Volume 4
Fourth Session
September 19-21, 1972
Chicago, Illinois
ILLINOIS
CONFERENCE
Pollution of Lake Michigan
and its Tributary Basin,
Illinois, Indiana, Michigan, and Wisconsin
U.S. ENVIRONMENTAL PROTECTION AGENCY
-------
FOURTH SESSION OF THE CONFERENCE
IN THE MATTER OF POLLUTION OF LAKE MICHIGAN
AND ITS TRIBUTARY BASIN
IN THE STATES OF
WISCONSIN, ILLINOIS, INDIANA, AND MICHIGAN
VOLUME III
(Part 2 of 3 Parts)
Bal Tabarin Room
Sherman House
Chicago, Illinois
September 21, 1972
Ufialityn S\ail ^Associates
COURT AND CONVENTION REPORTING
1372 THURELL ROAD
COLUMBUS. OHIO 43229
614 . 846-3662
-------
3
4
5
6
7
14
16
17
18
19
20
21
22
23
_541
Y. Barber
2
STATEMENT OF YATES M. BARBER, JR.,
FISH AND WILDLIFE ADMINISTRATOR,
BUREAU OF SPORT FISHERIES AND WILDLIFE,
U.S. DEPARTMENT OF THE INTERIOR,
WASHINGTON, D. C.
a
9 il MR. BARBER: Mr. Chairman, conferees, ladies and
10 gentlemen. My name is Yates M. Barber. I am Fish and
11
11 i: Wildlife Administrator in the Office of Environmental
12 j! Quality, Bureau of Sport Fisheries and Wildlife, U.S.
13 Department of the Interior, Washington, D.C.
Two years ago, here in this same building, at the
1$ I Workshop Session of the Lake Michigan Enforcement Conference,
I presented a statement which summarized a paper entitled
"Physical and Ecological Effects of Waste Heat on Lake
Michigan."
Let me interrupt here, gentlemen. I do not have
copies of the statement which I am reading from for you,
They are a summary — the bulk of my statement is a summary
of this report which I have just had distributed to you.
MR. MAYO: Excuse me, Mr. Barber. Do you want the
24 report you have distributed entered into the record as if
25 i: read?
-------
542
I. Barber
2 MR. BARBER: les, sir, I do.
, (The document previously referred to follows in its
i entirety.)
5
6
7
a
9
10
11
12
13
14
15
16
17
ia
19
20
21
22
23
24
25
-------
Statement by
Yates M. Barber, Jr.
Fish and Wildlife Administrator
Office of Environmental Quality
Bureau of Sport Fisheries and Wildlife
U. S. Department of the Interior
Washington, D. C.
Mr. Chairman, Conferees, Ladies, and Gentlemen:
Two years ago, here in this same building, at the Work Shop Session
of the Lake Michigan Enforcement Conference, I presented a statement
which summarized a paper entitled "Physical and Ecological Effects
of Waste Heat on Lake Michigan." That paper, prepared jointly by
the Bureau of Sport Fisheries and Wildlife and the Federal Water
Quality Administration, set forth the basis of our concern for the
effects of waste heat discharges on the aquatic resources of Lake
Michigan.
At the Chicago Workshop, most of the talk pertained to discharge
effects. Since then much has been learned and it is quite obvious
now that power plants with once through cooling can be as deadly
at one end as the other.
The problems of entrainment and impingement of organisms in the
intake flow are fully as great, and as serious, as the discharge
effects of the heated water in most cases.
As presented before the Fourth Session of the Lake Michigan Enforcement
Conference, Sherman House, Chicago, Illinois, September 19-21, 1972.
-------
During 1971, the Bureau of Sport Fisheries and Wildlife presented
testimony at State Hearings for Thermal Standards in Michigan,
Wisconsin and Indiana.
In those statements we tabulated twelve potential adverse impacts
on aquatic resources. These were:
1. Eutrophication effects over an area warmed by the plume,
including increased growth of algae with a shift toward
less desirable green and blue-green species.
2. Damage or destruction of zooplankton, phytophankton, fish
eggs, and larval fishes entrained in the cooling water
from heat, abrasive action, and turbulence in passing through
the system and where chemical cleaning is used, from too
frequent or excessive use of chemicals.
3. Interference with fish movements along shore zones from
thermal barriers.
4. Disruption of the normal inshore temperature structures
of the lake.
5. Kill of fishes in or near the plumes from thermal shock
caused by sudden natural overturns of the lake or sudden
cessation of heat discharges due to shutdown of the plant.
6. Predation on some species of fish (particularly the young)
may be increased where fish are stunned or their responses
are dulled by thermal shock or reverse thermal shock.
-------
7. Failure of sex products to develop in adult fish resident
in or near a plume, or failure of ripe adults to spawn
where drawn to a plume.
8. Destruction or damage to fish eggs or larvae on the lake
bottom from winter plume movements or from plumes impacting
the bottom in spawning sites.
9. Early spawning of fish or hatching of fish or other organisms
which may not find normal "in-phase" food supplies available.
10. Fish may be barred from use of favored shore zones by
excessive temperatures at some seasons.
11. Synergistic effects with other pollutants may occur,
including increased toxicity of pesticides or other toxics
to fish and other aquatic life.
12. Disease incidence may be increased for salmon exposed to
warmer waters.
We can now enlarge this list of possible, and probable, effects by
several additional points.
First we would expand item twelve of that list to include disease
impacts on fish other than just salmon.
Other impacts would include:
13. Disease in zooplankton organisms.
14. Increased uptake of pesticides and heavy metals by organisms
at higher temperatures.
-------
15. Increased release of phosphorous from bottom sediments
under anaerobic conditions at higher temperatures.
(Presently this might have application only in southern
Green Bay.)
16. Impingement of fishes on intake screens.
17. Kill of benthic organisms by chlorine or other biocides
contained in sinking plumes which flow along the bottom
in winter.
18. Loss of weight by fish resident in heated plumes in winter.
Our concern for the effects of once through cooling on the natural
resources of Lake Michigan has not been lessened by the course of
events of the last two years. During that time there has been some
research, though not nearly enough, plus many surveys and observations
concerning the effects of power plants on living aquatic resources.
Some of this work pertained particularly to Lake Michigan, other
was conducted at various points across the country, where the
concern for effects of power plants on aquatic resources is just
as great as it is here.
In total, the accumulation of evidence as to the adverse impact
of once through cooling is impressive. A review of some of the
observations and findings to date leads us inevitably to a
reaffirmation of our belief that large thermal power plants using
once through cooling are incompatible with the management of the
-------
living aquatic resources, and especially the fishery resources,
of Lake Michigan for the public good.
I would like today to run through a list of research findings
and of power plant incidents which we feel will substantiate our
concern for the effects of plants with once through cooling on
living aquatic resources.
Most of these data are new to this conference, although not all
of them are. In many cases you may be well aware of the incidents
but will realize that it has not been entered in the conference
proceedings.
This list is by no means complete. We did not include many
incidents or research findings of which we knew but did not have
time to obtain the publication, or to contact the worker, or to
obtain confirmation of the incident.
We have included a number of newspaper reports of fish kills,
mainly because this seems to be the only public record in many
cases. We are led to believe that most fish kills at power plants
in the past have gone unrecorded in the public record. Time did
not permit our verification of the details of all the newspaper
reports since we began work on this list quite recently.
The question of exactly how many fish were killed or even how
they were killed may be of less concern at the moment than the
-------
fact that a kill did occur at a power plant.
The list of power plant effects is taken from a summary of
information prepared recently by the Great Lakes Fishery Laboratory
of the Bureau of Sport Fisheries and Wildlife at Ann Arbor, Michigan.
I offer for the record a copy of this summary entitled "Review
of Recent Technical Information Concerning Waste Heat Discharges
Into Lake Michigan."
The paper is now undergoing a final editing and will be issued
soon by the Ann Arbor Laboratory. I offer it for the record here,
in its present draft form because it contains the bibliographic
references for the list I am about to cite.
This list has been divided into intake effects and discharge effects.
One of the serious effects of plant intakes with large withdrawals
of water is the impingement of fish on the intake screens. Most
such screens are movable and have a mesh of about 3/8". Thus
impinged fish are usually about 2" or more in length. Virtually
all fish so entrapped are killed. The problem is a widespread one
and is of major concern.
State Fish and Wildlife biologists in California estimate kills
of 4 to 25 tons each month at plants sited along 200 miles of the
California coast between Ventura and San Diego.
-------
One of the best documented records is that at the Indian Point
generating station on the Hudson River in New York. It has been
estimated that several million fish have been killed at this
285 MW plant in recent years. Kills occurred as early as 1963
and apparently each year since.
Between November 6, 1969 and January 11, 1970, 1,310,345 fish
were killed on the intakes at Indian Point. Most were white
perch but more than 10% were striped bass.
A preliminary test of just two of the six pumps needed for Indian
Point Number Two, killed 75,000 fish on the intake screens in
a few days of operation in January 1971.
In February 1972, when two pumps were again tested, one of them
at but half of capacity, about 150,000 to 175,000 fish were killed
en the intake screens in four days of operation.
It has been estimated that about 60% of the fish killed at Indian
Point were white perch. Twenty-three species were represented
in the total kill.
The AEC concluded that operations of Indian Point Units 1 and 2
would likely result in a loss of a significant portion of the
striped bass population of the Hudson River and would also effect
the fisherie3 of New Jersey and Long Island coasts.
-------
A heavy kill of young herring over a 9 day period was reported
at Glenwood Landing, New York in December 1952.
An estimated 2 million young menhaden were reported lost in
August and November 1971 at Waterford, Connecticut on Long Island
Sound.
Records of kills on intake screens on the Great Lakes are
difficult to locate but we have included a number of such
incidents.
In December 1970, a fish kill occurred at a generating plant
on Saginaw Bay on Lake Huron. The duration of the kill was
unknown, but 4,760 distressed and dead fish were reported as
observed on one day and the kill for a week was estimated as
several times larger. Several species of fish were involved.
Heavy kills of fish (mostly alewives) have been reported for
1963 and 1965 from the Saginaw-Midland water intakes, a municipal
supply.
In 1952, some 2 to 3 tons of grizzard shad from the Detroit River
were killed when they entered the intake pipe of the Parke Davis
Company.
A one hour power failure was reported in 1955 as a result of
gizzard shad entering the intake pipe of the Pennsylvania Electric
Company plant on Lake Erie.
-------
On April 7, 1972, at the Monroe Plant on Lake Erie, Michigan
Water Resources Comnission biologists weighed 1,357 pounds of
fish trapped on the travelling screen. These were not all the
fish killed since the collection basket overflowed. Sixty
percent of the fish were perch and 13 species were listed.
Apparently 300-600 pounds of fish per day were taken during
each of the preceeding 3 days.
On Lake Michigan, an alewife problem at Waukegan was one of
the earlier reported fish kills. A 1967 report indicates some-
times massive impingements in 1961, 1962, 1963, and 1964. In
1965 and 1966 massive jams occurred again.
Alewives were reported entering water intakes at U. S. Steelfe
Gary Works in 1966 and Inland Steels Indiana Harbor Works has
had similar problems.
The City of Chicagds Central District water filtration plant
in 1965 encountered problems with Alewives on its intake screens
at an hourly rate of 30,000 pounds during peak periods. At the
South Filtration plant intake annual kills ranged from 21,000
pounds in 1965 to 123,000 pounds in 1971.
Studies by the Environmental Protection Agency in November 1971
report many large lake trout were drawn into the intakes of the
Big Rock Power Plant although the fate of the fish is not given.
-------
10
However, conditions favorable to losses of chubs and suckers
are given as are those for smelt in similar investigations at
the small Escanaba Power Plant in Michigan.
A massive fish kill occurred at the Consumer Power Company's
Campbell Plant on Lake Michigan in January and February 1971.
Michigan Water Resources Commission personnel reported a kill of
several hundred thousand fish. The kill had been going on for
7 to 10 days before it was reported to the Commission on February 4th.
Most of the dead fish were gizzard shad, but alewives and perch
were included. Of special interest, in this case is the proof that
massive fish kills in winter are not conspicuous. The several
hundred thousand dead fish from the screens had been discharged
into the outlet canal where they were washed out into the lake.
Yet, on February 4th after 7 to 10 days of such kill and discharge
to the lake, the dead fish were not visible in the 10 to 20 acres
of ice-free open water around the mouth of the discharge canal.
Observations of fish under study in the laboratory, suggest that
fish freshly killed at power plants in winter may sink to the bottom,
perhaps due to contraction of the swim bladder upon entrainment with
colder water.
One of the latest pieces of evidence on impingement of fishes on
Lake Michigan was presented at the National Conference of the
American Fishery Society on September 11 by Dr. Robert Benda.
-------
11
He reported that 51,235 fish weighing 4,995 pounds have been
taken from the screens of the Palisades Power Plant between
May 16 and August 25, 1972. These fish include 17 species.
While the Alewives were about 60% by number and 44% by weight
the yellow perch with 8,608 fish were about 16% by number and
40% by weight. Trout and salmon totalled only 28 fish but
included one 13 pound chinook salmon. Bloater, smelt, shiners,
and sculpin were included in good numbers. The large catch of
7,343 sculpins in early June suggests opportunity for extremely
heavy annual losses of this fish since it is usually most abundant
in the 18 to 30 foot depths in winter and early spring.
Argonne has reported the principal mortality at Palisades in
January and February to be Sculpins. Dr. Benda stated that the
intake velocities at Palisades were only about 3/4 ft. per second
or less.
I would point out that the intake velocities of the Palisades
plant which amounts to only about 1000 cfs appears to be one of
the more favorably designed intakes of the large plants under
construction on the Lake.
By contrast, at the Zion Plant the intake velocities of up to
2.47 ft. per second during non-winter operations (and up to 3.7 ft.
per second during winter operations) with a gross volume of up to
about 3400 cfs flow presents a very real potential for significant fish
-------
12
losses, as do many of the other plants.
Information from the Great Lakes Fishery Laboratory indicates high
populations of several species of fish in the beach water zone
(at depths less than 30 ft. deep) where most of the intakes are
located.
Wells has shown that peak abundance of bloaters, smelt, trout -
perch, and adult yellow perch occurs in 18-30 ft. of water in
sunnier in southeastern Lake Michigan. Slimy sculpins occur there
in February through mid-April, adult alewives show peak abundance
in April through June, and young-of-the year alewives in October
and November.
Data for other species is less well documented but available data
indicate that burbot, lake herring, lake whitefish, and most of
the trout and salmon species can be expected to be abundant in the
18 to 30 ft. depths in the fall.
Exploratory fishing by the Great Lakes Fishery Laboratory research
vessels in November and December 1971 showed spawning lake trout
to be abundant near the intakes of both the Palisades and the
Donald C. Cook Generating Stations.
A second major loss of fish can occur from the entrainment of
non-screenable fish with the intake water. These are considered
to include fish eggs and any fish small enough to go through a
3/8" screen. Obviously all larval and fry fish can go through
-------
13
the plant as can young fish up to about two inches for most
species. Apparently few of these fish survive the physical
battering, the pressure changes, and thermal shocks of this trip
over the condensers, and many which do expire to long exposure
to excess temperature or fall prey to predators as they emerge
in the plume in a dazed condition.
Fish eggs sometimes simply disappear on passage through a plant,
perhaps due to rupture. Loss of up to 99.7% of striped bass
eggs has been recorded at a generating station at Vienna, Maryland,
apparently through disintegration.
Sampling of fish and larvae at the Chalk Point, Maryland generating
station revealed mortality of 92.4% on passage through the plant.
At the Haddam Neck, Connecticut Nuclear Plant, 100% mortality of
entrained young fish of 9 species was found when temperatures
exceeded 86 F for passage through a 1.14 mile canal. These fish
were alewives and a close relative, the glut herring. The
investigator found also that 65% of larvae were killed when
exposed for only 93 seconds to a 10.7°F increase to 82.7 . 83%
were killed in 93 seconds when exposed to 92.3 F temperatures.
At the Brayton Point plant at Mount Hope Bay, Rhode Island a
heavy kill of manhaden fry was recently documented by the
Environmental Protection Agency. Some flounder were also killed.
-------
164,000,000 manhaden larvae were killed in passage through this
plant in 24-hours on July 2, 1971. Subsequent sampling indicated
that the kill continued through July and well into August with
a minimum observed 24-hour kill of 7 million fry in August.
There are few data on fish eggs, or fry passing through the plants
on the Great Lakes. Some sampling was conducted at the Point
Beach Station and at the Oak Creek Station by the State of Wisconsin
from March 3 to May 27, 1971 and March 22 to April 22, 1971
respectively.
At Point Beach plankton nets fished on 14 days produced a catch
of one sculpin each on eight days and a few smelt eggs on another
two days and an unidentified fish egg on another.
The volume of water measured was 5/1000ths of one percent of the
total volume of flow. Extrapolation of the test results would
suggest that around 4 million sculpins may have gone through the
plant during 42 days of operation between March 3 and April 29.
Between April 29 and May 19, about 23/1000ths of the water was
sampled. Assuming a few smelt eggs to mean 10, then the number
passing through the plant may have been on the order of 400,000
in 24-hours on May 4 and more than one million on May 5.
The Oak Creek entrainment studies show that in 17 days of fishing,
smelt eggs in quantities from few to numerous were taken on five days
-------
15
and smelt in size from fry to adult were taken on 7 days and 1
alewife was taken on another.
The number of these organisms in the intake water as compared to
the discharge is not known nor is the percent survival of any
of these organisms after passage through the plant. In any case,
the fact that a minimal sampling took both fish and eggs consistently
at these plants suggests a high probability of entrainment and
destruction of large numbers of fish and eggs at both plants.
Studies of distribution of fish fry along the eastern shore of
Lake Michigan were made by the Great Lakes Fishery Laboratory in
spring and summer of 1972.
Samples were taken at surface to 4 meter depths and the densities
of fry for 3 species were determined. These were alewives, smelt
and yellow perch.
Based on these samples only, and assuming that the water is
withdrawn from the 3 to 4 meter depth and assuming equal distribution
of larvae throughout the entire volume of cooling water, we estimate
that entrainment of fry could be as high as 5 million alewives,
100,000 perch fry and 170,000 smelt per day at the Donald C. Cook
plant at the periods when highest densities were sampled.
-------
16
At the Palisades plant under the same assumptions entrainmetit of
fry could be as high as 1/2 million alewives, 150,000 perch and
60,000 smelt, based on the Bureau of Sport Fisheries and Wildlife
data.
I emphasize that we have no reason to believe that we necessarily
sampled at the peak density of any of these species so how high
the entrainment might be under some particular set of circumstances
at a given time is not quantifiable. It could be lower but it is
also possible that it could be many times higher, expecially if
water from the top 3 meters of depth was entrained. Fry densities
were much higher for perch and alewives nearer the surface.
In work by Dr. Benda at the Palisades Plant plankton sampling of
3.4 million gallons of water in 300 hours resulted in a catch of
less than 1000 fish eggs and 5 larvae. At the pumping rate of
405,000 gallons per minute this indicates possible passage of 20
million eggs and 1,000 larvae during the 300 hours of sampling.
Expansion of these data to cover the full period of May 16 to
August 25 suggests massive losses of eggs and larvae may occur
at the Palisade site. We recognize that a direct extrapolation of
Dr. Benda's data may not be appropriate but it does give some idea
of the relationships of the figures involved.
-------
17
The potential loss of whitefish larvae is of great concern to t'.
Fish and Wildlife Service. The whitefish population of the southern-
most end of the Lake is probably at its all time low but limited
sampling at Saugatuck suggests a potential comeback of these
populations. Populations in the northern Lake still support
commercial and sport fisheries.
Newly hatched whitefish are at the surface in very shallow water
in early spring but as temperatures approach 68 F they move off
to deeper and slightly cooler water. 62.6 F is the temperature
at which the bulk of population has been reported in Lake Huron.
The fish are found where the 62.6 F isotherm touches bottom. In
Lake Huron this moves off shore between July and mid-September
when it reaches a 67-foot depth.
In Lake Michigan 62.6 F water would be available from mid-June or
early July to mid-September or early October depending on the year.
All Lake Michigan once through cooling water intakes are within
the zone that the 62.6 F isotherm would pass outward through and
beyond.
Recently completed studies of temperature tolerance of whitefish
fry at the Great Lakes Fishery Laboratory indicate that the
temperature increases and time of exposures to be caused by the
Palisades and Zion Plants coincide almost exactly with the
temperature and time exposures that cause 50% mortality from
thermal shock alone in whitefish fry acclimated to 62.7°F.
-------
18
At the Kewaunee plant the 20 F increase and 2.2 to 4.7 minutes
exposure time will also cause 50% mortality from heat alone
when intake temperatures are at about 62.7 F.
Whitefish fry not killed by elevated temperatures, mechanical
mauling by screens, pumps and cooling system or by chlorination
will likely be more susceptible to capture by predators concentrated
in or near the plumes. This is explained more fully later.
Concentration of fishes by heated effluents has been recognized
for some time. This results from temperature but also from
currents or availability of crippled food organisms. Fish and
other organisms can be attracted by warmer water at times, as in
winter and repelled at other times as in summer when preferred
or tolerance limits of a species are exceeded.
Several observations on Lake Michigan confirm these points:
In summer elevated temperatures tend to attract some species of
warmwater fish as carp, alewives, smallmouth bass, spottail shiners,
perch and gizzard shad, while repelling trout, salmon and other
coldwater species.
When effluent temperatures are below about 65UF both warm and
coldwater species may be attracted.
-------
19
Concentration of these fish at the plumes where fishermen can
harvest them is often touted as a great benefit brought about by
once through cooling.
Perhaps it is but there are several negative aspects which should
not be ignored.
Heavy mortality can result to these concentrated fishes from
sudden sharp increases in temperature where fish are confined in
a small area, as in a discharge canal. Such a kill of 1,000 game
fish (mostly striped bass 10-14 inches in length) on June 7, 1971
has been reported from Tompkins Cove, New York, when condenser
cooling water temperatures were sharply increased.
Of special interest are the results of studies which show a major
weight loss by fishes overwintering in a plume. At Haddam Neck
on the Connecticut River studies of tagged fish (brown bullhead
and white catfish) showed an average loss of body weight in 4
months of 20% for fish wintering in the plume. Some individuals
lost as much as 60% of body weight. Poor condition was noted for
some individuals of these species in the canal during summer.
Of greater relevance is the sudden interruption of heat input
during winter.
-------
20
A number of low temperature kills in marine waters are known.
One recent case was a massive kill at Oyster Creek on Barnegat Bay,
New Jersey. A drop of 22 F from 59 F to 37 F, during an operational
shutdown resulted in a kill of menhaden, anchovies, bluefish, striped
bass and herring.
A conspicuous freshwater kill occurred in February 1971 on the
Susquehannah River when a leak in a plant at York Haven, Pennsylvania
forced a sudden shutdown. Temperatures dropped from a high of around
72 F to about 38 F within one hour. A tally of dead fish three days
after the sudden outage was about 15,000 game fish. Fish smaller
than 5 or 6 inches and certain rough fish were not tallied. The
incidence of dead fish which did not float or were not otherwise
visible is unknown.
Two kills were recorded at Fremont, Ohio on the Sandusky River,
tributary to Lake Erie in January 1967 and in the winter of 1968.
I do not have details of these kills.
The records of kills due to winter shutdown at electric plants on
Lake Michigan are slow to appear. However, I suggest that this
deserves special investigation and close observation of plants
during winter shutdown.
-------
21
Numerous shutdowns without effect are claimed, but assurance that
close examinations were made at that time would be most reassuring.
The difficulty of detecting kills is evident. The incident of
huge numbers of dead fish discharged to the lake at the Campbell
plant without any being visible in a 10-20 acre area of open water
is a case in point. Laboratory evidence that recently dead fish
moving from hot to cold water will sink is important as is the
short period of daylight, poor observing conditions and ice cover,
during Lake Michigan winters. The ability of predators and scavengers
to remove a large number of dead fish from the surface in a short
time is also important.
The likelihood of kills when sudden outage of plants occurs on Lake
Michigan seems high if we examine known lethal temperatures for
some Lake Michigan fishes. Data indicate that 50% kill might be
expected as follows:
Coho Salmon acclimated to 41 F are killed by a sudden drop
of 8°F.
Chinook Salmon and Ciscoes acclimated to 43 F would be killed
by an 11 F decrease.
Grizzard shad acclimated to about 50 F would die from an 18°F
temperature drop.
Emerald shiners acclimated to about 54 F will die following a
sudden 22°F drop.
-------
22
White Suckers acclimated to 62 F would be killed by a drop of
about 30°F.
Available data for Brooktrout and Sculpin suggest they might not
be effected by a sudden drop.
However, we lack specific data for several important species.
It is probable that such fish as whitefish, brown and rainbow trout,
spottail shiners, smelt, and alewives have temperature change
tolerances no greater than those listed above.
A review of the temperature rise at some 20 plants on the Lake
(existing and under construction) suggests that a sudden outage in
winter could cause a fish kill if any of several species of fish
were in the plume and were acclimated to warmed water of the plume.
Another source of damage to fish populations from the discharge of
power plants is from entrainment of fish fry and other weak swimming
organisms into the plume.
High velocity jet discharges are dependent on quick entrainment
and mixing with the cooler receiving water.
Research at the Great Lakes Fishery Laboratory has shown that thermal
shock increases the vulnerability of whitefish fry to predation.
Fry acclimated to 64.4 F (their preferred temperature is 62.6 F) and
-------
23
given a 1 minute shock exposure at 84.2 F are significantly more
susceptible to predation. The time of 1 minute exposure to this
20 F increase could occur in the mixing jet of the Zion plant and
probably others as well.
The increase in predation from shock may be one of the more
significant impacts of the waste heat discharge. This shock may
not only result from temperature but also from physical damage
during passage through a plants cooling system or while entrained
or from sub-lethal doses of biocides. Weak swimmers which are
entrained may simply be displaced by being buoyed to the surface
in the warmest part of a floating plume where chance of attack by
predators is increased.
Combinations of thermal, chemical, and mechanical impacts probably
would be additive and vulnerability would increase where one or more
impacts coincides with another.
Effects of sinking plumes on incubating fish eggs may be especially
important. Of interest is that the sinking plume does not appear
to have been recognized as existing in Lake Michigan until the
questions were raised in discussions with Argonne Laboratory technicians
during a working session of the Lake Michigan Enforcement Conference
Technical Committee during the fall of 1970.
-------
24
Research by Argonne has proven the existence of the plumes and
that even modest sized thermal plants can cause bottom plumes of as
much as 2.6 C over ambient at a distance of 1525 meters from the
discharge and a difference of A.O C at closer ranges.
Sudden changes of up to about 4 C in bottom temperatures were
recorded at some locations. Argonne concluded that hatching of
lake herring eggs could be advanced 7 days by the higher temperatures
caused by the sinking plumes. Possible stimulation of periphyton
growth by higher temperatures was also recognized.
Recent research at the Great Lakes Fishery Laboratory on the
effects of temperature on the incubation and hatching of the eggs
of whitefish has shown a 136 day incubation period under simulated
normal lake conditions.
Increase of temperatures by 1.8, 3.6, and 7.2 F every 4th day during
the full incubation period shortened the incubation to 138, 134,
and 125 days respectively.
Constant addition of 1.8, 3.6, and 7.2 F over natural temperatures
resulted in hatching at 128, 115, and 86 days respectively.
A discussion of the shortening of the incubation of whitefish eggs
is included in Appendix A of the Palisades Environmental Impact
Statement. This indicates a shortening of even 13 days would
significantly reduce the production of whitefish fry and the abundance
of whitefish for sometime thereafter.
-------
25
Another item of concern is the effect of temperature on attainment
of sexual maturity and egg viability of fishes.
Research at the National Water Quality Laboratory of EPA at
Duluth has shown that yellow perch achieved optimum gametogenesis
and spawning when exposed to 4 C for a period of 185-200 days.
Large deviation from these values reduced fecundity in terms of
production of viable eggs, number of females spawning and the quality of
the spawn. Deviations from the optimum 185 days at 4 C may affect
males and cause a greater proportion of unfertilized spawnings.
Perch were among the fish killed at the Campbell plant and this
suggests that they are attracted from the 4 C water where their
fecundity may be affected by higher temperatures.
An inconspicuous but possibly significant effect of increased
temperature on fish is in the increased incidence of disease in
fish at higher temperatures.
A review of the literature shows clearly that elevated temperature
plays a vital role in incidence and severity of infection. It
has been demonstrated that higher temperatures drastically increased
the effects of kidney disease, furunculosis, vibro disease and
columnaris in young salmonids.
-------
26
The effects of temperature and disease is documented for a major
kill of perch in Chesapeake Bay, for an incidence of columnaris
disease in the Columbia River and in the near obliteration of the
sockeye salmon in the Columbia River in 1941.
There already are serious problems with fungal infections, perhaps
in concert with other diseases, in male brown trout along the
Wisconsin shore when the fish enter warmer shore waters to spawn.
Mortalities of 88% in 1968 and nearly 100% in 1970 were recorded
for male brown trout.
Heavy fungus, perhaps coincident with bacterial infection, has
been noted on spawning browns and rainbows which enter Michigan
streams to spawn.
Kidney lesions have been reported in Lake Michigan coho salmon
and dead salmon with kidney lesions have been recovered from the
Lake. In 1970 kidney disease was reported from 1.83% of 273 cohos
examined.
Concentration of fishes in plumes may offer opportunity for spread
of disease from fish more severely infected because of their presence
in warm water.
The uptake of some pollutants by fish appears to be higher at higher
water temperatures.
-------
27
Recent research at the Great Lakes Fishery Laboratory has shown
that lake trout exposed to 0.20 ppb methylmercury accumulated
almost twice as much from water at 10 C as from water at 5 C.
Rainbow trout exposed to similar concentrations for eight weeks
in water at 5, 10, and 15 C accumulated 50% and 100% more at the
higher temperatures than at 5 C.
Temperature may effect the uptake of other pollutants by fish.
It has been shown that a correlation exists between respiration
and uptake of DDT by the mosquito fish. Though Gambusia are not
Lake Michigan fish, this finding suggests a relationship between
temperature and DDT uptake which cannot be ignored in view of the
high levels of DDT and PCB now occurring in some Lake Michigan
fishes.
It is an established fact that some toxicants are more lethal to
fish at higher temperatures than at lower temperatures. It has
been suggested that some chemicals used in power plants may also
be more toxic at higher temperatures.
A matter of concern is the effect of temperature on higher nutrient
release from bottom sediments under anaerobic conditions. Recent
research at the Ann Arbor Fishery Laboratory has confirmed that
phosphorous is released at a rate four times greater at 77 F than
at 44°F.
-------
28
Much has been said about planktonic algae in Lake Michigan but we
still know far too little about the effects of temperature on this
primary element of the aquatic biota.
A 1969 report indicates that within some temperature ranges (68 F
or cooler) a higher temperature stimulated photothensis but above
68 F further increases inhibited it. At high ambient temperatures,
a permanent inhibition of photosynthenis occurred for phytoplankton
that had passed through the power plant. During chlorination all
phytoplankton passing through the plant were killed.
A study at Turkey Point, Florida indicated a decrease in species
diversity with temperatures of 9 F above intake and blue-green
algae increased when ambient temperatures were 78.8 to 82.4 F.
Other workers have found that increased temperature from a power
plant on the Delaware River resulted in a decrease in the total
number of phytophankton species but an increase in bluegreen algae
species.
In the Susquehannah River, heated water reduced the number of species
of algae.
However, the effects of heated plumes on the productivity of
planktonic algae relative to suppression of desirable species and
blooms of undesirable forms has not been clearly established.
-------
29
The movement of discrete water masses with each carrying its own
assemblage of planktonic forms through the sample area results in
complications of the study. Most discharge sites are potentially
productive areas because of nutrients released by organism killed
on passage through the plant.
Entrained algae carried to the surface in the nutrient rich,
buoyant plumes would appear to be favorable to increased growth.
Chlorination may debilitate many of the algal species and
selectively effect the production of desirable or undesirable
species.
These considerations viewed with respect to evidence of periphyton
production, to be discussed next, suggest that net increases may
be occurring among populations of planktonic algae in heated plumes
in Lake Michigan.
The periphyton communities seem to differ from the planktonic algae
communities in that they seem to be responding to heated effluents
in a predictable manner.
Connecticut River investigations showed similarity of planktonic
communities above and below a heated discharge. Among the periphyton,
however, diatoms dominated samplers above the discharge and blue-
greens below. One year after the plant began operation numbers of
-------
30
organisms in the effluent were 4.3 times as abundant as before
the discharge when numbers were similar in both areas.
Studies at Point Beach in the summer of 1971 showed significantly
greater biomass at near field stations than at far stations on a
temperature difference of only 3.6 F. Winter stimulation of
periphyton growth by sinking plumes could be of significance and
should be carefully searched for.
Cleaning of condenser tubes in power plants to remove biological
fouling is essential to plant maintenance and efficiency. Heat
shock, chemicals and passing mechanical devices through the system
have all been used.
Chemicals are generally the most serious threat to the ecology.
Chlorine as hypochlorite or gaseous chlorine is probably the most
widely used biocide in power plant cooling systems. Various con-
centrations are used and effectiveness of chloramines can be
hampered by high BOD or ammonia levels.
Unfortunately, all these forms of chlorine are toxic to aquatic
organisms and often at levels below those used in power plants.
During chlorination, all the planktonic organisms, including fish
larvae, may be killed in the water passing through the plant while
large numbers probably are affected in the plume.
-------
31
Long-term exposure of rainbow trout to as little as 0.05 ppm may
be toxic.
Other organisms have extremely low tolerances for chlorine on
long-term exposure.
Fish kills have resulted from chlorine discharges into plume
areas where fish were concentrated. This may have been a factor
in a fish kill effecting the intake screens at the Waukegan power
plant.
Some fish detect and avoid chlorine at concentrations as low
as 0.001 ppm and several species have been observed avoiding
discharges when chlorine was present. Conversely fish have been
observed dying by thousands immediately after chlorination began.
If chlorination during winter drives fish out of heated areas to
which they are acclimated, the possibility exists that these fish
would be killed by low temperature shock.
Benthic and psammo-littoral communities may be especially hard
hit by chlorine residuals in sinking plumes which flow over the
bottom. The invertebrate species of these communities appear to
be especially sensitive to chlorine.
Unfortunately, some power plants appear to use excessive amounts
of chlorine at times, perhaps because of inadequate measurement
techniques.
-------
32
More studies of acute and chronic effects of chlorine are needed.
Preliminary evidence indicates that sublethal doses of chloramine
can cause reduction of egg production in fish and invertebrates.
Gentlemen, in the interest of time I will not summarize this long
list of problems with once—through cooling at power plants.
Needless to say, the draft document provided you contains an
elaboration on these matters and the references for the information
it contains. I commend this document to your careful consideration.
I believe it provides ample proof of the significant adverse
impact of once-through cooling on aquatic resources and of the
necessity of closed cycle cooling for all the larger power plants
on the shores of Lake Michigan.
-------
_ 543
I. Barber
2 ' MR. BARBER: That paper, prepared jointly by the
Bureau of Sport Fisheries and Wildlife and the Federal Water
Quality Administration, set forth the basis of our concern
for the effects of waste heat discharges on the aquatic
resources of Lake Michigan.
7
17
22
23
24
25
At the Chicago Workshop, most of the talk pertained
to discharge effects. Since then much has been learned and
j
9 it is quite obvious now that powerplants with once-through
i
10 ! cooling can be as deadly at one end as the other.
11 j| The problems of entrainment and impingement of
12 i organisms in the intake flow are fully as great, and as
13 |j serious, as the discharge effects of the heated water in
most caseso
15 During 1971, the Bureau of Sport Fisheries and
11
16 ! Wildlife presented testimony at State hearings for thermal
standards in Michigan, Wisconsin and Indiana,
11
18 ii in those statements we tabulated twelve potential
19 ' adverse impacts on aquatic resources. These were:
20 i. Eutrophication effects over an area warmed
21 i by the plume, including increased growth of algae with a
shift toward less desirable green and blue-green species.
2. Damage or destruction of zooplankton, phyto-
plankton, fish eggs, and larval fishes entrained in the
cooling water from heat, abrasive action, and turbulence
-------
344
1 Y. Barber
2 in passing through the system and where chemical cleaning is
2 used, from too frequent or excessive use of chemicals.
3. Interference with fish movements along shore
zones from thermal barriers.
4. Disruption of the normal inshore temperature
structures of the lake.
5. Kill of fishes in or near the plumes from
9 thermal shock caused by sudden natural overturns of the lake
10 or sudden cessation of heat discharges due to shutdown of
11 the plant.
12 6» Predation on some species of fish (particularly
13 the young) may be increased where fish are stunned or their
14 responses are dulled by thermal shock or reverse thermal
15 shock.
16 7. Failure of sex products to develop in adult
17 fish resident in or near a plume, or failure of ripe adults
to spawn where drawn to a plume.
19 #. Destruction or damage to fish eggs or larvae
20 on the lake bottom from winter plume movements or from
21 plumes impacting the bottom in spawning sites.
22 9. Early spawning of fish or hatching of fish or
23 other organisms which may not find normal "in-phase" food
24 supplies available.
25 10. Fish may be barred from use of favored shore
-------
- 545
Y. Barber
2 zones by excessive temperatures at some seasons,
3 11. Synergistic effects with other pollutants may
occur, including increased toxicity of pesticides or other
5 toxics to fish and other aquatic life.
i
6 i 12. Disease incidence may be increased for salmon
i
i
7 exposed to warmer waters.
I
8 We can now enlarge this list of possible and
i
9 ! probable effects by several additional points.
10 First, we would expand Item 12 of that list to
11 include disease impacts on fish other than just salmon.
i
12 Other impacts would include:
13 i 13. Disease in zooplankton organisms.
14 14. Increased uptake of pesticides and heavy
15 metals by organisms at higher temperatures.
16 i 15. Increased release of phosphorus from bottom
i
17 sediments under anaerobic conditions at higher temperatures.
j:
13 | (Presently this would probably apply only to southern
19 Green Bay.)
i
20 16. Impingement of fishes on intake screens.
17. Kill of benthic organisms by chlorine or
OO i
other biocides contained in sinking plumes which flow
^ ! along the bottom in winter.
IS. Loss of weight by fish resident in heated
05 I
plumes in winter.
-------
546
1 Y. Barber
2 Our concern for the effects of once-through cooling
on the natural resources of Lake Michigan has not been
lessened by the course of events of the last 2 years. During
that time there has been some research, though not nearly
enough, plus many surveys and observations concerning the
effects of powerplants on living aquatic resources. Some
g |, of this work pertained particularly to Lake Michigan, other
9 was conducted at various points across the country, where
10 the concern for effects of powerplants on aquatic resources
i
11 I is just as great as it is here.
12 In total, the accumulation of evidence as to the
13 adverse impact of once-through cooling is impressive. A
14 review of some of the observations and findings to date leads
15 us inevitably to a reaffirmation of our belief that large
16 thermal powerplants — and I might add, after seeing the
17 data of the last witness and other large thermal dischargers
18 «- using once-through cooling are incompatible with the
19 management of the living aquatic resources, and especially
20 the fishery resources, of Lake Michigan for the public good.
21 I would like today to run through a list of
22 research findings and of powerplant incidents which we feel
23 will substantiate our concern for the effects of plants
i
24 with once-through cooling on living aquatic resources.
2$ Most of these data are new to this conference,
-------
__ _______ _ _________ 547
I. Barber
although not all of them are. In many cases you may be well
aware of the incidents, but will realize that it has not
A II been entered in the conference proceedings in the past.
MR. McDONALD: Mr. Barber.
5
7
MR. BARBER: les.
MR. McDONALD: I wonder if, as you run through
these, you would identify those that are new to the confer-
9 "
ence.*
10 i MR. BARBER: If I can, sir. I may not be fully
i
11 I aware of the total record of the conference in the past,
12 ! but many of these are incidences of fish kills, many of
13 which are not necessarily in the Great Lakes, but I think
14 that if I could not do it at this moment, I could do it for
15 | the record insofar as my knowledge of the conference record
16 goes.
17 ! MRo McDONALD: Very good.
MR. BARBER: This list is by no means complete.
19 l| We did not include many incidents or research findings
20 | of which we knew but did not have time to obtain the publi-
21 i cation, or to contact the worker, or to obtain the confirma-
22 | tion of the incident.
23 i We have included a number of newspaper reports of
fish kills, mainly because this seems to be the only public
record in many cases. We are led to believe that most fish
*(See following page.)
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
BUREAU OF SPORT FISHERIES AND WILDLIFE
WASHINGTON, D.C. 20240
ADDRESS ONLY THE DIRECTOR,
BUREAU OF SPORT FISHERIES
AND WILDLIFE
b 1372
Mr. Francis T. Kayo, Chairman
Lake Michigan Enforcement Conference
U.S. Environmental Protection Agency
One North Wacker Drive
Chicago, Illinois 60606
Dear Mr. Mayot
When I testified at the 4th session of the Lake Michigan Enforcement
Conference in Chicago on September 21, 19?2, the Federal Conferee,
Mr. James McDonald, asked whether the information presented in my
statement was new to the Lake Michigan Snforcement Conference.
I have not reviewed all the proceedings of the earlier sessions of
the Conference but I have examined several documents pertaining to
sessions dealing with thermal pollution. I have also reviewed my
files on the Lake Michigan Technical Committee in which I participated.
Some of the predicted impacts on aquatic life which I discussed
were recognized in the earlier sessions of the Conference, of
course. However, in so far as I can determine the confirming
evidence of known instances of damage from once-through cooling,
and the research findings supporting the various predictions of
impacts were not reported in the proceedings of previous sessions
of the Conference.
This would hold true both for my statement and for the draft document,
"Review of Recent Technical Information Concerning Waste Heat
Discharges into Lake Michigan", which I presented for the record.
'fours very truly,
/Yates M. barber
Pish >~nd Wildlife Administrator
Office of Environmental Duality
-------
Y. Barber
kills at powerplants in the past have gone unrecorded in the
public record. Time did not permit our verification of the
details of all the newspaper reports since we began work on
this list quite recently.
The question of exactly how many fish were killed
or even how they were killed may be of less concern at the
moment than the fact that a kill did occur at a powerplant.
I think we would not question in the case of those
10 clippings which we have used that there was an incident
11 which occurred although the details might justify verifica-
12 tion.
