have you found any

evidence of harm caused by heat inputs in Little Traverse


          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.


                      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


                      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

                     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-


          MR. FETTEROLF:  What is the draft of that boat,


          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


          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


          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



                      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

                     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


                     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


          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


                     W. J.  Scott




          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


                     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


          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


          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

                     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.)

                   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


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

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
     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


clearly define the principle upon which future decisions can be

     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.

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,
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-
Treasurer of American Microscopical Society, 1953-56.
Executive Committee, American Society of Limnology § Oceanography,
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.

                                                     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):

/jidsi'son,  Richs.i'd 0., 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.

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

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
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  

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.


                       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.




          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


          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

                     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


                      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.


                       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,


                     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

                     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

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.

                      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


          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

                      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


                      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-


          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


                     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


          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


          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

                     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

                       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


          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?


                      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-


          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

                     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


          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,


                      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?

                     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


                     J. E. Bardach

about 1? to 1$ degrees centigrade — to raise in an intensive

fashion a million pound of trout.  So there are possibilities


          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


          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


                     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


          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


                     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-


          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

                      Mrs. L. Botts


          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.

                                         FACT SHEET              September,  1970
Plant Name,
Cooling Water, *
Gallons /Day
Permit Date
Ci- *ent
2 units
Zion, 111.
Edison _,_.,
each unit
1 billion
each unit
2600 ft.
760 ft.
Much pub-
lic opposi-
tion, 2
Donald Cook
2 units
Indiana &
Power Cg^
1 billion
each unit
2200 ft.
1200 ft.
21 degrees
1 lawsuit
pending on
Point Beach
2 units
Two Creeks
Electric &
each imtt
500 millioi
each unit
1750 ft.
150 ft.
tion filed
to oppose
1 unit
South Haven
3500 ft.
Canal to.
28 degrees
on lake
since June
1 unit
1600 ft.
220 ft.
1 ,~,
1 unit
Harbor. Ind.
Service Co.
No permit
Big Rock
_jmiUion. .
1600 ft.
No permit Canal
application > to lake
20 degrees
20 degrees
Announced j 1960
Feb., 1070 I
Pioneer j
Service & Sargent-
Engineering Lundy
house <
Five j
miles !
Two Creeks
schedule '
Nat'l Park,
public oppo-
sition befor<
plant on
water _
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.

                     Hon. R. E. Mann

          MR. STEIN:  Thank you.

          May we hear now from State Representative Robert

E. Mann?





          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.


                       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


          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.


                     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


                     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


          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


                     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


          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

                     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

                       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

                       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


          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,,)


         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

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

              Lake Michigan Beach Zone V. aters:
              Vjriatio/is in Temperature Arising
                    from Natural Causes
                  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,

   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.
                         C. H. Mortimer,  Director
                       Center  for Great Lakes Studies
                    University of U isconsin — Milwaukee
                        Milwaukee, V>isconsin 53201
         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).

        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.

the actual temperature changes must nave been more rapid than the figure
        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.

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


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.

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
        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
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.

         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.
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)









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.

       Lake Michigan: Estimated thermal influence of electric power
                  generation for the years 1970-1990, II.

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
(iii) percentage of mean out-
flow (46 x 103 cfs)
(iv) percentage of natural
annual evaporation (26 in)
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
* 8% of whole lake surface
^assuming all heat dissipation is through evaporation (590 g-cal/cm3  at 10°C)

                            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

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.]

w c
C ?H
TO 0)


  C. C
  rt 0
o. o o;

S §^
"I « 13
 0)  !H  I



                                                       i I I i i i i i i i i i i i i

                                                      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
                                                   SYNOPTIC  3ZI
                                                   9 AUGUST  1955
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.

Figure 4.

                       kilometres  from  Milwaukee  breakwater
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.

                        Kilometres  from Milwaukee  breakwater
                           40     .     6O          8O
                                                         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

kilometres  from  Milwaukee  breakwater
   4O     .     60         80
                                                                          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.


	 1 	 L_

1 . . . 1 , , , 1 , _.

1 , , ,
] " ~:

i i

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).