13 | The list of powerplant effects is taken from a
summary of information prepared recently by the Great Lakes
15 Fishery Laboratory of the Bureau of Sport Fisheries and
Wildlife at Ann Arbor, Michigan.
17 I offer for the record a copy of this summary
entitled "Review of Recent Technical Information Concerning
j
•^ ! Waste Heat Discharges into Lake Michigan.*1 This is the
20 green-covered document which I gave you.
2^ I The paper is now undergoing a final editing and
22 i
will be issued soon by the Ann Arbor Laboratory. I offer it
23
for the record here, in its present draft form, because it
2A- ii
l| contains the bibliographic references for the list I am
25 I!
'i about to cite.
-------
549
Y. Barber
(The document previously referred to is on file
at U.S. EPA, Headquarters, Washington, D.C.; and EPA, Region
V Office, Chicago, Illinois.)
This list has been divided into intake effects
and discharge effects.
One of the serious effects of plant intakes with
large withdrawals of water is the impingement of fish on
the intake screens. Most such screens are movable and have
10 a mesh of about 3/#M» Thus, impinged fish are usually
11 about 2W or more in length. Virtually all fish so entrapped
12 are killed. The problem is a widespread one and is of major
concern.
State Fish and Wildlife biologists in California
15 estimate kills of 4 to 25 tons each month at plants sited
along some 200 miles of the California coast between Ventura
and San Diego.
11
i A
-1-0 One of the best documented records of fish kills
° ' by impingement is that at the Indian Point generating
20
station on the Hudson River in New York. It has been esti—
21
mated that several million fish have been killed at this
22 i
11 ~Ac MW plant in recent years. Kills occurred as early as
23
1963 and apparently each year since.
24 !
Between November 6, 1969, and January 11, 1970,
I!
25
" 1,310,345 fish were killed on the intakes at Indian Point.
-------
550
3
4
I. Barber
Most were white perch but more than 10 percent were striped
bass.
A preliminary test of just two of the six pumps
10
11
12 IS
13
14
15
16
17
18
19
20
21
needed for Indian Point No, 2, located at the same site,
killed 75,000 fish on the intake screens in a few days of
operation in January 1971.
In February 1972, when two pumps were again tested,
one of them at but half of capacity, about 150,000 to 175,000
fish — according to which agency's estimate you use — were
killed on the intake screens in 4 days of operation.
It has been estimated that- about 60 percent of
the fish killed at Indian Point were white perch. Twenty-
three species were represented in the total kill.
The AEG concluded that operations of Indian Point
Units 1 and 2 would likely result in a loss of a significant
portion of the striped bass population of the Hudson River
and would also affect the fisheries of the New Jersey and
Long Island coasts.
Another incident of importance is a heavy kill of
young herring over a 9-day period reported at Glenwood
oo
Landing, New York in December 1952.
^ !| An estimated 2 million young menhaden were reported
OL :
|| lost in August and November 1971 at Waterford, Connecticut
? ^ '
? 'l on Long Island Sound.
-------
551
1 Y. Barber
2 Records of kills on intake screens on the Great
3 Lakes are difficult to locate but we have included a number
4 of such incidents*
5 In December 1970, a fish kill occurred at a gener-
6 ating plant on Saginaw Bay on Lake Huron. The duration of
7 the kill was unknown, but 4,760 distressed and dead fish were
8 reported as observed in one day and the kill for a week was
9 estimated as several times larger. Several species of fish
10 were involved.
11 Heavy kills of fish (mostly alewives) have been
12 reported for 1963 and 1965 from the Saginaw-Midland water
13 intakes, a municipal supply.
14 In 1952, some 2 to 3 tons of gizzard shad from
j
15 the Detroit River were killed when they entered the intake
16 pipe of the Parke Davis Company.
17 A 1-hour power failure was reported in 1955 as a
13 result of gizzard shad entering the intake pipe of the
19 Pennsylvania Electric Company plant on Lake Erie.
20 on April 7, 1972, 60,000 emerald shiners were
21 killed in the intake of a generating plant in Erie Harbor,
22 Pennsylvania.
23 on April 7, 1972, at the Monroe plant on Lake
i
24 Erie, Michigan Water Resources Commission biologists weighed
2 5 1,357 pounds of fish trapped on the traveling screen. These
-------
, Y. Barber
2 were not all of the fish killed since the collection basket
overflowed. Sixty percent of the fish were perch and 13
species were listed. Apparently 300 to 600 pounds of fish
per day were taken during each of the preceding 3 days*
On Lake Michigan, an alewife problem at Waukegan
was one of the earlier reported fish kills. A 196? report
indicates sometimes massive impingements in 196l, 1962,
1963, and 1964. In 1965 and 1966 massive jams occurred
10
12
13
15
again
Alewives were reported entering water intakes at
U.S. Steel's Gary Works in 1966, and Inland Steel's Indiana
Harbor Works has had similar problems.
The city of Chicago's Central District water fil-
tration plant in 1965 encountered problems with alewives
16 on its intake screens at an hourly rate of 30,000 pounds
17 during peak periods. At the South filtration plant intakes
IS I in Chicago, annual kills ranged from 21,000 pounds in 1965
19 fl to 123,000 pounds in 1971.
I
20 Studies by the Environmental Protection Agency in
21 lj November 1971 report many large lake trout were drawn into
1 i
22 ij the intakes of the Big Rock powerplant although the fate
23 J of the fish is not given. However, conditions favorable
1
24 i to losses of chubs and suckers were given, as are those
25 j for smelt in similar investigations at the small Escanaba
-------
5
6
7
9
10
11
12
13
15
16
17
19
20
21
22
23
24
25
553
I. Barber
power plant in Michigan.
A massive fish kill occurred at the Consumer Power
Company's Campbell plant on Lake Michigan in January and
February 1971. Michigan Water Resources Commission person-
nel reported a kill of several hundred thousand fish. The
kill had been going on for 7 to 10 days before it was re-
ported to the Commission on February 4. Most of the dead
fish were gizzard shad, but alewives and perch were included.
Of special interest in this case is the proof that massive
fish kills in winter are not conspicuous. The several
hundred thousand dead fish from the screens had been dis-
charged into the outlet canal where they were washed out
into the lake. Yet on February 4, after 7 to 10 days of
such kill and discharge to the lake, the dead fish were
not visible in the 10 to 20 acres of ice-free open water
around the mouth of the discharge canal. Lab studies sug-
gest that fish freshly killed at powerplants in winter often
sink to the bottom, perhaps due to contraction of the swim
bladder upon entrainment with colder water after being in
the heated water of the plume.
one of the latest pieces of evidence on impinge-
ment of fishes on Lake Michigan was presented at the National
Conference of the American Fishery Society on September 11
by Dr. Robert Benda. He reported that 51,235 fish weighing
-------
, 554
I, Barber
|
]
2 4,995 pounds have been taken from the screens of the PalisacUs
3 | powerplant between May 16 and August 25, 1972. These fish
4 I include 17 species. While the alewives were about 60 per-
cent by number and 44 percent by weight, the yellow perch,
with 8,60$ fish, were about 16 percent by number and 40
percent by weight. Trout and salmon totaled only 28 fish
but included one 13-pound Chinook salmon. Bloater, smelt,
9 shiners and sculpins were included in good numbers. The
10 large catch of 7,343 sculpins in early June suggests oppor-
i
11 tunity for extremely heavy annual losses of this fish since
12 ! it is usually most abundant in the 18-to 30-foot depths in
13 winter and early spring.
14 Argonne has reported the principal mortality at
15 Palisades in January and February to be sculpins. Dr. Benda
i
16 stated that the intake velocities at Palisades were only
17 about 3/4 foot per second or less.
il
1° ' I would like to point out that the intake veloci-
19 | ties of the Palisades ^p'lant which amounts to only about
20 : 1,000 c.f. s. is one of the more favorably designed intakes
21 | of the large plants under construction on the lake.
By contrast, at the Zion plant the intake
3 velocities of up to 2.47 feet per second during nonwinter
p j
^ : operations (and up to 3»7 feet per second during winter
p C
? ; operation) with a gross volume of up to about 3,400 c.f.s.
-------
555
1 I. Barber
2 presents a very real potential for significant fish losses,
as do many of the other plants.
4 Information from the Great Lakes Fishery Lab
5 indicates high populations of several species of fish in the
beach water zone (at depths less than 30 feet deep) where
most of the intakes are located.
Wells has shown that peak abundance of bloaters,
9 smelt, trout, and adult yellow perch occurs in 18 to
10 30 feet of water in summer in southeastern Lake Michigan.
11 Slimy sculpins occur there in February through mid-April;
12 adult alewives show peak abundance in April through June;
13 and young-of-the year alewives in October and November.
14 Data for other species is less well documented
15 but available data indicate that burbot, lake herring, lake
16 whitefish, and most of the trout and salmon species can be
17 expected to be abundant in the 1&- to 30-foot depths in the
13 fall.
19 Exploratory fishing by the Great Lakes Fishery
20 Lab research vessels in November and December 1971 showed
21 spawning lake trout to be abundant near the intakes of both
22 the Palisades and the Donald C. Cook generating stations.
23 A second major loss of fish can occur from the
2^- entrainment of nonscreenable fish with the intake water.
2^ These are considered to include fish eggs and any fish small
-------
556
I. Barber
enough to go through a 3/3 inch screen. Obviously all larval
and fry fish can go through the plant as can young fish up to
about 2 inches for most species. Apparently few of these
5 fish survive the physical battering, the pressure changes,
6 and thermal shocks of this trip over the condensers, and many
7 which do, expire to long exposure to excess temperature or
fall prey to predators as they emerge in the plume in a dazed
9 condition.
10 Fish eggs sometimes simply disappear on passage
11 through a plant, perhaps due to rupture. Loss of up to 99.7
12 percent of striped bass eggs has been recorded at a gener-
I
13 ating station at Vienna, Maryland, apparently through disin-
14 tegration.
I
15 Sampling of fish and larvae at the Chalk Point,
Maryland generating station revealed mortality of 92.4 per-
17 cent on passage through the plant.
° At the Haddam Neck, Connecticut nuclear plant,
19 jj 100 percent mortality of entrained young fish of 9 species
i
2® I was found when temperatures exceeded $6° F. during passage
21 |j through a 1.14 mile long canal. These fish were mostly
i
22 | alewlves and a close relative of the glut herring. The
oo il
^ investigator found also that 65 percent of larvae were
24 li
25
-------
537
I. Barber
2 killed when exposed for only 93 seconds to a 10.7° P.
increase to 82.7° F. Eighty-three percent were killed in
4
5
6
7
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
93 seconds when exposed to 92.3° F. temperatures.
At the Brayton Point plant at Mount Hope Bay,
Rhode Island, a heavy kill of raanhaden fry was recently
documented by the Environmental Protection Agency. Some
flounder were also included in this kill but they were
probably a minor percentage. One hundred and sixty- four
million manhaden larvae were killed in passage through this
plant in 24 hours on July 2, 1971. Subsequent sampling
indicated that the kill continued through July and well into
August with a minimum observed 24-hour kill of 7 million
fry in August.
There are few data on fish eggs or fry passing
through the plants on the Great Lakes. Some sampling was
conducted at the Point Beach Station and at the Oak Creek
Station by the State of Wisconsin from March 3 to May 27,
1971, and March 22 to April 22, 1971, respectively.
At Point Beach, plankton nets fished on 14 days
produced a catch of 1 sculpin each on & days and a few
smelt eggs on another 2 days and an unidentified fish on
still another.
The volume of water measured was 5/1,000 of 1
percent of the total volume of flow. Extrapolation of the
-------
_ _ 553
I. Barber
2 test results would suggest that around 4 million s*"uipins
o j may have gone through the plant during 42 days of operation
i
i between March 3 and April 29, We realize these data are not !
*+
5 necessarily directly translatable, but the significance
5 of the incidence of capture of fish is quite impressive,
i
7 Between April 29 and May 19, about 23/1?000 of
' i
1 percent of the water was sampled. Assuming a few smelt
I
9 eggs to mean 10, then the number passing through the plant I
I
10 may have been on the order of 400,000 in 24 hours on May 4
|
11 and more than 1 million on May 5. i
i
12 The Oak Creek entrainment studies show that in 17
i
13 ' days of fishing, smelt eggs in quantities from few to numer- i
14 ous were taken on 5 days and smelt in size from fry to !
!
15 adult were taken on 7 days and 1 alewife was taken on
16 II another,
17 The number of these organisms in the intake water
18 as compared to the discharge is not known nor is the percent
19 survival of any of these organisms after passage through the
20 ; plant. In any case, the fact that a minimal sampling took
i
21 i both fish and eggs consistently at these plants suggests a
1 j
22 | high probability of entrainment and destruction of large
23 jj numbers of fish and eggs at both plants,
24 Studies of distribution of fish fry along the
!i
25 |! eastern shore of Lake Michigan were made by the Great Lakes
-------
559
1 I. Barber
2 Fishery Laboratory in spring and summer of 1972,
3 Samples were taken at surface to 4-meter depths
4 and the densities of fry for 3 species were determined.
5 These were alewives, smelt and yellow perch.
6 Based on these samples only, and assuming that the
7 water is withdrawn from the 3- to 4-meter depth and assuming
$ equal distribution of larvae throughout the entire volume of
9 cooling water, we estimate that entrainment of fry could be
10 as high as 5 million alewives, 100,000 perch fry and 170,000
11 smelt per day at the Donald C. Cook plant at the periods
12 when highest densities were sampled.
13 At the Palisades plant, under the same assumptions,
14- entrainment of fry could be as high as .5 million alewives,
15 150,000 perch, and 60,000 smelt, based on the Bureau of
1° Sport Fisheries and Wildlife data.
17
i A
•L0 I I emphasize that we have no reason to believe that
° we necessarily sampled at the peak density of any of these
20
species, so how high the entrainment might be under some par-
21 I
I ticular set of circumstances at a given time is not quanti-
22
fiable. It could be lower but it is also possible that it
23
could be many times higher, especially if water from the top
24
3 meters of depth was entrained. Fry densities were much
25
higher for perch and alewives nearer the surface.
-------
560
1 Y. Barber
2 In work by Dr. Benda at the Palisades plant,
3 plankton sampling of 3.4 million gallons of water in 300
4 hours resulted in a catch of less than 1,000 fish eggs and
5 5 larvae. At the pumping rate of 405*000 gallons per minute,
6 this indicates possible passage of 20 million eggs and
7 100,000 larvae during the 300 hours of sampling. Expansion
8 of these data to cover the full period of May 16 to August
i
9 25 suggests massive losses of eggs and larvae may occur at
10 the Palisades site.
i
11 The potential loss of whitefish larvae is of
12 | great concern to the Fish and Wildlife Service. The white-
i
13 fish population of the southernmost end of the lake is
14 probably at its all-time low but limited sampling at
15 ! Saugatuck suggests a potential comeback of these populations.
16 Populations in the northern lake still support commercial and
17 sport fisheries.
1° !j Newly hatched whitefish are at the surface in very
19 j! shallow water in early spring but as temperatures approach
20 | 6$° p^ they move off to deeper and slightly cooler water.
i
21 || 62.6° F. is the temperature at which the bulk of population
22 1 has been reported in Lake Huron. The fish are found where
i
^ the 62.6° F. isotherm touches bottom. In Lake Huron this
o / !
i moves offshore between July and mid-September when it reaches
2^ i a 67-foot depth.
-------
. 561
1 Y. Barber
2 In Lake Michigan, 62.6° F. water would be avail-
3 able from mid-June or early July to mid-September or early
4 October depending on the year.
5 All Lake Michigan once-through cooling water in-
6 takes are within the zone that the 62.6° F, isotherm would
7 ! pass outward through and beyond.
8 Recently completed studies of temperature toler-
9 ance of whitefish fry at the Great Lakes Fishery Laboratory
10 indicate that the temperature increases and time of exposures
11 to be caused by the Palisades and Zion plants coincide almost
12 exactly with the temperature and time exposures that cause
13 50 percent mortality from thermal shock alone in whitefish
14 fry acclimated to 62.7° F.
15 At the Kewaunee plant, the 20° F. increase and
2.2 to 4.7 minutes exposure time will also cause 50 percent
17 mortality from heat alone when intake temperatures are at
about 62.7° F.
19 Whitefish fry not killed by elevated temperatures,
mechanical mauling by screens, pumps and cooling systems or
21 by chlorination will likely be more susceptible to capture
22 by predators concentrated in or near the plumes. This is
discussed more fully later.
Concentration of fishes by heated effluents has
^ been recognized for some time. This results from temperature
-------
562
. .. ,
]_ Y, Barber
2 | but also from currents or availability of crippled food
organisms. Fish and other organisms can be attracted by
warmer water at times, as in winter, and repelled at other
times, as in summer, when preferred or tolerance limits of
6 a species are exceeded,
7 i Several observations on Lake Michigan confirm
8 these points: In summer, elevated temperatures tend to
9 i attract some species of warmwater fish as carp, alewives,
10 smallmouth bass, spottail shiners, perch, and gizzard shad,
11 i while repelling trout, salmon, and other coldwater species,
12 When effluent temperatures are below about 65° F.
i
13 both warm- and coldwater species may be attracted.
14 Concentration of these fish at the plumes where
15 i fishermen can harvest them is often touted as a great
16 benefit brought about by once-through cooling. Perhaps it
17 is, but there are several negative aspects which should not
1^ i be ignored.
i
19 Heavy mortality can result to these concentrated
i
20 fishes from sudden sharp increases in temperature where fish
i
21 are confined in a small area, as in a discharge canal. Such
22 a kill of 1,000 game fish (mostly striped bass 10-14 inches
23 ] in length) on June 7, 1971, has been reported from Tompkins
2^ {| Cove, New York, when condenser cooling water temperatures
5 | were sharply increased.
-------
563_
1 Y. Barber
2 Of special interest are the results of studies
3 which show a major weight loss by fishes overwintering in
4 a plume. At Haddam Neck, on the Connecticut River, studies
5 of tagged fish (brown bullhead and white catfish) showed an
6 average loss of body weight in 4 months of 20 percent for
7 fish wintering in the plume. Some individuals lost as much
$ as 60 percent of body weight. Poor condition was noted for
9 some individuals of these species in the canal during
10 summer.
11 Of perhaps greater relevance than temperature
12 increase is the sudden interruption of heat input during
13 winter.
14 A number of low temperature kills in marine waters
15 are known. One recent case was a massive kill at Oyster
16 Creek on Barnegat Bay, New Jersey. A drop of 22° F. from
17 59° p. to 37° F., during an operational shutdown, resulted
in a kill of menhaden, anchovies, bluefish, striped bass,
19 and herring.
A conspicuous freshwater kill occurred in February
21 1971 on the Susquehannah River when a leak in a plant at
22 York Haven, Pennsylvania forced a sudden shutdown. Tempera-
23 tures dropped from a high of around 72° F. to about 3#° F.
within 1 hour. A tally of dead fish 3 days after the sudden
outage was about 15,000 game fish. Fish smaller than 5 or
-------
3
4
5
9
x
10
11
12
13
14
15
16
17
21
23
564
Y. Barber
6 inches and certain rough fish were not tallied. The inci-
dence of dead fish which did not float or were not otherwise
visible is unknown.
Two kills were recorded at Fremont, Ohio on the
Sandusky River, tributary to Lake Erie, in January 196?,
and in the winter of 1963. I do not have details of these
kills.
The records of kills due to winter shutdown at
electric plants on Lake Michigan are slow to appear. How-
ever, I suggest that this deserves special investigation
and close observation of plants during winter shutdown.
Numerous shutdowns without effect are claimed,
but assurance that close examinations were made at that time
would be most reassuring. The difficulty of detecting kills
is evident. The incident of huge numbers of dead fish dis-
charged to the lake at the Campbell plant without any being
visible in a 10-20 acre area of open water is a case in point,
19 ;! Laboratory evidence that recently dead fish moving from hot
to cold water will sink is important as is the short period
of daylight, poor observing conditions, and ice cover, dur-
ing Lake Michigan winters. The ability of predators and
scavengers to remove a large number of dead fish from the
OL
\ surface in a short time is also important,
25
The likelihood of kills when sudden outage of
-------
565
Y, Barber
plants occurs on Lake Michigan seems high if we examine
known lethal temperatures for some Lake Michigan fishes.
Data indicate that 50 percent kill might be expected as
5 follows:
6 1» Coho salmon acclimated to 41° F. are killed
7 by a sudden drop of 8° F.
8 2, Chinook salmon and ciscoes acclimated to 43°
9 F, would be killed by an 11° F, decrease.
10 3. Gizzard shad acclimated to about 50° F. would
11 die from an ±8° F. temperature drop.
12 4. finerald shiners acclimated to about 54° F.
13 will die following a sudden 22° F. drop.
14 5» White suckers acclimated to 62° F» would be
15 killed by a drop of about 30° F.
16 I might note that all of these are sudden drops
17 that we talk about, not normal seasonal adjustments over a
period of several days or weeks.
19 Available data for brook trout and sculpin suggest
20 they might not be affected by a sudden drop in temperature,
21 However, we lack specific data for several important
22 species. It is probable that such fish as whitefish, brown
and rainbow trout, spottail shiners, smelt, and alewives
have temperature change tolerances no greater than those
25
' listed above.
-------
566
1
2
5
6
7
a
10
25
Y. Barber
A review of the temperature rise at some 20 plants
on the lake (existing and under construction) suggests that
4 i a sudden outage in winter could cause a fish kill if any of
several species of fish were in the plume and were acclimated
to warmed water of the plume.
Another source of damage to fish populations from
the discharge of powerplants is from entrainment of fish
fry and other weak-swimming organisms into the plume.
High velocity jet discharges are dependent on
11 quick entrainment and mixing with the cooler receiving water.
12 ij Research at the Great Lakes Fishery Laboratory has
13 j shown that thermal shock increases the vulnerability of
11
14 whitefish fry to predation. Fry acclimated to 64.4° F.
15 '! (their preferred temperature is 62.6° F.) and given a 1-minute
16 I! shock exposure at #4.2° F. are significantly more susceptible
17 |] to predation. The time of 1-rainute exposure to this 20° F.
1$ ; increase could occur in the mixing jet of probably the Zion
19 •! plant and many of the others as well.
! |
20 The increase in predation from shock may be one
21 : of the more significant impacts of the waste heat discharge.
22 , This shock may not only result from temperature but also
*^ from physical damage during passage through a plant's
^ ! cooling system or while entrained or from sublethal doses
of biocides. Weak swimmers which are entrained may simply
-------
567
I. Barber
2 be displaced by being buoyed to the surface in the warmest
3 part of a floating plume where chance of attack by predators
is increased.
5 Combinations of thermal, chemical, and mechanical
6 impacts probably would be additive and vulnerability would
7 increase where one or more impacts coincides with another.
Effects of sinking plumes on incubating fish
9 eggs may be especially important. Of interest is that the
10 sinking plume does not appear to have been recognized as
11 existing in Lake Michigan until the questions were raised
12 in discussions with Argonne Laboratory technicians during
13 a working session of the Lake Michigan Enforcement Conference
14 Technical Committee during the fall of 1970,
15 Research by Argonne and by others has proven the
16 existence of the plumes now, and the Argonne work has shown
17 that even modest-sized thermal plants can cause bottom
plumes of as much as 2,6° C. over ambient at a distance of
1,525 meters from the discharge and a difference of 4.0° C,
20 at closer ranges,
21 i might add that what a large plume will do —
22 such as Zion or Donald C. Cook — may be an entirely dif-
ferent and larger matter.
24 Sudden changes of up to about 4,0° C, in bottom
temperatures were recorded at some locations, Argonne
-------
•i
2
3
5
j
6
7
B
12
13
16
21
22
__ 568
I. Barber
concluded that hatching of lake herring eggs could be ad-
vanced 7 days by the higher temperatures caused by the
sinking plumes. Possible stimulation of periphyton growth
by higher temperatures was also recognized,
Recent research at the Great Lakes Fishery Labora-
tory on the effects of temperature on the incubation and
hatching of the eggs of whitefish has shown a 136-day
9 i incubation period under simulated normal lake conditions.
10 jj Increase of temperatures by 1,3°, 3.6° and 7.2°
i|
11 ! F. every fourth day during the full incubation period
shortened the incubation to 13^, 134, and 125 days,
respectively.
14 ji Constant addition of 1,8°, 3.6° and 7.2° F. over
15 ] natural temperatures resulted in hatching in 123, 115, and
86 days, respectively.
17 I A discussion of the shortening of the incubation
|i
18 i| of whitefish eggs is included in Appendix A of the Palisades
ij
19 P Environmental Impact Statement by the Atomic Energy Commis-
20 sion» This indicates a shortening of even 13 days would
significantly reduce the production of whitefish fry and
the abundance of whitefish for sometime thereafter.
Another item of concern is the effect of tempera-
ture on attainment of sexual maturity and egg viability of
fishes.
-------
. 369
1 I, Barber
2 Research at the National Water Quality Laboratory
3 of EPA at Duluth has shown that yellow perch achieved optimum
4 gametogenesis and spawning when exposed to 4.0° C. for a
5 period of 1&5-200 days* Large deviation from these values
6 reduced fecundity in terms of production of viable eggs,
7 number of females spawning and the quality of the spawn.
Deviations from the optimum 185 days at 4.0° G. may affect
9 males and cause a greater proportion of unfertilized spawn-
10 ngs.
11 j Perch were among the fish killed at the Campbell
12 plant and this suggests that they are attracted from the
13 4.0° C. water where their fecundity may be affected by
higher temperatures.
15 An inconspicuous but possibly significant effect
of increased temperature on fish is in the increased
17 incidence of disease in fish at higher temperatures.
-I rt
±0 A review of the literature shows clearly that
° elevated temperature plays a vital role in incidence and
severity of infection. It has been demonstrated that
higher temperatures drastically increased the effects of
22
kidney disease, furunculosis, vibro disease and columnaris
23
in young salmonids
01
The effects of temperature and disease is docu-
25
mented for a major kill of perch in Chesapeake Bay, for an
-------
570
1 I. Barber
2 incidence of columnaris disease in the Columbia River and
3 i in the near obliteration of the sockeye salmon in the
|i
4 ! River in 1941.
i
5 ii There already are serious problems with fungal
i
6 infections, perhaps in concert with other diseases, in male
i
7 | brown trout along the Wisconsin shore when the fish enter
ji
& ' warmer shore waters to spawn. Mortalities of 8& percent in
9 i, 196# and nearly 100 percent in 1970 were recorded for male
10 brown trout.
i.
11 I Heavy fungus, perhaps coincident with bacterial
M
12 infection, has been noted on spawning browns and rainbows
13 ]•• which enter Michigan streams to spawn.
i!
j i
14 i Kidney lesions have been reported in Lake Michigan
15 | coho salmon and dead salmon with kidney lesions have been
j
1° i recovered from the lake. In 1970, kidney disease was
17 || reported from 1.33 percent of 273 cohos examined.
1° ii Concentration of fishes in plumes may offer oppor-
, i
1° tunity for spread of disease from fish more severely
20 infected because of their presence in warm water.
2^ | The uptake of some pollutants by fish appears to
, i
22
,, be higher at higher water temperatures.
23 '
ii Recent research at the Great Lakes Fishery
I'
O} !
! Laboratory has shown that lake trout exposed to 0.20 ppb
I
25
i methylmercury accumulated almost twice as much from water
-------
Y. Barber
2 at 10° C. as from water at 5° C.
o Rainbow trout exposed to similar concentrations
4 for $ weeks in water at 5% 10°, and 15° C. accumulated $0
5 percent and 100 percent more at the higher temperatures than
5 at f>° C.
7 Temperature may affect the uptake of other pollu-
j
g tants by fish. It has been shown that a correlation exists
o between respiration and uptake of DDT by the mosquito fish.
i
10 Though Gambusia are not Lake Michigan fish, this finding
11 suggests a relationship between temperature and DDT uptake
12 which cannot be ignored in view of the high levels of DDT
13 and PGB now occurring in some Lake Michigan fishes.
14 It is an established fact that some toxicants
15 are more lethal to fish at higher temperatures than at
16 lower temperatures. It has been suggested that some
17 chemicals used in powerplants may also be more toxic at
l£ higher temperatures.
19 A matter of concern is the effect of temperature
20 on higher nutrient release from bottom sediments under
21 anaerobic conditions. Recent research at the Ann Arbor
22 Fishery Laboratory has confirmed that phosphorus is released
23 at a rate 4 times greater at 77° F. than at 44° F.
24 Much has been said about planktonic algae in Lake
Michigan but we still know far too little about the effects
-------
572
1 I, Barber
2 of temperature on this primary element of the aquatic biota.
A 1969 report indicates that within some tempera-
4 ! ture ranges (68° F. or cooler) a higher temperature stimu-
5 lated photosynthesis, but above 68° F. further increases
6 inhibited it. At high ambient temperatures, a permanent
7 i inhibition of photosynthesis occurred for phytoplankton
& that had passed through the powerplant. During chlorination
9 all phytoplankton passing through the plant were killed,
i
10 A study at Turkey Point, Florida indicated a
i
11 decrease in species diversity with temperatures of 9° F.
12 above intake and blue-green algae increased when ambient
13 temperatures were ?S.S° to 82.4° F.
14 Other workers have found that increased tempera-
1$ ture from a powerplant on the Delaware River resulted in a
16 decrease in the total number of phytoplankton species but
17 an increase in blue-green algae species.
In the Susquehannah River, heated water reduced
19 the number of species of algae.
20 j However, the effects of heated plumes on the
21 | productivity of planktonic algae relative to suppression
^2 of desirable species and blooms of undesirable forms has
3 \ not been clearly established.
The movement of discrete water masses with each
! carrying its own assemblage of planktonic forms through
-------
573
1 I, Barber
2 the sample area results in complications of the study. Most
3 discharge sites are potentially productive areas because of
4 nutrients released by organisms killed on passage through
5 the plant.
6 j Entrained algae carried to the surface in the
7 nutrient-rich, buoyant plumes would appear to be favorable
o to increased growth.
9 Chlorination may debilitate many of the algal
10 species and selectively affect the production of desirable
11 or undesirable species.
12 These considerations viewed with respect to evi-
13 dence of periphyton production, to be discussed next, sug-
14 ! gest that net increases may be occurring among populations
1$ of planktonic algae in heated plumes in Lake Michigan.
The periphyton communities seem to differ from
17 the planktonic algae communities in that they seem to be
responding to heated effluents in a predictable manner.
Connecticut River investigations showed
similarity of planktonic communities above and below a
21 heated discharge. Among the periphyton, however, diatoms
22 '
dominated samplers above the discharge and blue-greens
below. One year after the plant began operation, numbers
of organisms in the effluent were 4.3 times as abundant
25
as before the discharge when numbers were similar in both
-------
574
I. Barber
2 areas.
3 Studies at Point Beach in the summer of 1971
I
4 showed significantly greater biomass at near field stations
5 than at far stations on a temperature difference of only
J
6 I' 3.6° F. Winter stimulation of periphyton growth by sinking
I
7 ; plumes could be of significance and should be carefully
8 \ searched for.
i [
11
11
9 Cleaning of condenser tubes in powerplants to
10 I remove biological fouling is essential to plant maintenance
11 I and efficiency. Heat shock, chemicals, and passing mechanical
12 \i devices through the system have all been used.
i!
ii
13 i Chemicals are generally the most serious threat
i
14 ji to the ecology. Chlorine as hypochlorite or gaseous
i i
15 ii chlorine is probably the most widely used biocide in power-
16 : plant cooling systems. Various concentrations are used
17 !; and effectiveness of chloramines can be hampered by high
1^ |; BOD or ammonia levels.
19 !; Unfortunately, all these forms of chlorine are
' i
20 toxic to aquatic organisms and often at levels below those
21 used in powerplants.
22 !| During chlorination, all the planktonic
1 i
2^ i! organisms, including fish larvae, may be killed in the
^ J! water passing through the plant while large numbers probably
i;
oc i!
^ H are affected in the plume.
-------
575
I. Barber
2 Long-term exposure of rainbow trout to as little
3 as 0.05 ppm may be toxic.
4 Other organisms have extremely low tolerances for
5 chlorine on long-term exposure.
6 Fish kills have resulted from chlorine discharges
7 into plume areas where fish were concentrated. This may
8 have been a factor in a fish kill affecting the intake
9 screens at the Waukegan powerplant.
10 Some fish detect and avoid chlorine at concentra-
11 tions as low as 0.001 ppm and several species have been
12 observed avoiding discharges when chlorine was present.
13 Conversely fish have been observed dying by thousands
14 immediately after chlorination began.
15 If chlorination during winter drives fish out of
16 heated areas to which they are acclimated, the possibility
17 exists that these fish would be killed by low temperature
shock.
19 Benthic and psammo-littoral communities may be
especially hard hit by chlorine residuals in sinking plumes
21 which flow over the bottom. The invertebrate species of
22 these communities appear to be especially sensitive to
chlorine.
Unfortunately, some power — excuse me, I'm sorry.
I have got the wrong word there* The invertebrate species
-------
576_
•, I. Barber
2 of these communities appear to be especially sensitive to
biocides.
Unfortunately, some powerplants appear to use
5 excessive amounts of chlorine at times, perhaps because of
6 inadequate measurement techniques.
7 More studies of acute and chronic effects of
chlorine are needed. Preliminary evidence indicates that
9 sublethal doses of chloramine can cause reduction of egg
i
10 production in fish and invertebrates,
i
11 Gentlemen, in the interest of time, I will not
12 summarize this long list of problems with once-through
13 cooling at powerplants. Needless to say, the draft document
14 provided you contains an elaboration on these matters and
15 the references for the information it contains. I commend
16 this document to your careful consideration. I believe it
17 provides ample proof of the significant adverse impact of
1# once-through cooling on aquatic resources and of the
19 j necessity of closed-cycle cooling for all the larger
20 j powerplants on the shores of Lake Michigan.
21 MR. MAIO: Thank you, Mr. Barber.
22 ji Do we have any questions or comments by the
23 conferees?
Mr. Currie.
MR. CURRIE: Yes.
-------
7
11
12
13
14
15
16
17
19
20
21
22
23
24
25
577
I. Barber
Mr. Barber, in your report, one of the things which
is discussed is the effect, on page 52, on algae. And I be-
] eve you refer to certain tests which find a greater concen-
raf,ion of blue-green algae in plumes than in the ambient watejr
a.iC a greater biomass of algae in the plume than outside.
Do you view this evidence as impairing the confer-
ence's earlier finding No. 17 which was that the residence
time of algal cells in the heated plume from a properly
10 designed single 1,000 MW plant is probably too short to
cause any significant problems?
MR. BARBER: On this table over there is my copy
of those conclusions, and by that item there is a little
rea "X" which indicates I did feel here was an item that
perhaps we have sufficient evidence to warrant some change
in the conclusion.
Now, let me clarify this. We are talking about
sessile organisms which are resident in an area and are sub-
jected to the heat for prolonged periods in the periphyton.
If we look at the single-celled floating plankton
organisms which simply pass through and are carried on out
of the plume area by water currents, I believe you will find
this green book concludes that we don't really yet have all
of the evidence to conclude that there is an increase in
this.
-------
__ ' 573
n
1 I. Barber :
2 ' But when you say algal mass, yes, I think we do j
3 ; have an increase in the biomass in the periphyton communi-
4 j' ties subjected to the heat*
i
5 ; I would regard these two incidents as a very
I !
6 ji strong indication of that.
I
7 | MR. CURRIE: But this effect is, so far as we know
3 lj from the evidence that is now before us, limited to the
9 | attacked forms of algae? i
II
10 i MR. BARBER: I think there are those who might feelj
11 jj that there is evidence, but I am not an algologist and we j
!
12 I concluded that we did not yet have the information in hand.
11
13 ; MR. CURRIE: Secondly, one of the conclusions that
14 i! the Illinois Board reached was that the area affected by a
i
15 ' single powerplant, if well designed, was likely to be rather
!i
16 jj small, and that, therefore, it might not have any very sig-
17 nificant effect on the lake as a whole.
And I gather from perusing this report that your
19 l conclusion might lead to some modification of that position
which is — and I would like to check with you whether this
^x "' is an accurate characterization of what you are saying •—
22 '
:! that even though the area affected may be rather small,
i j
^ that because a heated plume will attract a substantial
2.L '!
\ congregation of fish from miles around, the effects which
25
ji that plant might have are greater than might be expected
-------
579
Y. Barber
from the small amount of the area that is actually affected.
Is that a fair characterization?
MR. BARBERs Yes, sir, I would agree with that.
I would also point out that--as I did in the statement —
that &he effects of powerplants are very much in both ends.
The entrairiiicnt and impingement of fish on the intakes is a
8 very vioal part of the picture; it is not just the waste
discharge which draws the fish where they may be subject to
10 adverse impacts.
11 But a single plant — let's take, for example, the
12 Zion P. ^nt, whose intakes, if I remember, are somewhere in
13 the 20-plus-foot range, 3,400 c.f.s., if I remember, taken
14 in through the two discharges combined, with intake velocities
15 of 2.4 or 2.5, if I remember correctly, feet per second — I
16 think it is inevitable that under some circumstances that
17 plant could engulf or envelope a great deal of aquatic life.
must recognize that we do have continual move-
19 ments of currents in these shores in response to wind,
20 temperature, and other factors, and if you happen to have
a prevailing current that sails by this point for several
22 ! days at a time, this plant will be sampling that current at
-* all times.
If the critical temperature of plumes as, for
example, for the whitefish, happened to involve those
-------
7
11
22
23
24
Y. Barber
isotherms in the neighborhood of that intake, and at some
point they were to pass that, then the opportunity for
entrainment of very large numbers of fry or larval fish is
certainly there. And we are not at all convinced, as many
people seem to be, that these areas of Lake Michigan are
really that sterile. This is a 365-day a year proposition
that life goes on out there. These plants work 365 days a
9 i year, and these fish and other things live in that lake 365
i
10 I days a year. And while we hate to confess so much ignorance,
the truth is that we don't know where a lot of these fish
12 !j are, but the more evidence we gather, the better we think
13 we understand that they do use these shallow areas and they
14 i do pass through these zones. !
15 ! A plant sitting there operating full-time inevitabl^
16 gets, let's say, a crack at them at some point in time.
17 MR. CURRIE: Well, I was somewhat struck by the
ji
IS I rather large numbers of fish that you were discussing in each
11
i
19 |j instance of fish kill at an individual plant that might not
11
20 have a very large amount of influence if you look simply at
21 j the acres which are significantly warmed.
Currie?
MR. MAIO: Do you have any further questions, Mr.
MR. CURRIE: No, thank you.
MR. MAYO: Any other questions or comments,
-------
_ 5jSl
.-..
-i Y. Barber
x
2 gentlemen?
3 MR. PURDI: Mr. Chairman, will Mr. Barber be
4 available to the '-onferees as we progress into this thermal
5 question? There is a great deal of information here that
6 has been presented, and I think it would be most valuable
7 if we had a chance to digest it. and discuss it with Mr.
8 Barber.
9 MR. MAYO: Will you be available the remainder of
10 the day, Mr. Barber?
11 MR. BARBER: I will be here all day, sir, and as
12 long as you need me I will be here. I am accompanied by
13 Mr. Tom Edsall, who is one of the principal — perhaps the
14 principal author of this paper and who will assist me in
15 providing you with any answers that you may need.
16 MR. PURDY: I think it would be most valuable and
17 even if we don't get at it today, at some later point in
time, I would hope Mr. Barber's people would be available
19 to us.
20 in some of the studies cited, has there been any
21 attempt to asses what effect the, say, sanitary waste dis-
22 charges from that particular plant might have and how that
23 might influence what is observed within the plume? In some
instances, the powerplants have their own sanitary waste
disposal system and treated effluent is discharged into the
-------
582
Y. Barber
plume.
j \ Would this have an influence on what is, say,
!
^ " observed to take place in the plume with respect to peri-
5 i phyton, and so forth?
6 MR. BARBER: I am not aware of any such evaluation j
7 , of that. That does not mean they have not been made.
g At most plants that I am familiar with, the total
9 volume of discharge from the domestic sewage system is so
10 small, and the volume of polluting water with which it is
11 diluted is so great that I would suspect, in many cases,
12 it would be difficult to separate the effect of that waste,
13 as nutrient, from the probably much greater supply of
14 'l nutrient generated by the kill of the microscopic and the
15 small organisms passing through the plant.
16 MR. MAYO: Any other questions, gentlemen?
17 Mr. Barber, if you would leave a copy of your
13 remarks with Mr. Pratt, we will arrange to have them copied
19 as quickly as possible and have copies made available to the
20 conferees and the press and other interested parties as
21 quickly as we can.
22 ; MR. BARBER: All right, sir. I would like to say
23 that this is a rather rough marked-up copy that I am using
2^ , and there are two or three little errors I wish to correct.
' MR. MAYO: Some of us are rather rough, marked-up
-------
1 [ R, Catlin
2 conferees] (Laughter)
3 MR. BRYSON: The next Federal agency that has
4 requested an opportunity to speak to the conferees is Mr,
5 Robert J, Catlin of the U.S. Atomic Energy Commission,
6 Washington, D.C.
7
& STATEMENT OF ROBERT J. CATLIN, DIRECTOR,
9 DIVISION OF ENVIRONMENTAL AFFAIRS,
10 U.S. ATOMIC ENERGY COMMISSION,
11 WASHINGTON, D. C.
12
13 MR. CATLIN: Mr. Chairman, conferees, ladies and
14 gentlemen,
i
15 My name is Robert Catlin. I am the Director of
16 the Division of Environmental Affairs of the U.S. Atomic
17 Energy Commission, and I am accompanied here today by Mr.
Walter Belter, also of the Division of Environmental Affairs.
19 We appreciate the opportunity to present a state~
20 ment at this, the Fourth Session of the Lake Michigan
Enforcement Conference,
22 At the Third Session of the conference held in
23 May 1971 —
MR. MAYO: Excuse me, Mr. Catlin,
I have a request to make to the press. If the
-------
R. Catlin
lights currently aren't in use, would it be possible for
them to be turned off? They are quite uncomfortable. We
are more than pleased to have them on when they are being
5 used for camera work; we have no objection at all. But
6 when they are not being used, it is quite an eye strain.
7 Thank you very much.
MR. CATLIN: At the Third Session of the conference
held in May 1971, Mr. Enrico Conti presented a statement on
10 behalf of the Atomic Energy Commission in connection with
11 its developmental responsibility concerning the report of
12 the conference's Technical Committee on Thermal Discharges
13 to Lake Michigan dated January 29, 197L It will be my
14 purpose to update that presentation.
1$ In so doing, I will make certain observations on
16 the activities conducted pursuant to the AEC's regulatory
17 authority during this last year. I do not purport to speak
for the regulatory arm of the Commission since, under the
statute, their regulatory role is separate and apart from
20 | the developmental and research role of the Commission which
21 I represent. Moreover, decisions in several Lake Michigan
22 [ licensing actions are presently pending in the regulatory
process. Since the Commission may be the final arbiter of
these cases, my remarks — in total — will review present
activities rather than present a statement of policy on the
-------
535
1 R. Catlin
2 part of the Commission or its staff.
3 At the risk of intrusion into the legal field, I
4 will briefly review several developments that relate to the
5 subject of this conference on thermal water quality standards^
6 They relate to the role of the AEG — through its regulatory
7 branch — in its address to specific nuclear licensing
8 actions affecting the Great Lakes, and will serve to put in
9 context the environmental statements that have become avail-
10 able on Lake Michigan plants.
11 On July 23, 1971, the U.S. Court of Appeals for the
12 District of Columbia Circuit rendered its decision in Calvert
13 Cliffs Coordinating Committee, lac, .v.a... Atomic Energy
14 I Commission. This decision was principally directed toward
15 an interpretation of the scope of the National Environmental
16 Policy Act and the AEC's responsibilities related to the
17 implementation of this Act.
13 On September 9, 1971> in response to the Court's
!9 I conclusions, the AEG issued an amendment to Part 50, Appendix
D, of its regulations. A copy of the revised Appendix D
regulations is enclosed to my statement for inclusion in
22 the record of this hearing.
2 3 (The document above referred to follows in its
entirety, and is identified as Enclosure 1.)
i
25
-------
PART 50 - LICENSING OF PRODUCTION AJSu , il. i/.All ON "W!' I i , ,-
(As revised September 9,
1971—includes correction
of September 21, 1971, and
further amendments of Sep-
tember 30, 1971)
APPENDIX D-—INTERIM STATEMENT OF GEN-
ERAL POLICY AND PROCEDURE- IMPLEMENTA-
TION OF THE NATIONAL ENVIRONMENTAL
POLICY ACT OF 1969 (PUBLIC LAW 91-190)
INTRODUCTION
On July 23, 1971, the U.S Court of Appeals
for the District of Columbia Circuit rendered
Its decision in Calvert Cliffs' Coordinating
Committee, Inc , et al. v. United States
Atomic Energy Commission, et al , Nos. 24,839
and 24,871, holding that Atomic Energy Com-
mission regulations for the implementation
of the National Environmental Policy Act of
1969 (NEPA) in AEG licensing proceedings
did not comply In several specified respects
^7 with the dictates of that Act, and remanding
o the proceedings to the Commission for rule
00 making consistent with the court's opinion,
~~ The Court of Appeals' decision required, in
* summary, that the Commission's rui^s make
provision for the following -
0 1. Independent substantive review of en-
M vironmental matters in uncontested as well
as contested cases by presiding Atomic Safety
and Licensing Boards
2. Consideration of NEPA environmental
issues in connection with all nurlear power
reactor licensing actions which took place
after January i, 1970 (the effective date of
NEPA)
3 Independent evaluation and balancing
of certain environmental factors, surh PS
thermal effects, notwithstanding the fact
that other Federal or State agencies have
already certified that their own environ-
mental standards are satisfied by the pro-
posed Met- ing action In each individual
case, the benefits of the licensing action
must be assessed and weighed against en-
vironmental co^ts; and alternatives must
be considered which would (.JKL'L tae Bal-
ancing of valxies
4 NEPA review, and appropriate i."ti-.n
after such revlev., for construction permits
issued prior to January 1, 1970, iu ear.es
where an operating license has not a& yet
been issued The court's opinion also states
that, in order that thi-3 rc-^lr--v be as effec-
tive as possible, the Commission should con-
Mdf-r the requirement of a temporary halt
i)i construction pp-iding its revl^iA and the
biickfitiing of tf-Lhiiolo^u',11 inmnalions
As summary background, trie National En-
vironmental FoMrv Act of 1909 (Public Law
91-190) becaiuo <>:1er 11 '>r ex-
ercising AEC responsibilities under the Act
in its licensing proceedings iH5 FR 5463).
Substantial aiaendnients U> At prndix D
were published on December 4, 1970 (35 F R.
18469), and further miner amendments on
July 7, 1971 (36 PR 12731).
The amendments to Appendix D issued
herewith ha\e be^n adopted by the Com-
mission to ina^p Interim changes in its reg-
ulations for implementation of NFPA in
AEC licensing proceedings in light, of the
Court of Appeals' t'ecM^ion
A Basic prGcrdiiit"! 1 Caeh applicant1 for
a permit to cotistrnct a nuclear power reac-
tor, testing facility, or fuel reprocessing"
plant, or such other production or utiliza-
tion facility whose construction or opera-
tion may be determined by the Commission
to have a significant impact on the environ-
ment, shall submit with Ms application three
hundred (300) copies, in the case of a nu-
clear power reactor, testing facility, or fuel
reprocessing plant, or two hundred (200)
copies, !n the case of such other produc
tion or utilization facility, of a separate doc-
ument, entitled "Applicant's Environmental
Report-—Construction. Permit Stage," which
discusses the following environmental con-
siderations
(a) The emirmimental Impact of the
proposed action,
(b) Any adverse emlronmental effects
which cannot be avoided should the propoep-1
be implemented,
(c) Alternatives to the proposed action,
(d) The relationship between local short-
term uses of man's environment and the
maintenance and enhancement of long-term
productivity, and
(e) Any irreversible and irretrievable com-
mitments of resources which would. l>e in-
volved in th*» proposed action should it be
implemented
2. The discussion of alternatues to the
proposed action in the Environmental Report
required by patf-graph 1 shall be sufficiently
complete to aid tb*1 Pom r; listen m develop-
ing and exploring, pursuant to spction 1O2
(2) (D) of the National Environmental Policy
Act, "appropriate alternatives • * * in any
proposal which involves xnmssiMw^i conflicts
concerning alternative u,-->es of available
resources "
3. The Environmental Report required by
paragraph 1 s'vall iiu lude a COPt-benefit
analysis which considers and balances the
environmental effects of the facility and
the alternative ^vaiiab'f f->- i educing or
avoiding adverse envlroni-iejital efferrts, as
well as the env tro'.in.i'ntal, e-K/uo^jJc, tech-
nical and other benefits of the facility The
cost-beiiefH a ia]y; is sh**!l, to tho fullest
1 Where the "applicant", as used in this
appendix, is a Federal agency, different ar-
rangements for Implementing th*> National
Environmental Policy Ac\ may be made, pt*r-
suant to the guidelines established by the
Council on Knvironrorutftl Quality.
< A * i pun u. <*.!,:.* -_u<'.ii!ity Uie various fac-
r,-r i i. - M UifTfNl 'f o 1 ne extent that such
i,. "> tann a ! o juaiit'iijPd, they shall be
diccu ^T''t in iiitti' -P tx?rmK The Envlron-
nu'iit i.' K«'pMt -O.M • tain sufficient data
t-( n,,nis- u . -, its development of
aii independent c-x^t-benefit analysis cover-
irg the factors specified in this paragraph
4 Hie Environmental Report required by
par'\gra})h 1 phall include a discussion of
tlit* st it us nt C'Miiphanoc of the facility with
apjJu aMf: em iron mental quality standards
and requireme'its fit eluding, but not limited
to Jiorin.i] .tnd <. itwr water quality standards
pr'ntiul^iirel uit it-i t'u- ^edei.J Vivt^r Pol-
liiLJon Conrrcu Ai ?) whK h nave beoi, imposed
by Federal, Stare, and reiiional agencies hav-
ing reF-p^nsibil'f v for en\ iroriment^' protec-
tU'ii In addiLio.,, ('.V p'i\ iionineiital impact
of the fac'lity -hail be fully discussed with
respect to matters covered by such standards
and requirement*, irrespective of whether a
certification from the appropriate authority
has been obtained (including, but not lim-
ited to, any certification obtained pursuant
to section 21 (n) of the Federal Water Pol-
lution Control Act-). Such discussion shall
bt3 refltHUed. In the cost benefit analysis pre-
scribed in paragraph 3 While satisfaction of
AEG standards and criteria pertaining to
radiological effects will be necessary to meet
tho licensing requirements of the Atomic
Energy Act, the cost-benefit analysis pre-
scribed in paragraph 3 shall, for the purposes
of the National Environmental Policy Act,
consider the radiological effects, together
with the thermal effects and the other en-
vironmental effects, of the facility
5 Each applicant for a license to operate a
production or utilization facility described in
paragraph 1, shall submit with his applica-
tion three hundred (300) copies, in the case
of a nuclear power reactor, testing facility,
or fuel reprocessing plant, or two hundred
(200) copies, in the case of any other pro-
duction or utilization facility described In
paragraph 1, of a separate document, to be
entitled "Applicant's Environmental Re-
port--Operating License Stage," which
discusses the same environmental considera-
tions described in paragraphs 1-4, but only to
the extent that they differ from those dis-
cussed in the Applicant's Environmental
Report previously submitted in accordance*
with paragraph 1 The "Applicant's Environ-
mental Report - Operating License Stage"
may incorporate by reference any informa-
tion contained In the Applicant's Environ-
mental Report previously submitted In
accoi dance with paragraph 1. With respect
to the operation of nuclear power reactors,
the applicant, unless otherwise required by
the r >mmlsstoii, shall submit the "Appli-
cant's Environmental Report—Operating
I,'cense Stage" only in connection with the
first 11 reusing action that would authorize
full-power operation of the facility,5 except
that such report shall be submitted in con-
nection with the conversion of a provisional
operating license to a full-term license.
6 After receipt of any Applicant's Environ-
mental Report the Director of Regulation
or bis designee will cause to be published in
the FFUERAL REMOTER a summary notice of
the a\ ^liability of the report, and the report
will be placed In the AEC's Public Document
Rooms at 1717 H StreH I*W . Washington,
IX', and In the virlnlty of the proposed site,
and will be made available to the public at
aNo p«a-mlt or license will, of r,.urse, be
Issued with respeot to an activity 'or which
a certification required by section 21 (b) of
the Federal Water Pollution Control Act haa
j-ot been obtained.
'This report is In addition to the report
reqair^d at the construction permit stage.
October 15, 1971
16 Id
-------
PAKT
!CtNSiN(, OF FKoDUC'nON AND UTILIZATION FACILITIES
the appropriate State, reglon&l, «*u< i>»^Uv>
politan clearinghouses.' In addition, a pi,i,'lo
announcement of the availability of tat re-
port will be made. Any comments by irnar-
estca persons on the report will be coru^ j««d
by the Commission's regulatory staff, uud
there will be further opportunity for public
comment 111 accordance with paragraph 7.
The Director of Regulation or his debigiHxi
will analyze the report and prep^it- a draft
detailed statement of environmental con-
siderations. The draft detailed statement will
contain an assessment of the matters speci-
fied In paragraph 1; a preliminary COM
benefit analysis based on the factors speclflei
In paragraph 3; and an analysis, pursuant to
section 102(2) (D) of the National Environ-
ments.! Policy Act, of appropriate alternatives
to the proposed licensing action in any case
which Involves unresol"td conflicts concern-
Ing alternative ir-s of available resources
(I.e., an analysis o- iltematlves which would
alter the environmental impact and the cost-
beneflt balance). The Commission will then
transmit a copy of the report and of the draft
detailed statement to such Federal agencies
designated by the Council on Environmental
Quality as having "Jurisdiction by law or
special expertise with respect to any environ-
mental Impact Involved" or as "authorized to
develop and enforce environmental stand-
ards" as the Commission determines are ap-
propriate,' and to the Governor or .appropri-
ate Btate and local officials, who are author-
ized to develop and enforce environmental
standards, of any affected State The trans-
mlttal will request comment on the report
and the draft detailed statement within
forty-flve (46) days In the case of Federal
agencies and seventy-five (76) days in the
case of State and local officials, or within
such longer time as the Commission may
deem appropriate. (In accordance with 5 2.101
(b) of Part 2, the Commission will also send
a copy of the application to the Governor
or other appropriate official of the State In
which the facility la to be located and will
publish In the FEDERAL REGISTER a notice of
receipt of the application, stating the pur-
pose of the application and specifying the
location at which the proposed activity will
be conducted.) Comments on an "Applicant's
Environmental Report—Operating License
Stage" and on the draft detailed statement
prepared In connection therewith will be re-
quested only as to environmental matters
that differ from those previously considered
at the construction permit stage If any such
Federal agency or State or local official fails
to provide the Commission with comments
within the time specified by the Commission,
«Su3li clearinghouses have been estab-
lished pursuant to Office of Management and
Budget Circular A-95 to provide liaison and
coordination between Federal and State,
regional or local agencies with respect to
Federal programs. The documents will be
made available at appropriate State, regional
and metropolitan clearinghouses only with
respect to proceedings in which the draft
detailed statement Is circulated after
June 30, 1971, In accordance with the
"Guidelines on Statements on Proposed Fed-
eral Actlonu Affecting the Environment" of
the Council on Environmental Quality (38
F.B. 7724).
• Requests for comments on Environ-
mental Reports and draft detailed statements
from the Environmental Protection Agency
will Include a request for comments with re-
spect to water quality aspects of the pro-
posed action for which a certification pursu-
ant to section 21 (b) of the Federal Water
Pollution Control Act has been Issued, and
with n«i>«ot to aspect* of the proposed action
to which section 900 of the Clean Air Act to
•HptiMbt*.
1* will tic j i.-.M.mea thai the «£em'y „> >ff,cl«J
h«vS i.o ,.\>nauent U. make, miles*. ", specific
extension of time has been requested
7 in addition, upon preparation v>f & draft
deWI-xI st&teuitiiit, the Comml.'wti/i; win
cause to to ijubllsheti ii* the FETJERM Peuis-
TER a aumnituy notice of the availability of
the Appik-nit's Environmental Report and
the draft detailed statement Thtj summary
notice to be , ublished pmauant to '.hi;; para-
graph w'.U icquest, within seventy-five (76)
days '^\ such lunger r/rn 'd Ui the Commission
may determine tu rx- practli,a^ie oommetit
srom UitoiebU". ^.-i,v>:5 on the proposed
action oiid on the draft statement Trie sum-
mary notice will also contain a statement to
the effect that the comments "tf Federal
agencies and State and local officials thereon
will be available when received •
8 After receipt ol the comments requested
pursuant 10 paragraphs H and 7. the Dheotur
of Regulation or his dcr.lgnee will prepaie
a final detailed statement on the environ -
mental considerations apeclned in phrft^r^pn
1, including a discussion of problems (rid ob-
jectioiis raised by Federal, State, and local
agencies or officials and private organization:
and indr'l.l'ials H >^l i.h" .>• -),... ",:ui> :,i i-re.rf
The deta'-^d statement wl't .ontol.i a Ha.iz
cost-benefit R^vlysls which ror.Mflens anri
balances the environmental ef the
facility and the altern'it: v?n avalle'M? /or re-
ducing 01 avoiding adverse environmental ef-
fects, as well as tLe cnviionruentai, e^onord",
technical, and other benrnts of tbs facility.
The cost-benefit analyst will, to the lullest
extent practicable, quantify the vrrSo-Js fac-
tors considered. To the extent that such fac-
tors cannot be quantified, they will be dis-
cussed in qualitative terms. In the case of
any proposed licensing action ihat involves
unresolved conflicts concerning alternative
uses of available resources, the Detailed
Statement will contain an analysis, pursuant
to section 102(2) (D) of the National Envi-
ronmental Policy Act, of alternatives to the
proposed licensing action which would alter
the environmental Impact and the cost-
benefit balance. Conr-pllancc of facility con-
struction or operation with environmental
quality standards and recjulrements (includ-
ing, but not limited to, thermal and other
water quahtj standards promulgated under
the Federal Water Pollution Control Act)
which have been Imposed by Federal, State
and regional agencies having responsibility
for enviroiu-uertal protection will receive due
consideration In addition, the environmental
impact of the facility will be con^lde^^u in
the cost-benefit analysis with respect to
matters covered by ouch stanrfurds ana re-
quirements, Irrespective of wher.htv y. certi-
fication from the appropriate autriurlty has
been obtained (including, but not limited to,
any certification obtained pursuant to sec-
tion 21 (b) of the Federal Water Pollution
Control Act' ). While satisfaction of AEC
standards and criteria pstr ,',-L! >;i penult With respect to the opera-
tion of nuclear power reactors, It is expected
that In most cases the detailed statement will
be p epared only in connection with the first
licensing action that authorizes full-power
operation of t^.e facility,8 except that such
a detailed statement will be prepared in con-
reci.iui with the conversion of a provisional
ipti atir.g license to a tall-term license
o The Commission will transmit to the
Oc ut'Ci' on Environmental Quality copies of
>ui ,-„> -n Applicant's Environmental Report,
•;h) «tt.:r> draft detailed statement, (c) com-
•Tu-uLu uiereoa received from Federal, State,
<*nd local agencies and officials and private
organizations and individuals, and (d) each
detailed statement prepared pursuant to
paragraph 8. Copies of such report, draft
statements, comments and statements will
be made available to the public as provided
in this appendix and as provided in 10 CFR
Part. 9 * and will accompany the application
through, and will be considered in, the Com-
mission's review processes. After each detailed
statement becomes available, a notice of Its
availability will be published In the FEDERAL
REGISTER, and copies will be made available
to appropriate Federal, State and local agen-
cies and State, regional, and metropolitan
clearinghouses.' To the maximum extent
practicable, no construction permit or operat-
ing license in connection with which a de-
tailed statement Is required by paragraph 8
will be issued until ninety (90) days after
the draft detailed statement so required has
beon circulated for comment, furnished to
the Council on Environmental Quality, and
made available to the public, 'and until thirty
(30) days after the final detailed statement
therefor has been made available to the
Council and the public If the final detailed
statement Is filed within ninety (90t days
after ft diaft statement has been circulated
for comment, furnished to the Council and
made available to the public, the thirty (30)
day period and ninety (90) day period may
run concurrently to the extent that they
overlap In addition, to the maximum extent
practicable, the final detailed statement will
be publicly available at least thirty (30) days
bel'ore the commencement of any related
evidentiary hearing that may be held.
10. Irx a proceeding for the issuance of a
construction permit or an operating license
for a production or utilization facility de-
scribed In paragraph 1 in which H hearing is
held, the Applicant's Environmental Report,
comments thereon, and the detailed state-
ment will be offered in evidence. Any party
to the proceeding may take a position and
offer evidence on environmental aspects of
8 This statement is In addition to the state-
ment pi epared at the construction permit
stage
• 10 CFR Part 9 Implements the Freedom
of Information Act, section S51 of title 6 of
the United States Code-.
October 15, 1971
163e
-------
PART 30 - LICENSING OF PRODUCTT<:r:
the propoeed licensing action in accordance
with the provisions of Subpart G of 10 CFR
Part 2.
11. In » proceeding for the twuanee of a
construction permit for a production or uti-
lization facility described In paragraph 1,
and in a proceeding for the issuance of an
operating license In which a hearing is held
and matters covered by this appendix are
In Issue, the Atomic Safety and Licensing
Board will (a) determine whether the re-
quirements of section 102(2) (C) and (D)
of the National Environmental Policy Act
and this appendix iiave been complied with
in the proceeding, (b) decide any matters in
controversy among the parties, (c) deter-
mine, In uncontested proceedings, whether
the NEPA review conducted by the Commis-
sion's regulatory staff has been adequate, and
(d) Independently consider the final balance
among conflicting factors contained In the
record of the proceeding for the permit or
license with a view to determining the ap-
propriate action to be taken.
The Atomic Safety and Licensing 3oard,
on the basis of Its conclusions on the above
matters, shau determine whether the permit
or license should be granted, denied, or ap-
propriately conditioned to protect environ-
mental values The Atomic Safety and Ll-
c°nslng Board's initial decision will Include
findings and conclusions which may affirm
or modify tbe contents of the detailed state-
ment described In paragraph 8 To the ex-
tent that findings and conclusions different
from those In the detailed statement are
reached, the detailed statement shall be
deemed modified to that extent and, as modi-
fled, transmitted to the Council on Environ-
mental Quality and made available to the
public pursuant to paragraph 9 If the Com-
mission or the Atomic Safety ana Licensing
Appeal Board, In a decision on review of the
Initial decision, reaches conclusions different
from the Atomic Safety and Licensing Board
with respect to environmental aspects, the
detailed statement shall be deemed modified
to that extent and, as modified, transmitted
to the Council on Environmental Quality
and made available to the public pursuant
to paragraph 9.
18 The Atomic Safety and Licensing
Board, during the course of the hearing on
an application for a license to operate a pro-
duction or utilization facility described In
paragraph 1, may authorize, pursuant to
f 60.57(c), the loading of nuclear fuel in the
reactor core and 1 imlted operatlon *!tliln
the scope of 5 60 67 (c), upon compliance
with the procedures described therein.
Where any party to the proceeding opposes
euch authorization 011 the basis of matters
covered by this appendix, the provisions of
paragraph 11 shall apply In regard to the
Atomic Safety and Licensing Board's deter-
mination of such matters Any license so
Issued will be without prejudice to subse-
quent licensing action which may be taken
bv the Commission with regarrt to the en-
vironmental aspects of the facility, and eny
license issued will tie conditioned to that
effect
13 The Commission will incorporate In all
construction permits and operating licenses
for production and utilization facilities de-
scribed iu paragraph 1. a rendition, In addi-
tion to any conditions Imposed pursuant to
paragraph jl, to U":e effevt that, uie licensee
shal! pr*erve such standards and require-
ments for trie prdX'CtJon of the environment
as are salldly imposed pursuant to authority
established under Fvdeial and State law
and as are determined by the Commission to
be applicable to the facility that is subject
to the HceiiSlTig a *Adr» Involved This con-
dition will not apply to radiological effects
«*nc* r*dkri<«*c*l affects are *MU vfttli in
«rth« provisions of tb« construction p*nealt
*s4 operating license
14 The Cornmissioi- hat, de-term lued Ctaa
the following activities subject to materials
licensing may also significantly affect the
quality of the environment. " (ft) Licenses
for possession and use of special nuclear ma-
terial for process! rig and fu^l fabrication,
scrap recovery and conversion of uranium
hexaffuoride; (b) licenses for possession and
use of source material for uranium milling
and production (4 uranium hexafiuoride, and
(c) licenses authorising commercial radio-
active waste disposal fry land burial Appli-
cants fe context may >i\. -rwlse require,
procedures and measures sin'liar to those
described In Sections A, B D, und E of this
appendix will be followed Mi prcw^edinps for
the Issuance of si- pr^ediires
and measures to oe followed with respect- to
materials licenses will, of course, reflect the
fact that, unlike the licensing of production
and utilization far ill ties, the licensing of
materials does not require separate authori-
zations for construction and operation Ordi-
narily, therefore, there will be only one Ap-
plicant's Environmental Report required and
only one detailed bxatemeut prepared in con-
nection with an application for a materials
license If a propoeed subsequent licensing
action involves environmental considerations
which differ significantly from those dis-
cussed in the Environmental Report filed and
the detailed statement previously prepared
In connection with the original licensing
action, a supplementary detailed statement
will be prepared. In a proceeding for the Is-
suance of a materials license within the pur-
view of this paragraph where the require-
ments of paragraphs 1-9 have not as yet been
met, the activity for which the license Is
sought may be authorized with appropriate
limitations, upon a showing that Uie conduct
of the activity, so limited, will not have a
significant, adverse Impact on the quality of
the environment In addition, the Commis-
sion recognizes that theie uiay be other cir-
cumstances where, coruslsU,nt with appropri-
ate regard for environmental values, the con-
duct of such activities may be warranted dur-
ing the period ol the ongoing NEPA environ-
mental review Accordingly, the activity for
which the license is sought may be author-
ized with appropriate limitations after con-
sideration and balancing of the factors
described below Provided, howevi'r. That
such activity may not be authorized for a
period in excess of four (4) months except
upon specific prior appiovai of the Com-
mission Such approval will be ex tend*-d only
for good cause shown
(a) Whether K is likely tnat the activity
conducted during the prospective review
period will give rise to a significant, adverse
impact on the environment,, the nature and
extent of such Impact, if any, and whether
ledress of any such adverse environmental
impact can reasonably be effected should
modification f the license re-
sult from the ongolrif NEPA environmental
review
(b1 Whether the activity i'i inducted dur-
ing Uie piospeeuve review ptnod would fore-
close subsequent, adoption of alteinaUves In
the conduct of the activity of the type that
could result from Uie ongoing NEPA environ-
mental review.
(c) The effect o' deJAy lu iii«» conduct cf
the activity upon the public Interest. Of
"Additional activities subject to materials
U con King may be determined to significantly
*ff«ct tH* quality of tb* eDvtronmeat goA
thus be subject to the provision* ,nder this criterion ar«
the nettfti t*> txe staved by the conduct of tb«
activity, the availabiLty of alternative
•sources If any, to mert those necxls on a
timely basis; and delay costs to the licensee
and to consumers
Any license so Lssued will be without prej-
udice to subsequent licensing action which
may be taken bv the Commission with re-
gard to the em Ironmental aspects of the
activity, arid any license issued will be con-
ditioned to that effect
B Procedure!- f >r 7r»ieic of certain licenses
to construct or operate production en utiliza-
tion facilities and certain licenses for source
material, rpecial nuclear material and by-
proditCt vtatenat innued (n the period Jan-
uary i 1970— September *, 19*1
1 All holders of (A) construc-
tion permits or operating licenses for pro-
duction or utilisation facilities of the type
described In section A 1, (b) licensee for pos-
session and use of special nuclear material
for processing and fuel fabrication, scrap
recovery and conversion of uranium hexa-
fluorlde !c) licenses for possession and use
of source material for uranium milling and
production of uranium hexafluorlde, and (d)
licenses authorizing commercial radioactive
waste disposal by land burial. Issued during
the period January 1, 1970—
September tvitflj •&*;! submit,
«s soon as possible, tout no later than (sixty
<«o) days after,September 9r 1&71
or ruch later date as may be
approved by the Commission upon good cause
shown, the appropriate number of copies of
an Environmental Report as specified In sec-
tion A 1-5.
If an Environmental Report had been sub-
mitted prior to the Issuance of the permit
or license, a supplement to that report, cover-
ing the matters described in section A 1-5
to the extent not previously covered; may be
submitted In lieu of a new Environmental
Report
2. After receipt of any Environmental Re-
port or any supplement to an Environmental
Report submitted pursuant to paragraph 1
of this section, the procedures set out in
section A 6-9 will be followed, except that
comments will be requested, and must be
received, within thirty (30) days from Federal
agencies, State and local officials and inter-
ested persons on Envlronmetal Reports and
draft detailed statements If no comments
are submitted within thirty (3O) days by
such agencies, officials, or persona, It will be
presumed that such agencies, officials or per-
sons have i!O comments to make. The detailed
statement (or supplemental detailed state-
ment, as appropriate) prepared by the Direc-
tor of Regulation or his designee pursuant to
section A 8 mill, on the basis of the analyses
and evaluations described therein, include a
conclusion by the Director oT Regulation or
his designee as to whether, after weighing
the environmental, economic, technical and
other benefits against environmental costs
and considering available alternatives, the
action called for is continuation, modifica-
tion or termination of the permit or license
or Ita appropriate conditioning to protect
environmental values
3. Upon preparation of a detailed state-
ment or supplemental detailed statement as
specified in section A 8 and paragraph 2 of
this Ejection B, the Director of Regulation
will, in the case of a construction permit
for a nuclear power or test reactor or a fuel
reprocessing plant, publish In the FEDERAL
REGISTEE a notice of hearing, In accordance
with f 2 703 of this chapter, on NEPA envi-
ronmental Issues as defined in section All,
which hearing notice may be Included In the
notice required by paragraph 2. Upon prepa-
rftOoc at * (ftvteUwl staUmeat or Mppfemea-
t*l detailed statement M specified to Motto*
A 8 and paragraph 3 of this section B for
October 15, 1971
-------
PART 50 - LICENSING JF PR.'JOCfION AND UTILIZATION FACILITIES
any other permit or license for a facility if
a typa described In section A.I, the nir»c'or
of Regulation will publish a notlix In Uie
VEKLRAI. BEOISTKS, whicb may be U.eludt-rt
In the notice required by paragraph 2, setting
form t-.'f, or Sis deslgnee's, conclusion as to
whether, after weighing the environmental,
economic, technical and other benefits
against environmental costs and considering
a' allable alternatives, the action called for
Is continuation, modification or termination
of the permit or license, or appropriate con-
ditioning to protect environmental values
and providing that, within thirty (30) days
from the date of publication of the notice.
the holder of the permit or license may file
a request for a hearing and any peison whose
interest may be affected by the proceed!i ~
may, In accordance with § 2714 ot this chap-
ter, file a petition for leave to Intc-rvene and
request a hearing In any hearing : eM pur-
suant to this paragraph, .he pr< -Ifions of
sections A 10 ar 1 -I will apply. I.' Com-
mission or the presiding Atomic Surety and
Licensing Board, as appropriate, may pre-
scribe the tiros within which proceedings, or
airy portions thereof, conducted pursuant to
this paragraph will be completed.
C. Procedures for review of certain con-
struction permits for production or utilisa-
tion facilities issued -prior to January 1, 19?0,
tor uhicti operating licenses or notice of
npp^rtuniti} for hearing on the operating
license application have not been issued.
1. Each holder of a permit to construct
a production or utilization facility of the
type described In section A1 issued prior
to January 1, 1970, for which neither an
operating license nor a notice of opportunity
for hearing on the operating license appllca-
tlon had been issued prior to September 9,
1971, shall submit the appropriate number
of copies of an environmental report as
specified in sections A.1-4 of this Appendix
is soon as possible, but no later than sixty
(BO) days after September 9, 1971, or such
later date as may be approved by the Com-
mission upon good cause shown. If an envi-
ronmental report had been submitted prior
to September 9, 1971, a supplement to that
report, covering the matters described In sec-
tions A 1—4 to the extent not previously cov-
ered, may be submitted In lieu of a new
envu ournental report.
2. Upon receipt of an Environmental Re-
port or supplemental Environmental Report
submitted pursuant to paragraph I. the pro-
cedures set out In section A. 6-9 will b«
followed, except that comments will be re-
quested, and nvist be received, within
thirty (30) days from Federal agencies, State
and local officials, and Intereeted persons on
Enviromnentai Reports and draft detailed
statements. H no comments are submitted
within tb'.-tv (30) days by such agencies,
Officials o« persona. H will be presumed that
4uch agencies, officials or persons have no
comment to make. The detailed statement
(or supplemental detailed statement, as ap-
propriate) prepared by the Director of Regu-
lation or his deslgnee pursuant to section
AS will, on the basis ot the analyses and
evaluations described therein, Include a con-
clusion as to whether, after weighing the
envisou;nentaj, economic, technical and other
beaeflta against environmental costs and
considering available alternatives, the action
nailed for is the continuation, modification
or termination of the construction perrnit or
Its appropriate condltlonng to protect en-
virontnental values Upon preparation of the
detailed statement, the Director of Regula-
tion will publish In the FSDIRAL REOISTD a
notice, which may be Included In the nolle*
required by section A 9, seeing forth hU, or
hlo assignee's, conclusion as respects th«
oouUnuatton, modlfioattoti or termlrurttoo
of tb« oooBtruetton permit or I*8 appropM»t*
ooQAHtonlng to ptoteet envloram«nt«l
values. Tbc notice wffi jrovlde that within
thirty (SO) A*y« from tt* date of It* puMt-
Uctober 15, 1971
e"tion, any person wliooe Interest may b&
atfccted by the :>r« ,• -i'-i;; i:iay nlo ,iu ai;b'>-,T
to the naUnued !j;.*ainfcd,
terminate.! cr condltionrd is proposed Iny
such person nay, 311 'T' rdarme w th § 2 714
of i-hLs chapter, lile a p'HUAn foj Jeav'e to
intervene &• ' requrtU 'i healing In p.n?
hearing, the piovisions "f section A 10 ana 11
will apply u. th,- extent 1 ertlner.t The Com-
mission o. the jirwHiu^ Atomic Safety and
Licerr-in^ s>>uj-.' at. Fj^m^rlate, !~iay pie-
scribe i he o:ne yithin which proceedings, or
any por\U>ns thereof ronch'rtcrl pvirsvarit to
this pan-.f;! an1? */.:. .0 - ducted
3 The re. it •• „. , ', ir.mmentM /inU»rs
conduced In accordance with this tecilon O
win not be duplicated at the operating ilcen^**
stage, absent new significant lii Tor'nation
relevant to these mattere
D. Procedures applicable to pending ^tar-
ings or proceedings to b« noticed in tr-.f. mar
future. 1 In proceeding in whlcfi hearing
are pending as of September 9,1971
or In which a draft or
final detailed statement ot environmental
considerations prepaiert oy the Director of
Regulation or hie Jddienae has been eij'< u
lated prior to said d&U-, Uie jp-'sidii,^ .V/.>m4c
Safety and Liceii'hi;. L.u ,""x,, prooe i e.\per*roatk>n
related t«> the O^rnir1^ Ion's 5ic-f i&u$ re-
quirement,., under the .'tomlc Energy Act
pending the submission of Enviro'.'ae!!-,^
Reports and detailed statements as -,;.u;;fied
in section \ and complUfH'? with oVner pp.
pllcable ^qulrem-;n^p -"-f (-.•. ti<^n A A supple-
ment to the EliUi >nm«.tai Repoi-t, cover-
ing the matters described in Section A 1-4
to the extent not previously covered, may be
submitted in lieu of a r ew Env!r >nmental
Report Upon rcuelpl of tho supplem6!':ai
Environmental Report, tl.'i procedures set out
In section A 6- 9 will be followed except tbat
comment/. ,vill be refiue^tcd. and n^'ibt be re-
ceived, -within thirty (30) days fronx FeOeral
agencies, State and local officials, and inter-
ested persons on environmental reports and
draft detailed statements I* no comments
are submitted within thirty (30; days by
sucii agencies, officials, or persons, It will be
presumed that such agoni les, officials or per-
sons have no comment to n-jtke In uny sub-
sequent session of the hearing ri^ld on t.Ue
matters covered by thii, lippendix, the pro-
visions of section A 10 and 11 will fcuply to
the extent pertinent. The OorarfLSsxjlon or the
presiding Atomic Safety fuul Lioer.sl-
as appropriate, may prescribe the t'ms
In whicto the proceedini;, or any pwrtlon
thereof, will be completed
3 In a proceeding for the !^ i-si.c^ o>' an
operating license where t'ic )?qu'remuiu« of
paragraphs 1-9 of secttoii A have not a<) yet
been met and the matter Is pending before
an Atomic Safety and Ll.ieu-Stng Roard, the
applicant may make, purt-uant to § 50 67Xc),
a motion In writing for the Issuance of a
license authorizing the londiiig of fue! In ihe
reactor core and limited operation within the
scope of 5 6067(c). Upon a showing on tno
record that the proposed licensing action
will not have a signlflca it, adverse Impact
on the quality of the environment «nd upon
satisfaction of the requirements c-i § fifl 87 (c),
the presldl:ig Atomic Safety and licensing
Board may grant the applicant's motion In
addition, the Commission recognl?/es that
there may be other circumstances where,
consistent with appropriate regard for envi-
ronmental values, limited operation may be
warranted during the period of the ongoing
NEPA environmental review. Such circum-
stances Include testing and verification of
plant performance and other limited activi-
ties where operation can be justified without
prejudice to the ends of environment*] pro-
tection. Accordingly, the p.eaJAtnf
Safety and Licensing Board may, upon satis-
faction of the requirements of 5 60.57(c),
grant a motion, pursuant to that section.
after consideration and balancing on the
record of the factors described below: Pro-
vided, however, that operation beyond twenty
percent (20%) of full power may not be au-
thorized except upon specific prior approval
of the Commission.
(a) Whether it Is likely that limited op-
eration during the prospective review period
will give rise to a significant, adverse impact
on the environment; the nature and" extent
01 suoh Impact, if any; and whether redress
of any such adverse environmental impact
can leasonably be effected should modifica-
tion or termination of the limited license
resuli. from the ongoing NEPA environmen-
tal review.
(b) Whether limited operation during the
prospective review period would foreclose
subsequent adoption of alternatives In fa-
cility design or operation of the type that
could result from the ongoing NEPA environ-
mental review.
(',.) Tlie effect of delay In facility opera-
tion upon the public interest. Of primary
importance under this criterion are the
^oMior needs to be served by the facility; the
&« liability of alternative sources. If any, to
rm-et those needs on a timely basis; and
del iy co'sts to the licensee and to consumers.
If es of this paragraph.
-------
PAK'l '.0 - LICENSING OF PRODUCTION tu'o (' • I L.I /AT! ON FACULTIES
the requirements of paragraphs 1-* at wo-
ttou A have been met, ttee provisions ol Mo-
tion B.3 applicable to operating licensee win
be followed.
E. Contuteration o/ tujpcnoion o/ certain
permits arw! licenses pending NEPA Environ-
mental Review
1 Iti legard to (a) proceedings subject to
Section B othej titan those In which a hear-
lug on an operating licence application has
commenced, (h) proceedings subject to sec-
tion c involving nuclear power reactors and
testing taollltlus." end it) prixx-t/dtngs tr.
which the O j.ii., -j-.. ,u .,-,.,.^.atfco tn»t con-
struction • . 't. a p. fmi' .ml not i>e com-
pleted i,> j»uua.'i.pletl ,r of the ffBPA envi-
ronmental review sneclfiefi in those sections
2. In tojfclclifiK tb« dtet«rtxd nation ctJled for
In paragraph i. tn« Commission will coo-
elder and balance the following factors:
(ft) Whether It le likely that continued
constr.K tton or operation during the pro-
spective review period will give rise to ft
elgulflctuxt exlv«r«t- unp*ft on tbe environ-
ment; the nature and extent of such lin~
p&oc, If &i y trid wjts«tli*r v^lrsftsfi of any such
adverse envl* .mortal ^n^^j . t can reasonably
t«i efrwAwJ M^Luut jM.v,'ti viUion, tfospension
or teriji'.ruxUon of trie ^^i^'Ut or license re-
sult from the '/ngxang NEPA environmental
review
(b) Wr-etlw-r oontlmied oonstmcrtlon or
opernUwa sturlifig tJ>« prtxyttwctlve review pe-
riod would forecl xj* suris^nwent » the 11-
oen«e« attd to c. aevaum
4. The Oonanlaalon will thereafter deter-
mine whether the penult ur Ucen«e BCH1 be
suspended pending NHPA enTlromnental re-
view and will publiih tJdat determination
In the PKDIEAI, REQJSTKB. A public announce-
ment of that determination will also be
made.
(a) If the Commission determines that
tiie permit or license shall be suspended, an
order to show cause pursuant to i 2.202 of
this chapter shall be served upon the li-
censee and the provisions of that section
followed.13
(b) Any person -.\iios« interest may be
affected by the ~p:oceedlJig other than the
licensee, mty file a request for a hearing
within thirty (3O) days after publication
of the CommlBsiun'u d«u:nuu.ation on this
matter in tr*e FEDERAL Rt-Gisrha. Such re-
quest shall set forth the matters, with' ref-
erence to the criteria set out in paragraph
2, alleged to warrant a suspension determi-
nation other than that made by the Com-
•risiton. and rtnll e«t forth the factual b**te
for -«tre request. H the Commission deter-
•Ones that the matter* stated In »uch re-
qne*t warrant a hearing, a notice of hear-
tag will be published in the PKDBUU.
HECISTXX.
(c) The Comrnlsiiuri or the presiding
Atomic Safety and Licensing Board, at ap-
propriate, may prescribe tha tima within
which a proceeding, or any portion thereat,
conducted pursuant to this paragraph shall
be completed.
? Utti n holder or «, pt-t. n <•: !icen.-.e sub-
ject to paragraph 1 of this section E shall
TiirnkA tc. tne Comi!.:-.M(.n before 40 days
afwr September 8 .'B' > ,1 ij'irh later date
as may b« appix)ve\l U^ U:u v,^mii,U»31on upon
KIK^.I cause shown a wrlttva «iatemeut of any
reucx-ns, with suppC'riing factual submission,
why, with retereui-i t._< tr e criteria lu para-
graph 2, the permit or Itoenae should not be
suspended, lu wtou- or !r, piut, pending com-
pletion of the NEPA environmental review
specified 1^ .-,« tmfn, fc i\ tl n Such docu-
ment will be puo'lcJy (.uUlnble and any
Interejlca pfisou ,-ii.i uubmlt comments
thoi't'in to the ."!-.». >•'!. '. , u
Vuel reproceeatng
ilca hiui* oaly ui\* surh
tloit c and U« constiti
11 10 CFR 8.202 among other things, pro-
have been eji- ^ei for rnntlWtlan o/ a proceeding to mod-
»u Is subject «) tfj,, nopend, or nrrofce a license by Issuance
3n Is ,»mpiete. of ^ .,4,, te ^^^ „„„, „„, providce an
opporttufltj for hewing.
16 3h
October 15, 1971
-------
1 R. Catlin
2 The effect of the Court's decision and the revised
3 regulations was to make the AEC directly responsible for
4 evaluating the total environmental impact, including aquatic,
5 terrestrial, and atmospheric effects of proposed nuclear
6 powerplants, and for assessing this impact in terms of the
7 practicable alternatives and the need for electric power.
& Accordingly, AEC licensing regulations now require
9 that Environmental Statements contain a cost-benefit analysis
10 which considers and balances the environmental effects of the
11 facility and of the alternatives available for reducing or
12 avoiding adverse effects, against the environmental, econ-
13 j omic, technical, and other benefits of the facility. On the
14 I basis of these evaluations and analyses, conclusions are
15 reached as to whether, after weighing these factors, the acti
called for should be licensing approval, denial, or appro-
17 priate conditioning to protect environmental values.
Under Section 21 (b) of the Water Quality Improve-
19 ment Act of 1970, the AEC is prohibited from issuing licenses
or permits for activities involving discharges into navigable
waters, without a certification from the appropriate Federal,
State or interstate agency that there is reasonable assur-
ance of compliance with applicable water quality standards.
or
Accordingly, under licensing regulations, compliance with
25
all State, regional, or Federal standards which have been
Dn
-------
5B7
|l
-^ R. Catlin
i
2 established under the Water Quality Improvement Act is a
3 minimum requirement. However, licensing responsibility does
j j
^ not end there.