                 The thermal bar.
     Forel'e concept
                LAKE  ONTARIO

                                                                       Surface Temperature

                                                                             i C«nhgro4<

                                                                          Junt 7-9.1942
28-30 JUNE, 1965
                                                             • -V1 '   -'"' '   fc
                                                               si" v-   / '  MA
                                                               ,y»}  ,,'  i  ,,/•
                                                 Figure  9.  The thermal bar.


                     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


          MR. STEIN:  Dr. Sobota.



          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


                     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


                     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.

                     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

                     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

                     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


                     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


                     J. F. Sobota


          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


                     J. F. Sobota

to the Department of the Interior.  Is this the type of

inaction to be expected from a responsible representative


          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.


                     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

                     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


          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


                     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

                     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


                     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.


          Dr. Sobota, I understand you are a medical


          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


                      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 —


           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,


           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


                     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


                     J. T. Sobota

Lake Michigan basin was also some of the reasoning for the

intervention in that particular plant by conservation


          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


          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


          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


                       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?


                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.

                     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


                     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


          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

                       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

                       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


                       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


          "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

                     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,


          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.)


          (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


          (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



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


          (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.)

                           STATEMENT TO THE FEDERAL
                 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

                               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

    Strict enforcement of the strictest standards will be the only way

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

                     Mrs, L. Erickson

          MR. STEIN:  Mrs. Erickson.



                      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


          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


                     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


          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

                     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


          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


          The Point Beach Park is also near to the Point

Beach Forest in Wisconsin and isn't a very good help for

that area.


                      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,

                      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.





           MR. McCANDLIS:  Ron McCandlis.,  I live at  5619

Clato Street, Kalamazoo, Michigan.  I am President of the

Michigan Steelhead and Salmon Fishermens Association.


                     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


          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

                     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


                     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

                      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.



                   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


                      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


                      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

                      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


          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

                      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


                      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.')


                      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


                      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


                     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

                     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


                     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


          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


                      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


           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*)

               Lake Michigan at
               MANISTEE, MICHIGAN
                  Presented by
              Miss Dana Schindler

                MANISTEE, MICHIGAN
                  PRESENTED TO THE
                     FOUR STATE
           September  23 - October  2,  1970
                       at the
                    SHERMAN HOUSE
                   Chicago, Illinois

 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.


 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


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

       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

                                                                  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

 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,


 - . U.' •- v '- '-• •(<>• •- • - '-'•'
 F% Winchester


             K l f'LloIT. J  A MtrtDZINiKl. Z R. MILLER, L. VAMIK HORS1. A. O. HU5IVCDI

Client :
j,t>ri.-<- ' U-L v/V

Water - Waste Water - Soils

	 _        Project No.

                  Date:  •?*
                                         Chemist:   2) A) ' /)g

              1 £
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 ie^'-r'jsg, questioning, and i^.l-c;:? wslt-itigo   Ssiia ef *oiiis  data vas c

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"The Galas-Ida  Isvsls indioa^sd la this' report s-.ra part ©f thes* rc-2
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 vjs ifce Ji^nlstea ehiar^nej. arid  Into ^fenisc^as  L?Jcs"3.
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 is^it-a an Order of 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
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 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 a PCU.  ssca
         il .plant ie ta be in operation DaGsabe? Ij, 1972£

                 ivs en E3.ll  sr;ill s^splala af c-fivir end water diseol&ra^lc
Irs  ." s.vfear bffiafe 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  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
                          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 "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
{ 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 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


                     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
 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 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