5 ; MR. MAIO: Excuse me, Mr. Catlin. I think they
i
6 :! are having difficulty in hearing you in the back; and it is
7 ii probably the consequence of two factors: one, there is a
8 ! great deal of noise in the foyer, and perhaps you might
Q i speak just a little bit louder.
H
10 1 MR. CATLIN: I am sorry. I have a case of
11 |! laryngitis, but I will try to do better.
12 ! MR. MAYO: Thank you.
i
13 , MR. CATLIN: However, licensing responsibility
14 does not end there. The regulatory process still requires
15 ; a determination, through balancing of benefits and costs of
16 ; specified cases, whether or not more rigorous limits or
i!
17 j restrictions should be applied.
IB , Since the July 23, 1971, Calvert Cliffs decision,
19 AEG Regulatory has issued 32 draft and 16 final Environmental
20 Statements. Two final statements describe the environmental
21 impacts of nuclear plants constructed or planned for Lake
22 ; Michigan: Point Beach and Palisades. The summaries and
23 conclusions regarding thermal aspects of these two plants
2L* ,. are enclosed for the record. I have copies of the two
25 j| final statements for introduction into the record.
-------
1 R. Catlin
2 Again, since the effects analyzed in these state-
3 ments are pending before the Commission's licensing process,
4 they do not reflect or suggest a final Commission position.
5 They do represent, however, the regulatory staff analysis
6 and position.
7 (The summaries above referred to, identified as
8 Enclosure 2 and Enclosure 3 follow in their entirety.)
9 (The Environmental Statement related to operation
10 of the Palisades Nuclear Generating Plant, Consumers Power
11 Company, Docket No. 50-25$, June 1972, published by the
12 United States Atomic Energy Commission; and the Environ-
13 mental Statement related to operation of Point Beach
1^ Nuclear Plant, Units 1 and 2, Wisconsin Electric Power
15 Company and Wisconsin Michigan Power Company, Docket Nos.
1° 50-266 and 50-301, May 1972, published by the United States
1? Atomic Energy Commission are on file at U.S. Environmental
i #
Protection Agency Headquarters, Washington, D.C. and Region
19 V, Office, Chicago, Illinois.)
I
20
21
22
23
24
25
-------
Enclosure 2
Extracts from Final Environmental St itement
Point Beach Nuclear Plant
Units 1 and 2
(May 1972)
Summary and Conclusions (as related to thermal a ;pects of plant operation)
"This Statement is submitted in relation to the proposed issuance of an
operating license to the Wisconsin Electric Power Company and the Wisconsin
Michigan Power Company for the Operation of the Point Beach Nuclear Power
Plant Unit 2 located in the State of Wisconsin, County of Manitowoc,
near the City of Manitowoc, and includes consideration of the combined
effects of Units 1 and 2. Each unit is a pressurized water reactor
rated at 497 MWe using 1518 MW of heat. The system is designed to utilize
a maximum of 700,000 gpm of Lake Michigan water for direct once-through
cooling."
"Summary of environmental impact and adverse effects:
• No significant adverse impact on air, water, or land resources
is expected.
• Minor impact on aquatic resources from possible entrainment of
plankton and small fish in the intake cooling water and from
temperature increases in the thermal zone of influence by
effluent discharges into Lake Michigan.
• A potential adverse aquatic impact from residual chlorine if
chlorine is used as an antifouling agent.
• A potential long-term aquatic impact from the discharge of
demineralizer regenerant waste."
"Principal alternatives considered:
• Alternative power sources — results in a major increase in
monetary costs, an increase in the acreage of land converted
to industrial use, and an increase in aesthetic impact (i.e.,
visual, noise, air pollution) while producing only a minor
environmental benefit through reduction of heat released to
Lake Michigan.
• Alternative heat dissipation systems — results in a significant
increase in capital and operating costs, an additional loss of
agricultural land, and a potential for atmospheric fogging and
icing while producing only a negligible environmental benefit
through reduction of heat released to Lake Michigan."
-------
— 2 —
"On the basis of :he analysis and evaluation set forth in this state-
ment, after weighing the environmental, economic, technical and other
benefits of the P /int Beach Power Plant against environmental costs
and considering available alternatives, it is concluded that the actions
called for are:
The continued operation of Unit 1 under License No. DPR-24
and the issuance of an operating license for Unit 2."
-------
Enclosure 3
Extracts From Final Environmental Statement
Palisades Nuclear Generating Plant
June, 1972
Summary (As related to the thermal aspects of p]ant operation)
"The present once-through condenser cooling systBm raises 405,000 gallons
per minute (gpm) of Lake Michigan water to 25F° above ambient resulting
in a thermal plume with an area of 370 acres witnin the 3F° excess temper-
ature isotherm. This area represents only 0.002% of the total area of
Lake Michigan. Although these thermal discharges will meet the standards
set for this Plant by the State of Michigan Water Resources Commission,
they will not meet the Environmental Protection Agency's recommendations
for thermal discharges for Lake Michigan after December 31, 1972."
"Although thermal discharges may have localized effects such as inter-
ruption of passage of juvenile fish along the shoreline and thermal shock
on spawning of certain fish, free-swimming biota are not expected to
remain in the mixing zone for sufficiently long :;ime to be adversely
affected. The dominant effect will be the attraction of fish to the warm
water area of the plume, especially during the winter months."
"For the most part fish and free-swimming organisms may avoid impingement
or entrainment in the once-through cooling system because of the location
of the intake crib, which is 20 feet below the lake surface, 6 feet from
the bottom, and 3,300 feet from the shoreline, and the low intake velocity
of 0.5 to 0.6 feet per second. Since zooplankton recover and reproduce
rapidly, the 30% entrained and killed in the cooling water will have a
minimal effect on the productivity of the lake as those killed will serve
as a food base for other biota in the lake."
"The limited chlorine treatment of 1 hour per month at concentration
levels of 0.5 ppm residual chlorine will reduce to a minimal level the
chlorine impact on aquatic life in the vicinity of the Plant."
"Although operation of the Plant with the once-through cooling will cause
an adverse effect on a small fraction of the nearby aquatic community,
the impact is considered to be of little significance on the overall
population levels of biota in Lake Michigan."
"After January 1, 1974, the applxcant is committed, through an agreement
with the intervene.s in the licensing proceeding to have installed and
commence operation of mechanical-draft cooling towers to reduce the
thermal load rejected to the lake. The use of the towers reduces impinge-
ment, entrainment and thermal impact on fish and other aquatic biota.
However, they introduce a long-term adverse impact of chemicals from
continuous blovdown of 1,320 gpm of concentrated salts which would accumu-
-------
- 2 -
late in Lake Michijan over the long-term operation of the cooling towers
and cause serious r.egradation of the water quality of Lake Michigan in the
vicinity of the Pl.-Mt. The increased concentration would result in
phosphate enrichmeit of the lake water and reconcentration of zinc and
chrornate in biota."
"Cooling towers introduce terrestrial environmental impacts on flora
and fauna in the dines from chemicals deposited by the drift, evaporation
of 12,320 gpm of lc ke water, fogging under certain meteorological con-
ditions, and icing in the winter. Although the towers are hidden from
view, they will cat se an adverse aesthetic effect from the lake side and
will have a noise jmpact on the area."
"The" cooling towers will not only require an increase in capital and
operating costs of the order of about $67,000,000 but will result in a
decrease of about 1% in net electircal output due to the electrical pox-^er
required for the fans in the towers."
"Alternatives considered were:
Heat dissipation with mechanical draft cooling towers
Heat dissipation with natural-draft cooling towers and dry
cooling towers
Heat dissipation with cooling ponds and spray ponds
Reduction of thermal effects with a redesigned and relocated
discharge structure
Reduction of chemical effects with a redesigned condenser
cleaning system."
Conclusions:
"On balance, the staff concludes that the minimal ecological impact fore-
seen by operation of the Palisades Plant with once-through cooling docs
not provide sufficient justification for the additional increased cost
to the consumer necessary to provide cooling towers inasmuch as the eco-
logical impact of the cooling towers is minimal and comparable to that of
once-through cooling. Thus, on the basis of the analysis and evaluation
set forth in this Statement, after weighing the environmental, economic,
technical and other benefits of the Plant against environmental costs and
considering available alternatives, it is concluded that the action called
for would be the issuance of an operating license authorizing operation
of the facility with an once-through cooling system."
-------
"The project before the Commission for licensing consideration, however,
is one in which mechanical draft cooling towers are to be installed for
operation by January 1, 1974. Since the ecologi'..'1! impact of the oper-
ation of the Plant utilizing the cooling towers ss proposed by the
applicant is comparable to that associated with operation utilizing once
through cooling, the use of such towers is an accsptable action in terras
of its environmental effects. Accordingly, weighing the environmental,
economic, technical and other benefits of the Palisades Plant utilizing
mechanical-draft cooling towers against environmental costs thereof and
finding no alternatives (other than those specified as conditions below)
which would materially reduce environmental damage or enhance the benefits
compared to the environmental costs, the staff concludes that (despite
the lower cost of the alternative of once-through cooling) the action
called for is the issuance of an operating license, authorizing operation
of the Plant with once through cooling prior to January 1, 1974 and
with mechanical draft-cooling towers thereafter, subject to the following
conditions for protection of the environment:
a. For the period prior to operation with coolin; towers, the following
conditions apply for protection of the environment:
(1) The incorporation of a non-radiological, as well as radio-
logical, monitoring program as required in Appendix B to
Amendment No. 2, for the Technical Specifications to Lir.e.ris^
No. DPR-20.
(2) The performance of a monitoring program to determine:
(a) chlorine discharges and its effects on biota;
(b) size, shape and location of different isotherms of
the thermal plume during different wind and weather
conditions;
(c) thermal discharges and their effects on spawning
fish eggs and larvae and interruption of migratory
paths of fish along the shoreline corridor;
(d) impingement and its effects by counting the number,
types, and sizes of fish collected on the screens and
trash racks of the intake structure, and entrainment
by me"8uring the extent of mortalif and damage of
biota, such as plankton, after passage through the
condenser;
(e) any changes in biota life in botton areas of the lake,
around the intake crib and the discharge canal, and
onthe beach from the operation of the Plant with the
once-through cooling system.
-------
(3) Concurrent development of an affirmative plan of action for
Plant operation to prevent and remedy detrimental effects on
biota, to i.nclude means of reducing cold kills, chlorine
discharges, and to improve dispersion of the thermal plume
through an alternate discharge structure design. Such a plan
shall provide for implementation so as tc eliminate or signi-
ficantly reduce such effects as are revefled by the monitoring
program.
b, For the period that cooling towers are used, the conditions specified
under a., above, plus the following:
(1) Extension of Technical Specifications to include monitoring
of effects of operation with the cooling towers on ter-
restrial biota, including salt deposition from drift and
extent of fogging and icing, and on aquatic biota from
the continuous discharge of chemicals in the cooling tower
blowdown in the lake.
(2) The development and use of alternate methods to effectively
reduce or eliminate the amount and type of toxic chemicals
as corrosion inhibitors and biocides in the operation of
the cooling towers or by treatment of such chemicals to
minimize the impact.
(3) An evaluation of comparative effects of the two alternate
cooling systems on th'e environment."
-------
589
Ro Catlin
The Commission has utilized the services of two
qualified scientific organizations — Oak Ridge National
Laboratory and Battelle Northwest Laboratories -- in prepar-
5 ing these statements. Several organizations have conducted
6 or are conducting research for the development arm of AEC on
7 generic environmental matters relating to the thermal aspects
8 of plant siting. A list of these studies, with pertinent
9 descriptions, and several of the full reports are also pro-
10 vided for the record.
11 (The documents above referred to follow and are
12 identified as Enclosure 4 and Enclosure 5.)
13
14
15
16
17
18
19
20
21
22
23
24
25
-------
Enclosure
AEC PROJECTS RELATED TO THE THERMAL
ASPECTS OF POWER PLANT STTTN3
Thermal Plume Studies
Contractor
Argonne National
Laboratory
Hanford Eng.
Laboratory
Project Description
Joint studies with several utilities in
La
-------
- 2 -
Contractor
Project Description
Region of Study
Holmes & Narver
Johns Hopkins
University
Power Plant Siting Studies
Joint study with California to investigate
and evaluate new and improved methods of
nuclear power plant siting particularly
applicable to ocean coasts
Joint study with Maryland to develop a
framework for identification and evalu-
ation of direct economic costs and external
effects affecting decisions on pDwer
plant siting and design
California
Chesapeake Bay
Fresh Water Bn'ol o^ir-al Studies
Pacific North-
west Laboratories
Fine structural effects of Temperature in
fish
Columbia River
Effects of Modifications on Aquatic
Ecosystems
Effects of Thermal Discharges on Aquatic
Biota
Columbia River
Columbia River
Argonne National
Laboratory
Michigan State
University
University of
Michigan
University of
Wisconsin.
Synergistic Effects of Temperature Pol-
lutants and Disease in Aquatic. Organisms
Great Lakes Thermal Studies
Dissolved Organic Matter and Lake
Metabolism
A Field and Laboratory Study of Nuclear
Power Plant Condenser Effects on Plank-
tonic and Pelagic Organisms
Investigation of the Influence of Thermal
Discharge from Large Electric Power
Station on the Biology and Near-Shore
Circulation of Lake Michigan-Part A:
Biology
Columbia River
Great Lakes
Midwest
Midwest
Lake Michigan
-------
- 3 -
Contractor
Woods Hole Ocean-
ographic Institute
University of
Rhode Island
Virginia Poly-
technic Inst. &
State Univ.
Savannah River
Plant
Savannah River-
Plant
San Diego State
College Foundation
Oak Ridge National
Laboratory
University of
Wisconsin
Project Description
The Effects of Sublethal Tempersture on the
Social Behavior of Fishes
A Model Study of Entrainment Effects on a
Striped Bass (Morone soxatilis)
The Effects of Temperature Shocks from
Thermal Plumes on Invertebrate Drift
Organisms
Thermal Effects on Flowing Streams
Thermal Effects on the Fate of R.idio-
nuclides in Par Pond
Investigations on Physical Processes
Affecting Leaf Temperature Profiles
and Primary Production in the Reg Man-
grove Ecosystem
Thermal Enrichment Studies
Modeling of Populations
Cooling Towers
Microbiology of Thermally Polluted
Environments - Thermal Springs Yellow-
stone Park
Region of Study
Northeast
Northeast
Mid-east
Southeast
Southeast
Southeast
Southeast
Southeast
Southeast
Far West
University of
South Carolina
Duke Univ.
Pacific Northwest
Laboratories
Univ. of Miami
Marine Science
The Response of Estuarine Fish Embryos
to Environmental Temperature Shock
Effect of Cyclic Temperatures on Larval
Development of Marine Invertebrates
Bioenvironmental Effects of Effluent
Discharge from Nuclear Power Plants to
Coastal Waters
An Ecological Study of South Biscayne
Bay and Card Sound, Fla.
Southeast
Southeast
Pacific Northwest
South
-------
Contractor
Project Description
Region of Sfudv
U. S. Dept. of
Commerce
University of
Maryland
Effects of Temperature on the Activity
Feeding of Adult Atlantic Mackeral
Scomber Scombrus
Biological Effects of Nuclear Steam
E.-ectric Station Operations on
E;';tuarine Systems
Northeast
East Coast
Argonne National
Laboratory
Pacific Northwest
Laboratories
Atmospheric Studies
Applied Micrometeorological
Cooling Tower & Cooling Pond Atmospheric
Impact
Great Lakes
Southeast
Westinghouse
Gulf-General
Atomic
Cooling Tower Studies
State-of-the-Art Study of Salt Water
Cooling
Dry Tower Thermal Plume Study
-------
ENCLOSURE
AEC RESEARCI REPORTS ON THE THERMAL ASPECTS OF
POWER PLANT SITING
A. Great: Lake.?; Stu-iics - Argonne National laboratory (ANL) ,
Center for Envii onmental Studies (CES)
*1. Effects of Thermal Discharges on the Mass/Energy Balance
of Lake Michigan, ANL/ES-1.
*2. Physical (Hydraulic) Modeling of Heat Dispersion in Large
Lakes, ANL/ES-2.
*3 . Thermal Plumes in Lakes: Compila tib is of Field Experience,
ANL/ES-3.
4. A Photographic Method for Determining Velocity Distributions
Within Thermal Plumes, ANL/ES-4 .
*5. A Phenomenologi cal Relationship for r'redicting the Surface
Areas of Thermal Plumes in Lakes, ANL/ES-5.
6. Wind Driven Currents in a Large Lake or Sea, ANL/ES-6.
7. A Compilation of the Average Depths of Lake Michigan and
~ T>vT^ V -,* ^ , , «- ~ p ,- 4 ,1 A>TT / r* <"' "1 A
ct JL W V JJ-Ulllik-C- VJ J _L l-l * ^T.1YJJ/I>|» J \i ,
*8. Heated Effluent Dispersion in Large Lakes - S ta te-o f - the-
Art of Analytical Modeling, Part 1. Critique of Model
Formulations, ANL/ES-11.
James River Estuary Study - Virginia Institute of Marine
Science (VIMS)
1. The Design of the Monitoring System for the Thermal Nuclear
Power Plant on the James River, Special Report in Applied
Marine Science and Ocean Engineering Number 16.
2. Thermal Effects of the Surry Nuclear Power Plant on the
James River, Virginia, Part II - Results of Monitoring
Physical Parameters of the Environment Prior to Plant
Operation, Special Report in Applied Marine Science and
Ocean Engineering Number 21.
Thermal Plume Prediction Model Development - Battelle Northwest
Laboratory (BNWL) , Hanf ord Engineering Development Laboratory
(HEJ)L) and Chesapeake Bay Institute (CBI), The Johns Hopkins
University (J11U)
*Reports provided for the Fourth Session of the Lake Michigan
Enforcement Conference, September 20, 1972.
These documents are on file at U.S. EPA Headquarters, Washington,
B.C., and Region V Office, Chicago, Illinois.
-------
— 2 —
1. A Test Simulation of the Temperatures of the Dearfield
River, BNWL~f-28.
2. A Test Simulation of the Temperature cf the Illinois
River and a Prediction of the Effects of Dresden II and
Dresden III Reactors, BNWL-728.
3. Evaluation of the SIMPL-1 Hybrid Computer Concept on a
Water Quality Benchmark Problem, BNWL-1228.
4. Potential Thermal Effects of an Expanding Power Industry:
Ohio River Basin I, BNWL-1299.
*5. Potential Thermal Effects of an Expanding Power Industry:
Upper Mississippi River Basin, BNWL-1405.
6. The Estuarine Version of the Colheat Digital Simulation
Model, BNWL-1342.
7. TOPLYR - A Two-Dimensional Thermal Energy Transport Code,
HEDL-TMS 71-39.
*8. Thermal Effects of Projected Power Growth: Missouri
River Basin, HEDL-TME 71-180.
*9. Potential Thermal Effects of an Expanding Power Industry:
Columbia River Basin, BNWL-1646.
*10. Thermal Effects of Projected Power Growth: Lower
Mississippi River Basin, HEDL-TME 72-69.
11. Ocean Mixing, Technical Report 62, CBI, JHU.
12. A Preliminary Report on the Characteristics of a Heated
Jet Discharged Horizontally Into a Transverse Current
Part I - Constant Depth, Technical Report 61, CBI, JHU.
13. The Distribution of Excess Temperature from a Heated
Discharge in an Estuary, Technical Report 44, CBI, JHU.
14. Design and Siting Criteria for Once-Through Cooling Systems
Based on a First-Order Thermal Plume Model, Technical
Report 75, CBI, JHU.
*15. Thermal Effects and U. S. Nuclear Power Stations,
WASH-1169.
washington-
-------
590
R. Catlin
The Environmental Statements are prepared by
these organizations using all available information per-
taining to the site and environs. In the cases of Palisades
5 and Point Beach, the detailed evaluations of environmental
6 effects suggest that they are local in nature. The evalua-
7 tions concluded that the adverse impacts on the local environ-
ment resulting from operation with once-through cooling would
9 be associated with zooplankton mortality due to entrainment,
10 possible interference with fish movement in shallow waters
11 along the shore, and potentially toxic effects from chemical
12 discharges. However, the statements also present the judg-
13 ment that these effects were of little overall significance
14 due to population distributions and the life habits of the
i
15 important species of biota in the vicinity of each plant.
16 Those effects attributed to thermal discharges in particular
17 were judged to be of little significance due to the low
population densities, avoidance mechanisms, and the minimal
19 spawning areas involved. Available data indicate that
20 those species most abundant in the general vicinity do not
21 extensively use the beach zone during their annual life
i
22 cycles. Further, the benthic organism populations in the
affected nearshore areas are naturally sparse due to the
type of bottom and to scouring wave action.
25 in the case of Palisades and Point Beach, a
-------
591
R. Catlin
2 balancing of environmental and economic impacts from once-
3 through cooling systems against those of alternative cooling
4 systems resulted in the staff conclusion that the added cost
5 of closed cooling systems was not warranted. In the Palisadejs
6 case where the licensee proposed utilizing cooling towers,
7 a favorable licensing recommendation was reached in spite
of the imbalance resulting from the added cost, because the
9 total environmental impacts were judged virtually the same
10 for either system.
11 Recognizing the possibility that species composi-
12 tion and distribution of biota can change due to outside
13 influences, a major condition of every final decision by
14 the Commission to license a nuclear powerplant to date has
15 been a requirement for careful monitoring of appropriate
radiological and nonradiological parameters. This is to
17 assure the continued adequacy of the plant design to protect
the environment. Such programs are on-going for those plants
currently operating, and it appears that they will provide
useful data from operating and proposed plants.
From a practical point of view, we believe that
22 water quality standards for Lake Michigan are desirable and
^ should be established within the framework of our knowledge
^ of the lake and its ecosystems. We believe that care should
be taken that any interim standards resulting from the
-------
592
I
1 R. Catlin
2 considerations of this conference have sufficient flexibility
3 to avoid placing undue stress on adjoining nonaquatic eco-
4 systems. They should permit a reasoned balancing of terres-
5 trial and atmospheric as well as aquatic impacts of proposed
6 projects. Our basic concern is with the adequacy of the
7 amount and depth of available research and knowledge, and
B the basis that presently exists for generalized rules, such
9 as the thermal effects recommendation of last year's con-
10 ference.
11 This evaluation of the total environmental aspects
12 of proposed licensing actions is a Federal mandate, as I
13 have outlined. This mandate is clearly confirmed in recent
1^- court actions providing interpretations of the National
15 Environmental Policy Act. It is also important that water
1^ quality standards reflect the best technical information
17 available from laboratory and field studies, which should
1° take into account the results of pertinent monitoring pro-
19 | grams. The standards should permit optimum use of the lake
as a natural resource, recognizing its effective capacity
as a heat sink as well as its utility for other purposes,
22 ]
1 including aesthetics. The standards should recognize the
detail of the relationship between these effects and uses
i
24
on the basis of sound scientific data.
25
We endorse the suggestion made in earlier sessions
-------
593
!
1 R. Catlin
2 of this conference that a regional coordinating group, with
3 representation by appropriate Federal, State and private
4 organizations be established to oversee the varied research
5 activities that are presently established or planned for
6 Lake Michigan. The AEG, for example, supports varied
7 research activities on the lake in addition to its regula-
8 tory activities. At the University of Michigan, the Commis-
9 sion supports studies on the effects of powerplant condenser
10 effluents on aquatic organisms and research on nutrient
11 enrichment and eutrophication of Lake Michigan. It also
12 supports the University of Wisconsin's studies on the
13 influence of thermal discharges from a large powerplant on
14 I the ecology of nearshore lake waters. Argonne National
15 Laboratory carries out a varied Lake Michigan research pro-
gram with primary concern for the effects of thermal and
17 radioactive discharges into the lake. Several States and
i £
xo private organizations support research on various aspects
of Lake Michigan. Continued evaluation of these individual
programs and establishment of a mechanism for channeling
their results to appropriate regulatory authority could lay
00 j
i the groundwork for establishing a flexible, useful and
23
practical set of regional water quality standards.
^ Thank you.
25 ' MR. MAYO: Thank you, Mr. Catlin.
-------
594
R. Catlin
Are there any comments or questions from the con-
ferees?
4 MR. CURRIE: Yes, I have one, Mr. Chairman.
5 The conclusion that was reached in the two Impact
Statements mentioned was that any adverse effects would be
7 purely local, partly because of the low populations of fish
species in the neighborhood.
I wonder how this squares with Mr. Barber's find-
10 ings, in the first place, that there would be an attraction
11 of fish from the whole general area to the vicinity of the
12 powerplant; and, secondly, that there are rather substantial
13 fish kills that result because of that congregation.
14 MR. CATLIN: Well, Mr. Belter, maybe you would
15 prefer to speak to this.
16 MR. MAYO: As you come to the podium, please
17 introduce yourself.
MR. BELTER: My name is Walter Belter, AEG, Division
19 of Environmental Affairs.
20 The results of these analyses of the two Impact
21 Statements that you make are concerned with attracting fish to
22 the discharge structures. Of course, this is a known fact
23 insofar as any powerplant discharge structures are concerned.
The analyses that were made by our staff, however, did not
' indicate or was not able to reveal any type of information
-------
59$
R. Catlin
on Lake Michigan as far as present powerplant sites were
concerned that have shown this fish kill phenomenon.
I think, as Mr, Barber has indicated, much of the
data is very scarce or lacking insofar as Lake Michigan plants
are concerned, and our ecologists1 evaluation of the data
that we have available — and as I am sure you are aware, in
these statements there are hundreds of references indicated
— we were not able to find informational data to back up the
10 concern for that part of it.
11 MR. CURRIE: You are familiar with the data that
12 Mr. Barber has given?
13 MR. BELTER: Yes. As far as I know, the staff who
14 evaluated both of the two plants that the Environmental
15 I Statements mentioned here, are aware of the data that
16 Mr. Barber has stated. Mr. Barber did give a lot of informa-
17 tion that I think would be worthwhile having time to digest,
1$ such as Mr. Purdy has indicated.
19 We are aware of fish kill data very much so at
20 intake structures, and the data that he quoted certainly at
21 Indian Point is one of the primary concerns, I think, of
22 the Atomic Energy Commission and the whole power industry.
Intake designs are certainly a science, at this point in
time, that is not really developed, and there are, of course,
indications of massive fish kills at certain plants. This
-------
596
1 R. Catlin
2 is not just for nuclear powerplants but for all types of
3 steam electric systems.
4 MR. CURRIE: Yes. Well, I would like to refer to
5 one case that Mr. Barber mentioned, on page 10 of the report,
6 where he talks about January and early February 1971 at the
7- Consumer Power Company's Campbell plant on the eastern shore
& of Lake Michigan, several hundred thousand fish had been
9 killed by impingement.
10 MR. BELTER: Which is an existing fossil fuel
11 plant, correct?
12 MR. CURRIE: That is my understanding.
15 MR. BELTER: Yes.
MR. MAYO: Are there questions from any of the
15 other conferees?
MR. McDONALD: Mr. Catlin, in regard to the bottom
of page 5, top of page 6 of your statement, you talk about
your monitoring program. Do you have available for submis-
1Q
7 sion to this conference the complete details of your moni-
20
toring program from each plant that you have licensed?
i
21
MR. CATLIN: We can certainly make these available
22
' for the record.
23
MR. McDONALD: I think this would be helpful if
24
we could receive this during the next week while the record
25
is open, Mr. Catlin.
-------
597
R. Catlin
2 MR. CATLIN: We would be happy to do so.
3 I MR. BELTER: I might just add to that point: Those
monitoring programs are an integral part of the technical
specifications for those plants and, as such, have been pre-
pared and are part right now of the hearing procedures that
are going on in both of these plants; so the detailed moni-
toring specifications are available for both of the plants.
And, as Mr. Catlin stated, they can be made available
10 readily to the conferees.
11 MR. McDONALD: Have the monitoring requirements
12 been prepared by the applicant?
13 I MR. BELTER: The usual procedure on the prepara-
14 tion of the technical specifications, both for radiological
15 and nonradiological specifications, are prepared in a draft
16 form by the applicant. They are then reviewed by the Commis-
17 sion and its staff, similarly to the review of safety reports.
1° And only after usually very extensive review, discussions,
19 and dialogue concerning these specifications are they then
written up by the AEG and it then actually becomes a tech-
nical specification of the Commission.
22 i
MR. McDONALD: Do you have a set of criteria
27
J against which you review the monitoring requirements, and
2L
do you make these criteria available to the applicant if
25
you do have them?
-------
R. Catlin
MR. BELTER: Right offhand — there are safety
guides that are being prepared — a number of them have been
issued by the AEG. I believe they are up in the twenties
right now. One of these safety guides has to do with criteria
for radiological monitoring of nuclear powerplants. This
has been published and is readily available.
Criteria for nonradiological aspects of powerplants
are at this point in time just slowly being developed. In
10 fact, the preparation of nonradiological specifications has
11 only begun here with the detailed preparation of the Environ-
12 mental Impact Statements, which has taken place here since
13 the Calvert Cliffs decision and really only over the past
14 year.
1$ So those, at the present time, will be different,
16 I would say, for individual plants, depending again on the
17 location and the specific environmental characteristics of
each of the plant sites. These specifications that I have
19 seen anyway are not in that regard standardized but are
20 more in the position of being developed — an involvement
21 type of specification.
22 MR. McDONALD: Are those individual criteria
available?
MR. BELTER: Yes.
25 f/[R. McDONALD: I wonder if those could also be
-------
599
R. Catlin
made available?
MR. BELTER: As part of the safety guides pertain-
'• ing hereto, monitoring can be made available to the con-
•^ i
t, ferees*
£ I (The following documents were submitted by the
'aj ;
!
1 j
7 i| AEC and have been accepted as exhibits on file at U.S. EPA
•* 1 !
3 ! Headquarters, Washington, D.C., and Region V Office, Chicago,
9 Illinois?
0 A. For Palisades Nuclear Powerplant
]_ 1, Radiological and Nonradiological
Technical Specifications
2. Environmental Monitoring Program
3. Administrative Controls, Including
Reporting Requirements
B. For Point Beach Nuclear Powerplant, Unit
No. 1 and Unit No. 2
1. Technical Specifications
2. Appendix B to Facility Operating
License DPR-24 and DPR-27)
-------
600
1
2
8
10
11
12
13
14
15
16
17
19
20
22
R, Catlin
25
MR. McDONALD: In terms of the Environmental Impact
Statements that AEG prepares or has prepared for them —
specifically Palisades and Point Beach — have independent
technical field studies been conducted to support these
statements by AEG?
MR. BELTER: The separate independent field
studies — right now, this is a part of the AEC's program on
Lake Michigan, and our principal contractor, at this point,
is Argonne National Laboratory. And during the past 2 to 3
years, Argonne National Laboratory has been conducting
analytical, laboratory, and field studies on the lake, and
most of their efforts so far, on the lake, have been devoted
— as far as one plant is concerned — to the Point Beach
plant
They have also been involved in part of the
Waukegan studies and also for the University of Wisconsin
studies out of Milwaukee, which is below a fossil fuel plant
located on the lake.
30 that the answer to your question is that we
are definitely trying to follow up these statements here
with the detailed field studies that were recommended as a
part of the last session of the conference, and which was,
as a part of our statement, we felt, highly essential
that at least somewhere in the range of 5 years
-------
601
5
10
11
12
13
15
16
17
IS
19
20
21
R. Catlin
of field studies be carried out in order to determine what
the effects of these plants would be on Lake Michigan.
MR. MCDONALD: If AEG grants a full operating
license to, say, Point Beach, and if as a result of the
6 i monitoring that takes place at Point Beach substantial damage
i
is uncovered to the aquatic environment, would AEG, then,
conduct hearings on the desirability of backfitting that
plant?
MR. BELTER: I don't know whether I can give a
categorical answer to that question.
In the environmental reviews and assessments that
have been made, I would say most of the conclusions were,
in the statements, that if a deleterious effect is found
through the operation of the plant in question, it will be
necessary for the applicant to take the action required to
remedy that effect. That is a standard recommendation, and
actually usually it is a conditional part of the technical
specifications that this type of action will have to be
taken if harmful effects are found.
MR. McDONALD: Well, what criteria guidelines has
22
AEG developed that would enable AEG to measure whether such
23
deleterious effects have indeed taken place on the basis
24
of monitoring information that might be available?
25
1 MR. BELTER: I would say on something like that,
-------
602
•j_ R. Catlin
2 this conclusion of deleterious effects would be developed
3 in conference with the various groups that are involved in
A the monitoring operation. In other words, the AEG, in con-
5 cert with the involved States, with EPA, and with other
6 appropriate Federal agencies, would determine what these
7 deleterious effects are. It would not be a separate action
£ whatsoever by the AEG, but it would be an action or a
9 decision or a conclusion that would be reached in conference
10 with the appropriate State and Federal agencies involved.
11 MR. McDONALD: What would be the mechanism for
12 this? This statement you just made is somewhat new informa-
13 tion as far as I am concerned personally anyway.
14 is there in the offing a mechanism that would be
15 developed to make this assessment?
16 MR. BELTER: Well, in the cases of the technical
17 specifications that I have seen, as a part of these Environ-
1S mental Statements and as a part of the licensing process,
19 the monitoring operations — reports of these operations
20 \ are provided to all of the involved agencies and groups
21 pertaining to that site or that plant. There will be
22 meetings that are usually specified, again, in the specifi-
23 cations on some type of a time framework, that call for
24 discussing the results of the plant operations.
25 in other words, all of the data that is collected
-------
603
1 R. Catlin
2 in the monitoring programs will be reviewed by these agen-
3 cies and, if there are any effects pointed out as a result
4 of these operations, it then would be the intent of the
5 Commission to take the action as called for, as a result of
6 the monitoring and the meetings of the involved organizations
7 MR. McDONALD: Well, I believe, sir, what I am
8 driving at is this: We find ourselves now at a state where
9 there are a number of views on what constitutes damage or
10 whether, in fact, there is any damage. And it would seem
11 to me that if AEG grants a license to, say, Point Beach, or
12 any other facility on the lake, that there should be some
13 I rather definitive guidelines on what would constitute either
14 a revocation of that license or damage to the environment,
15 or what would constitute a very clear case of affirmative
16 action to remedy that deficiency within a given period of
17 time. Or else, when we get to the matter of damage, I think
18 we may be right back where we are right now.
19 | MR. BELTER: Well, without attempting to preempt
20 what any kind of decisions would be in these hearing pro-
21 cesses involving the plants in question, I would say that
op
*• the AEG is looking for any kind of help or guidance that we
2*3
J j can obtain from any Federal or State agencies in regard to
!
^ what constitutes damage below the plants. In the preparation
25
[ of the nonradiological technical specifications, there has
-------
604
1 R. Catlin
2 been serious efforts taken to try and come up with what
3 would be damage below the plants. For example, one of the
4 most sticky problems, or the roughest ones to handle is:
5 What constitutes an acceptable fish kill below a plant or
6 at an intake structure above the plant?
7 We realize that in these cases fish have been
$ killed, but the overall question is: What effect does it
9 have on the total population of these various species in
10 that situation? If one fish dies and you count that, perhaps
11 maybe that would not be too damaging. If it was perhaps
12 maybe a carp or a sucker, maybe that wouldn't be too, too
13 harmful. If 5 fish die, if 500, 1,000, 100,000 — what is
14 considered to be an acceptable number to the regulatory
15 agency?
16 And we have had many discussions with many dif-
17 ferent ecologists around the country, with various agencies,
1$ attempting to come up with an acceptable number, so that it
19 could be included in the specifications as a point for tak-
20 ing corrective action. And I will say, at this point, that
21 we really haven't arrived at any kind of an acceptable
22 number.
23 The same thing, I think, can be carried to impinge-
ment on the intake screens, on the entrainment of organisms
25 | going through the condenser. Is there any kind of acceptable
-------
605
R. Catlin
numbers in terms of what the overall population is? We are
well aware that — and you will hear further today, too, the
Humbert. a.ud povcfciioages of various species — zooplankton
4
5 j! and that -- that are killed going through the condenser.
I
6 These numoers will vary all over the place — 10 percent,
7 ii 20 percent, 30 percent — Mr» Barber has given numbers up
g ! to 90 to 100 percent*
9 | 1 think, the basic issue here though is: What
10 effect dues this type of entrainment kills have upon
11 | the total population surrounding the plant? And from what
i
12 \ we have been able to determine, from the ecologists who have
13 ! evaluated it4 in the AEG assessments, we have not been able
14 ! to determine that there has been an overall decrease in
15 these essential populations making up the total ecosystem.
16 ,! So i-uese are areas that we are looking for, for
17 guidel-LUt,-., in v.e^Hd of how you can specify this type of
1$ •thing iu nut. c-eci/iiicai specifications for the plant opera-
19 tion* A.M ii' thsi-tt is anyone here, in the various States or
20 '| Federal agencies involved that can assist us in this regard,
21 ;; we wou.'.ui o^ mo.st pleased to have that type of consultation.
22 ;. Mil, Ilu.OjMLDs Well, I think we are talking on the
•^ ',• same th-u.^ i appreciate the extent of your remarks, and I
^ ii will ciuse oil my questioning by, again, restating: I think
i [
*-' I the imperativeness is having criteria by the time a license
-------
606
R. Catlin
is granted, if that facility goes forward without adequate
cooling facilities.
MR. BELTER: I might ask the same kind of a ques-
tion, Mr. McDonald. Has the EPA in its various programs
of research and monitoring come up with any draft criteria
that you would consider could be used by an agency like the
AEC in its licensing process that would indeed define damage
and the other types of criteria, that you consider important
10 in terms of plant operation?
11 MR. McDONALD: We are doing this, under our Refuse
12 Act Permit Program, so that we will be able to detect what
13 a violation is, and I think this matter really has to be
14 pursued.
15 MR. BELTER: I agree.
16 MR. MAYO: Any other questions, gentlemen?
17 MR. FETTEROLF: Yes.
Mr. Belter, one of your senior scientists involved
19 in determining how you assess the environmental impact is
20 Dr. Charles Coutant, is that correct?
21 MR. BELTER: Yes.
22 MR. FETTEROLF: And while Dr. Coutant was under-
23 going the throes of working through what you have just dis-
cussed about how you evaluate biological damage — whether it
25 is on the basis of individual organisms killed or whether
-------
6
7
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
607
R. Catlin
it is on the total impact to the population — he was also
serving on a committee with the National Academy of Sciences,
which was made up of the outstanding aquatic scientists
throughout the country, and they helped him and he helped
this other committee.
I attended all of these meetings, and I know the
pangs they went through in trying to reach a correct decision.
And, as an example of where literally millions of larval fish
can be killed and yet apparently not influence adult popula-
tions, I would refer to Mr. Barber's report, where he cited
the work of Marcy at the Connecticut Yankee Plant, where
some &5 to 90 percent of the fish were killed.
Now, I believe a followup to Barton Marcy*s work
was that a cost-benefit report was turned in to AEG on what
was the value of those fish that were killed. Do you recall
the results of that report?
MR. BELTER: Which plant is this?
MR. FETTEROLF: This is Connecticut Yankee at
Haddam Neck, Connecticut.
I heard Mr. Marcy give this report at the
| Westinghouse International School for Environmental Manage-
ment in Colorado this summer and, on the basis of the larvae
that were killed going through the plant and the larvae
going down the Connecticut River outside of the plant, and
-------
1 R. Catlin
2 on the basis of the populations that returned, the value of
3 the fish killed was $131.
4 MR. BELTER: Is that right?
5 MR. FETTEROLF; Something like that; something in
6 that neighborhood; and that was on an annual basis.
7 Now, 1 am a defender of the environment, but I
g want to put these figures in perspective, and I would like
9 to leave the record open so I can check with Dr. Marcy that
10 this was the value assigned to these fish,
11 MR. BELTER: My only comment, Mr. Fetterolf, to
12 that statement is that, at this point in time — and I
13 don't recall the names of the total 32 draft Environmental
14 Statements that have been prepared and the 16 final Environ-
15 mental Statements — but I do not believe that the Environ-
16 mental Statement for that Connecticut Yankee Plant has been
17 prepared or issued at this point, primarily because it was
1$ listed down lower in the list of the total number of state—
19 ments that had to be prepared. Over a year ago, a decision
20 had to be made on which statements would be prepared first,
21 and the critical list that was prepared at that point,
22 consisting of around 10 or 11 plants that were most critical
23 from a potential power shortage standpoint around the
24 country — those statements were given the initial attention
25 of the Commission staff* Then there were other ones
-------
609
—
., R. Catlin
2 listed in descending order of priority being prepared and,
3 to the best of ray knowledge, I do not believe the Impact
4 Statement for the Haddam Neck plant has been issued.
5 MR. FETTEROLF: Perhaps this was simply a special
6 study.
7 MR. BELTER: Well, I can verify that for you very
$ easily.
9 MR. MAYO: Are there any other questions, gentlemen'
10 MR. BRYSON: I do have one question, Mr. Mayo.
11 On page 4 of your statement and also page 5, where
12 you are talking about imbalancing of environmental and
13 economic impact, can you elaborate somewhat on what you mean
14 by that comment? Are you considering environmental impact
15 in the immediate vicinity of that plant, or do you include
16 environmental impacts on the Palisades plant and its effect
17 on the lake in conjunction with effects that may occur from
13 the Cook plant, from Zion, Point Beach, Kewaunee, and so on?
19 Is it strictly a local consideration, or do you consider
20 regional implications?
21 MR. BELTER: Most of the considerations, at this
22 i point in time, have been on a — I would say — localized
basis*
24 Now, I don't believe that in the statements that have
been included heretofore in the record, there has been pointed
-------
610
R. Catlin
out any discussion in terms of evaluation of the potential
effects, say, of the Cook plant or other plants. That
assessment was more comparing the alternative types of
cooling systems — for instance, the once-through system
as compared to various types of auxiliary -- cooling towers,
spray ponds, other types of ponds — and comparing the
differences there as far as total impact that would be
involved in the discharge of blowdown, possible atmospheric
10 effects that would involve icing and fogging with cooling
11 towers, the noise problem, and comparing that with the once-
12 through effects on the aquatic ecology.
13 But as far as the impacts of these plants or the
14 effects on a regional basis, all of the information we have
i
15 been able to obtain so far is that these impacts or effects
16 will not be anything more than on a localized basis — and
17 by "localized," I would hate to put a number on it, but I
13 would imagine it would be somewhere in the range of, say,
19 5 miles or 10 miles, that any effect or impact of that
20 plant, per se, would be essentially nil beyond that dis-
21 tance.
22 ! 30 this, I believe, is the reason why there has
not been any further consideration given to evaluation on
a larger scale insofar as Lake Michigan plants are involved.
25 MR. BRYSON: Mr. Currie made reference to
-------
611
•[_ R. Catlin
2 Conclusion 17 of the conference and the remarks by Mr. Barber
3 concerning the fact that these effects may not be strictly
4 local in nature. So I still — while I think you have
5 answered my question, it appears that AEC does just look at
6 the local situation and you do not relate any evidence of
7 the fact that they —
8 MR. BELTER: Well, let me qualify that a little
9 bit.
10 If, in the analysis, it was determined, say, that
11 potentially the impact or effect would be at a point 3«5
12 miles or 5 miles from the plant, then an assessment would
13 be made of — if there was, say, another plant there —
14 what that effect would be.
15 But in the cases of these plants here that we
16 have mentioned, there was no effect or impact determined,'
17 so, therefore, there was no further assessment mentioned in
13 the report.
19 MR. MAYO: Any other comments, gentlemen, or
20 questions?
21 If not, thank you very much, gentlemen.
22 we will recess for lunch and reopen the session
at 2:00 p.m.
(Noon recess.)
25
-------
612
1 T. Falls
2 | THURSDAY AFTERNOON SESSION
3
4 MR. MAYO: May we have your attention, ladies and
5 gentlemen? There is a need to get started again as soon
6 as we can.
7 We are back in session, ladies and gentlemen.
8 In keeping with the published agenda, the first
9 State presentation and the presentation of public statements
10 related to the individual States will be by the State of
11 Indiana.
12 Mr. Miller.
13 MR. MILLER: Thank you, Mr. Chairman.
14 As we indicated this morning, the State of Indiana
15 | does not have a statement on the thermal question, but we do
16 have several people who would like to speak on this subject,
and I would now like to call on Ted Falls of the Izaak
Walton League.
i
19
20 STATEMENT OF TED FALLS,
21 | PORTER COUNTY, INDIANA, CHAPTER,
22 IZAAK WALTON LEAGUE, WHEELER, INDIANA
23
I
r\ I i
MR. FALLS: Mr. Mayo, members of the conference,
25
' ladies and gentlemen.
-------
^ 613
•^ T. Falls
2 MR. MAYO: Excuse me, Mr. Falls. Would you be
j kind enough to lower the mike, please, sir?
• Thank you very much.
5 MR. FALLS: My name is Ted Falls. I am a member
6 of the Porter County, Indiana, Chapter of the Izaak Walton
7 League, and am active in the Indiana Division and the
# National Izaak Walton League. I am also active in the Lake
9 Michigan Federation.
10 I am a retired research development engineer. My
11 major work was in hydraulics. I have been a life-long
12 amateur naturalist and a spare-time scholar of biology. I
13 think I have carried much of the discipline of my profession
14 into my hobbies. With this background I think I might
15 attempt a few constructive comments.
16 I have recently studied in detail Dr. Donald W.
17 Pritchardrs paper "Temperature Standards for Lake Michigan,"
1$ given before you in the fall of 1970. In this paper, Dr.
19 Pritchard has explored the condition of the plume discharging
20 cooling water from powerplant condensers for velocities of
21 discharge from essentially zero to a value that purports to
22 j mix the plume with lake water successfully to a temperature
23 of 1° above lake ambient. The case for maximum mixing,
Case IV, has been applied to the system planned for the
Zion plant of Commonwealth Edison Company, with some
-------
_ 614
T. Falls
modification.
I have the highest respect for the engineering work
Dr. Pritchard has done, and I think he will have the respect
of every engineer that reads him with comprehension. I have
applied a number of tests within my present scope and find
him consistent.
The alteration at Zion is important. Dr. Pritchard
describes Case IV with an orifice 15 feet wide and 10 feet
10 high discharging into 10 feet of water. The jet immediately
11 fills the whole depth of the lake. At Zion, the jet is
12 II designed to discharge in a sheet about 75 feet wide and 3
13 feet deep, at the bottom of the lake in 12 feet of water.
14 This provides additional surface of contact with lake water
15 for the first step in mixing with lake water. The jet
16 stabilizes through the whole depth of the lake at about the
17 12° isotherm, as near as I can tell from reading Dr.
1# Pritchardfs data. Beyond that, mixing with cold lake water
19 must be made wholly at the sides of a broad body of warm
20 water.
21 The jet discharges a volume of 1,705 c.f.s. at
22 | the nozzle, or 141 acre-feet per hour, an easier figure to
handle. At the 12° isotherm it has taken up 94 acre-feet,
2/f which may be reasonable. Between the 12° and the 1°
isotherms, 2,575 acre-feet must be taken up through the
-------
615_
1 T. Falls
2 sides. This seems optimistic, considering the narrow area
3 of the sides between the lake surface and the bottom, and the
4 fact that much of the essential kinetic energy in the jet is
5 being spent against viscosity in the turbulence between the
6 jet and the cold lake. We do not have any means to test
7 this analytically. This, however, is the essential point
j
o for my objections in my previous statements.
9 Another factor with the wide Zion jet is the extent
10 of the interface at the bottom. This is a region of high
11 turbulence, and it is persistent the whole length of the
12 jet. Energy is dissipated in turbulence both as storage in
13 heterogeneous velocities in heterogeneous directions and as
work against viscosity. At the bottom it can have no part
15 in mixing. The rate at Zion will be in the order of 5 times
the rate in Case IV. For this reason, we are skeptical of
17 the apparent proportionally longer plume at Zion. We hope
the Zion jet has been examined in the tank.
There is a serious objection to the second jet
20 30& feet away from the first at Zion. In still water there
21 will be no interference. But with any current, the two
op 1
**• will combine producing a plume up to double the size of
23
* In still water, the system will "clog." With a
25
' continuously operating jet, the field beyond the region of
one,
-------
616
T. Palls
decaying turbulence will be taken up as lake water. This
will have a continuously increasing temperature, enlarging
all areas of the plume. This condition exists in the lake
at times.
A cross-current is essential to maintain a supply
of cold lake water for the continuous successful operation
of the process. Dr. Pritchard limits the cross-current to
10 percent of the initial velocity (according to Policastro
and Tokar, "Heated-Effluent Dispersion in Large Lakes.")
For Zion, this limit would be 10 percent of 9 feet per
second, or 0.6l m.p.h. — that is about a half a knot. Lake
currents sometimes exceed this velocity.
We recently flew over the mouth of the St. Joseph
River, Michigan, when there was a north-flowing current
in the lake. The river was markedly colored. The interface
of the two streams was sharply marked for a long distance.
This indicates a total absence of interchange of water be-
tween the two streams. We do not know the relative veloci-
ties of the two streams, nor did we measure the distance
before turbulence began the process of mixing. It is widely
known that acceleration of a stream in a pipeline damps out
turbulence. Apparently transverse acceleration does the
same thing. Since turbulence is the essential factor in
mixing, the plume will enlarge as the result of many current
velocities.
-------
617
T. Falls
Commonwealth Edison states that the jet velocity
at the nozzles will be about 9 f.p.s. at "full load opera-
tion." And I quote that from their statement. This implies
that the pumping rate may be reduced for lighter loads to
maintain the discharge temperature at 20° over the lake.
This may well be, for the pumping costs are high and perhaps
exceed the savings for working the turbines at the possible
higher efficiency of reduced condenser temperature. The
10 plant will operate normally at about 90 percent rating.
11 This, with the pumping reduced, will result in a 10 percent
12 reduction of the heat discharges and a 19 percent reduction
13 in kinetic energy at the nozzles. At BQ percent rating, the
14 figures will be 20 percent reduction of heat and 36 percent
15 reduction of kinetic energy. The consequence will be larger
16 areas within the isotherms of the field.
17 We suspect that both Commonwealth Edison and Dr.
Pritchard have submitted the data for maximum performance,
19 without regard to the adverse effect of variations.
20 J Heat transfer to the air within the 1° isotherm,
21 for both Zion and Case IV, appears to be between 2 percent
22 | and 3 percent of the total heat contained in the discharge.
This means that 97 percent to 98 percent of the heat dis-
charged passes the 1° isotherm. The heated water fills the
2 5 lake at this point, or very nearly so. The rate of rise
-------
1 T. Falls
2 due to buoyancy at 1° is very low. An estimate of heat
3 dissipation to the air, according to the rate used by Dr.
4 Pritchard for a moderate condition, indicates that the body
5 of water between the 1° and the 0.5° isotherms will have an
6 extent of 25 to 100 square miles.
7 Due to lake currents, this far field affects pri-
$ marily the inshore waters. It creates a climate equivalent
9 to a move of several degrees of latitude southward. It
10 becomes the ambient temperature above which neighboring
11 plants raise their discharges. The inshore temperature
12 raises progressively by this process.
13 We question the superiority of the Case IV high
14 velocity jet. At Zion, the estimate for the area within the
15 1° isotherm is 1,260 acres, nearly 2 square miles. Orig-
16 inally, the outfall for the Cook plant at Bridgman, Michigan
17 approximated Case I. For this, the area within the 1° iso-
therm is about 6 square miles. (I am using Dr. Pritchard1s
19 projections.) But Zion dumps 97 percent to 9$ percent of
20 its heat into the lake beyond the 1° isotherm; the Cook
i
21 i plant dumps only 10 percent to 15 percent. The recent
22 alterations to the Cook discharge system are a disadvantage
in this respect.
Meandering of a long plume has been reported
frequently. The consequence is the detachment of large
-------
619
1 T. Falls
2 bodies of warm water. This has been observed and mapped at
3 the Bailly fossil-fueled plant in Porter County, Indiana,
4 and is reported in the "Environmental Report for Bailly
5 Nuclear 1" to the AEG, and in the "AEG Environmental Report"
6 for the same plant. Quantitative studies of the plumes at
7 Zion and other plants must take these detached bodies into
8 account.
9 The Kewaunee flume discharging at the shoreline
10 of the lake is unforgivable. It is well documented that
11 this form has the greatest adverse consequence to the near-
12 shore.
13 I have the greatest sympathy for an engineer's
14 I desire to test his work against the full-scale working
15 system. On the other hand, the outfalls at Zion, Cook, or
16 Kewaunee will not be discontinued for another method if the
17 actual hydraulic performance fails in its promise on the
diversity of working conditions, and especially if it is
19 found that there is a grave impact on the ecology of the
20 lake.
21 I want to say some more on the biology, but before
22 I leave this I would like to make a point that I did not in-
elude in my paper. That had to do with the point that I
made that there is a high level of turbulence between this
jet located at the bottom of the lake and the jet itself.
-------
620
1 T. Falls
2 j The dynamics of flow are such that that jet is per-
petuated and enhanced until it becomes one of the major
sources of dissipation of energy.
But there is another point here that I think is
apropos, but I did not include it in my paper because when
I wrote it I was not so sure, and that is that this turbulenc^
under the jet has a very high scouring action and will dig a
trench in the sand for a very considerable distance beyond
10 the jet. If we look at Dr. Pritchard's dimensions, it is
11 going to be of the order of a mile or more.
Now, I want to draw a conclusion that comes from
13 what I observed along the Indiana shore at Michigan City.
That trench is going to be costly to the beach because of
the effects of erosion. The jet will pick up and carry any
sand away that is carried into the trench and the sand will
be continuously taken away from the shore due to wave action.
-| rt
And I would suggest that we should thoroughly investigate
this effect before we permit the Zion plant to operate with
this outfall, otherwise it is going to cost the park up
21
there at Zion at Sunny Beach.
2? '
Now, this has happened at Michigan City where they
2*3
dug a channel into the harbor there to the east — slightly
2L
north of east — of the channel. There is an entrance there.
25
That was done 2 years ago,
-------
621
jL T. Falls
2 At the time that was done, there was a beach that
3 must have been 100, 150 feet wide, due to the accumulation
4 of sand that had been swept down from up the lake and had
5 formed a filler. Today that is completely gone and there
6 is deep water against the bulkhead, and that has gone down
7 into the channel which was dug.
& I have pictures to substantiate this from 2 years
9 ago and now. I had not expected at the time I took them —
10 not even when I took the last pictures —it was when I
11 viewed them that I realized that the beach was gone.
12 MR. McDONALD: Do you have those pictures, Mr.
13 Falls?
14 MR. FALLS: I didn't bring those pictures. I did
15 bring some pictures showing the sharp interface between the
16 lake current and the discharge at the St. Joseph River.
17 I wasn't sure I would be able to use them. I tried to write
1# a description so that it wouldn't be necessary to show them.
!9 But I did bring them and I can supply some pictures of
20 Michigan City, too, if you like. They are color slides and
they don't reproduce very well in black and white.*
22 Certain biological studies submitted to this con-
ference and to other bodies responsible for making regula-
tions are entirely inadequate. The power companies respon-
sible for making these studies apparently do not avail
*(The pictures were submitted following the conference and
follow this page.)
-------
Wheeler, Indiana 46393
October 2, 1972.
Mr. Glenn Pratt, Enforcement Division,
US Environmental Protection Agency, Region V,
One North Wacker Drive,
Chicago, Illinois 60606.
Dear Mr. Pratt:
Enclosed are five sets of photographs pursuant to the
suggestion of Ms?. Francis Mayo. They are supplemental to
my statement of September 2} 1972 to the Four States
Enforcement Conference. They are strictly for the record.
One could hope for clearer pictures, but the details in
question can be perceived with careful examination.
I have included a text for the remarks in addition to my
written statement. With references at hand I am able to be
more specific in one or two matters.
Yours respectfully,
-------
SUPPLEMENT to Statement to Lake Michigan Enforcement Conference
by Ted Falls, September 19-21, 1972.
To folloxv discussion of the hydraulics of the plune, page 3.
In view of the breadth of the discussion that has gone before, in
this Conference, I would like to add a point that I deleted from
ray prepared statement for the sake of brevity.
I have spoken previously of the high turbulence between the jet
and the bottom ot the lake at Zion. This turbulence will scour a
channel in the sand. The depth and length ot the channel depends
on the initial velocity of the jet at the nozzles. All sand that
might be drawn into the channel will be picked up and carried out
into the lake,
Due to wave action, the sand betxveen the jet and the beach will
flow into the channel to be carried away. The inevitable result
will be the destruction of the beach at the plant, and in a short
time, the reduction or complete loss of the beach at the adjacent
State Park.
This effect has occurred at Michigan City (Ind.) Harbor, at the
mouth of Trail Creek. In early 1970 a cargo ship that tried to
enter the Harbor at the east entrance ran aground. By June, that
year, the Army Engineers completed dredging a channel through the
entrance, approximately 1000 ft. offshore. At the time there was
a wide beach along the bulkh.ead at the small boat harbor, with
the characteristic fillet against the jetty that makes the major
harbor.
By July 1972, the beach had entirely disappeared. We can only
presume that the beach sloughed off into the channel.
-------
8/16/70. Michigan City Harbor and Small Boat Harbor,
showing east entrance through which channel was dredged,
Beach as visible at bulkhead at the lake side of the
Small Boat Harbor.
7/9/72. Michigan City Small Boat Harbor. Bulkhead
and jetty for Michigan City Harbor. Note disappearance
of beach at bulkhead, and erosion east of the Small
Boat Harbor.
-------
7/9/72. Mouth of St. Joseph River, St. Joseph, Mich
Sharp demarkation between river outfall and northwar<
lake current.
7/9/72. Demarkation continues great distance beyond
mouth of river. Note extensive mixing on shore side
of plume. This was more marked to the naked eye.
-------
622
T. Falls
themselves of sophisticated authority in planning the work,
I will cite two studies in particular:
1. "Benton Harbor Powerplant Limnological
5 Studies" made by Great Lakes Research Division, University
6 of Michigan. This was a study of relatively undamaged lake
7 biota, preliminary to the operation of the Cook plant.
A study in the surf and immediately adjacent
9 waters was neglected on the supposed absence of life there.
10 Cladophora appears in this region on the shores of Indiana
I
! I
11 | below the outfall of the Michigan City plant of NIPSCO,
12 I presumably due to the rise in mean annual temperature.
13 No studies were made of fish spawn and hatchlings
14 over the gravel and rock beds offshore, nor were the beds
15 mapped. It is well known that these are important breeding
16 ! areas for fish important to the ecological structure.
17 2. "NIPSCO Environmental Report, Bailly Nuclear
1," to the AEG. This makes the most frank report of the
19 | impact of a heated plume on the marine ecology of any I
i|
20 have come across. The plume discharges at a maximum of 14°
21 above ambient.
i
22 i it shows increases in the plume of a number of
23 | species of algal types and invertebrates and the disappearanc
of others. It particularly notes a serious fungal infesta-
2 5 tion of Burytemora and Daphnia, absent in the surrounding
-------
623
•^ T. Falls
2 lake.
3 The study was limited to 3 days in October. This
4 is not the season of major impact.
5 It covers only one element of biota quantitatively.
6 It disregards — or fails to report — the temper-
7 ature at the point of sampling. By averaging, it conceals
& the effect of temperature in relation to multiplication or
9 disappearance of species. There is no possibility of eval-
10 uating Dr. Pritchard's proposals to release large quantities
11 of water 1° over ambient from this work.
12 The plume must be studied throughout the season.
13 You must know how much the algal bloom and the increase of
14 invertebrates is advanced before the normal season, and
15 how much it is extended beyond. You must know the increases
16 during the normal season.
17 The increase of plankton adds to the organic
IS detritus in the lake. This enhances the support and the
19 multiplication of living organisms in the long run. This
20 is acceleration of eutrophication in the lake.
21 I To my knowledge, at this writing, no study has
i
i
explored the phenomenon of the concentration of predator
fish at thermal plumes, with their marked disappearance
after several weeks. We can conjecture the cycle: the
increase of plankton attracts and concentrates the forage
-------
624
T. Falls
fish; the concentration of these attracts the predators.
There are two likely factors in the concentration of the
vertebrates*
5 1. The increased temperature raises the metabo-
6 lisra rate of the cold-blooded species. This may be
7 attractive.
2. The increased temperature increases the food
9 supply. We suspect this to be the greater force,
10 The predators and the prey fish must come from
11 other parts of the lake. How wide an area supplies the
i
12 prey fish?
13 The disappearance of the predators would indicate
14 the possible decimation of the prey. If this is true, what
|
15 is the consequence to the biological balance of the system?
16 Two points are presented before you that are
17 invalid:
1. Statements of the impact of thermal discharges
19 i on the lake as a whole are deceptive to only the uninitiated,
!j
20 The impact is on the inshore waters.
21 2. Emphasis on the existence of natural limited
22 [ bodies of water in the lake of comparable temperature dif-
23 ferences is equally untenable. Thermal plumes add to these
areas in major quantities as I have mentioned above. They
increase the effects of temperature beyond the natural
-------
625
-j_
2
5
8
10
11
12
13
14
1$
16
17
19
20
21
2 5
T. Falls
balance.
Evaluation of the issues before you falls into
two categories: 1) the ethical, and 2) the economic. To
try to evaluate them on the same plane is adding apples
and oranges.
The ethical decision must be cleared first. Do
we want to proliferate heat discharges into the lake until
damage becomes obvious? In Lake Michigan there will be no
return in our lifetimes if we exceed the tolerance of nature
here. The lake is valuable to people as well as to industry.
The true economic decision is in the balance
between a lakeside site, with the use of the lake for cool-
ing water, on the one hand; and, on the other, an inland
site using less critical resources for cooling. Granted,
the cost to the consumer may increase somewhat. The economy
is more flexible than the lake.
Thank you.
MR. MAYO: Thank you, Mr. Falls.
Do the conferees have any questions or comments?
MR. McDONALD: I would like to refer to page 4,
22 Mr. Falls, on your comment on the Bailly Report as "the most
frank report of the impact of a heated plume on the marine
ecology of any" that you have come across.
You mean this in what way now?
-------
626
1
2
T. Falls
9
10
11
MR. FALLS: I am speaking primarily of the reports
to bodies like yourselves that have a decision to make that
are produced by the required studies by the people who would
suffer by adverse reports. Frankly, directly, I mean the
power companies are turning in what appear to be very
weighted reports — weighted by neglect of some of the
essential factors that I have discussed.
MR. McDONALD: Well, I was interested to see that
comment because when I read the Bailly report, I had the
same feeling that you had. It was a very frank report; it
12 il laid out the situation that happened and was most informa-
13
15
16
17
19
20
21
22
23
24
tive.
MR. FALLS: Yes.
MR. McDONALD: The thing that I would like to
pursue just a moment is: Are you suggesting in the items
below, where you discuss the Bailly report, that the situa-
tion — despite the frankness of the Bailly report — is
much worse because of the limited duration of the study?
MR. FALLS: That is true. I think they failed —
at least they did not pick the time that revealed the worst
to permit an overall picture of what would happen throughout
the thermal site,
MR. McDONALD: I would like to thank you for a
2 5 ; very detailed and very informative statement.
-------
627
J. Jontz
2 MR. FALLS: Thank you.
3 MR. McDONALD: I think it is refreshing to get
this type of statement from a man who is a member of this
5 group.
6 MR. MAYO: Any other questions or comments,
7 gentlemen?
Thank you, Mr. Falls.
9 MR. MILLER: Thank you, Ted.
10 The next person I have to call on is Mrs. L. E.
11 Bieker. It appears that she is not here.
12 We have a statement from Sylvia Troy, who is not
13 here, but Jim Jontz from the Lake Michigan Federation will
14 i read Mrs. Troy's statement.
15
16 STATEMENT OF JIM JONTZ, PRESIDENT,
17 I INDIANA EGO-COALITION,
18 i VALPARAISO, INDIANA
19
I
20 Ji MR. JONTZ: My name is Jim Jontz, J-o-n-t-z. I
11
21 j would like to submit two brief statements on behalf of
|j
22 ]| citizens that are not able to be here at the conference
23 | proceedings today. In addition, I think we could find Mrs.
i!
2^- Bieker's statement if you don't have a copy.
2 5 jj Mrs. Troy's statement is presented for the Save
-------
2
3
4
5
6
7
B
9
10
11
12
13
14
15
16
17
20
21
22
23
25
628
J. Jonts
the Dunes Council.
Mrs. Florence Dale has also prepared a statement
which she would like to introduce into the record as an
individual.
I would like to take just a few seconds more than
that to explain some of the concerns of the individuals who
were not able to be here today.
Both of these statements — I should say the
general feeling among many citizens in Indiana is that they
would like to indicate their concern to the conference that
action be taken to protect Lake Michigan from thermal dis-
charges as quickly as possible.
we do not have expertise, in many cases — when
you stated previously — I believe it was Mr. McDonald —
about the quality and the nature of the statements from
environmental groups — I hope that we are not looked to
for expertise, but we do have experience in some of the
other facets that are important in deciding these decisions.
MR. McDONALD: Well, just to clarify that I did
not mean that in any sense to mean that every statement
from an environmentalist group had to be a technical state-
ment. But I think this statement by Mr. Falls was an
unusual statement because I know how difficult it is to
get the expertise that is often required to make statements
-------
4
5
10
11
12
13
14
15
16
17
18
629
J. Jontz
on behalf of environmentalists. He happens to be a technical
man and I think he has put his technical knowledge to good
use.
MR. JONTZ: We certainly agree with you that we
wish more of us could make statements like Mr. Falls1.
The comments we have just been making relate very
directly to the point that I think many of us would like to
make. The thermal question becomes, I think, of both inter-
est and concern, perhaps rightfully so, in that much of the
input into the decision-making process is not of a technical
nature but of a socio-economic political nature instead.
We have been very upset, I guess you could say,
that this decision has been made in a manner that we would
quarrel with. Rather we are faced with making a decision
not in a manner we would call scientific but rather
political. And we, as citizens, are not too keen about
the prospects of making this decision on a political basis.
19 i On the one hand, we have the power industry who
i
I
20 j for a few minutes present a series of scientific technical
21 l| experts to sell their point. I think you recognize that
i
22 1 these gentlemen are able to make such a complete presenta-
[
23 tion because they are in service to sell a product from
24 which they get profits from which they can employ and hire
technical and scientific experts to give the best possible
-------
630
1
2
3
4
5
6
7
a
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
J. Jontz
presentation of their side. On the other hand, there are
very few of us that make very much money from protecting the
environment in our spare time. We get no profit from this
and we do not have the opportunity to put in these profits
to work and hire technical, scientific experts to present
the best side of our argument.
Now what one must conclude from this is that it
is necessary for the governmental agencies of all the States
and the Environmental Protection Agency to do the functions
that they are supposed to do as governmental agencies, and
that is those things which individuals, citizen groups --
all citizens — cannot do. We may not have the resources to
present the best side or the best arguments for our side,
and that is your job.
So many of us are led today to question what the
Environmental Protection Agency and what the States have done
in the last 2 years as far as finding the correct scientific
evidence upon which to make a decision. We feel that making
a decision only upon what the power companies can represent
cannot be a decision based on adequate grounds. Objectivity,
for scientists, is a goal, but it is never completely
attainable, and what we would like to ask you today is why
EPA has been reluctant to make these expenditures, why you
were reluctant to approach the problem of doing the studies
-------
: 631
J. Jontz
2 so that we do have the information upon which to make the
3 decision.
4 One alternative would be for Commonwealth Edison
5 to provide the same amount of money that they have used to
6 make their studies to, let's say, BPI, so that BPI can make
7 a study. BPI can't make that study if Commonwealth Edison
isn't going to give them that money, and I'm sure that Mr.
9 Coraey would be glad to accept a check any time.
10 I think many of us would like to know why we have
v
11 been discussing the thermal issue year after year, and your
12 reports say that there is no technical information. And I
j
13 think the most important point we have to make today is:
14 When are we going to be able to come to an enforcement
1$ conference and see that you all have done your homework.
I
16 That is the conclusion of my statement.
17 MR. MAYO: Excuse me, Mr. Jontz. You said you
i
13 !j had some material from Mrs. Troy that you wanted to submit
19
20 \ MR. JONTZ: I do.
i
!
21 | MR. MAYO: — for the record.
22 | MR. JONTZ: Yes. I have to retype one of them.
p-3 II
^ I have another one of them, too. Mrs. Dale's letter is com-
24 plete.
25 I
' ii (The documents above referred to follow in their
J! entirety.)
-------
Statement of Sylvia Troy, President, Save the Dunes Council, before the Lake
Michigan Enforcment Conference-
September 21, 1972
I am Sylvia Troy, president of the Save the Dunes Council. The Indiana Dunes National
Lakeshore was dedicated earlier this month after almost 60 years of herculean
conservation effort. With thirteen miles of shoreline on Lake Michigan included in
the park, we are vitally concerned with the health of the Lake. It would be ironic
indeed if the Lake were not swimmable just when a sizable chunk of Indiana's shoreline
is made available for public use.
The federal EPA has indicated that despite its efforts the quality of Lake Michigan
at its southern end has not imporved. Dr. Stoermer's testimony before this Conference
was alarming and expressed as scientific fact many changes we feared were occurring.
Federal water pollution legilsation is moving in the direction of elimination of all
discharge including thermal discharges, perhaps by 1980 — but will that be too late
for Lake Michigan?
If we have learned anything from the enforcement conferences (I believe I have
attended them all), it is that the federal government must take the lead, and a
consistent and positive one, in demanding a cessation of all pollutants into the Lake
including heat.
In September of 1970 Department of Interior experts stated in their "white pages"
that large amounts of heat are damaging to the lake. If they could not back up those
assertions with hard evidence, why has not Interior or EPA pursued intensive research
in this area?
Since 1970 EPA has done a shameful backsliding act on the thermal issue under
pressure from the utilities. May we urge some statesmanlike courage on the part
of EPA to maintain their no-heat standard of 1970.
I would also like to comment on the siting of power plants, which is perhaps not the
direct focus of the Conference, but in our minds a closely related topic. The
Indiana Dunes National Lakeshore is being surrounded by power plants; both fossil
fuel and nuclear. Anywhere along the shore in Indiana one is confronted with utility
smokestacks and soon, perhaps, cooling towers. EPA should be concerned with our
total environment, including the problems of visual blight. We would hope that there
would be a ban on construction of utility plants on Lake Michigan where they threaten
in any way our natural and recreational areas.
Thank you very much for the opportunity to appear before this conference.
-------
7
f)(l n •
J- JUo-
^IT
s&sCviJ&AM^
xUjMifo
jfcJliL. cuJk*
<+yi.
^-*-^
-3 o-o
-------
632
•j_ C. Kern
2 MR. MILLER: I have a statement from Mr. Charles
o W. Kern of the Northern Indiana Public Service Company.
4
5 STATEMENT OF CHARLES W. KERN,
6 ENVIRONMENTAL TECHNOLOGIST,
7 NORTHERN INDIANA PUBLIC SERVICE COMPANY,
g HAMMOND, INDIANA
9
10 MR. KERN: My name is Charles W. Kern. I am
11 appearing today on behalf of Northern Indiana Public Service
12 Company.
13 It is our pleasure to again appear before the
14 members of the Lake Michigan Enforcement Conference so that
15 the views of Northern Indiana Public Service Company may be
16 known on the issues. Several of the areas currently under
17 discussion at this conference affect public utilities in
1# their responsibilities to provide electrical power and ser-
19 vices to their customers. Northern Indiana Public Service
20 Company serves approximately 320,000 customers in northern
21 Indiana with electrical energy. All of NIPSCO's generation
•
22 ! facilities utilize Lake Michigan waters for once-through
cooling.
24 we recognize that a considerable effort has been
under way for some time to assess the environmental impact
-------
633
1 C. Kern
2 of thermal discharges. A great deal of information has been
3 collected from utility companies and a large amount of
4 research has been sponsored by utilities to accurately assess
5 the effect of thermal discharges. As this information has
6 become available and has been evaluated, a clear picture
7 of environmental effects from thermal discharges has become
8 more evident. Detrimental effects resulting from thermal
9 discharges to Lake Michigan have not been demonstrated.
10 Developments since the promulgation of the 3°
i
* i
11 thermal standard for existing plants on Lake Michigan indi-
12 cate that a new approach to thermal regulation for Lake
13 Michigan is necessary. The Lake Michigan Enforcement Con-
14 ference in adopting the 3° standard did not gain the con-
15 sensus of the member States. Only one of the four partiei-
16 pating States accepted the standard and adopted it as law.
17 it is apparent that there is a great divergence of opinion
as to the thermal regulation appropriate for Lake Michigan
even among the authorities responsible for the regulation,
20 j| The AEG draft Environmental Statement for
21 NIPSCO's N-l at Bailly Station submits an opinion that once-
22
i through cooling at that installation would be more accept-
23
J able than a closed system using a cooling tower,
2,|
At earlier hearings before this body, Northern
25
i Indiana Public Service Company has asserted that the
-------
634
l C. Kern
2 evidence does not indicate a thermal regulation such as the
3 3° standard is necessary for Lake Michigan. We again urge
4 the conference to reconsider the 3° limitation and to adopt
5 some other mode of regulation that will be compatible with
6 the realities of thermal effects, acceptable to the conferee
7 States, and one which will not require the spending of
8 millions of dollars without first determining, through
9 factual evidence, that a given plant effluent is detrimental,
10 The data to date, upon which regulatory judgments
11 must be formed, demonstrates that a study and evaluation of
12 each thermal discharge and its surrounding environment is
13 the only responsible manner in which thermal discharges may
14 be adjudged.
1$ Thank you.
16 MR. MAIO: Thank you, Mr. Kern.
17 Are there any comments, gentlemen?
13 MR. BRISON: Yes, I have a comment.
19 i In paragraph 3 of your statement, you say: "The
20 Lake Michigan Enforcement Conference in adopting the 3°
21 standard did not gain the consensus of the member States."
|j
22 jj i think it is very important to point out that
| i
23 | all 4 States did indeed adopt the 3° rise. There was a
i
2^- disagreement with respect to the mixing zone, but all four
i
25 i adopted that 3° rise.
-------
635
C» Kern
MR. MAYO: Mr. Frangos.
MR. FRANGOS: Mr. Kern, did I understand the
, situation with this — let me give you my understanding of
c what your statement says.
It is my understanding that your company had
reached a decision to provide cooling devices at this
facility?
o, MR. KERN: Yes, sir, that is correct.
10 MR. FRANGOS: And now your statement tells us that
11 the AEC draft Environmental statement at least suggested that
12 is not the most acceptable environmental decision?
13 MR. KERN: That is correct also.
14 MR. FRANGOS: Thank you.
15 MR. MAYO: Any other comments, gentlemen?
16 Thank you very much, Mr. Kern.
17 MR. MILLER: Mr, Chairman, Mrs. Bieker's paper
was passed out to the conferees, and then there was also a
19 statement by Mrs. Ethyle R. Bloch, Chairman of the Coalition
20 ! for the Environment, Fort Wayne, and her statement was
21 passed out to the conferees yesterday, and I would like these
i
22 I two statements included as part of the record, and this
23 would conclude Indiana's portion on the thermal question.
!
24 (The documents above referred to follow in their
25 entirety.)
-------
AMERICAN ASSOCIATION OF UNIVERSITY WOMEN
Indiana Sfo/e Division
September 20, 1972
To The Lake Michigan Enforcement Conference
The Sherman House
Chicago, Illinois
Prom The Great Lakes Basin Task Force of the
Northeast Central Region of the
American Association of University Women
The Northeast Central Region of the American Association
of University Women represents more than 31,000 university
women of the states of Indiana, Illinois, Ohio, Michigan,
and Wisconsin. Their Great Lakes Basin Task Force is em-
powered to state their position on the thermal standards
to be imposed on Lake Michigan.
We are opposed to the addition of thermal pollution to
the other pollutants that endanger the lake. We believe
that for the protection of the lake and those who use its
waters you should set high thermal standards. Any facil-
ity that is located or proposed to be placed on the shore
or in the lake which would threaten to raise the tempera-
ture of the water should have to be proved not harmful,
either of itself or as adding to the effects of other
facilities. The burden of proof of its not being harmful
should be on the user of the facility.
s . L. W. Bieker, Chairman, Indiana
Mrs. E. Horowitz, Illinois
Mrs. Joan Weikle, Ohio
Mrs. Jane Lahy, Michigan
Miss G. Freudenreich, Wisconsin
(Mrs. L.W. Bieker
1154 Ridge, Rdc,01 x
Munster, In 56321)
-------
Coalition For The Environment, Inc.
Fort Wayne, Indiana
September 19, 19?2
Mr. Perry Miner
Indiana Stream Pollution C®ntr©l B©ard
In* i anap ©1i s, Int teia
Dear Mr. Miller:
The F©rt Wayne Coalition ^or The Environment may seem to© far away t©
make pertinent comment on Lake Michigan water quality, particularly since
our area even lies in a separate watershed. H@wever, we have several
specific interests in Lake Michigan which we feel compelled t© discuss.
We would ask you t© submit ©ufr comments t© the Lake Michigan Enforcement
Conference Chairman.
First, ©ur electric power is not produced in our area but comes principally
from Installations sited on the shores ©f Lake Michigan. We have a decided
interest in the thermal discharges and radioactive wastes from these in-
stallations for we are giving Lake Michigan the waste while we enjoy the
product. The health of Lake Michigan involves our second parameter ©f
interest which is the natural feature and ^reereational facility ©f the
Indiana Dunes area and we rise to the defense of high water quality here,
considering this an obligation of Indiana and U.S. citizens everywhere.
We would add too that the policies and procedures promolgated by the
Lak§ Michigan Conferees will have direct bearing ©n Lake &rie of which
we are a direct tributary - so in this regard we feel a keen interest and
concern with the Lake Michigan Conference.
We support continued controls on phosphate levels through detergent uses.
We support controls on pesticides and chlorides which have direct effect
on the lake's biology.
We support all efforts to dissipate heat and minimize the thermal effects
to the lake from the huge volume of water used in cooling processes for
power production.
We support efforts t© pr©ve absolute safety of Emergency COre Cooling
Systems in atomic generation before construction.
We support efforts to prevent any further siting of power generation or
heavy industrial development ©n the Lake Michigan shore for pollution
control reasons as well as aesthetic reasons Tvisual pollution).
We support flood plain management for tributaries and close surveillance
for pollution sources including agricultural runoff.
-------
9/19/72
Lake Michigan Enforcement Conference Page 2
We support all enforcement actions underway and believe these should
be steppe* up markedly with the next echelon of offenders tackle*
promptly and effectively.
Respectfully submitted,
Mrs. kthyle R, Bioch, Chairman
COALITION FOR THE ENVIRONMENT
63^0 Donna
Pert Wayne, Indiana 46819
-------
636
C. Fetterolf
2 MR. MAIO: To continue with the agenda, the State
3 of Michigan and the related speakers are next.
4 MR. PURDI: Mr. Chairman, I would like to initiate
5 our report by having Mr. Fetterolf give a report on the
6 "Effects of Chlorinated Powerplant Cooling Waters."
STATEMENT OF CARLOS FETTEROLF,
9 CHIEF ENVIRONMENTAL SCIENTIST,
i
10 MICHIGAN WATER RESOURCES COMMISSION,
11 LANSING, MICHIGAN
|
12
l|
13 ; MR. FETTEROLF: Mr. Chairman, conferees, ladies
i
i
14 j and gentlemen.
15 i The common practice at the utilities and industries
i
16 | using water as a coolant is to introduce chlorine intermit-
i
17 tently into condenser tubes as an antifoulant. Field investi
gations by biologists on the staff of the Michigan Bureau of
Water Management in the fall and winter of 1971 —
I
i
20 MR. PURDI: Carlos, do you have copies of that to
21 pass out — that report that you are reading now?
22 MR. FETTEROLF: I don't think so.
MR. PURDI: If you don't know, I don't!
MR. FETTEROLF: That is what the staff did.
5 ; Field investigations by biologists on the staff
-------
637
1 C. Fetterolf
2 of the Michigan Bureau of Water Management in the fall and
3 winter of 1971 indicated that chlorinated compounds dis-
4 charged in powerplant condenser cooling waters could be toxic
5 to fish life. An Environmental Protection Agency grant was
6 obtained to study in greater depth the effects of these
7 intermittently discharged chlorinated compounds to fish life,
$ The objectives of our proposal were to determine
9 chlorine toxicity to various fish species, document any
10 seasonal variations in toxicity and note any fish avoidance
11 behavior. A further objective was to establish statewide
12 water quality standards for chlorine discharges.
13 To date, work has been conducted at the Campbell
14 and Cobb plants in the Lake Michigan Basin, Karn and Weadock
15 plants in the Saginaw Bay Basin, Connors Creek .plant in the
16 Detroit River Basin, and the Monroe plant in the Lake Erie
17 Basin. These plants were selected to include different intake
1^ and receiving chemical water qualities, a variety of fish
19 life and variety of physical receiving waters. Caged fish
studies will be conducted at each plant 4 times during the
coming year. In these studies, various fish species held
22 in cages in the condenser cooling water channel and receiving
3 water are exposed to the cooling water discharge containing
chlorinated compounds. Throughout each exposure period,
the chlorine concentrations are measured with an amperometric
-------
633
C. Fetterolf
2 titrator.
3 Preliminary results indicate that during the
4 summer months temperature of the discharge is the most
5 critical factor affecting survival of salmonid species.
6 Fish species that are resident in the discharges at this
7 time — white bass, gizzard shad, sheepshead, catfish, gar,
8 pike, carp — are able to survive the increased temperatures
9 and the low level chlorine concentrations.
10 To date, caged fish results using brown trout» when
* i
11 discharge temperatures were suitable for their survival, were
12 obtained at Campbell plant on Lake Michigan. Significant
13 brown trout mortality was observed throughout the mile-long
14 channel during chlorination. There was a slight decrease in
15 mortality at the farthest downstream station. No mortality
16 of brown trout was seen at either control station. Similar
17 results were obtained with the fathead minnows. No stations
1^ i could be placed in Lake Michigan due to high waves. Subse-
19 quent monitoring showed that the chlorine plume extended
20 into the lake approximately 600 to BOO yards.
2i | Skindivers made observations of fish behavior in
22 the Campbell plant's discharge channel throughout one
chlorination period. Resident fish — mainly alewives —
in the channel became very excited when the peak chlorine
25
concentration was reached, but returned to normal immediately
-------
„ 639
1 C. Fetterolf
2 after passage of the chlorine slug. Similar behavior by
3 rainbow trout and white suckers was observed by divers
4 during chlorination at the Big Rock plant on Lake Michigan.
5 In summary, preliminary results of this work
6 indicate that concentrations of chlorine toxic to salmonid
7 fish do occur in powerplant discharge channels. The present
8 policy of restricting intermittent discharge of chlorine to
9 levels less than 0.5 mg/1 for no more than 30 minutes in any
10 2-hour period may have to be modified. Our preliminary
11 results show acute toxicity to brown trout exposed inter—
12 mittently to as little as 0.07 mg/1 of total chlorine for
13 a 96-hour period.
14 Our work with fish more tolerant to temperature
15 and chlorine (fathead minnows and sunfish) has been incon-
16 elusive but indicates less of a problem than for the
17 salmonid fish.
1° During summer months, temperature in these channels
prohibits fish that are more sensitive to chlorine from
20 inhabiting the area.
We will continue this project during the coming
fall and winter months when salmonids can and do inhabit
the channels and plumes. We will then be in a much better
2L
position to recommend limits on levels and duration of
25
chlorine discharged by Michigan powerplants. It appears
-------
640
1 C. Fetterolf
2 that each plant will have to be evaluated and limits applied
3 on a seasonal or monthly basis. The actual limits recom-
4 mended at a given plant will reflect the intake and receiving
5 water qualities, fish species and life stages present, the
6 peculiarities of the particular cooling water discharge
7 system, and the physical characteristics of the receiving
water body,
9 That concludes my statement, Mr. Chairman.
10 MR. MAYO: Any questions or comments, gentlemen?
11 MR. BRYSON: As a way of comment, I would like to
12 point out that on page 115 of the "Summary of Recent Tech-
nical Information Concerning Thermal Discharges into Lake
Michigan" by the Argonne National Laboratory, there is a
comment on the chlorine levels that Dr. William Brungs has
found applicable to water quality criteria in Lake Michigan.
Dr. Brungs is on the staff of the National Water
-i rt
x Quality Laboratory at Duluth, and these values do provide
guidance for acceptable levels of chlorine in the receiving
i
20 i
waters of Lake Michigan.