     £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$td othar pipes eomSsg • farom Sfcaadard Lime with ona tssfe
l^.sJ'O ppm of hsxana extS'aotablss (dll)0  Standard. Lime h33 alsa
fill d ;>a:ct of the laS:ec
      pips souit la 58 to dates with 4 pipes  arssently disc@ygr®4
In t » l-lanistes Blve3P0  The^'3 are ©nly the pipes  that are' ab©Ta vat©rc
T^3 < f those pipes ay® leaiuig ell lat-a Msalstea  Lake0  W
Mr0 ; Udle that ws ars will Jag to furnish a beat  end personally
hij •© iihos® two  oil pipes 9 ©f "Whleh ha is not aware0  When-ws
>Ir, MadlR if lie  was going to shut down ths 38 Illegal pipes that hs
dlia-t Jacw a^^ufe he "N«p I caa8t shut  tlism dawn until I tai&v
vhit li eomlng out ©f them0 w  'this Is In spite of ^he faet that the
ce.ip. al«s haTe eonstrueted illagal disehargg pipes »  and that thsy
n® 0. dsr ©f D®te2tt.lQatl©n tc esver their disehsygSo
     A3 you G0a.S3S from th-s absTe,, we da ha-re a various pr@blea0
Ouif : air has bsen landfilled by Ind-astxlal 2fubblslis  polluted by
talsy fj^ra raw elty esirage "t.e high pateuey ehemicils and ehl©rld§p0
Ons ( f -Jiho VfilO bl©l©gists9 Michael Nswton admitted th-at ttueh ©f the
bottia is dead and the rest af it is bslow aysragjo   Thielc sludgs and
seit! l:^s fa^m these Industrial psroesssea have e©it;ed the bottom of
ttt-j ra^po  For exaapl89 off tha Hardy dlsobaxges,  'she daoth s©uad«r
go js fixm 42 feet to 18 feet t© 38 feetp ijadlcatias  a substantial
b® 5',t a buildup*   Wa do not willingly sat th$ penflah in Msaistss I>a\;a
b*'?5tt so of their bad tasta.0

      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

                               Ti^ CuUMTf Aiv'Tl POLLLi'i'lOW
Box 282
I-ianictee, jiichi^an 49"»0
June 13, 1970                                                       •

                                                           f"\ v         ,,                .,
Kr. Hal ph. ,/.  I\irdy, Executive Secretary                       v        •' ,               '  '
Uater j\esoui-ces Co^.assion                        /      I           /  ,.^            \
Stevens T. Ilacon BAilding-                         !       v •''       {
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,:^, 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«

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
     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 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.

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


                                      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



                                    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.
TMI  f  (~
CHfAT I    I
""'  I   /
«"" /., /

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

                                               Very truly yours,

                                               WATER RESOURCES COMMISSION
                                               Ralph W.  Purdy          XJ
                                               Executive Secretary






                                      STATE OF MICHIGAN
           WILLIAM G. MILLIKEN, Governor

              RALPH A. MACMULLAN, Diredr

                July 30, 1970

 '  Chairman






      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


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

                                        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 tfd: 5..-1 sc-Jia 50  square  miles is. ?ad ar^un-i

'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  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
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

                            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
~cc:   G.  E. Eddy
                                    WATER RESOURCES  COMMISSIOl
                                                        lf ' ^ *"'~C'J
r .
G. Liddlo, Or.
;C. Chi Ids
R. Courchaine -.
                                    Norman  Billings
                                    Assistant  Executive Secretary

                 Statement of  the



         prsseatad bj".l-l:-:.-'j0 GsrcoXs -^.gnus 0

                     rcsa:v:!l:ig  the
                      P-- ^,-,. -, '• --r\ <-.. .j
                      J. .U--V ... S.-  - 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 

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) 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
          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 ?


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

     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.  > 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.

                                       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

               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

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
cc—R. J. Courchaine
                               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
   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.

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.
                                       Gerald E. Eddy
cc L. F. Oeming


                                     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
            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
CC--C. Harvey

                                                                2016  - 17
                              (MA CAPO)
Box 282
Manistee, Michigan 496GO
September 1, 1970
William G. Milliken
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

                           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
 CERNS THE PUBLIC EtGHrs OF NAVIGATION.  (See 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


       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 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! 5.)
  subject  to the  following  conditions:

     (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 be uccJ until eihijjtod.
                                       o. 5

                  DEPARTMENT OF THE ARMY

     (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.

                           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
 "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-
  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™'' ""-""•'"               ,  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
                                                                                 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
             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


     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.

     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:.:
                                                          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 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.

 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.

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

                     R. F. Sturgis

          MR. STEIN:  May we have Raynor Sturgis?




          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

                     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

                     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


                     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.


                     H. P. Read





          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


                     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


          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


                       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


                        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


                     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


          (Mr. Read's statement follows in its entirety.)

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

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, 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,  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


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 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'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.

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

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.
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


                     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.


                    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.