I
21 MR. FETTEROLF: And by way of comment, I have
22
worked with Dr. Brungs when a panel named by the National
23 '
! Academy of Sciences was trying to decide on the water
24
quality criteria for chlorine in intermittent dosages after
25
short time periods, and after Dr. Brungs had reviewed a
-------
641
I C. Fetterolf
2 great deal of information — about all there was available —
3 and had reached his decision, recent information provided
4 by the Michigan Water Resources Commission staff caused him
5 to alter his recommendation in a downward, more conserva-
6 tive way.
7 MR. BRYSON: Do you have those figures available
$ on how he did revise that?
9 MR. FETTEROLF: That information is not public
10 information yet to me. I believe his final recommendation
11 to you included some of our information.
I2 When did he give his final information to
13 you?
14 MR. BRYSON: This is dated December 20, 1971.
15 MR. FETTEROLF: It has been changed since then.
16 MR. BRYSON: Okay. We will communicate with Dr.
17 Brungs and get the latest information and transmit it to
the conferees.
Carlos, Mr. Zar just pointed out, in the Argonne
report, the National Water Quality Laboratory recommenda-
21 tions were reissued about June 1972. There were no changes
22
in the specific recommendations.
23 MR. FETTEROLF: Well —
/-M i
MR. BRYSON: Either way I will check with Dr.
25
Brungs and transmit the required information to the
-------
642
R. Purdy
conferees.
MR. MAYO: Any other questions or comments,
gentlemen?
Thank you, Mr. Fetterolf.
6
7 STATEMENT OF RALPH W. PURDY,
EXECUTIVE SECRETARY,
9 MICHIGAN WATER RESOURCES COMMISSION,
10 LANSING, MICHIGAN
11
12 MR0 PURDY: In the request for State participation
13 in this conference, your letter, Mr. Mayo, directed that we
14 report on the rationale and difference between the recora-
15 mendations issued by the Administrator, following the prior
16 session of this conference, and the water quality standards
17 as they relate to thermal discharges that were adopted by
Michigan.
19 In the report that I presented on Tuesday and
20 asked to be incorporated into the record, a comparison was
21 made of the thermal standards, as adopted by Michigan, with
those recommended by the Administrator. (See pp. 13$a,
23 133b and 13Sc)
^ I would like to summarize that briefly, at this
point in time, and add some additional comments.
-------
643
1 R. Purely
2 With respect to the mixing zones, the Michigan
3 Water Resources Commission did not adopt the recommendation
^ of the Administrator as it related to a maximum distance of
5 1,000 feet from a fixed point adjacent to the discharge.
6 The mixing zone criteria that Michigan adopted is as
7 follows:
g The mixing zones for thermal discharges will be
9 established on a case-by-case basis and will be designed to
10 minimize effects on the aquatic biota in the receiving waters
11 and to permit fish migration at all times. Configuration
12 will be based on the physical characteristics of the receiv-
13 ing water body and the biological importance of the area to
14 be protected, such as spawning areas, migratory routes, etc.
15 Within mixing zones, other standards than those presented
16 may be applicable but will not interfere with the designated
17 water uses for the area.
1& The Michigan Water Resources Commission, at the
19 time that it adopted this criteria, felt that on the basis
20 of the information that had been presented to them at the
21 public hearing, that such a criterion represented a reason-
22 I able approach to the thermal discharge matter. In fact,
it appears to be quite similar to the recently announced
position of EPA as it relates to thermal discharges and
as that policy is shown in the report that EPA has presented
-------
644
1
2
3
10
11
12
13
14
15
16
17
19
20
21
22
R. Purely
to this conference.
The Commission, in adopting this on a case-by-case
basis fully recognized that you could not treat each indi-
vidual discharger as a case by itself without some consider-
ation being given to the effects of a number of cases on
that particular body of water. And, in fact, later on in
the standard adopted by the Commission, they addressed
themselves to that problem in the same fashion that the
Administrator's recommendations had the nonproliferation
statement.
For the southern portion of Lake Michigan, the
standards adopted by Michigan in the way of a monthly
maximum temperature are identical to those recommended by
the Administrator,
For the northern portion of Lake Michigan, the
information that we have available to us, and that was
presented to the Commission, indicated that this particular
portion of the lake could be maintained and should be main-
tained at a lower temperature than the southern portion of
the basin and the standards adopted for that sector of the
lake are somewhat lower than those — that is a lower
^ temperature as a monthly maximum was adopted by Michigan.
7L \
* The criteria with respect to water intakes,
25
' although worded somewhat differently, I think contains
-------
645_
1 R. Purdy
2 the essential requirements of the Administrator's recommenda-
3 tions.
4 The same pertains to the geographic area affected
5 by the thermal discharge.
6 With respect to backfitting of existing plant
7 discharges, the Water Resources Commission did not accept
8 the recommendation to require backfitting, but determined
9 that on a case-by-case basis that the need for such back-
10 fitting would be determined in view of studies that were
11 being required of the discharger, and further by studies
12 conducted by the Michigan Water Resources Commission, and
13 any other such information that would be available to them
14 by studies conducted by others.
15 With respect to the moratorium or so-called
16 nonproliferation of new plants on Lake Michigan, this was
17 agreed to and incorporated in the Michigan Water Resources
13 Commission requirements as a moratorium for a 5-year period
19 at which time a reevaluation will be undertaken to see
20 whether or not that policy should be modified in view of
21 the information then available* In no way does this indi-
22 cate, at this point in time, that the Water Resources Com-
^ mission does not intend to continue that restriction. It
indicates only that, at that time, the Commission will
establish this as a point certain, that the thermal
-------
646
1 R. Purdy
2 temperature standards would be reevaluated and, in fact, all
3 standards, other than thermal standards, will be reevaluated
^ on a routine basis.
5 In the comments as to the Commission not adopting
6 a reporting requirement in its standards, a reporting require-
7 ment is included in the Michigan statute and, as such, it is
g not repeated in a standard. In fact, if the Commission had
9 attempted to adopt this as a part of an administrative regu-
10 lation, it would have been stricken from that regulation by
11 our Legislative Service Bureau in its review of those
12 regulations.
13 Pre- and post-operating studies are included by
14 an order of the Water Resources Commission. Those studies
15 — that is pre- and post-studies by the discharger — those
16 studies are under way; information has been developed; and
17 periodic reports have been filed with the Commission.
That completes the State report at this time.
19 MR. MAYO: Any comments or questions, gentlemen?
20 MR. McDONALD: Mr. Purdy, in regard to the mixing
21 zone question, in actual fact, in relation to the Donald C.
22 Cook plant and the Palisades plant, have you applied your
mixing zone criteria to establish the zone of mix for those
two plants?
MR. PURDY: Modeling studies were conducted by
-------
_^ 647
R. Purdy
both proposed dischargers and, on the basis of those modeling
studies, a mixing zone of the size identified by those
modeling studies has been established.
The Commission reviewed the modeling studies and,
on the basis of information that was available, at that
point in time, did not feel that it was necessary to restrict
the size of that mixing zone to an area less than that shown
by the modeling studies.
10 MR. McDONALD: What does that mean, that there is
>»
11 no definable mixing zone there; you have not restricted them?
12 MR, PURDI: No, sir, that does not mean that. In
13 both cases, a mixing zone defined as — I can't remember
14 whether it is acres or square miles — has been identified.
15 MR. McDONALD: Well, relating it to the 1,000 feet
16 that was recommended by the conference, what type of footage
17 are we talking about?
IB MR. PURDY: In both cases, it would be consider-
!9 ably larger by several orders.
20 MR. McDONALD: Do you have those figures?
21 MR. PURDY: I do not have those available. I can
I
22 furnish them to the conferees.
23 MR. McDONALD: I think that would be helpful.
24 MR. PURDY: I should add that the Commission, in
its studies, has engaged the services of Willow Run
-------
643
R. Purdy
2 Laboratories to do remote sensing on thermal plumes to the
3 Great Lakes so that it will have this information available
4 to them to add to its ground studies that its staff is con-
5 ducting
6 MR. McDONALD: How will you enforce a violation
7 of mixing zones if one of these plants violates your mixing
zone area?
9 MR. PURDY: I think two considerations will be
10 necessary: One, in fact, has an injury occurred due to the
11 fact that the mixing zone was larger than that indicated by
12 the modeling studies? The size of the plume will have to
13 be determined by surveys and, in this case, the most expe-
ditious means of determining the size of that plume
^ will be by aerial remote sensing techniques. However,
16 this will not satisfy the requirement for a determination
of the effect of the plume during the winter operations and,
as such, that plume will have to be studied from boats and
19 with depth thermometers if, in fact, we can do this during
| the winter months on the lake.
I
21 MR. McDONALD: Does this really mean, in effect,
j
22 then, that the mixing zone — the real extent of the mixing
23 zone will not be established until the plants are fully
operable, and until there is sufficient year-round evidence
25 of the type of discharge that they have in terms of plumes?
-------
4
5
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
649
R. Purdy
MR. PURDY: The final proof will not be in until
those plans are in operation and you can, in fact, observe.
MR. MCDONALD: How long will that be?
MR. PURDY: If I knew how long the licensing
procedure was going to take I might have a better means of
predicting that. (Laughter)
MR. McDONALD: Let me phrase the question another
way: How long will that be once the license is granted,
assuming that it is granted, along the lines of your mixing
zone? How long before you know what the extent of the real
plume is and what the extent of the damage may be so that
you can enforce anything beyond that zone?
MR. PURDY: The thermal plumes for the Palisades
plant at a 60 percent power level are being observed at the
present time. So that at least at the 60 percent level that
information is being accumulated now, and the plant only
reached the 60 percent power level this year. So that
it will be accumulated — that information will be accumu-
lated as soon as the plant goes into operation.
With respect to the Cook plant, the Water Resources
Commission, in its order, as it relates to that plant, set
an outside limit of 2 years when it would evaluate the
2/4- i| effects of that discharge, as shown by the study.
However, again, periodic reports are being filed,
-------
650
R. Purdy
and the Commission, when it set the 2-year date as an out-
side limit, made it clear that, at any time the periodic
reports showed that there was a significant increase to Lake
Michigan, it anticipated taking immediate action requir-
6 ing remedial facilities.
7 MR. McDONALD: Well, let me ask, again, now: How
long will it be after the plant is fully operable that you
will impose a mixing zone with some precision so that a
10 discharger and others know what that zone is? You say a
11 2-year period of evaluation. Is that the time it is 100
12 percent operable?
13 MR. PURDY: That is an outside date. If, at any
14 point in time the studies show an injury and that there is
15 a need to take remedial action, it will be taken then.
16 MR. McDONALD: Now, an injury to what? Where?
17 Outside the mixing zone? Inside?
MR. PURDY: If the injuries that take place within
19 the mixing zone are such that they impair the total ecology
i
2° j of Lake Michigan, it will be taken on the basis of the effect
21 within the mixing zone.
22 ]y[R. McDONALD: What do you mean by "total ecology
of Lake Michigan?"
MR. PURDY: This morning we heard reports from
Mr. Barber on the number of fish fry, eggs, adult fish, that
-------
651
R, Purdy
2 could be killed either by impingement on the water intake
3 .screen, by thermal shock after traveling through the con-
densers, or by chlorination — all of those things must
5 be considered, And if a determination is made that those
6 will have a significant effect upon the fishery of Lake
7 Michigan I fully expect the Water Resources Commission to
take action.
9 MR. McDONALD: Now, where is that information
10 going to come from in toto — the total impact upon the lake?
11 MR. PURDY: That information is going to come from
12 Water Resources Commission staff employees. Hopefully we
13 will have the benefit of the experience of others, including
14 Mr. Barber and his colleagues, in evaluating that data.
15 MR. McDONALD: Well, I know of no overall program
16 at the present time that is on the horizon, that is funded,
17 that has been agreed upon to assess this total impact upon
the lake, that you would relate these discharges to.
19 Maybe I am wrong on that, but I don't know. Do
20 you, Mr. Mayo?
21 MR. MAYO: No, I am not aware of any.
22 MR. McDONALD: I am not saying we shouldn't have
one, but if you are going to assess this discharge and the
severity of it to the total impact of the lake, it seems
2 5 like we need a program for the total lake, that we certainly
-------
652
i R. Purdy
2 don't have if that is your criteria for assessment,
3 MR. PURDY: It seems to me this is what we are
4 interested in,
5 MR. McDONALD: I am pursuing this point for this
6 reason, Mr. Purdy — and I was not a part of the delibera-
7 tions at the last conference. But I do know, on the basis
3 of the record, that the mixing zone that was decided upon
9 — 1,000 feet fixed point — was given a good deal of
10 thought, and it was based upon minimizing damage to aquatic
11 life and for ease of enforceability. And, as you know, if
12 you have got a regulation and you can't enforce it because
13 | of the difficulty of enforcing, and the lack of evidence to
14 enforce it, it is a very difficult regulation when it comes
15 to meaning something.
16 So your regulation, if the prime emphasis on
17 enforcing it is going to be the total lake program — unless
11
j
1° | I am missing the point here — it is going to be extremely
li
19 | difficult to enforce because we don't have a total lake
i
20 program,
21 |! MR. PURDY: Well, I feel very uncomfortable in
; i
22 recommending to my Commission that it adopt, or that it
97 1
*•-> \ adopt a particular requirement for the sake of ease of
enforceability,
* Occasionally the requirements of the Commission
-------
n 653
1 R. Purdy
2 are challenged in the courts, and unfortunately the Coramis-
•3 sion does not sit on the witness stand; its staff sits on
^ the witness stand. And when I am on the witness stand I
5 would like a rationale better than "ease of enforceability"
6 as to why a particular requirement was, in fact, adopted.
7 MR. McDONALD: Well, I think, when I explained
$ "ease of enforceability,*1 I was talking beyond enforce-
9 ability. I said that you conferees at the last session
10 based this mixing zone on damage to aquatic life, and
11 attempting to minimize that damage by establishing the
12 1,000 feet; at the same time having a fixed footage that
13 would be recognized throughout the lake as a uniform
14 parameter and thereby having a precise zone for enforce-
15 ment and outside that zone would constitute a violation.
16 MR. PURDI: As I recall that last session of the
17 conference, we conferees were faced with a Federal recommenda-
tion that we received the night before the session, and that
19 at the close of the session we did, in fact, agree to present
20 those, if the Administrator concurred in them, to our
21 respective States for their adoption under State and local
22 i law.
23 i do not remember any great amount of deliberation,
either privately or in the record, that would support the
particular rationale of 1,000 feet.
-------
654
R. Purdy
MR. MCDONALD: Well, I won't debate that, although
I have been advised that there has been considerable thought
4 given to the 1,000 feet,
5 A thousand feet does sound very precise. I think
6 maybe I would agree with you if it was 998 feet, you would
7 think a great deal of thought went into that. (Laughter)
Let me move on to one other point, Mr. Purdy.
9 In terras of Recommendation III of the conference —
10 that is Roman III — relating to corrective action for water
11 intakes to minimize entrainment and killing of fish on in-
12 takes — have there been reports of such entrainment, such
13 fish mortalities in fisheries at Consumers Power Company's
14 Campbell plant?
15 MR. PURDY: Well, many of the references cited
16 by — not many, but some of the references cited by Mr.
17 Barber, and some of the references cited in other informa-
tion that has been presented to this conference, have been
19 gathered by the members of the Water Resources Commission
20 staff in its studies.
21 The full report shows that the Michigan Water
22 Resources Commission has initiated a program to determine
23 the significance of intake mortalities to fish and other
aquatic life. Present studies under way at two existing
facilities will also give a better indication whether intake
-------
655
R. Purdy
2 structures are detrimental to aquatic organisms which pass
3 through them.
Sometime ago, Michigan asked your office if it
5 had information that would help them guide their studies
6 and to evaluate the adequacy of present intake structures
7 as it relates to minimizing the entrainment of organisms
drawn into those structures.
9 If you have such information available to you,
10 to aid us in our studies, we would appreciate that
11 information.
12 MR. McDONALD: We will look into this and pursue
13 it again, if we do.
14 Are you saying, then, that at the present time
15 that Michigan does not have a program to reduce the entrain-
16 ment damage to desirable aquatic organisms?
17 MR. PURDI: We have studies under way to determine
whether or not this is a problem at the various intakes,
19 and hopefully this will give us some guidance as to the type
20 of intake structure that is necessary to minimize the
21 entrainment. But we do not have a corrective program under
22 way at the present time because I do not have the criteria
from which an evaluation can be made.
MR. McDONALD: Well, is the company independently
doing anything — the individual companies — because Mr.
-------
656
R. Purdy
Barber's report talks in terms of deaths of hundreds of
thousands of fish.
MR. PURDY: Well, Mr. Barber's report also talks
5 about the independent studies that were being conducted by
6 several of the companies and, again, those studies have
7 been developed as a part of a cooperative effort between
those water users, our Fisheries Division of the Michigan
9 Department of Natural Resources and, in turn, some Federal
10 representatives, to advise that discharger or that water
11 user on the type of studies that it should be making to
12 determine whether this is a problem, and the remedial action
13 necessary if a problem is found.
14 I MR. McDONALD: Are the power companies themselves
15 exercising any initiative in trying to solve what; appears
16 certainly to be an apparent problem?
17 MR. PURDY: They are the ones making those
studies.
19 MR. McDONALD: Are you hopeful for some solution
20 in the fairly immediate future?
21 MR. PURDY: It will depend upon the information
22 that those studies develop and how complicated the remedial
23 action might be.
MR. McDONALD: One final area, Mr. Purdy: Michi-
gan, as I understand your standards, ho.s declared a
-------
657
1 R. Purdy
2 moratorium on the construction or approval for construction
3 of new powerplants until 1975?
4 MR. PURDY: This is new powerplants that include
5 a once-through cooling system with discharge into the Great
6 Lakes.
7 MR. McDONALD: Now, what will happen in 1975 and
g why was that date set?
9 MR. PURDY: As a date certain by which this will
10 be evaluated by the Commission on the basis of studies and
11 information available to them at that time* I can't predict
12 what will happen. However, I would assume that if the
13 information that is developed confirms the fears and the
14 projections of damage that have been presented to this
15 conference and to prior conferences that that prohibition
16 against the use of the once-through cooling system will be
17 continued, and, in fact, it may even be made more restrictive
13 in view of the technology that might be available at that
19 time to provide cooling systems that would fill the need
20 of that particular thermal discharger.
21 MR. McDONALD: Thank you, Mr. Purdy. I think your
22 answers have been complete on a very difficult and complex
23 subject.
24 i am still bothered about this question of enforce-
2 5 ability of mixing zones, very much so.
-------
653
1 R. Purdy
MR. MAYO: Mr. Purdy, I have a question, if I may.
-2 I think it may be helpful to the conferees to have
• _ a little better insight into what the review process has
5 been in Michigan with respect to the models of the discharge
6 facilities.
7 Did the State apply to a given model a variety of
g discharge configurations, or did the State review a specific
9 configuration proposal by the discharger and not get involved
10 in a comparative evaluation of alternative discharge config-
*i
11 urations?
12 MR. PURDY: Well, the modeling studies were per-
13 formed by the thermal discharger. The extent of those
14 modeling studies depended upon the particular situation,
15 as it related to the Palisades plant.
16 When those modeling studies were conducted, the
17 outlet structure was, in fact, in place, and therefore the
18 study was made on that particular outlet structure.
19 Further, at that point in time, a decision had
20 i been reached to modify that once-through cooling system to
i
21 a forced draft wet cooling system, so that the once-through
22 cooling system won't apply, on an interim basis, I believe,
23 until 1974.
01 '
*•+ The modeling studies for the Cook plant were con-
25 ducted prior to the construction of that outlet facility
-------
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
i
659
R. Purdy
and, in fact, a number of configurations were studied, and
the size of plume that each configuration would have was
reviewed with members of my staff. A decision was reached
as to which would be likely to have the least impairment
upon Lake Michign water quality, and then that particular
configuration was selected for more detailed studies.
MR, MAYO: Just by way of observation, Ralph,
each one of us who shares the responsibility of trying to
reach some balance between what is a reasonable burden for
the discharger to assume and what is a reasonable burden
for the regulatory agency to assume are always challenged
by what is a "reasonable" balance.
It seems to me that in this instance the State of
Michigan has certainly taken on a rather onerous burden of
proof when it comes to making a determination of the
extent to which it will judge any damage being done under
those circumstances as the basis for taking some form of
corrective action. I think it is an onerous burden indeed.
MR. PURDY: Your comment there, Mr. Mayo, reminds
me of some earlier statements that have been presented to
this conference. Number one, that the burden of proof ought
to be upon the waste discharger and should not be a cost
borne by the State.
On the other hand, there are frequent statements
-------
660
R. Purdy
that it is ridiculous for a State regulatory agency or a
Federal regulatory agency to depend upon information
furnished to it by the waste discharger, and therefore why
don't you do something?
In this case, we are making confirming studies
but, in turn, the Commission orders require considerable
pre- and post-operative data, not only on the effluent but
9 the effect of that effluent upon the receiving body of
10 water to be performed by the waste discharger. So we hope
11 that we are sharing that burden before one of the waste
12 dischargers points, it out.
13 They are also sharing in the burden of the State
14 cost of performing that surveillance activity beyond what
1$ they would pay and what has been, say, normal taxes — and
16 I don't intend to call this a tax because our legislature
17 did not call it a tax — but in Michigan an industrial
waste surveillance fee is imposed,, That fee is based upon
19 the volume and so-called strength of that discharge. The
20 purpose of that fee is to finance monitoring and surveil-
21 lance activities by the State — finance in part — those
22 | activities that are made necessary by the fact that that
23 particular waste discharger is discharging something to
waters of the State and it is necessary, then, for the State
to carry out a monitoring and surveillance program.
-------
661
1 R. Purdy.
2 MR. BRYSON: I have one quick question: The
3 studies that you and Mr. McDonald were going back and forth
on — were they on fish mortalities in environmental impacts,
or are they studies on modification of the intake structures
6 at Campbell and Palisades?
7 MR. PURDY: The first part was the mortalities
that are caused by impingement on the screens, and so forth.
9 The second part was what sort of remedial
10 action can be taken to prevent that from taking place,
i
11 whether it be bubble curtains, change in the velocities
12 or whatever myriad of actions might be available to
i
13 us.
14 | MR. BRYSONj Okay. What is the timing on the
15 terminal points on the studies, or is there a terminal point
16 at this stage of the game?
17 MR. PURDY: No terminal point at this stage in
the game. We don't know when we will have all of our
19 answers.
20 MR. McDONALD: Mr. Purdy, if, when all of the
returns are in, and you have a mixing zone, and if you are
able to assess total impact upon the lake in the studies
that are not yet designed — I don't know if they are on
the horizon — but if all these things come to be, would
you require, if substantial damage was demonstrated, a
-------
662
, , _______ _ __ _
-j_ R. Purdy
2 company to backfit?
3 MR. PURDI: The Water Resources Commission has,
4 for example, notified the Indiana-Michigan Electric Company
5 that if such studies do, in fact, show that, that it will
6 be required to backfit, and it has requested and has received
7 from that company plans by which it would progress toward
8 that backfitting; the plans are on the shelf ready to be
9 used, so that there will not be a delay for preparation of
10 plans. A contingency plan is on the shelf.
11 MR. McDONALD: Again, in closing, I think the
12 thing that really is troublesome here is finding when you
13 would trigger the action to put those plants into place.
14 I I frankly do not see the triggering mechanism that you may
15 think is there.
16 MR. PURDI: I am confident that if we don't find
17 it that you will help us find itj (Laughter and applause)
MR. McDONALD: I didn't realize you brought that
19 big a contingent down from Michigan.
20 MR. PURDI: I think that was your family.
2i (Laughter)
22 MR. McDONALD: I am sorry. I missed that.
Well, that is a good happy note to end on.
MR. PURDI: I would also point out that if the
mixing zone does, in fact, happen to be larger than that
-------
2
3
4
5
6
7
9
10
11
12
13
15
16
17
20 happened.
^
663
A. Voita
established by the order, that under Michigan statute this
would require them coming back to the Commission, and we
will have another crack at whether or not it should be
enlarged.
I would like to call upon Alma Voita, at this
point in time.
STATEMENT OF ALMA T. VOITA,
BRIDGMAN, MICHIGAN
MRS. VOITA: Alma Voita from Bridgman, Michigan.
I am just an angry housewife. And when you add to that,
that I am a grandmother, you will know just how angry I am,
because I am only concerned about my grandchildren and all
of the children of that generation. And I want to say to
y0u men sitting at this table: I hope each one of you
realizes just what you are going to have to account for if
anything worse happens to this lake than has already
And I just can't see how, when you listened to
the report — was it of Dr. Stoermer — and realized that
the algae in this lake is already beyond the danger level,
01
how in this world can the addition of heat to any part
25
of the water of Lake Michigan help?
-------
664
•^ A. Voita
2 Now, it seems to me that we are here to save the
o lake, to keep it from getting worse. Now why aren't we
i willing to take the steps that are going to do that?
5 Just as Mr. Purdy was talking, I was thinking that
^ if — supposing the Donald C. Cook plant was in operation
7 and it was discovered that all this harm was being done.
g Do you know how long it would take them to correct that
9 matter? And do you know all of the additional destruction
10 that would go on in the lake in this southern end of the
11 lake that is completely — it is completely impossible to
12 reverse the effects that take place here. We have heard
13 this for years.
14 I have attended almost all of the conferences
15 that have been held and I have listened time after time to
16 this type of evidence. It seems to me it is about time
17 that we are taking cognizance of this fact.
IB Now, I wrote a statement, and you can all sit
19 back because there is nothing technical in it. You don't
20 have to think of a thing except just maybe a little bit of
21 something to your conscience.
22 Now, besides this heat going on in the summer
23 months, there is also the fact that the heat would be going
24 on in the winter months.
We, who — I will start out this way though,
-------
665
1 A. Voita
2 telling you that we have had a summer home on Lake Michigan
3 just a mile south of the Donald Cook plant for 22 years,
4 and just this last summer we remodeled so that we are going
5 to have that for our permanent home.
6 Now, we realize — all of us who live within a
7 radius of maybe 5 miles from the plant — how much that ice
cap on the water during the winter months means to all of us
9 in the way of erosion to the beach. Now all of these
10 billions of gallons of hot water going into the lake hour
11 after hour, day after day, year after year, and in the
12 winter months, it would completely alter this condition that
13 is so beneficial to us.
I had this sort of organized and it is a little
15 bit difficult.
We who live on the lake have riparian rights. Now
17 my understanding of our riparian rights is that each owner
of property with this right has the right to have a peaceful
19 and safe enjoyment of his home. And I think that this is
guaranteed by the United States Constitution.
Overuse and misuse of a body of water can cause
Op I
^ damage to property values and is a violation of the law of
3 riparian rights.
2.L
^ Now it seems to me that the preservation of the
25
J environment should be the primary concern of the governing
-------
666
A. Voita
bodies of our land. The waters of Lake Michigan are Federal
waters and the lake belongs to the people to use and enjoy,
4 and it is their right not to have it jeopardized at any
5 time. We have the right to expect our government to pro-
6 tect our rights and interests at all times.
7 Now, I was present at the hearing in regard to the
Palisades plant, and it seemed to me at that time that it was
absolutely unfair to think that a group of citizens and
10 environmental groups had to go to the expense and all of
11 the effort to take the master to court, to the law, to
12 employ lawyers, to bring about what it seems to me our
13 governmental bodies should do for us; i.e., take care of
14 our rights. And finally it was done in this manner, and the
15 Palisades plant is required to put up cooling towers. But
16 in the meantime they are using the lake for once-through
17 cooling until they get this done, which I don't know when
it will be.
19 I want you to know that we — and I am speaking
20 for people all along the shore —• are not opposed to the use
21 j of nuclear power for the purpose of generating much needed
i
22 electricity. We are willing to live in the shadow of a
23 t)ig powerplant, like the Donald C. Cook nuclear plant, the
largest being constructed on Lake Michigan, realizing fully
^ the hazards that it entails.
-------
66?
A. Voita
But we are opposed to once-through cooling involv-
ing the introduction of quantities of heated water into the
lake. We are opposed to any radioactive discharges into
5 the lake involving potential hazards which can never be
6 retrieved. We are opposed to any tampering of the lake
7 which already is in a condition of eutrophication beyond
redemption. And, finally, we are opposed to the apparent
9 permissive policy of our governing bodies.
10 Now I realize that you men have put in a great
11 deal of time and effort into this problem. I know that it
12 has been a year and a half since the first enforcement con-
13 ference, and I realize that you have been thinking about
14 this and working on it ever since.
15 Isn't it time that a definite standard be made
16 that will really assure us that nothing worse than has
17 already happened will happen to our lake?
Thank you.
19 MR. PURDI: Mrs. Voita. Correct me if this is
20 not your understanding, but, for the purposes of correction
or correctness of the record as far as the conferees are
22 concerned, is it not true that the citizen intervention in
the Palisades matter was at the AEG licensing hearing level,
and that this matter was resolved by agreement between the
intervenors and the Consumers Power Company at that level,
-------
663
1 0. Petersen
2 and that the cooling towers were not established as a re-
quirement of a court decision?
4 MRS. VOITA: I believe that is so.
5 I felt very sorry to realize that Indiana feels
6 that they would not have had to have done this, because I
think they are doing absolutely the right thing, and it just
8 seems to me that they should be commended for having done it
9 in spite of the fact that they might not have had to, and
10 I believe that is true. I believe what you say is absolutely
11 true.
12 MR. PURDY: It was not a decision that was found
13 to be necessary by the court. It did not reach that stage.
14 It was an agreement between —
15 MRS. VOITA: Well, it seemed to me that Palisades
16 could not come through with any evidence that proved that
17 they were not going to harm the lake. Therefore, they
agreed.
MR. PURDY: I would like to call on Mr. 0. K.
20 Petersen of Consumers Power Company.
21
22 STATEMENT OF 0. K. PETERSEN, ATTORNEY,
23 CONSUMERS POWER COMPANY,
JACKSON, MICHIGAN
25
-------
669
0. Petersen
MR. PETERSEN: My name is 0. K. Petersen. I am
an attorney for Consumers Power Company.
We have passed, out a copy of what we propose to
5 say today. We will not say all of that in order to conserve
6 time and perhaps be one of the first to do so.
7 MR. MAYO: Do you want this printed statement
introduced as if read?
9 | MR. PETERSEN: Virtually yes. I will make some
10 small changes in the statement as I go. I will be reciting
11 much of the first, second and seventh pages.
12 (Mr. Petersen's printed statement follows in its
13 entirety.)
14
15
16
17
18
19
20
21
22
23
24
25
-------
CONSUMERS POWER COMPANY
STATEMENT TO
THE LAKE MICHIGAN ENFORCEMENT CONFERENCE
Chicago, Illinois
September 19-21, 1972
The Report of the Environmental Protection Agency to the Lake
Michigan Enforcement Conference on (the)Thermal Question, September, 1972
provides a brief section as background on the history and workings of
the Conference. While it would not be appropriate to give a critique on the
entire history, the remarks concerning the last session, which occurred on
March 23-25, 1971, do require comment.
2
It is stated that the report of the Technical Committee authorized
at the October 29, 1970 Executive Session was presented at the March 23-25,
1971 session and then "on the basis of the full discussion on the question,
the conferees made certain findings and recommendations" which were sub-
sequently approved by the EPA Administrator.
In fact, at the March 23-25 Conference the Federal Conferee presented
a new position, prior to any discussion and quite unrelated to the Technical
Committee Report. That position was pushed through the conference before it
could be carefully evaluated, with the Federal Conferee explaining that the
EPA position was that it was anxious to have the states employ the EPA
"recommendations'1 and would "employ the full extent of the administrative and
the legislatively defined processes that are available to the Environmental
Protection Agency to achieve that end. The arbitrary circumstances under
which the findings and recommendations at the last conference were promulgated
should cause no one to wonder that the states have in large measure rejected
them.
We would also take issue with the inference on Page 11 and in
Tables I - IV that the latest recommendations of the Enforcement Conference
-------
2
are "established requirements." The recommendations of the Conference are
only that and require the regulatory authority of the states for implementation.
In this regard, it is our position that the procedure for enforcing Enforcement
Conference Recommendations, contained in the Refuse Act regulations, is invalid.
There are some items of technical information upon which we would
like to comment as the result of a review by Consumers Power Company's technical
experts. Some involve relatively minor corrections or elaborations on the
h
"Argonne Report' and the others are to advise you of additional information
that might be considered in this review.
Beginning on Page 8 and again on Page 36 of the Argonne Report,
mention is made of a study and report by the University of Michigan Willow
Run Laboratories involving numerous multispectral aerial scanning observations
along the eastern shore of Lake Michigan during the spring thermal bar develop-
ment period in 1971. The power plants covered included the J. H. Campbell Plant,
the Michigan City Plant and the Bailly Plant. The project involved 17 separate
flight lines and a total of 80 sets of data for all of the lines, the processing
of which "showed no evidence of any water masses that could be attributed to
the effect of warm water discharges from power plants into the lake."
We believe the importance of this work warrants its inclusion into
the record of this conference. The original copies include a large number
of color photographs which would aid the reader in interpretation, however,
the black and white copies provided show or describe the major features of
interest. Color copies can be provided on loan should any of the conferees
desire. It should also be noted that in connection with the Willow Run aerial
flights numerous water samples were collected by field personnel for correlative
study. Detailed phytoplankton data and other water quality observations are
included in the Benton Harbor Power Plant Limnological Studies Part X, Cook
Plant Preoperational Studies 1971, Special Report No. M*, Great Lakes Research
Division, The University of Michigan, August 1972.
-------
3
On Page 28 of the Argonne Report there is mention of a tabulation
of one month's growth of periphyton in the Palisades area during May -
August 1969 which appears in the supplement to the Environmental Report for
7
the plant. Actually, the quantitative data referred to, include nine separate
samples at various periods; May-June, May-July and July-August. The same
supplement also includes data on periphyton growth at three locations near
Palisades in May-June, 1968 based on chlorophyll analyses. Additional
quantitative periphyton data collected near the Palisades Plant in 1970 and
in 1971> before this phase of the program was discontinued, are included in
a Consumers Power Company report to the AEC, entitled "Environmental Impact
Q
of Plant Operation up to July 1, 1972," dated July 19, 1972. The technique
of using artificial substrate for monitoring attached periphyton growth in
the vicinity of the Palisades Plant was abandoned in favor of doing detailed
analyses of substrate samples collected along the beach. Data are not yet
available on these collections. The above referenced 1972 report includes
recent information on all aspects of the thermal effects study program at
the Palisades Plant and should be consulted for extensions of data referred
to in the Argonne Report.
The Argonne Report, as well as the Report of the Environmental
Protection Agency to The Lake Michigan Enforcement Conference on the Thermal
Question, includes the B. C. Cobb Plant in Muskegon, Michigan as contributing
to the thermal loading of Lake Michigan. This plant is located on the east
end of Muskegon Lake, about five miles from the shore of Lake Michigan, and it
is inconceivable, either from a theoretical analysis or from the numerous
field measurements that have been made, that the plant could in any way
contribute preceptably to the "thermal question"of Lake Michigan. It should
be excluded from any further consideration in this context.
-------
On Page 3^ of the Argonne Report reference is made to 1970 and
1971 Water Quality Studies conducted by Consumers Power Company and the
9-1Q
thermal plume measurements contained therein. In connection with the
reported surveys, various biological collections were made and analyzed
as described in the following reports by Beak Consultants, Inc.
a) 1970 Biological Survey of Lake Michigan Near Holland, Michigan,
November 1970. (includes identification of benthic organisms
from three replicate collections from each of 13 stations
sampled offshore of the J. H. Campbell Plant discharge in
August 1970).
b) 1971 Biological Survey of Lake Michigan Near Holland, Michigan,
April, 1970 (includes identification of benthic organisms
from three replicate collections from each of 13 stations
sampled offshore of the J. H. Campbell Plant discharge and
one artificial substrate sampler in the plant intake in
August, 1971. Data are also included on fish caught by
12
seining in the vicinity of the intake and discharge).
c) Identification of Miscellaneous Pish and Artificial Substrate
Samples, 1971, April 1972 (includes, for stations on Lake
Michigan, identification of organisms recovered from artificial
substrate samplers placed in the discharge of the Big Rock
Point Plant).13
It should be noted that additional surveys are being undertaken
this year to provide further data on aquatic characteristics in the vicinities
of these plants.
On Page ^9 of the Argonne Report, a study conducted by the Michigan
Ik
Water Resources Commission in the vicinity of the J. H. Campbell Plant is cited.
There are two statements included in the citation which may be misleading if
considered out of context with the entire report. In the second paragraph it
-------
5
is stated that "Large amounts of filamentous green algae, Cladophora,
were collected in the trawl through the plume area. The origin of the
algae was unknown." We believe it should also be noted that another some-
what parallel trawl, also in the plume but in shallower water did not
encounter large amounts of filamentous algae, and that surface water
samples showed relatively fewer numbers of green algae in the vicinity of
the plant than at the control stations.
In the same report it was stated that increased benthic productivity
in the plant's outfall was the only adverse effect that could be attributed
to the warm-water discharge. We would note that the interpretation of
adversity is tenuous at best in view of the fact that there were no signifi-
cant increases in total numbers of individuals along the outfall transect
and that practically all of the additional species in this area near shore
are of the intolerant or facultative organism groups.
On Page 71 of the Argonne Report it is stated that, during winter
operations of the Palisades Plant, about 17,000 gpm of discharge water will
be withdrawn from the discharge canal and returned to the intake. So that
this statement will not be misinterpreted, we would point out that the return
water will actually be discharged to the onshore forebay and will not be
transported to the intake structure located in the lake.
On Page 75 of the Argonne Report reference is made to entrainment
studies at the Big Rock Point Plant during November, 1971 and the statement
in the EPA report on the study that the plants involved were chosen because
of their proximity to whitefish spawning grounds. So far as we know there
has been no additional information available on the location of whitefish
spawning grounds since the representative of the U.S. Bureau of Sport Fisheries
and Wildlife testified at the Wednesday session of the Conference Workshop in
September, 1970 that no one has identified a whitefish spawning ground along
the eastern shore of Lake Michigan. Further, the EPA study at Big Rock Point
did not detect any whitefish eggs.
-------
6
With regard to the zooplankton investigations from the same EPA
study, the quote regarding the Big Rock Point data that "Regardless of
whether the mortality is 29 or 55$, there appears to be significant popula-
tion mortality" doesn't recognize the variability of the data or its true
significance with regard to effects on other aquatic life. In fact, from
the data included in the report it is not possible to derive the indicated
population mortalities. Live/dead zooplankton ratios for Copepoda are the
only figures included in the report and vary at the time of collection from
0.29 to 1.U5 for intake samples and from 0.11 to 1.23 for the discharge
samples. In addition, some of the intake-discharge paired samples were
obviously taken during transition periods of zooplankton populations and
should not be averaged with more representative samples. Moreover, the signifi-
cance of any such observations cannot, of course, be determined by looking at
changes in only one isolated group.
On Page 77 of the Argonne Report is reference to fish entrainment
data for the intake at the Palisades Plant. It should be noted that continuous
records of fish entrainment are being obtained and that totals up through
July 1, 1972 are included in the report to the AEC of Environmental Impact of
Plant Operation up to July 1, 1972.
On Page 109, Section 10, of the Argonne Report there is reference to
testimony, given at the Michigan hearings, pertaining to the cost of providing
cooling towers on Consumers' system. The paragraph should be corrected to read:
Dr. John Z. Reynolds, Consumers Power Company, testified
at the Michigan hearings concerning the cost of outfitting
Consumers' 7500 - MWe system, present and proposed, with towers.
He estimated that $76,000,000 would be required in capital costs
and $73,000,000 additional would be required for replacement
capacity to account for the 3-5$ system-capacity losses. Total
annual costs, including fixed charges, added fuel costs, and
operating and maintenance costs were estimated to be about
$31,000,000 per year. Total capital costs, including equivalent
costs escalated to a reasonable date of completion, were projected
to be about $2UU,000,000.
-------
7
A great deal of detailed enumeration of chemical effluents is
presented in the Argonne Report in Table 11 on Page 111. These figures
are largely prorated estimates based on data from only a few plants.
While it is not claimed these are necessarily dissimilar plants, it should
be recognized that this basis of estimating may be grossly in error and
that any substantial action that depends on such data should await more
accurate determinations.
In concluding, we would urge the Conferees to reconsider the
weight of the technical evidence on the thermal question and adopt a
position that actually involves a case-by-case evaluation of power plants
using Lake Michigan waters for cooling. Unfortunately, the memo of John
Quarles, Jr., Assistant Administrator for Enforcement and General Counsel
of EPA, to the Regional Administrators on Policy on Thermal Effluent, dated
May 12, 1972, does not require reasonable case-by-case evaluation for all
discharges. Mr. Quarles presumes a need for "thermal pollution control "
for all new plants and thereby precludes a reasonable examination of the
relevant factors in these cases.
Much work has been conducted in the evaluation of thermal dis-
charges and other power plant usages of water since the 1970 Workshop of
the Conference. We are aware of no instance where an independent review
of plants on Lake Michigan has resulted in the conclusion that once-through
cooling has had significant adverse effects on the aquatic environment.
Moreover; significant questions have been raised as to whether alternatives
are potentially more damaging to the environment than once-through cooling.
We are confident that the conferees will proceed with a careful evaluation
of all the recent studies and base any findings and conclusions on a con-
sidered weighing of the technical evidence.
-------
REFERENCES CITED
1. "Report of The Environmental Protection Agency to The Lake Michigan
Enforcement Conference on Thermal Question," U.S. Environmental
Protection Agency, September, 1972.
2. "Recommendations of The Lake Michigan Enforcement Conference Technical
Committee on Thermal Discharges to Lake Michigan," January, 1971.
3. "Reconvening of the Third Session of the Conference in the Matter of
Pollution of Lake Michigan and its Tributary Basin in the States of
Wisconsin, Illinois, Indiana and Michigan" - - Volume I, Transcript,
March 23, 1971, Pages 16-17.
k. "Summary of Recent Technical Information Concerning Thermal Discharges
into Lake Michigan," Argonne National Laboratory, Contract Report 72-1
August, 1972.
5. Stewart, S. R., Brown W. L., and Polcyn, F. C., "Multi-spectral Survey
of Power Plant Thermal Effluents in Lake Michigan," Willow Run Labora-
tories, The University of Michigan, April, 1972, Page 9U.