                         Mrs. S, Gruen

           Mrs. Shirley Gruen, Wisconsin Federation of

Women's Clubs, has a 3-minute statement.  Mrs. Gruen.



                     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

                     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

                     Mrs. S. Gruen


          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


                     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


          FROM THE FLOOR:   Mr. Chairman, may I ask a


          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.


                      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


                     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


          MRS. DUNLOP:  I will take longer than that.

          MRo STEIN:  Thank you.  Go right ahead.




          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


                        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


          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


                        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


                        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.


          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


                      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.



          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.

                        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


                        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.


                       Mrs* M. Dahl



                    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.


                       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


                       Mrs, M. Dahl


           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,


                       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,


                       Mrs, D.  Trump


           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.




           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

                    Statenent to
         The Third Session Federal Conference on
         Lake I.ichigan and its Tributary Basin
            Workshop on October 2, 1970
      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.


                       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,

                       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


           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

                       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


           Nuclear powerplants are now considered to be the

major "new" source of thermal additives.  If it is


                       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


           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


                       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,)

                          League of  Women  Voters
                                     Thermal   Pollution
League of Women Voters
67 E. Madison
Chicago, Illinois
price on
  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.

  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)

  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
   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
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
     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
  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.

      Reported fish kills caused by heated waste water discharges from electric power generation plants
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
W. Va.
or lake
Raystown Branch,
Juniata River
Discharge canal
to Montrose Lake
Rock River
Unnamed stream
Schuylkill River
Greater Miami
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
town or
Erie County
New Cumberland
Sandusky County
of fish
1 1 ,250
  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

              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 *

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

   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-
   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."

   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
 O 2
 u '-'
                 	  Power per Capita  12 years
                 	Population     46 years
                 	  Power Generation  10 years
              I95O     I960     1970     1980

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).

                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

$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
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).

   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
   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.
   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
   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.

  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 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
 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

                       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.
           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,

                       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

                       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


                       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,


                       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

                       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


                       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


                       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


                       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


           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


                       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


           MR. STEIN:  John F. Wilson.




           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


           I would like to comment, before I present the

                       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


           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


                       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,)

           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


        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.


        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.,

1968, Howmlller and Beeton, 1070) when Urge areas suffer oxygen
        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).



       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.


       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%

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

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 
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-
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

/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
        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.


        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).

        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

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.

        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.

        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.

        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.

        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.


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.


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.

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,
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
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.

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.

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.

Nematoda 8


Leeches ||



>— i

i Other
0 gQPsychoda
554 19 LampsUU

*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.

                   FIGURE LEGENDS
Figure 1.  Lower and middle Green Bay, Lake Michigan, showing
        bottom sampling stations of 28 and 28 May 1952 and 23 M
Figure 2.  Distribution and abundance of OUgochaeta In the sediments
        of lower and middle Green Bay en 26 and 28 May 1932 (left)
        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
Figure 8.  Distribution and abundance of Chlronomldae In May
        and 1969.









                              Curriculum Vitae
                         RICHARD P. HOWMILLER

Born:  9 January 1939, Milwaukee, Wisconsin

  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


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

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.

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


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.

                                 A. M. Beet on
                               Curriculum VLtae

Present Address: 340 Park Circle, Cedarburg, Wisconsin
Born:  August 15, 1927, Denver, Colorado


 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.

 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.

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.

        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


                       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

                       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


           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

                       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-


           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


           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


                       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


                       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.


                       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
           For the first time, the actual physical
process of introducing large amounts of hot water has
been described.  Rejecting the notion that the heated


                       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


                       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


                      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

                      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,

                      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


          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

                      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.

                      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

                       J, F, Wilson

spend a fiendish amount of money and resources to prove


           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


           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)


           Would it be necessary for us to ask Governor

Ogilvie to point this out to the Federal people in order


                       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


                     Mrs. E. Wilkinson

prohibit thermal pollution.  Urge push for prejudgment,





           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.


                     Mrs. C. 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


           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.


                     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
           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
           2.  The myth that cooling towers are too


               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


           "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

                     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,



                      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


                     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


                     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.

                     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

                     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

                     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
           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


                       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.


                       V. Van Laanen

           (Following is the agreement referred to by Mr.