6. Ayers, J. C., et al, "Benton Harbor Power Plant Limnological Studies
Part X: Cook Plant Preoperational Studies 1971," Special Report No kk,
Great Lakes Research Division, The University of Michigan, August, 1972.
7. "Supplemental Information on Environmental Impact of Palisades Nuclear
Plant," Consumers Power Company, August 18, 1971.
8. "Environmental Impact of Plant Operation up to July 1, 1972 - Consumers
Power Company, Palisades Plant," Consumers Power Company, July 19, 1972.
9. "1970 Water Quality Studies" by Consumers Power Company Environmental
Activities Department.
10. "1971 Water Quality Studies" by Consumers Power Company Environmental
Activities Department.
11. "1970 Biological Survey of Lake Michigan near Holland, Michigan," for
Consumers Power Company, T. W. Beak Consultants, Ltd, November, 1970.
12. "1971 Biological Survey of Lake Michigan near Holland, Michigan," for
Consumers Power Company, Beak Consultants, Inc, April, 1972.
13. "Identification of Miscellaneous Fish and Artificial Substrate Samples -
1971" for Consumers Power Company, Beak Consultants, Inc, April, 1972.
Ik. "Biological Survey of Lake Michigan in the Vicinity of the Consumers
Power Company's Campbell Plants Thermal Discharge - August 11-13, 1970,"
Michigan Department of Natural Resources, January 22, 1971.
-------
REFERENCES CITED (Contd) I
15. "Lake Michigan Entrainment Studies, Big Rock Nuclear Power Plant, Escanaba
Power Plant, November-December, 1971," Environmental Protection Agency,
January, 1972.
16. "Michigan Water Resources Commission Public Hearing on Proposed Revision
to Interstate and Intrastate Temperature Standards for Protection of Fish
and Aquatic Life," Statement by Consumers Power Company, June 2U, 1971.
-------
^ 670
1 0. Petersen
2 MR. PETERSEN: We have also presented a copy of
3 the record of the hearing in the State of Michigan on
4 standards. In addition to the regular hearing record, there
5 is also a copy of the scientific papers which were presented
6 for the record following the hearing and were made a part
7 thereof,
3 MR. MAYO: May I try to make a distinction that
9 would be acceptable to you, Mr. Petersen?
10 May we take the material supplemental to your
11 statement and have it introduced as an exhibit so that we
12 arenft faced with the burden of reproducing it?
13 MR. PETERSEN: By all means.
14 (The documents above referred to are on file
15 at U.S. EPA Headquarters, Washington, D. C., and Region
16 V Office, Chicago, Illinois.)
17 MR. PETERSON: The Report of the Environmental
13 Protection Agency to the Lake Michigan Enforcement Confer-
19 ence on (the) Thermal Question, September 1972, provides
20 a brief section as background on the history and workings
I
21 | of the conference. While it would not be appropriate to
22 give a critique on the entire history, the remarks concern-
ing the last session, which occurred on March 23-25, 1971,
01
^ do require comment.
5 It is stated that the report of the Technical
-------
671
0. Petersen
Committee authorized at the October 29, 1970, Executive
Session was presented at the March 23-25, 1971, session
and then "on the basis of full discussion on the question,
the conferees made certain findings and recommendations"
which were subsequently approved by the EPA Administrator.
In fact, at the March 23-25 conference the Federal
8 conferee presented a new position, prior to any discussion,
and quite unrelated to the Technical Committee report. That
10 position was pushed through the conference before it could
11 be carefully evaluated, with the Federal conferee explaining
12 that the EPA position was that it was anxious to have the
13 States employ the EPA "recommendations" and would "employ
14 j the full extent of the administrative and the legislatively
I
15 S defined processes that are available to the Environmental
16 Protection Agency to achieve that end." The arbitrary cir-
i
17 I cumstances under which the findings and recommendations at
1^ !i the last conference were promulgated should cause no one to
19 II wonder that the States have in large measure rejected them.
j i
20 | We would also take issue with the inference on
^ i page 11 and in Tables I-IV that the latest recommendations
99 i1
of the Enforcement Conference are "established requirements."
2 "I
! The recommendations of the conference are only that and
li
i require the regulatory authority of the States for imple-
25 '
mentation. In this regard, it is our position that the
-------
672
0. Petersen
procedure for enforcing Enforcement Conference recommenda-
tions, contained in the Refuse Act regulations, is invalid.
4 Now, there are some comments, which are not in the
5 paper which we have presented, that we would like to make very
6 briefly on the paper presented by the Pish and Wildlife
7 Administrator of the Environmental Protection Agency, on
which we had no opportunity for cross examination and which
9 paper we have not yet received.
10 However —
11 MR. MAYO: Excuse me, Mr. Petersen. Are you
12 referring to Mr. Yates Barber's material?
13 MR. PETERSEN: Yes, sir, I am.
14 MR. MAYO: Okay. In point of clarification,
15 Mr. Barber is with the Department of the Interior --
16 MR. PETERSEN: I thought he had identified —
17 MR. MAYO: — Fish and Wildlife Service.
MR. PETERSEN: — that as being under the Environ-
19 mental Protection Agency in his statement this morning.
20 MR. MAYO: No, I think he identified himself as
21 an Environmental Advisor in the Bureau of Sport Fisheries
22 and Wildlife, Department of the Interior.
MR. PETERSEN: Thank you for bringing that to
my attention.
2 5 jn any event, it was our observation that the
-------
673
0. Petersen
paper was in large part based upon theoretical facts which
were not applicable as used; that that was based upon
unjustifiable extrapolation of data; and that the figures
on theorized damage were not placed in appropriate context;
in addition to which, I might comment that the newspapers
7 are hardly a scientifically sound source of data.
MR. MAYO: You are going to insult Casey Bukro,
Harlan Draeger, and a few other fellows in Chicago.
10 (Laughter)
11 MR. PETERSEN: I am not intending to insult anyone,
12 I am merely commenting upon a paper. My intention is to —
13 • MR. McDONALD: Well, all of the reporters are
smiling, if that means anything. (Laughter)
15 MR. MAYO: Excuse the interruption.
i
16 MR. PETERSEN: That's all right.
17 There are some items of technical information
upon which we would like to comment as the result of a review
by Consumers Power Company's technical experts. Some
involve relatively minor corrections or elaborations on
21 the "Argonne Report" and the others are to advise you of
additional information that might be considered in this
^ revew.
2.L,
Beginning on page & and again on page 36 of the
25
Argonne Report, mention is made of a study and report by
-------
674
1 0. Petersen
2 the University of Michigan Willow Run Laboratories involving
numerous multispectral aerial scanning observations along
the eastern shore of Lake Michigan during the spring thermal
5 bar development period in 1971. The powerplants covered
6 included the J. H. Campbell plant, the Michigan City plant
7 and the Bailly plant. The project involved 17 separate
flight lines and a total of BO sets of data for all of the
9 lines, the processing of which "showed no evidence of any
10 water masses that could be attributed to the effect of
11 warm water discharges from powerplants into the lake."
12 We believe the importance of this work warrants
13 its inclusion into the record of the conference. The
14 original copies include a large number of color photographs
15 which would aid the reader in interpretation. However, the
16 black and white copies which should have been given to you
17 already show or describe the major features of interest.
A color copy will be furnished the conference by Joseph
Dominick, Esq., on behalf of I & M.
20 it should also be noted that in connection with
21 the Willow Run aerial flights, numerous water samples were
22 collected by field personnel for correlative study.
23 Detailed phytoplankton data and other water quality
observations are included in the Benton Harbor Powerplant
Limnological Studies, Part X, Cook Plant Preoperational
-------
675
0. Petersen
Studies 1971, Special Report No. 44, Great Lakes Research
o Division, the University of Michigan, August 1972.
• At this point, I will skip a large portion of what
5 I had prepared, which is being included in the record.
6 ;! In concluding, we would urge the conferees to
ii
H
7 ii reconsider the weight of the technical evidence on the
' ]
g | thermal question and adopt a position that actually involves
!
9 J! a case-by-case evaluation of powerplants vising Lake Michigan
11
10 waters for cooling. Unfortunately, the memo of John
ii
11 ]! Quarles, Jr., Assistant Administrator for Enforcement and
12 ! General Counsel of EPA, to the Regional Administrators on
13 | Policy on Thermal Effluent, dated May 12, 1972, does not
i
14 ; require reasonable case-by-case evaluation for all dis-
15 \ charges. Mr, Quarles presumes a need for "thermal pollution
16 control" for all new plants and thereby precludes a reason-
17 able examination of the relevant factors in these cases.
18 Much work has been conducted in the evaluation of
I
19 thermal discharges and other powerplant usages of water
20 i since the 1970 workshop of the conference, itfe are aware
i
21 i of no instance where an independent review of plants on Lake
i
22 Michigan has resulted in the conclusion that once-through
23 ; cooling has had significant adverse effects on the aquatic
i
24 !; .j-:ivironment. Moreover, significant questions have been
25 i raised as to whether alternatives are potentially more
-------
6?6
0. Petersen
damaging to the environment than once-through cooling. We
are confident that the conferees "will proceed with a care-
ful evaluation of all the recent studies and base any find-
5 ings and conclusions on a considered weighing of the tech-
6 nical evidence.
7 Thank you.
B MR. McDONALD: Mr. Petersen.
9 MR. PETERSEN: Yes.
10 MR. McDONALD: Knowing your love of the newspapers,
11 I would like to point out that in your exhibit that you
12 presented of your hearings of the Michigan Water Resources
13 Commission you did include copies of newspaper articles.
14 (Laughter)
15 MR. PETERSEN: I included a reference to —
16 correction — what I included was the entire record of the
17 conference as prepared by the Michigan Water Resources Com-
mission, without editing, and I will assure you that, in
19 fact, I do love the newspapers. I take two of them, and I
20 find them very enjoyable and a source of never—ending
information. But I do challenge them- as a scientific,
22 accurate source of data.
MR. MAYO: A point of information, Mr. Petersen.
Do you desire the Willow Run report to be a part
of the record or submitted as an exhibit?
-------
677
1 0. Petersen
2 MR. PETERSEN: I think probably because of its
3 bulk, it would be better accepted as an exhibit.
4 MR. MAYO: Thank you.
5 (The document above referred to is on file at
6 U.S. EPA Headquarters, Washington, D. C., and Region V
7 Office, Chicago, Illinois.)
& MR. McDONALD: I don't want to pursue this news-
9 paper argument but it seems to me that what Mr. Barber had
10 in his report was news. When you get a fish kill involving
11 hundreds of thousands of fish, there is not much scientific
12 evidence involved there; it is a fish kill. And usually
13 a picture accompanies that type of situation. So I really
14 think that casting credibility on his report because it
I
15 I happened to be newsworthy is not really germane to the
issue.
17 MR. PETERSEN: I am sorry. I have not been able
to see the report to see if it attributes hundreds of
19 thousands of fish to the newspaper report. I think that
the only place that I recall hearing hundreds of thousands
of fish was a report that there must have been from — or
22 accepted from the Michigan Water Resources Commission which
3 accepted some individual plant's estimate of what he thought
7L
* might have been the case as far as the fish kill was con-
i
i
25
cerned. It didn't even come from the newspapers, to the
-------
678
0, Petersen
best of my recollection,
MR. McDONALD: Well, sir, let me ask you, in terms
of fish kills: Do you keep records of fish kills over
5 entrainments that relate to your Campbell powerplant and
6 your Palisades plant in Michigan?
7 MR. PETERSEN: I hate to answer a question yes
and no. Obviously each individual fish that is impinged
9 upon a screen anywhere in the system is not necessarily made
10 a matter of record. On the other hand, we make every attempt
11 to make a full record and investigate any unusual occurrence.
12 Obviously the occurrence to which Mr. Barber made reference,
13 as to the Campbell plant, is an unusual occurrence and some-
14 thing of a vastly lesser magnitude would have been an unusual
15 occurrence of which we would have attempted to make a full
16 record and investigation.
17 MR, McDONALD: What do you classify as a power
company representative as an unusual occurrence regarding
a fish kill?
20 MR. PETERSEN: As far as impingement upon the
screen is concerned, when we reach a point where the
2 people who are changing the screen observe a large number of
— and extraordinarily large number of fish on the screen,
2L.
^ because obviously there are going to be one or two fish,
25
in many circumstances —• they may have been dead when they
-------
679
0. Petersen
go there — but they should be reported.
Now, I do not have the records in this regard.
I do have — correction — I have Dr. John Z. Reynolds
with me, who has been active in constructing the plants
in regard to this matter. I would be very happy to have
him come up to the stand if you would like to question him
concerning this matter. But the standing instructions to
9 the plant are to report to the environmental people so we
10 can immediately pass the information on to the Michigan
11 Water Resources Commission and also send a biologist to
12 the scene to attempt to ascertain the damage, and to
13 ascertain what occurred to cause this damage, if possible.
14 MR. McDONALD: Well, Mr. Barber, in his report,
15 listed at least two significant kills involving up to
16 550,000 fish at Palisades and several hundred thousand at
17 Campbell.
Are there other kills of significance —
MR. PETERSEN: I am sorry. I am not aware of a
550,000 fish kill at Palisades. Perhaps I missed something
somewhere along the line.
|
22 MR. McDONALD: Page 11 of Mr. Barber's report.
23 MR. PETERSEN: As I told you, I haven't received
2L
a copy of the report, and perhaps I wasn't able to hear at
that particular place.
-------
680
0. Petersen
2 MR. McDONALD: Well, let me not burden you, then,
o with that report.
Let me ask you —
5 MR. PETERSEN: I think you are speaking about the
6 fourth line?
7 MR. McDONALD: Yes.
MR. PETERSEN: I think — I have been able to
borrow a copy here, and I think that the correction has been
10 made in this copy of the report reducing it by one magnitude,
11 55,000 fish over a period of time — a certain period of
12 time.
13 MR. MCDONALD: Fifty-five thousand.
14 I MR. PETERSON: Fifty-one thousand, according to
15 ! this; 51,235 fish, weighing 4,995 pounds removed from intake
16 screens from the Palisades nuclear generating plant during
17 the period May 16 to August 25, 1972. That's the way it
reads in this report which was handed to me as corrected.
19 MR. McDONALD: Well, I assume that the report Mr.
20 Barber gave us has a typographical error.
21 MR. BARBER: Yes.
I
22 j jvjR. McDONALD: He said yes, there is an error.
I
i
23 || MR, BARBER: I think all copies have been corrected
2^ but probably that one you have has not. (Laughter)
, McDONALD: That is very charitable of you,
-------
631
0. Petersen
Mr. Barber.
MR. MAYO: That's like winning a million dollars
in a lottery in New York.
5 MR. McDONALD: It does make 51,000 fish sound
6 relatively small compared to a half million.
7 MR. PETERSEN: I am not adequately qualified to
make a judgment as to whether 51,000 fish is large or small.
9 Dr. Benda is making a study of this matter and has pro-
10 duced a report.
11 MR. McDONALD: I guess what I am trying to say
12 here, Mr. Petersen, is I am wondering whether you do
13 tabulate entrainments and kills and quantify these so that
14 there is a record of what is going on, and then to whom do
15 you report these? Is there such a mechanism available?
16 Is it being used?
17 MR. PETERSEN: Certainly at the Palisades plant,
1$ yes. We have been taking records of the fish killed since
19 — well, since before last January — I can't recite the
20 precise date upon which we began to make records of the
21 | fish which were impinged upon the screens.
22 MR. McDONALD: Would it be possible to have that
information submitted in tabular form to the conference?
MR. PETERSEN: Certainly. You will not have it
2S
' today, however.
-------
6S2
0. Petersen
MR. McDONALD: The record will be open for a
week if you could submit it.
4 MR. PETERSEN: I would be pleased to do so.*
5 MR. McDONALD: One other question I have relates
6 to something I talked with Mr. Purdy about when he was
7 giving his statement.
Mr. Purdy was talking overall lake impact for a
9 given discharge. Do you, as a power company representative,
10 feel any responsibility for keeping up with the other power
11 companies to relate your total discharges to total lake
12 impact? Or should these be discussed on an individual basis
13 and let the regulatory agencies assess the total lake
14 impact?
15 MR. PETERSEN: We try to assess fully the impact
16 of what we are doing, both locally and as an effect upon the
17 ecosystem; and in assessing the ecosystem we necessarily
would have to take into consideration the effect upon the
19 whole lake, because, to some extent, as I am informed by
20 my scientific colleagues, the ecosystem of Lake Michigan is
interrelated.
22 MR. McDONALD: How do you make that total lake
assessment, Mr. Petersen?
MR. PETERSEN: I don't. I turn to my scientific
colleagues, try to give them the benefit of all of the
*(The document follows this page,;
-------
J. Z. Reynolds
Director of Environmental Planning
consumers
power
Company
General Offices- 212 West Michigan Avenue, Jackson, Michigan 492O1 . Area Code 517 788-O55O
September 28, 1972
Messrs. Francis Mayo - EPA, Chicago Region V
James McDonald - EPA, Chicago Region V
Ralph Purely - Michigan Water Resources Commission
William Blaser - EPA, Illinois
Thomas Frangos - Wisconsin Dept of Natural Resources
Perry Miller - Indiana Stream Pollution Control Board
Gentlemen:
During the Lake Michigan Enforcement Conference afternoon
session on September 21, 1972, the EPA Conferee, Mr. McDonald, inquired
of Mr. 0. K. Petersen, Senior Attorney for Consumers Power Company, as
to the availability of data on fish collected on the intake screens of
the Palisades Plant. In response to this inquiry, I am enclosing two
items for your information.
The paper "Thermal Effects Studies at the Palisades Nuclear
Plant — Preliminary Findings from the First Few Months of Operation,"
was quoted by Mr. Yates Barber, U.S. Bureau of Sport Fisheries and
Wildlife, as to the total numbers of fish collected on the screens
from May 16, 1972 to August 25, 1972. The distribution of fish by
species, number and weight is given in Table 3- Figure 2 indicates
the weekly totals- for the three dominant species for the period indi-
cated. Dr. Benda, the author, is a consultant to Consumers Power
Company.
The second item is Section II-E, FISH, of a document entitled
"Palisades Plant, Special Report, Environmental Impact of Plant Operation
up to July 1, 1972" which was filed with the U.S. Atomic Energy Commission
by Consumers Power Company on July 19, 1972. The report includes daily
tabulations of fish species collected on the plant intake screens between
January 23, 1972 and May 16, 1972 and weekly tabulations from May l6, 19?:
to July 1, 1972. Weekly tabulations subsequent to July 1, 1972 will be
reported as a part of semiannual submittals to the U.S. Atomic Energy
Commission. The report also contains data on other fish collections in
1972 as well as a description of the entire fish sampling programs at the
plant.
Yours very truly,
JZR/pgk
Enc.
-------
Thermal Effects Studies at the Palisades Nuclear Plant
Preliminary Findings From the First Few Months of Operation
By
Robert S. Benda, Ph D
Assistant Professor
Aquinas College
Grand Rapids, Michigan
American Fisheries Society
National Meeting
Hot Springs, Arkansas
September 10, 1972
-------
INTRODUCTION
This paper summarizes the results of the first four months of
study of the effects of the thermal discharge from the Palisades Nuclear
Generating Plant. The plant is located in Van Buren County on a 487-acre
site on the eastern shore of Lake Michigan in the southwestern part of
Michigan. The site is approximately 4-1/2 miles south of South Haven and
16 miles north of Benton Harbor and St Joseph (Figure 1).
The Palisades facility, which has a rated capacity of about 700
megawatts electric (MWe) with an ultimate electrical output up to 821 MWe,
began operations at 60% of rated power early in 1972. The plant utilizes a
pressurized water nuclear reactor system and the steam is condensed by
means of a once-through condenser cooling system using Lake Michigan water
to dissipate the waste heat. The waste heat at rated capacity will increase
the cooling water temperature a maximum of 25 F above ambient at the in-
take. The intake is submerged offshore about 3, 300 feet at a minimum depth
of about 25 feet. The heated discharge enters Lake Michigan directly at the
shoreline. The total flow rate through the once-through cooling system is
about 405, 000 gallons per minute (gpm). This system will be in use until
completion of mechanical draft evaporative cooling towers in early 1974.
These towers will convert the circulating water system to essentially closed
cycle cooling with only a small blowdown discharge to the lake which will be
no more than 5°F above ambient lake temperature.
-------
SCOPE OF THE STUDY
Consumers Power Company has undertaken to study the effects of
the thermal discharge until completion of the cooling towers. The study in-
cludes the following areas:
1. Temperature
A. Continuous Intake and Discharge
B. Thermal Plume Measurements
2. Chlorine Residuals
3. Benthos and Psammon Community
4. Phytoplankton
A. Mortality
B. Distribution and Abundance
5. Zooplankton
A. Mortality
B. Distribution and Abundance
6. Fish
A. Mortality
B. Distribution and Abundance
C. Spawning Sites
D. Juvenile Fish Use of Nearshore Areas
7. Attached Algae and Rooted Aquatics
-------
Temperature
The maximum temperature increase of the discharge water above
ambient thus far has been about 28°F, during short periods when only one of
the two circulating water pumps was in operation, but the normal increase in
temperature at 60% power has been about 15°F.
The thermal plume measurements thus far show considerable varia-
tion in size, shape and direction depending upon wind and current conditions.
Temperature measurements in the lake have shown the typical buoyant thermal
plume configuration with detectable effects on surface temperature influencing
areas in the range of about 100 acres to nearly 900 acres.
Chlorine Residuals
Thus far, it has not been necessary for the plant to chlorinate its
condensers, so no chlorine effects have been studied. It is intended that during
chlorination extensive measurements of chlorine residuals in the lake •will be
made to correlate with collections of plankton and observations of fish reactions.
Several chlorine demand tests have been conducted on lake water showing a range
of . 308 to . 75 ppm for 70 minutes incubation at ambient intake temperature. The
average chlorine demand is about . 55 ppm for all tests conducted.
Benthos and Psammon Community
Lake benthos have been collected using a ponar dredge at about 30
sampling stations for the past 4 years which will be compared to benthos sim-
ilarly collected during operation of the plant. Samples are also being collected
of the psammon community along the shoreline with a core sampler to determine
-------
effects on organisms residing in this zone. At the present time, there are not
sufficient data available from any of the bottom collections for evaluation.
Phytoplankton
Carbon 14 tests (Table 1) are being conducted to determine if any loss
of photo synthetic activity occurs as a result of the once-through cooling process.
Thus far, the photo synthetic activity in the samples has varied from a gain of
105% in the discharge over the intake sample to an 81% loss in the discharge
over the intake water. The results have not been consistent and show consid-
erable variation. Out of 12 tests conducted on a heated discharge, three have
shown more activity or no loss in activity in the discharge sample when com-
pared to the intake sample, but the majority (9 of 12) do show losses in activity
ranging from 11% to 79%. The tests have also been conducted when no heat was
being added and one of the two tests showed no loss in activity in the discharge
sample, while the other showed a loss of 13% in the discharge sample.
The dominant algal group observed in the intake water samples has
been the diatoms, especially Tabellaria fenestrata, Fragillaria crotonensis,
Melosira sp, and occasionally the flagellate Dinobryon sp,
Zooplankton
Tests have been conducted (Table 2) to determine mortality rates of
zooplankters in the discharge water by using the vital stain neutral red. Thus
far, mortalities have remained below 30% in the discharge as compared to the
intake. As with the phytoplankton tests, both heated water discharge samples
and nonheated water samples have been collected. In all samples examined to
-------
date, a higher percentage of the zooplankters have been dead in the heated
samples as compared to the unheated samples.
In late spring and early summer, the dominant organisms in the
samples were the cyclopoid copepods, but as summer progressed, the
Bosmina cladocerans have become the dominant group, especially Bosmina
longirostris and Bosmina coregoni. Asplanchna sp. and Kellicottia longispina
are the most dominant rotifers collected to date.
Fish
The fish have been divided into several areas of study. These are
as follows:
Entrainment - Fish entering the submerged intake structure are
eventually impinged on traveling screens and washed into a collection basket.
Thus far, the Alewife, Alosa pseudoharengus, Perch, Perca flavescens, Spottail
shiner, Notropis hudsonius, and Slimy sculpin, Cottus cognathus have been the
most frequently observed fish passing through the screens (Table 3 and Figure 2).
The salmonids and other game species have been observed in very low numbers.
Seining and Trawling - The results of seining and trawling collections
and visual observations show the Alewife, Carp, Cyprinus carpio, Spottail shiner,
and Perch are more numerous in the heated water area than in the unheated areas,
and salmonids are found in the unheated areas, but not the heated area.
The August seining collections in all five collection areas contained
numerous Alewife and Spottail shiner young of the year with no larger concentra-
tions being observed or collected in the heated water area.
-------
Eggs and Larvae - The intake water has been sampled periodically
by suspending a #20 mesh plankton net to collect fish eggs and larvae. Over
the summer, less than 1, 000 eggs and five larvae have been collected in over
300 hours of sampling and about 3, 400, 000 gallons of water. At this time, it
does not seem that the intake structure is located in an area of high fish re-
production activity.
Attached Algae and Rooted Aquatics -
No large concentrations of attached algae, such as Cladophora, have
been observed in the area of the heated discharge, as opposed to unheated areas.
Underwater transects of the bottom in the vicinity of the plant will be made yet
this year to determine the presence of rooted aquatics in the area of influence
of the plant.
Summary
The plant is still operating at only 60% power and some aspects of
the study effort are still in the initial stages of investigation. While some en-
vironmental effects are apparent and are being measured, definite conclusions
as to their significance should await further collection and interpretation of data.
-------
PALISADES
PLANT
FIGURE 1
-------
8000
tr
UJ
00
2
FIGURE 2:
Number of Alewift, Perch, and Slimy
Sculpin observed weekly on the traveling
screens from May 16 to August 25, 1972
at the Palisades Nuclear Generating Plant.
Alewife
Perch
Slimy Sculpin
AU&UST
WEEK NUMBER
-------
CO
CU
'o.
a
cd
CO
(1 1
\l>
CO
^
CU
S-f
ca
CJ
CO
Q
fl
CO
cu
CO
-*-*
t— 1
0)
c
'iH
t*
•t->
O
^
CJ
_^_,
cu
•*->
CO
o
"o
(x
TABLE ]
cu
-M 5i
re f .
» s
p
-H
'H
•*->
CJ
C* .^
<-> •£
3 fl
•n £>
cu m
OH •!->
O
tx
'w
CU
CJ -r^
-f-> 3
cu o
^ o
c ^
>> '2,
-fj t>2
o S
tX -H
"o
0 01 0)
tuO tuD OX
^ tn ^
ctf ... cO co
CU J ^43 0) j
-« CJ •* 0 -^ CJ
^5 .2 | .2 5 .2
,5 Q rS Q £ P
S
cr ^ t-
^22
T* CO
M ^
>-. cu o>
I 4 §
f< ^2 >-J
CO CO CO CO
cu cu cu cu
>H >H >H >-l
OO t- rH Tf
Tf< in CM CM
D™ CO ^J^ »H
Tfl 1 CO 1
COO2 COrH CD^f ^rH
corn t>cn CDO cooo
•^oo CMCM c~m coco
CO rH CM CM rH rH
in m CD CD
^O OOCM Tt1^ ^^
me- ini> coco coco
cu cu cu cu
ox tuo cm fcuo
In fj SH b
..CO ., CO .v CO „. CO
^^ ^-g 3-g 5-g
| .2 5 .2 5 .» 5 .2
c p, GI^I Cpv s^n
HHr-1 rHM rH 1— 1 rH I— 1
CM CM CM CM
t- c- t- t-
Cn C32 O2 O2
rH rH rH rH
^ tc TjT rf
""" ' ""^ rH rH
cu cu >>, hK,
C C rH rH
3333
CO
CU
><
CM
0
.
02
t-
O CO
CO CD
C- CO
rH
CD
^f ^
CO 00
cu
DJC
i-,
Intake
Discha
CM
r-
02
rH
rH
rH
3
1-3
-------
-a
"5
o
0
,_i
3
ffl
,..<"!
° "£
^ JE
ID M
O
PU
CO
CD
o •£
+J r-J
QJ J3
£ O
£H
co1 a
_0 ""
O -t->
£ >
£
CJ
o fe
cfl """
n p.
3 a
h-i H
-^
^ 0
Q4 's^'
d a
§ S
Cfi CD
H
i — 1
a
a
CO
CO
CD
CO
Q
CO CO
CD CD
K* >-<
i<-
CO 1-H
•* •*
CM CO
in co
1
in CD CM CM
CO O3 O3 CO
t- t- i-i m
CO rH (M CO
Tt< ^
t- t-
rt4 T— t ^1—1
C- O3 t> O3
CD CD
be be
.a! al
^3 .2 -2 .2
5 Q 5 Q
CM W
r- c-
O3 O2
r-( "-1
„
r-l "-I
CM CM
3 "a
1-5 ^3
CO CO CO CO
CD CD CD CD
>H >H >-l >H
CO O
O) CO O i-(
O "^ CO O3
rH CM CM CM
r-lCO t>r-l COC- O3CM
(MOO CO'* OCO O5r-l
COCM rHr-l COCM CMCM
LO Lrt lO ^^
^ r^ ^ CD
lOCSJ IOCSI LOC^l -^IM
T^K tO ^^ CD "^ CO CD CO
.1-1
Ir_i
-»-*
CJ
co
o
"CD
j^
U
CO
o
"o
a
.3
icrease
c
d
CO
CQ
CD
CO
CJ
d
»— i
-------
o ^
O
03
H
3
N PH
H co
rJ M
WQ
H co
j
^
CU
C
o
w
S
CO
• r-J
C
aJ
DJO
rH
O
C
o
J2
C
rH
rcx
O
0
N
r«
0
o
PH
a
3
o
O
C
_0
£;
C
o!
i 1
CX
o
o
N
tCj ^
B- a)
O
Q
cti
J_,
o
• 1— 1
"o
«
o
B5- a3
aj
Q
03
SH
O
CJ
o
a!
U
rH
O
^ oi
03
o
o
J
0 "2
•* 0
.2 w
C •£
1— 1 r- 1
rH rH
-a
_~;
t
. o
1°
in
00
t-
co
rH
CO
rH
CM
rH
CO
CD
CD
rH
CD
rH
O
rH
CD
•*
5
cd
H-J
i — i
CM
^
CM
CO
CD
rH
CD
rH
OO
rH
t-
in
CM
rH
OO
l-
CD
O
m
o
w
Q
CM
o
Z
•*
CM
CD
CD
CM
rH
rH
CM
rH
O
rH
t-
rH
O
m
oo
CM
0}
i — i
o
H
_oj
C
(._
rH
O
rH
CO
^
O
CM
rH
CO
in
CM
rH
CM
CM
^HH
CD
CM
CM
OI
o3
"o
H
O
tuC
s_
cti
^>
t-
1
CO
+
in
+
CD
03
G
i — i
OJ
6
o
rH
o!
O
w
Q
"
r- CM o
CM rH CO
t- o co i—
CM CD rH m
co a; o
CD in o
oo
m
CD
in
CD
CD rf
oo m
CD Tt< CO
rH OO rH
CO CM
rH CO
m CM
CD CM
OO CD CO
rH CM rH
o c-
QO CM
CO CD
CM CM
rH
QJ
>
O
OJ
tuO
rH
03
§«.
f. CD
CO
1—1
03
"5
H
-------
CO
0)
T3
(0
CO
tuo
«o
CM
corf
ooo
ITS
O)
CM
O
H
0)
£-,
o m
CO (M
tlD 4-.
c co
—' 3
to
a >
*^ ^H
T3 £
cu o
s
3
a
o
H
CO
S o
3 .
C •"
CJ
CO
^S o
O 3
H Z
W
J
CQ
<
H
Species
§
W 0
C 3
co
CO
"o
H
-------
11-72
E. FISH
Effects of plant operation on fish life are very important
indicators of apparent effects on the aquatic habitat. Fish are also
the most visible element of the aquatic ecosystem and are of prime im-
portance for public recreation. Fish sampling with gill nets, seines
and trawls, both within and outside the area of the thermal plume will
indicate, by their presence, the preferred location of the various fish
species that inhabit the area. The above, in conjunction with bottom
sampling and sampling the intake water with plankton netting, will
identify spawning and nursery areas and potential effects of plant
operation on fish reproduction in the area. Direct observations of
fish collected on the intake screen indicate the species of fish within
the area of the plant intake on a continuous and consistent basis as
well as the direct effects of entrainment within the intake system. No-
tations of fish mortalities under normal operation and periods of chlori-
nation will complement the systematic sampling of live fish and provide
indications of directly lethal conditions.
Data from the various fish collection efforts are presented
separately in the following sections. In total, 28 species of fish have
been sampled and are listed in Table II-E-1. Seven species were not collec-
ted in the preoperational studies, but five species collected in those
studies have not yet been sampled since plant operation began.
Fish Entrainment
The plant intake water is screened through 3/8-inch mesh
traveling screens and all fish collected on the screens are sluiced to
a collection basket where the fish are identified and counted on a
-------
TABLE II-E-1
PALISADES PLANT
List of species of fish collected by
entrainment on the traveling screens from
II-73
Common Name
Alewife
Chinook salmon
Coho salmon
Brown trout
Rainbow trout
Lake trout
Whitefish
Cisco
Bloater
Smelt
Northern pike
Carp
Longnose dace
Spottail shiner
White sucker
Longnose sucker
Channel catfish
Black bullhead
Trout-perch
Burbot
Bowfin
Nine-spine stickleback
Slimy sculpin
Rock bass
Bluegill
Pumpkinseed
Yellow perch
Johnny darter
(l) Not sampled in preoperational studies.
seining, trawling, and
January 23 to July 1, 1972.
Scientific Name
Alosa pseudoharengus
Oncorhynchus tschawytscha
Oncorhynchus kisutch
Salmo trutta
Salmo gairdneri
Salvelinus namaycush
Coregonus Sp.
Coregonus artedi
Coregonus hoyi
Osmerus eperlanus mordax
Esox lucius
Cyprinus carpio
Hhinichthys cataractae
Notropis hudsonius
Catastomous commersoni
Catastomous catastomous
Iclalurus punctatus
Ictalurus melas
Percopsis omiscomaycus
Lota lota
Amia calva
Pungitus pungitus
Cottus cognatus
Ambloplites rupestris
Lepomis macrochirus
Lepomis gibbasus
Perca flavescens
Etheostoma nigrum
-------
E. FISH (Contd)
Fish Entrainment (Contd)
regular basis, usually at least once each day. The fish entrainment
data compiled for this report are presented in two parts.
The data from January 23 to May 15, 1972 were gathered by
plant maintenance personnel with the assistance of Consumers Staff
Aquatic Biologist. During this period, only the total numbers and
length of the fish were recorded as shown in Table II-E-2. However the
average weights of some of the species can be evaluated from average
weights for the same species recorded from May 16 to July 1, 1972 as
follows:
Number Per Weight
Spottail shiners 25/pound
Trout perch 25/pound
Alewife 12-1/2/pound
Sculpin 71/pound
Perch U/pound
The fish entrainmenb collections after May 15 were made by environmental
study personnel stationed at the site when more detailed studies of
plant operation on lake biota were begun. Summaries of fish entrain-
ment data, including weights, for the period May 16 to July 1, are
given in Table II-E-3. The total number of fish collected on the screens
for this 6-1/2 week period came to 32,lU8, with a total weight of 2,966
poundso The 16 weeks of collection prior to May 16 accounted for a
total of 2,220 fish. For the entire period, alewives account for about
hO percent of the total fish reported and perch account for about 18
percent.
-------
11-75
The current procedure is to run the screens automatically every
12 hours and manually when conditions (ie, many fish) warrant it. The
usual condition of the fish ranges from decomposing specimens to fish
that are actively swimming. Most of the fish are dead or damaged.
The damage to the fish is mostly mechanical and varies from open wounds
to descaling and hemorrhaging.
-------
11-76
CVJ g
ri 5
M
w q
|1
§ H
S
OJ
a§
O VD
14 rH
•si
o o
CD 43
H
H OJ
0 ON
fi
to •*
•rH CO
Vt r"»
tt) P
33
CO h)
la
0) f-i
£j C/J
!a (U
CD
-p
a
0)
y
c
M
C
•H
§
H
O
rH
*•
OJ
CM
*
o
CO
R ni
1
OJ
H
f-\
OO
OO
a ni
o
OO
H
to
0)
o
O)
•rH
P
CO
o
•H
P
K ni
O H
O «I
co
a ni
eg
^ o
^
OJ
j.
1 — '
C^«
& ni
H
^
rH
-1
ir\
CO
3
on
vo
o
1
t-
00
IT
J-
S5 ni
6
i
cm
QO
0^
J
OJ
H
3
IP
£•—
^
CO
i —
oo
i
oo
in
i
OO
C"
C-.
oo
H
J-
1
OO
~^i~
ft ni
SCULPIN
MD
rn
H
C"
CO
VO
B ni
a
CO
rH
OJ
OJ
vo
o
H
00
O
rH
53 ni
RAINBOW
TROUT
OJ
H
OJ
VS
OJ
^Q
J-
J-
OJ
0
OJ
ViT
H
O
OJ
OJ
^j-
CO
H
s ni
SUCKER
H
H
00
VD
S5 ^I-H]
1
a HI
CHANNEL
CATFISH
B Hi
CHINOOK
SALMDN
s
8
CO
M
O
IT\
O
OJ
H
rH
CO
00
CO
H
O
IA
Q\
OO
00
H
J-
s
TOTALS
-------
11-77
Svo
O
CM
A
H
H
PH
V
•P O
O -P
0)
.e *•
^ oo
O 0)
0) d
H 3
•H >-}
ra
08 S
>H 0)
^ s
dl
I
C
H
0}
I
a
OO
I
CM
2
CM
CVJ
s
CM
1
CM
CvJ
CM
CM
ITN
CVJ
1
CM
pq
O
S
cvj
CVJ
CVJ
oo ka-
CM
IT
IT
X>
CO
CH
CM
S
CO
O OT
H c-
CO
ro
m
oo
-4 CM
L
ISH
S5
M
CH
SA
8
CO
M
O
oo
OO
OJ
OO
tr\
-------
11-78
CM
Ivp
CM
01
0)
•s
a
c
•H
4=
53
S
,3
II
^
£
n
K
CM
CM
CM
,-H
CM
CM
O
CM
CO
?
CM
CO
r-l
1
CM
C-
i-J
CM
VO
r-l
1
CM
in
tH
CM
-4-
7^
s
CM
1
SPECIES
fl,
^
CM
^
Hi
q
in
CM
•
3
t4
I
i^
^
3
3
O
^
z;
»
H
.^
i
j.
CM
^j
TROUT ]
CM
on
^
BOWFIN 1
x
i
in
X
i
on
r^
>JJ
r-
CM
H
^
1
^l
O
o
r-
VO
00
. 1
^ 1
Sj
in
5
\
n
in
i
on
j-
.3
H^
,
-<
0
. t
"H
RAINBOW 1
kJ
"H
H
H
CM
H
CM
SUCKER 1
p
CM
30
J2
0
8
• 3
•^
£4
q
i
.j
-^
,_
CHANNEL I
00
1
1— 1
§
1
CHINOOK J
1-3
z;
CQ
O
_>
1
CM
O
on
-*
on
0
O
on
o\
o
1
-------
11-79
8
CM
n
CO
3 o
O -P
O O>
O H
fi "
M CO
•H CM
P4
•H hj
CO
08 M
(-1 0)
0) g)
i co
B|
CM
I
co
CO
CO
CO
o\
CO
tj-
co
CM
CO
CO
CO
IT
I
VC
en
vo
H
IA
H
CM
CM
3
en vo
CO
8
Sa
5
CO
a
CO
CvJ
Cvl
r-ICO
cv
s
CM
§
00
\T\
CM
CM
8
CO
s
SS
K
-------
11-80
o
o
CM
t-
O\
H
!vq
) H
0)
-P O
O -P
0)
H CM
to CO
-H CM
P* N
-------
II-81
•d
«y
w
H
PH
O -P
V
H CM
0
W CO
•H CVI
I
8
o
03
Q)
•a
s
M
0)
!
i
IfN
ro
I
UA
tA
S
°9
ITi
f\VD
UMT\
00
IT
O
CM
IT
C\J
IT
IT
09
cvi
CO
ir\
IT
H
cu
00
8
*
!B
S
8
CD
C
CVI
L
SH
CA
K
IK
e
03
M
k>
-------
11-82
u
C
0)
ft1
CJ
CO
FJ1
S"
•H
H
£
1
0)
.C
p
EH 6
K O rvi
3 ft £1
M j
beJ*
*.o 5
en w4^
dfi^S
hH *^ (H
H V» >,
H 0 j?
H3T
prs lun
I-M QU
< ^H
EH.
tJ
3
H
<1>
ti
i-H
0)
-P
o
EH
x^s
W
C
•H
0)
«
0)
N
•rH
10
10
J3
r-l
•P
•H
<1)
*
i-l
d>
P
£
JL,
0)
I-l
s
p
o
EH
a
0)
•H
O
(U
£
00 VO VO
1 ' '
cvj cvi cvj
-3-
ay ~^f H
OO CO ON
ON CVJ
»,
I h
1 1 ! 2 1
0) 0) ft -P JH -H U
Vi a -p a> at
^H C P -P -P 0)
> 0«ScdHO<-P-P
^•S-i P5 S sSrS
r-l 09 MI-IS a) & .a
. ' — , H CVJ •>^» H "*v.
H H H PO
CVJ VO OO H CVI OO OO
CVJ CVI 3
ON
•g
1
w
H
Li rt 7i
H J3 V
a> is *a -H
•S C 1 vS 5 fc
8 1! fl f a, 3 t
0 H ft C 9 W 3
V ^0) -H o W r-l •O
ai-l^>P4 Piutfr-l
gl*)^^?^-0^,-!