Van Laanen.)


           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


                       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


           The provisions agreed to by Applicants and

Intervenors intended to implement this agreement are as


           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.

                     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

                       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

                     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


           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


                       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


           So the maximum permissible concentration factors

                      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?

                      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?

                     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

                      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


          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

                      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-


           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?


                   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

of their plant.

           But I speak to you today as a private citizen


                      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

                       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


                       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


                       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
           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

                      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,

                      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
           MR. MacDONALD:  No, it does not,
           MR. DOWD:  Well, that is what I was interested

                      T. MacDonald


           MR. STEIN:  Are there any further questions or


           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


           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


                                           October  I,  1970
     Mr. Murray Stein
     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.
     Sol Burstein               Senior Vice  President


 CHICAGO, ILLINOIS 6O8O4                                     TELEPHONE 012)431.2622

                           SEP 2 9 1970
                       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:


           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

                   STATEMENT OF JOHN C. BERGHOFF
                      FOUR-STATE CONFERENCE
                 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

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

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.


                     M. A. McWhinnie

           MR. STEIN:  Would you go ahead?





           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


                     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


           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

                     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


                     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


                      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

                       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:


                     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.


                     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


                       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


           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,


           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


                       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


           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,

                       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


           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


           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.

                       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.

                       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


                       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,)

                  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.


     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

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.

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
     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

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

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


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.

     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

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

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



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

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.


                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



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 arc-  boroa,  bury 1 li;:..i, bvo,...;-.o,

cadii.ii...i, cub.ilt, clii'oiaiiiiii, copper, lanthauui'i, nickel,  load, sc.iadiu..i,

                                                          05   ,30  20  Z5
                     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  ;,i low-v-a-tor- l^vol  (5'/6.8 feet).  Contourir.^ is
               based en U.S. /ov.y Corp.-, of ^^ L:.J:o  Survey District  churts.

     Takcp. fron i-'i^.  2,  l.S.G.S.  ;.:iv.'.:'o:i.  Coo] .  :;otu No.  30.

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) . 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


           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.



           Additionally, inasmuch as we  do not  know the procedures

whereby the metals beco.v.e fixed by  the,  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 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 is -..:at

there is a very  serious absence  o.J  basic .icicntific data abo'.t Lake

Michigan, uuat be  gathered  if ve  aru to effectively^.vc- ar.d

)..a^.ntain the good healtn  ar.d co/.'; u.-r.oJalnc-JS o^ ~ho la.:^.

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
                                             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..\..: ."..

a,.,. 4
                                       ^ O
                                       o o

                       GRAIN SIZE (%)
(Relotive o&unaonce based on
   diffraction effects)

                                                                              NONCLAY MINERALS

                                                                                       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
   ."•  r'r\ ^   \ \
LAKE •   •  V \ \ \ \
FCR.-IST *.  Aj \ \ \  \ :

   ^       \\\  \
   V.      \ \ \  \
   - 4 , -  	\ \ -•	
      V      \.^
             Vx •

      L.X-'.    ' ^
                                          . ' * \-:\'J b.f FALO



         "Here arc our specific views on thermal  input  standards  for  the


          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.



                 SUBMITTED TO


               CHICAGO, ILLINOIS




                SEPTEMBER 25, 1970

                           TESTIMONY OF JOHN D.  HARPER
                                    BEFORE THE
                                    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

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:


          "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,


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.



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



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


                            Chicago,  Illinois
                            25,  26, September

                 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

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,

     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


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

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)
Sta.S 52
Vertical Water
Sta.£ 1
14. 8
Temperatures (30

Sta.= 7
June 1970) (132
Sta. if 50

Sta.i 51
14. 8

Sta.£ 52

Sta. 2 53

Sta.= 55


Sta.£ 51
Sta.S 52
Sta.# 53


                Vertical Water Temperatures (24 Aug. 1970)


  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
                                                   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


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.


           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.

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

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

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.


     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


                              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. _£:':

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.


                       M« A* McWhinnie

           MR. STEIN:  Thank you,  Professor McWhinnie.


           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-


           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


                       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."


                     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

                      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


                       M. A. McWhinnie

 across this  land.  Today did we not hear a Representative

 use  an expression "paid mercenary experts"?  This has deep


           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


                      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


          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


                       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

                       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


           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


                       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 —

                      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


          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


          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,

                      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 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.


                      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


                      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.

                       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


                         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


           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


                     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


           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


                       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


           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


                      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


           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


                       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


                      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


           MR. READ:  All right*  In view of the explanation

here, the State of Illinois, under the explanation that was


                      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-


           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 ——


                     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


           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


                       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,


                     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


                       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


           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


                       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

                      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


          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


                        M.  A.  McWhinnie


           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


           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


           If not, thank you very much, Professor


           DR. McWHINNIE:  I am sorry for the time.

           MR. STEIN:  It wasn't you.

           Now, we have several people here who have filed


           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)


                     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.



           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


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.

                                    - 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
eymour Altman

                        Indiana Stale Division

                        October 2 1970

                                      1154 Ridge Road, Munster In

Lake Michigan Enforcement Conference
Sherman House
Clark and Randolph Sts
Chicago, Illinois


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

     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

                       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 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

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

     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-;t Conference ar;d pl?ccd directly in the  authority of the Feder-

al :/ater ?;jality -.dninistration ap sn agency of the Department of



                     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


                     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

                     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


                     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

                     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


                     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


           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


                      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,




           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


                     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


                     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

                      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.


                       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,)


               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

 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

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.

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
          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:

          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

 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

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

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
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
reaches a warm temperature point?  Bear in mind this/water will
be totally untreated and will average approximately 95 degrees
     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:

     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.

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

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.

    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
     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

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

             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,


                        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


          On its own motion



Investigation of Air Pollution in
the State of Illinois so far as
Illinois Public Utilities are
     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,

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:

     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

 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

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

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

 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

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.

          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,
                   )  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.
        otary Public.
Attorneys for Petitioners
130 East Madison Street
Ottawa, Illinois
Telephone: (&L5) 434-6206


                        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.




           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


           So since I have taken so much time already today,

I would like with your permission to submit a written

                                             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.

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

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.
                                             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


                        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?


                        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,


                       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,

                      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


                        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


           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 —

                         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-


           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


           MR. COMEY:  You are talking about the ISO-day


           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


                        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


           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?




                  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


                        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


           "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

                        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


           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.


                        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


                        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


           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

                        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.
           MR. STEIN:  I think we called on these names
           Mrs. Paul Kaefer.
           (The following statement was submitted to be
entered into the record as if read.)

                                                        CENTRAL 6-0565 • AREA CODE 312

                      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".
                                                   A. >J.  Soehm
                                              Executive Vice President


                       Mrs. P. Kaefer


                       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.
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.


                      Mrs. R, Herlocker




           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

                     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

                   ^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.

              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
                                  ,,- r
I           \  I



                     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)

                    ENVIRONMENTAL Pf.CTECHDft AGi^Ci
                        STATE Oril'JSKS

              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 &
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                 x    u           . ili ^^i LJ , at
                       - C C cuJ^C;a- l^c^Xxi-^
                        '-^^^^t«,<^- ^^>^t^
                                .  Vt ^ t    ^

            1064 SKOKIE RIDGE DRIVE, GLENCO£, ILLINOIS 60022
                  ,  _  RECEIVED
                           SEP 28 1970
                                     l~~4.^ ^£*<
           XJU,  .XU-A^


           (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,


                             Lucy M. Barr

SEP 2 8 1910
                            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


                    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


           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,


                   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


                 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.


                 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>

               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


                           STATE OF ILLINOIS

                OOLLUTIOM carvrrROL. BOARD
                       189 WEST MADISON STREET
                       CHICAGO. ILLINOIS 6O6O2              _
                                                           TEL. No.
                                   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

     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.

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.


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
           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


                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


           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

                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


           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


           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

                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.)

   "~ "    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.

                                                   Concerned Citizens
           V/ K> TMLsJ.* j
                                                   ;^   <{;'> ..\>/^J . t'f/IJS

                                          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

                                                                               - 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

                                     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.


       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.


       If the alternative were EITHER nuclear reactors OR no
electricity, this letter would not be written.  But in truth, the

                              - 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*


       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

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