»l3g*aSfll1S
O X3 r-l ft 3 -H r-l OH 4) O
rPomEHmjRraosrtPn^
CVJ
"^s^
^H
VO
€vt
o
J-
H
^
H
Totals
-------
11-83
(0
0)
S
on
o vo
H >,
J3 O
«t_i
O
CM
0>
W
10
X)
I VO
CM
£
a>
aj
a
O
fi
-P
\D
I
CM
VO
I
CM
00
r-t
CM
CM
I
21
V£>
CVJ
vb
00
"S
vo no -*
1 \O 1 1
CM CM CM
-3- CO _* CO
CO H H
O r-l O\ OO
CM rH H
ON
•8
0)
•8
%
to °
1 S I .
0) «H t) CO
1* $ ? 1 *
8 * 1 I 1
r-t
1
MD
CM
H
ITN
O
CM
0)
4
3 - &
t> o S
-------
II-8U
ca
0)
o
CO
0)
0}
E-i
0)
03
8
CO
H
ON
2 <"
^ c
n -J
»3»
3
0
0)
S5
r-l
-P
ca
0)
o
0)
£
ON
OO H VO
1 1 1
OJ VO -=f
OJ -=t -=t
H oo ro
1 1
s w
VO -* OO
o
O «J 8
IW W -P
!* O 4)
4> J3 M
rH O ^B
< 0
OO
I
OJ
VO
I
OJ
VO
rH
I
OJ
ir\
I
OJ
VO
I
OJ
OJ
rH
I
OJ
a")
CO
OJ
§8
ON
CO -3
I I
OJ OJ
OJ
OJ
ITN
ro
ON
co
-*
CO
H
I
R
•s
OJ
OJ
OJ
ON
ro
«
3
§)
a)
0)
.
c
S3
0
Totals
-------
11-85
to
g
y
CO
I
I
V
M
•H
CO
3
CVJ
a
0)
4-i
a
O VO H
i-l VO H \o pr,
I
i i i UN ro i i
CVI CVJ CO CVJ H H
J- CVJ CVI
> > > <
lA M H ti H
l>- H CO H H CO -* l>-
-* CVI H
H
•s
ed
«
o>
1-1
IH IW J "S
« « U -d iH
5 f, -9 C 8 «
J3 4) fl -P £ X?
€ -8 S 8 3 1 8
H 3 « 3 « -H
•S8S<3-°?t^tS<
•P -P «) C d >d -P O 1
Hg.-P45Ba^3*«
S 3 8. 2 S^H 8o5
nooaSi3umE-imis
LTN
-* iH
1 1
CVJ J-
CVI
i-4 VO
a »
IfN CVJ PO
ON O
oo ro
r- 1
a ^
•3 0)
Qi -P
,3* T<
3 U 03
0 W i-l T3
Q 0) r-l
.O i-l >>
s « r i i
r-l O r^ tt) O
W OS « O, "-3
on
vo
S
OO
•t
ro
n
rH
5
S
-------
11-86
c
(1)
B
o
CO
•H
1
r™»
0)
Oj
&•*
l£J
w -P
1 £ H
•a ^
£ -P H
§|s
'*"' e, V
W O S
1 £
H "P
M J3
tO
(S3 -jj
" 4?
si
01
tH
cd
-p
o
w
c
•H
0)
PS
0)
N
•H
co
to
3
*~*
-p
•a
M
•H
r-l
O
M
(H
0)
r-4
a)
-P
o
w
0)
•H
o
0)
£
CVJ VD O CM Q
CO H H H CO ^O CM
1
III II 1 1
H
CMVO^O VOCVJ CVJ fl CO
CM
ONH"H" vot- i>-cr>^j-
CVJ 1 H H
•^" fl
LT^ OO CO OO C^ ^^ ^U CO
M3 -3" l>- CM H
LTN
| «
•n (4 ^3
a -p ^ « 5
*M BO 4^ 4) CO
•fH C 4^ 4^ +5 O Cj
ilfi^po'v&'Q^C
r*4 O w H rH _S w _Mi ^3 O
H
« . 3
JH 3 -P
«-i «) m
151 s
3 ai «H
4) f 4-3 tt
C J^ 4-3 O 1
1 eS p *S C
,Q r*4 W ^ *H
0 pq H « K
vg
i i
CVJ CVJ
OQ
s 2
o
vo
a ^
•r) O
o ^ w^
^> wj r* rt
5 "o § £ J
rH O n4 ft) O
^*
^
1
VC
•
t-
M
i-l
$
O
tt> « « 0, ^ EH
-------
11-87
ra
C
CU
K
y
CO
*
•H
r-l
0)
id
E-i
a o>
j^o.
1^
|-3 ij ^
^ O (LI
* * S
0 X! ^
o w £_
°P «. «
w o §
1 K)
H -P ^
M a
bD
M iH
13 <£
S -a
fn
I
t-i
OJ
4J
0
CO
C
•H
01
£»
CO
P5
0)
N
•H
CO
a
3
-P
1
r-l
1
£•(
0>
•i
r-i
id
-p
o
Species
o
rH VO
I I VO
OJ OJ
oo
oo
OJ
t— OJ H
00
ITN
oo
a
1 1
r-l p
0) CO ft
— ^
H H OJ CO ^t
I \ I ON
LTN ur\ H t— -=r
rH
LP, t— IXN OJ ITN H ON
rH CO VO LT\ CO
H rH
•s
OJ
•s
cd
rO
0)
"8
S ^ 0 r,
5 *1 * P, V
r-l 0 4) J fn
1-4 fc C 3 to -H o w f"1 *O
XI P) Pi CO «d rH
I -P to ^> -H >>
AJ-PO 1 fe'j.j'''13^
i-lr(S-HrHOrHO)O
C^"
OO
OO
OJ
LfN
_-,.
OJ
ir\
CO
W
rH
cd
+i
S
-------
11-88
CO
g
O
co
OH
CM -
1^
(0
C
•H
0)
W
0)
•H
CO
IQ
-P
XI
•H
£
0)
1
0)
1
i— i
0)
-P
£
(9
0)
•rH
O
01
&
co
i
cvi
CM
pH
£
ON
, — |
0)
W
.a 4> 3 -P
•-4 p V
to iH to W r-l
fi a
o
CM J-
VO ro J- rH
OO 1 lit— 1
CM
CM H CM CM CM
CM -*
\ CO ^. CM t-
H \ OO \ CO
1 VO H 1 H OO
OO LT\
H J- LT\ VO O H
CO H H t-
-3~ O
r-T
•s
a!
"8
"S +3 a h
0) TO .H >
X -P O 1 feU)J3C
«JpHC-3O3»-ij3
Hfip-iHrHOrHdJO
OO
1
H
vS
ON
UA
rH
Totals
-------
11-89
to
C
0)
R
o
CO
S"
•H
rH
81
g
<3 A>
CO S
S££
2» ON
H -a H
fj 0) .
S3 4i _T
C4 0 H
l3*
8 !rj 0
S is -^
on£^
IVI ft_i .
H°|
H -P *
aS
£Q flJ
"S
>H
0)
rH
01
-P
£
0
C
•r
V
{
f
C
K
0)
t;
5
to
f
+:
•g
^
r-H
Jl
S
r<
0)
*§
r-H
H
*
S
a
o>
vH
o
0)
£
O ON vo O VO O
rHrHrH ONH VOrHCVJVO-^-VO
III II 1 1 1 1 1 1
CVIVOVO -*CVI CVIOOCO-*rOCVI
vomcviococoocovoocvjHcvi
O H
^
H
t— O O ir\couN ^t H ir\ on
CVIHmOONCO U\ VOrHCVl-*
OO i— 1 rH r- 1 IT\ O\ ITS
•N CO
CO
rH
rl »H J3
W jj 0) «5 TJ
•S W r, "S C «
§ o « fiJjt g ts a -s
3 g 8 H«1 « 8 "3 &
0) 05 C -P »H •H->&MrH^P<
SHW-P 0) OjQ O8>"
•H C -P .p -P K tt» C fi -^! -P
> 0 0 S Oj rH p,4>a>^ & S 0 3
5-S-S E5 S &8ot1 sa^ 8
rH O d) M rH 8 •) P< X Ju O J3 rH M
< O J « pq (S 0 «)"$ P G « EH
J-
w vn
, «n -r )5
w ' ' «- w ,
H H rH w
C^ m g ^ S^
H rH ^
^
H
VO H OO rH rH CVI
CVI CO F- VO
CVI i-l CVI
l^ VO~
•8
0)
ja
V
pH
*
•H
* 5
s t -
•H u U rH
&W 0) rH
r3 -H
1 i 1 « » I
b -H rH O rH V
« » CO « PQ (X,
CVI
1
rH
CO
rH
O
rH
(4
4)
t
•8
1
1
-------
H-90
The alewife, smelt, spottail shiners, trout-perch, slimy sculpin
and perch are thus far the most frequently observed species collected from
the screens. Pertinent observations for several species as they pertain
to the period after May l6, are summarized below:
Alewife; This species occurs often when the screens are washed. They have
become quite numerous since the beginning of June reaching a maximum number
of over 5000 the week of June 10 - 16. Most of the specimens are adults,
with only an occasional yearling being recorded.
Smelt; This species occurs occasionally when the screens are washed. The
maximum number collected at one time occurred on a day of exceptionally high
wind and rough wave action. Over 200 specimens totaling almost 7 pounds
were collected on June 23, which accounts for almost k of the total number
of smelt collected.
Spottail Shiner; This species has appeared regularly. In early June, 5 -
of the specimens were ripe females and expelled eggs were found in the col-
lection basket.
Trout-perch; This species is found in many collections, but usually in low
numbers. The most specimens recorded occurred during the weeks of June 10
through June 23-
Slimy Sculpin; This species also occurs frequently, and was collected in
large numbers (900-2500 per-week) during mid and late May, but has been
recorded in much lower numbers during June. Ripe females were noted, but
at less than k-5% of the total numbers observed. Several expelled egg masses
were from the sculpins.
-------
11-91
Perch; Few perch were recorded in May, but the numbers increased during
June and maintained an average of about 1500 per week during the month.
Ripe females were observed and made up less than 10$ of the total numbers
recorded.
Lake Trout; Only 13 lake trout have been recorded. All were marked with
a right pelvic fin clip, and except for one l6-inch specimen, all were
6 inches or less in length. These specimens were collected from late May
through June, but 60$ were collected in the week of May 27 to June 2.
Coho; Eleven Cohos have been recorded thus far. These were all 6 inches
or less, except for a single 12-inch specimen. This species, like the
lake trout, has appeared infrequently in the screen washings.
Bloater: This species began to appear in the collections the last three
weeks in June. They appear sporadically and are usually recorded in
numbers in one washing and not at all in others.
There seems to be an increase of most species entrained during
periods of high wind and wave action. The largest single collection ocurred
on June 23 when over 150 pounds of fish were recorded in a 6 hour period.
-------
11-92
Fish Sampling in Lake Michigan By Others
Preoperational fish sampling in the vicinity of the Palisades
Plant began in 19&9 when the Michigan Department of Natural Resources
began participation in the cooperative environmental study progam.
Their work has consisted primarily of selective placing of gill nets and
seining a portion of beach north of the plant property. Details of the
DNR fish collections through 1970 were given in a report submitted as
Appendix C of the Applicants "Supplemental Information on Environmental
Impact of Palisades Nuclear Plant". The station locations for this program
are shown on Exhibit II-E-1, as well as those for the Applicant's separate
fish collections.
During the period June 12-15, 1972 DNR biologists repeated
sampling runs in the same manner that had been done during the preopera-
tional surveys. They also did additional comparative gill netting within
and out of the influence of the thermal plume. The following section re-
ports the results of these collections as well as providing interpretative
comparisons with all of the preoperational collections.
-------
II-l
PALISADES PLANT
FISH COLLECTION STATIONS
Preoperational
Gill Nets * (2-24 hr periods up to 4 times/year)
Seining A day and night up to 4 times/year
Seining stations added in 1972
Trawling stations added in 1972 -
D
•
N
E
•
discarded
PALISADES
PLANT
H
•
Preoperational
Modifications & Notations
60' Gill Net Station discontinued in 1969.
Trawling data from Bureau of Commercial
sheries for 24' and 42' on May 3 1969
and 18' 42' and 72' on July 25 1969.
Also Gill Net data From Bureau of Sport
Fisheries and Wildlife for 18' and 30'
on November 16, 1971 and December 3, 1971.
SCALE IN MILES
0 1 2
1972
Modifications
Trawl - 10' and 25' depth off
the discharge, at the North and
South property lines and 5 miles
South of plant.
Seine - Directly adja ent to
discharge in direction of the
plume at the North and South
property lines and 5 miles South
of plant.
-------
Fish sampling at the Palisades power plant site
in June 1972
M. H. Patriarche
To start the fifth consecutive year of fish population sampling in Lake
Michigan at the Palisades power plant site in Van Buren County, gill netting
and seining were done during the week of June 12-15 by DNR biologists (June 14-
16 in 1971). The plant was operating at 60% of full capacity and had been doing
so for approximately 10 days. Prevailing light southerly winds kept the plume
along the shore north of the plant during the time we were sampling. A
previously scheduled May sampling period was cancelled both because the
research boat used in the past was disabled and the plant was shut down for
repairs for an extended period.
The four 250-foot nylon gill nets purchased last year were used.
Mesh sizes ranged from 11/2 inches to 4 inches (stretched mesh) and the nets
were set at four sites parallel to the shoreline on the 12th, raised the following
morning, re-set at foar different sites that evening, and again lifted on the
morning of the 14th. Surface temperatures were taken to ensure that fishing
was done within and without the plume and a maximum-minimum thermometer
was attached to the float line of each net. On the 12th two nets were set in
15-22 feet of water, one of which was in the plume. The other pair were set
in 40 feet of water outside the plume. On the 13th all nets were confined to
water depths of less than 27 feet, one pair lying parallel to shore and one pair
set perpendicular to shore. Furthermore, one of each of the above was set in
the plume. Water temperatures for each set are listed in Table 1.
-------
-2- -
Shoreline seining was done along the beach at Van Buren State Park
on the night of June 13 and again on the morning of the 15th. Four seine hauls
were made along 550 feet of beach using the same gear and technique as
previously except that the hauls were somewhat shorter than last year because
the end of the seining area was mis-identified in the dark. The seine was a
125-foot bag seine with 1/4-inch bar mesh in the bag; 3/4-inch elsewhere.
Most fish collected at night were preserved for later identification and
enumeration.
Gill net catches for the month of June in 1971 and 1972 are shown in
Table 2. Only the 1971 catches by the new gill nets are compared with those
in 1972, and the data are presented as number per 100 feet net because the
amount of net fished varied. Included in the table are depths, surface tempera-
tures when set, dates, and the amount of netting. Of immediate interest, of
course, are the catches in and out of the plume in water under 27 feet. The
total catch in the plume was 69% greater than outside for the shallower sets.
Most of this increase was due to alewives, large concentrations of which also
were seen congregated around the outlet. Many carp were seen there too, but
this fish is notoriously shy of gill nets and none were captured. Also caught in
somewhat larger numbers were perch, suckers, and the deepwater chub (C. hoyi)
In 1971 the surface temperature was almost the same (64°) at the time of the June
sampling and even larger catches of alewives and perch were made. Hence
no real significance can be attached to the results of this first sampling period
with respect to the plume effect. Catches in 40 feet of water were much
smaller in both years than in the shallower sets. The 1972 perch catch,
-------
-3-
however, was identical at both depths outside the plume. The total catches in
the parallel and perpendicular sets were the same, with minor differences among
the various species.
The seining results for not only 1972 but also those for June in prior
years are presented in Table 3. As usual, nighttime catches were much greater
than those during the day. In general the species were caught in the same order
of magnitude as in previous night catches with spottail shiners more abundant
than previously. No perch were captured this year but only once were any
number ever caught and that was during the day seining last year. Included
among the salmonids were brown trout fingerlings (16) for the first time,
chinook, and rainbows. A total of 23 salmonid fingerlings were caught in the
morning; 14 at night. Last June large amounts of filamentous algae coated the
seine on each drag but no algae problems were experienced this year. Water
temperatures were, on the whole, little different this year than in previous
years. In fact, the plume was presumably inshore but the night water
temperatxxre was 5° cooler than last year. Daytime temperatures were identical
this year and last (69°). The beach at the state park is perhaps 1/2-3/4 mile
north of the plant.
The next sampling period is expected to be the week of August 14-18,
at which time we hope to have the regular boat back in operation and attempts
will be made to also trawl in and out of the plume. The substituted Thunderbird
used in June was not suitable for that type of operation.
-------
11-97
Table 1. --Water temperatures at various 1972 netting sites
Set
No.
June 12
1
2##
3
4
June 13
1#*
2#*
3
4
Depth
(feet)
15
15-22
40
40
18
10-20
20
26
Temperatures (°F) *
Setting
54
65
53
53
64
67
60
60
Lifting
55
60
55
52
59
59
56
59
Minimum
53
55
52
48
58
54
52
56
JJC
Setting = surface temperature when nets were set
Lifting and minimum = temperature at float line depth.
&
Plume set.
-------
11-98
Table 2. --Number of fish per 100 feet of graded-mesh gill nets set
in front of the Palisades power plant in June 1971 and 1972
Depth (feet)
Surface tempera-
ture (°F)
Dates (June)
Feet of net
Species:
Alewife
Perch
Longnose sucker
Spottail shiner
Bloater
White sucker
1971
20
64
14-16
500
96. 2
15.2
0. 8
0.4
-
0.6
1972
Control
15-26
53-60
12-14
750
21.3
10. 1
1. 2
2.5
0. 1
0.3
Plume
10-22
64-67
12-14
750
38.9
13.2
3.9
2.3
1.5
1.1
1971 1972
40 40
64 53
14-16 12-14
500 500
3.2 11.2
25.0 10.0
1.2
1.2
1.4
0. 1
Coho - 0.5 0.3 0.6
Lake trout - - - - 0.8
Brown trout - 0.1-
Burbot - 0.1-
Total catch 566 270 458 144 130
Number per
100 feet net 113.2 36.0 61.1 28.8 26.0
-------
11-99
Table 3. --Number of fish per 100 feet of beach seined both day and night
at Van Buren State Park in June, 1969-1972*
Day
1969 1970 1971 1972
Night
1970 1-971 1972
Date (June)
Water tempera-
ture (°F)
Feet seined
25
16
16
15
56 65 69 69
1200 900 1000 550
22
67
16
69
13
64
900 1000 550
Species:
Spottail shiner
Longnose dace
Salmonids
Alewife (3 inches)
Ale wife (adult)
Trout-perch
Perch (2-3 inches)
19.3 0.9 40.7 36.7
3.8 12.7 3.7 5.3
0.4 0.7 0.5 4.2
0.3 - 12.9 0.9
(1) - - -
(1)
5.6
Total catch 297 132 636 267
91.0
11.7
-
0.2
43.9
8.4
0.4
1,407
43.6
10.2
0.2
(1)
0.9
4. 1
0.7
616
106.2
16.0
2.5
0.5
33.5
(1)
-
879
#
One fish is indicated by (1). Some species of numerical insignificance
have been omitted.
-------
11-100
In Appendix C of the Applicant's "Supplemental Information
on Environmental Impact of Palisades Nuclear Plant" data were also
included of fish collections in the vicinity of the Palisades site made
by the Bureau of Sport Fisheries and Wildlife, R/V Cisco. Additional
data have been supplied which include late 1971 as well as some
collections during plant operation in 1972, as shown in Tables II-E-lf-7.
In addition, to the data shown, it was reported that on Cruise V (June
6-22) tows with a 1/2 meter net of 351-micron mesh at various midlevels
over bottom depths of 3 and 5 fathoms resulted in collections of perch
and alewife fry.
-------
11-101
TABLE II-E-U
PALISADES PLANT
Numbers of lake trout and whitefish in various large-mesh (5, 3-1/2 inch, stretched)
gill net lifts, Cruise XII
Length
Depth of net
Date (Fathoms) (feet)
11/16/71
11/16/71
12/ 3/71
12/ 3/71
3
5
3
5
600
600
1,200
1,200
Lake trout
Male
17
9
1
2
Female
grand
1
0
0
0
Female
ripe
5
2
0
0
Female
spent
0
0
1
0
Total Whitefish
23
11
2
2
0
0
0
0
-------
11-102
TABLE
PALISADES PLANT
Numbers of fish caught in standard salmon gill net set (300 feet each of 3-l/2»
k, U-l/2 and 5 inch mesh on bottom at 3 fathoms)* Cruise n, April ^-20, 1972
Species
Coho
Chinook
Lake trout
Whitefish
Suckers
Yellow Perch
Northern Pike
Number
95 (average weight 1.9 Ibs)
1
k
I
3
1
1
*Based on fin clips, twelve of the cohos had been stocked in Platte River, Michigan
and two in Indiana; the others were unclipped.
-------
11-103
TABLE II-E-6
Catches per 10-minute tow with a 39-foot trawl, Cruise H, April l8, 1972
Species
Alewife (adult)
Alewife (young)
Bloater (adult)
Bloater (young)
Lake trout
Sculpin, slimy
Smelt (adult)
Smelt (young)
Spottail shiner
Stickleback, nine spine
Trout-perch
Lake herring
Number at
25 fathoms
1*66
-
^5
2
16
27
in
7
6
3
6
1
Number at
30 fathoms
161
3
1*5
1
1
10
56
-
-
«•
17
.
xcing refers to yearlings in collections made before August 1, and young-of-year
after August 1.
-------
11-104
TABLE II-E-7
PALISADES PLANT
Numbers of fish caught in gill net overnight (50 feet each 1-1/lj- and 1-1/2 inch,
100 feet 2-inch, and 600 feet each 3-1/2 and If-inch mesh, set with float lines
3 feet below surface over bottom depth of 9 fathoms) Cruise III, May 5, 1972
Species Number
Coho 8
Lake trout 17
Alewives 630
Smelt 7
Longnose sucker 1
Black bullhead 1
-------
11-105
Additional Seine Collections
All seine collections thus far have been made using a
125-foot nylon bag seine. Because of the selectivity of this seine,
supplementary collections will be made as a part of the Applicant's
study program using a ^0-foot, 1/8-inch mesh minnow seine. It is
felt that use of both seines will give a more accurate sample of
the fish at the various stations, especially the young-of-the-year
which may be in this area.
The 125-foot bag seine is pulled parallel to the shore for
a distance of 300 feet and then pulled into shore. Two 300-foot
sections are seined at each station if weather and time permits,
giving usually a sampling area approximately 1500 feet in length
along the shore in the plant area.
-------
11-106
Tables II-E-8-11 show the results of two daytime and two night-
time seining collections. Changing weather conditions enabled only the
control and heated north discharge stations to be seined on June 13.
Usually only one discharge section is seined per collecting trip de-
pending on the direction of the thermal plume. The north boundary
station was not seined on June 15 due to comparable collecting in that
area (Van Buren State Park) by the Department of Natural Resources
personnel.
In three of the collections, when a thermal discharge was
present, many more alewife, carp and spottail shiners were captured in
the heated water than in the stations not affected by the discharge.
This agrees with visual observations in the discharge canal where
these three species of fish are very numerous at all times when heated
water is being discharged.
The salmonids have been collected at all stations except where
the water is heated by the discharge, indicating they may avoid this
area. The heated discharge does seem to be an attractant to alewife,
carp and spottail shiners as evidenced by their absence when the plant
shuts down and no heated water is discharged. The only lake trout
collected by seining was captured on May 23 just north of the discharge
structure when no thermal discharge was present.
On June 13 and June 15 carp vere marked in the discharge with yellow
plastic streamers in the dorsal fins. The purpose was to establish rough
population estimates and to determine if the carp were remaining in the
discharge. One hundred carp were marked and visual observations were
made on subsequent days. Marked carp were observed for two weeks after
the marking, but the plant then shut down and no marked carp were observed
-------
11-107
up to July 1. Rough population estimates based on established mark
and recapture methods showed between 1,000 to 3,000 carp were in the area
of the discharge on any one day in late June, while the heated discharge
was present. It is thought this may be a low estimate, because at times
hundreds of carp were seen and none were marked. The discharge also
has an abundance of alewives as evidenced by seine and trawl hauls in
this area when heated water is present. It is impossible to estimate
how many alewives were in the discharge, but 100,000 would be a conservative
estimate for the late June period. Nowhere else in the immediate area
do carp or alewife numbers approach those in the discharge.
-------
II-108
TABLE II-E-8
PALISADES PLANT
Fish captured by use of 125-foot bag seine May 16, 1972 at night
Station
Species Control
Alewife
(Adult )
Coho3
Smelt
Spottail
shiner
Pumpkinseed
Sunfish
Temperature (°F)
2
0
0
0
0
51
North Boundary
0
2
0
1
0
50
South Boundary
0
3
1
2
0
51
North of
Discharge
1
5
0
25
0
51
•""South of
Discharge
5002
0
2k
20
1
58
(l) Thermal plume extended south and wanned seining area 7°F above ambient of 51°F«
(2) Estimated to be at least this many fish.
(3) Three to six inches in length.
-------
11-109
TABLE H-B-9
PALISADES FLSRT
Fish captured by
use of 125-foot
bag seine May 23,
1972 during
day
Station
Species Control
Alewife 26
(Adult)
Coho 1
Lake Trout 0
Smelt 0
Spot tail
Shiner 128
Temperature (°F) 50
North Boundary
21+
1
0
I3
56
51
South Boundary
95
162
0
0
k
51
North of
Discharge
35
5
1
0
1+7
51
South of
Discharge
26
1
0
0
1
51
(l) No thermal discharge, plant not operating but circulating water pumps working.
(2) Three to six inches long.
(3) Right pelvic fin clipped, 6 inches in length.
-------
11-110
TABLE II-E-10
PALISADES FLAW
Fish captured by use of 125-foot bag seine June 13, 1972 at night (NS - not seined)
Station
Spegies <
Ale wife
(Mult)
Coho
Smelt
Carp
Spot tail
Shiner
Temperature
Control North Boundary
80 NS
4
1
9
(°F) 62
"'"North of
South Boundary Discharge
NS 2,0002
0
0
ko
2
67
South of
Discharge
NS
(l) Thermal plume extended north and warmed seining area 5°F above ambient of 62°P.
(2) Estimated to be at least this many fish.
-------
11-111
Fish captured by use
Species
Alewife
(Adults)
Alewife
(3 inches)
Coho
Brown Trout
Carp
Spottail
Shiner
White Sucker
Nine -spine
Stickleback
Bluegill
Perch
Temperature (°F
TABLE ii=i-i;
PALISADESHSN1
of 125-foot bag seine June 15,
Station
L
P
1972 during
1
Control North Boundary South Boundary
20 NS
98
16
6
1
135
0
1
3
0
) 67
UO
U
k
U
*8
1
0
0
0
69
the day (NS
North of
Discharge
l^OO3
0
0
78
207
0
0
2
6
7^-77
- not seined)
South of
Discharge
NS
(l) Thermal plume extended north and warmed seining area 7°F to 10°F above ambient
of 67°F.
(2) Right pectoral fin clipped (3-6 inches in length).
(3) Estimated to be at least this many fish.
-------
11-112
Additional Fish Trawling
Two trawl collections have been made at each station (Exhibit II-E-l)
at 10 and 25 foot depths. A 25-foot trawl is utilized and 5-minute hauls
are made on the bottom at each station. Results of these trawl hauls on
May 2k and June 13 are shown in Table II-E-12. Also, Table II-E-13 shows the
results of 5-minute trawl tows on June 13 starting at the shore area of
each station and towing out into the lake from approximately a 3-foot
depth to a 25-foot depth. This type tow was tried twice at each station
and the data combined.
The tows of May 2k were done in the absence of a heated discharge
when the plant was not in operation. Few specimens were collected at any
of the stations and the only conclusion that could be reached is that fish
were not inhabiting the 10 to 25-foot depths at this time.
The tows of June 13 were done in the presence of a thermal plume
which varied in temperature at the surface from 12 F above ambient of
57 F at the point of discharge to 3°F above ambient lake at the 25-foot
depth. The thickness of the surface plume was only 1-2 feet at the 25-foot
location and more than 5 ft deep at the 10-ft depth near the discharge. From
the data, it can be seen that very few fish were captured at the 25-foot
depth (only at the North boundary station), but at the 10-foot depth more
alewives and smelt were captured in the discharge area than at any other
station. The alewives were also usually observed in greater numbers in the
discharge area. The smelt were not visually observed in the discharge
area, but more were collected in the discharge area than at any other
station. Both adult and young smelt were collected at each 10-foot
depth station with no increase of either group recorded at any one station.
-------
11-113
Additional Fish Trawling (Contd)
A very general conclusion from the trawling data would be that
alewives, and perhaps smelt, were more numerous in the area of the discharge
and the plume. Alewives, along with carp and spottail shiners, were found
to be more numerous in the area of the discharge and the plume in the
seining collections.
-------
o
o
• in
CVJl
O O O
O O O
o o o o
OO
o o
CO
CO
cK
rH
«v
-3-
CVI
>>
I.C?
&l
a
1
£
A
•P
e.
M
o
&
in
CVI
i*— -x
£
o
H
O O O O
o o
36
"&
H H
Hg
H £
<
P
g
B
g
5
Ifa
3 ^
3
§
a
SB
• H
M
H=J
H
hrt
M-<
CO
E
•2 5 H
5 ^ ^
CO OS
M c
-P H
0 ^
S -2 ^
^^
-p h O
0) -P
0) ft
.p 0 QJ
p) 4J
J . -p g
in "d
G
^ P>
cu o
ft W
co X!
cu -P
•g g
-p CO
_£ in 0 0 o g «
C -P ?
g
XII H f-i
-P ft CO
PJ ft
CO] •«
P CO CO
HO CO
SI -" o o o % -g
cd " X! -P
o o cd
ra cj
CO
bfl
schar
n
^^| 0000
4-1
X!l
•pj
S|O| cvj o m o
O|H| vo j-
b-
% '"
cd
-a
c
I
XI
•p
I
^^| 0000
£
si
II
Ol J- in ON CVI
H| CVJ
CO
cu
•H
O
CO,
ft
V
-p
cd
0)
.c
co
CO
_J
•n
o
-------
11-115
1
r+
A5
fi
£
£
09
<-•» H
-d & H
•£ «J p
C _ »-i &
O EH E-i .p
OS fa
v~' .
CU UNJ- ^- J- J- J- C
4343J MlfNOUNOirN o
P«?H 3 H H OJ CU ^
S7> — 1 co
" 1 X!
t
. CU H J- g
. 1 . . • (g
O 00 ONVO ^
rH| UNJ- J-
-d- co t>co J- ON
UN O vo m J- J- co
cu lAj-^-j-a-j-
x-s -3
+>43| JjinOUNOUN £
0,^1 3 rH H CU CU ^3
r-i - |
COCO
•. • «
O t— CO VO
rH UN2F J-
J- H CU O ON O
m ONC^- irMTkCO-d;
CU J- -st .* -*.*•*
£
j3*~J g*
•g,dl ^^SI^Scu i
P4 S-l 1 P f-i rn t\J t\J rH
CU| J-J-J-J-3-J- H C
* *o
.gx-sj ^Q^ ^ j?|
p»<£| S^HHCUCU flj^
^n w i«
•^•s
g
•-i cu vr\ co
•• • • »
O VO O UN
H UN UNJ-
»
j3^-s
P4^H
«s_x
Q
S
UN
CU
•^'"^1
•P 43
8*5
«
S
UN
CU
^!'~-
•P -p
P<«M
-P -P
ft«M
iS"
b
H
O- UNCU UN CU
,CU CO CU CU H rH
VO UN UN UN UN UN
Ih UNO UN O UN
3 rH r-l CU CVI
CO
co^t t-
ro,t-5oo
vo vo UN
•
,c
ICU ON CU CU O CVI "^
%H CO CO t- t- !>• §
VO UN UN UN UN UN
O
4-'
J4 UNO UN O UN ~C
3 r-j H cu cvi 5
CO f
WJ H
9
CJ
OJ O t- i
«vSu^ g1
•H
rf
SH
UN O VO OO-* ft
HVH t>-vdvovo °
VO VO UN UN UN UN 4_->
0
rJ
JJ
H UN O ITN O UN C
3 rH rH CU OJ «5
CO r-|
Pi
*\
voj- £
ON^ ON ^
vovS UN J5
CJ
02
•H
-d
cu j- co vo vo vo c
p CO t^- t> I> [>• ^
VO UN UN UN .UN UN M
(U
4J
c«
fH UN O UNO UN
P H rH CU OJ Ti
CO
-------
11-116
TABLE II-E-13
PALISADES PLANT
Catches per 5-minute tows pulled perpendicular to shore with a 25-foot trawl
June 13, 1972. (Total number of fish from two 5-minute tows combined.)
Location
Species
Alewife
Smelt
Spottail
shiner
Perch
South
Boundary
86
6
0
0
Discharge
600
0
7
0
North
Boundary
170
10
2
2
Control
5U
12
2
0
-------
11-117
Fish Eggs and Larva
The likelihood of fish eggs and larva being drawn into the
intake structure and passing through the plant has been studied and the
results of 1^2 hours of sampling are presented in Table II-E-lU. The
method employed in sampling the intake water is to suspended a #20 mesh
Wisconsin plankton net in the intake bay on an anchored line so the mouth
of the net faces the incoming water. The net remains oriented in this
position, although occasional currents move it in a laterial direction.
The amount of water passing through the net is calculated assuming a
constant current of 9 feet/second through the 5-inch diameter opening of
the net. Attempts to measure true velocity conditions in the intake bay
produced highly erratic results because of turbulent conditions. The
value selected is the theoretical average velocity through the intake
pipe and probably represents a maximum condition at the sampling point.
-------
11-118
«H
O 4)
h
(U .
*,3
o
a
I
g
T) CM
-------
11-119
A total of 9,201,500 gallons of water is estimated to have
been sampled in lU2 hours, producing a total of 918 eggs and k larva
in the samples. One sample, the June 15 one, contained a total of
826 eggs, which comprised 89$ of all eggs collected. These eggs were
thought to be perch eggs due to the occurrence of ripe perch in the
traveling screen collections during this time period. It is possible
that ripe female fish may be expelling their eggs in the intake pipe
rather than the eggs being pulled into the intake from the area around
the intake openings. The four larva have not been identified, but seem
to represent an insignifcant number passing into the plant at this point
in the study. It should be noted that the R/V Cisco cruise in mid-June
found perch and alewife fry near the plant at depths of 3 and 5 fathoms,
which would be comparable to intake withdrawl level.
Benthic samples are analyzed for the presence of fish eggs to
identify spawning and egg incubation areas in the vicinity of the site.
The numbers of fish eggs in the preparational benthic samples are tabulated
in Appendix F and classified by time of collection and depth zones. A
summarization of spawning information on selected fish species is also
included. Observations of fish eggs in the June, 1972 benthic samples are
included in the initial results reported in Table II-C-1.
In each year, the collections from June usually contained the
highest number of eggs at all depth zones and at each time of year. The
perch, alewife, and smelt are the principal species known to reproduce
in the area at this time of year; thus, they are in all probability the
type of fish eggs found in the analyses. This agrees with both the egg
-------
11-120
collection data from the intake and the fish collecting data. The moat
eggs collected from the intake were in mid to late June and the ripe
fish in the area at this time were generally perch and alewives.
Data from analyses of benthic samples in 1972 for fish eggs is not
yet available.
-------
683
-, 0. Petersen
2 information which we have, ask them what further information
., they need, and then ask them for their educated opinion as
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
to the effect upon the eco /ystem.
MR. McDONALD; Are you a lawyer?
MR. PETERSEN: I am a lawyer as I identified myself
at the beginning.
MR. McDONALD: Pardon?
MR. PETERSEN: As I identified myself at the
beginning of my statement, sir.
MB 1'c DONALD: I have no further questions.
MR. MAYO: Mr. Purdy.
MR. PURDY: Mr. Petersen, on page 2 of your state-
ment, as it relates to the — "no evidence of any water
masses that could be attributed to the effect of warm water
discharges from powerplants into the lake" —— these studies
did, in fact, show thermal plumes; they did not show a large
heated water mass from that plume moving out into the lake.
MR. PETERSEN: That is correct.
MR. PURDY: Thermal plumes were identified.
MR. PETERSEN: Yes, yes, indeed.
MR. PURDY: The other — not a question but a
comment — there is a difference, 1 believe, in the Water
Resources Commission feeling and what you have expressed
here, with respect to whether the Water Resources Commission
-------
684
0. Petersen
in large measure accepted or rejected the recommendations of
the Administrator.
It is my feeling that the Water Resources Commissioiji
feels that they did, in large measure, accept, not reject the
recommendations of the Administrator as it relates to thermal
7 jj standards for Lake Michigan.
8 MR. PETERSEN: May I state that that would have
been better phrased that 3 of the 4 States made what might
10
be considered significant deviations from the recommendations
11 j| which were presented by the Federal conferee and adopted by
I
12 I the conference.
13 I
MR. MAYO: Just by way of an observation, Mr.
14 jl Petersen, you at least implied in the third paragraph of
|
15 |i your statement that at the last session of the conference
16
17
the Federal conferee muscled the 4 State conferees into
taking a positon, and I would like to make the point very
clear: I consider Bill Blaser and Ralph Purdy, Perry Miller
i
19 j! and Tom Frangos, as being four of the very, very capable,
20 i1 and four of the tougher water pollution control adminis-
21 'i trators in the country, and we don't get away with muscling
22 jj them around.
oo !
*•-' !•: I think there was a good deal of rationale, and
2^ a good deal of concerted technical persuasion that led to
Q C ! |
•? |, the recommendations that came out of the conference, not
-------
635
1
2
4
5
6
7
8
9
10
11
12
19
20
21
A * Dowd
the application of muscle.
MR. PETERSEN: I thank you for your comment. I
am sure that your comment about the quality of the gentlemen
is quite accurate; however I do not withdraw mine. (Laughter!)
MR. PURDY: Mr. A. Joseph Dowd, American Electric
Power.
STATEMENT OF A. JOSEPH DOWD,
ASSOCIATE GENERAL COUNSEL,
AMERICAN ELECTRIC POWER SERVICE CORPORATION,
NEW YORK, NEW YORK
13 |
MR. DOWD: Mr. Chairman, conferees, ladies and
I!
15 gentlemen. My name is Joseph Dowd. I am Associate General
16 | Counsel of American Electric Power Service Corporation and
I
17 j| am appearing here today on behalf of Indiana & Michigan Power!
, ,* !i
Company, which is one of the companies of the American
Electric Power System, and which is presently constructing
the Donald C. Cook nuclear plant at Bridgman, Michigan, on
the shore of Lake Michigan.
22 || My remarks will basically consist of several
o-a !
^ i observations regarding the Federal Environmental Protection
^ I' Agency's thermal report, which was submitted to this session
25 i'
l| of the conference.
ii
[]
-------
636
1
2
3
4
6
7
8
9
10
11
I!
A. Dowd
At page 14 of the EPA report, reference is made
to the litigation instituted by the Indiana & Michigan
Electric Company against EPA. That reference states that
5 jj the litigation has been dismissed, but does not reflect the
fact that an appeal from that dismissal is presently pending
before the Federal Court of Appeals for the District of
Columbia. In fact, briefs on appeal by both parties have
already been filed, and we expect that oral argument will
take place within the next few months.
we would hope that the EPA report could be amended
12 is to reflect the pending appeal.
i
13 Also, it should be noted that in dismissing the
14 case on what basically were procedural grounds, the lower
15 court judge stated, and I quote: "It appears that the Water
i
16 Pollution Control Act confers no authority on the Adminis-
17 ! rator to provide how an electrical generating plant is to
be constructed."
19 The judge went on to say, and I quote: "Even if
20 the Administrator is authorized to require closed-cycle
i
21 I cooling for plaintiff's plant, I have serious doubts with
22 : respect to the legality of the procedure followed in this
23 : case. The Lake Michigan Enforcement Conference was convened
pursuant to Section 10 (d) of the Water Pollution Control
Act. That conference has to do only with existing pollution
-------
_________________________________________ 687_
A, Dowd
abatement."
Our participation in this conference today should
not be construed as being in any way inconsistent with the
5 views expressed by the court.
6 Having gotten these few preliminaries out of the
7 way, I would like now to address myself to EPA's thermal
policy, which appears on pages 17 and 18 of the EPA report.
9 I As stated on page 17, and I quote: "EPA has
10 established the policy that all discharges to the aquatic
11 environment involving waste heat must be evaluated on a
i
i
12 case-by-case basis, taking into account that some discharges
13
14
1$
16
17
19
20
21
22
3
^
must be evaluated collectively due to their combined impact
on the receiving water."
This "collective evaluation" must presumably
relate to those limited situations involving discharges
which are in close proximity to each other and which, there-
fore, present the possibility, the potentiality of overacting
or interacting plumes.
This policy would appear to apply to all plants;
those presently operating; those under construction, such
as our Cook plant; and future plants.
If our understanding of EPA's policy is correct;
i.e., if the words mean what they appear to mean, then a
2 S
' i case-by-case evaluation of thermal discharges is a sensible
ji
u
-------
688
^ - . ~~~ _—_——_—
, A. Dowd
2 and a constructive policy. It is a policy which, if properly
~ administered, will assure necessary environmental protection
|
, without the imposition of unnecessary costs on the consumers
of electric energy. It is a policy which makes sense, and
which should be applied to Lake Michigan as well as to other
7 major bodies of water in the United States.
' !
Also, such a policy would appear to be consistent
with the case~by-case approach adopted by the State of
10 Michigan in August of 1971, thereby permitting, we would
11 i hope, prompt approval by EPA of the Michigan standards.
12 Now, the foregoing represents our understanding
i
13 of the English language as it appears on pages 17 and 1& of
14 ! the EPA report. However, Mr. Bryson, in his oral presenta-
i
15 || tion this morning, added a concluding statement which does
16 jl not appear in the EPA written report. If I understand Mr,
11
11
17 j Bryson correctly — and I hope that he will correct me if
IB ij I misrepresent what he said, or the effect of what he said
19 i; — Mr. Bryson, in spite of the stated case-by-case approach,
11
I j
20 || said that EPA is adhering to its previous position by a
21 !' 1,000 foot mixing zone with no more than a 3°F. temperature
22 j; rise at the edge of that mixing zone for all thermal dis-
11
23 !! charges to Lake Michigan. And that all plants on the lake
i
24 i which were not in operation on March 1, 1977, that such
! i
25 plants be operated with closed cooling systems.
-------
•]_ A. Dowd
2
10
11
12
13
14
15
16
17
IS
19
20
21
23
24
This, of course, is hardly a case-by-case approach.
It is, in fact, the very antithesis of a case-by-case
approach,, Thus, black means white; yes means no; up means
down; and case-by-case really means across-the-board — at
least for Lake Michigan.
One can only speculate as to why this was not made
explicit in EPA's written thermal report to this session of
the conference, which report was made available to the public
several weeks ago.
Let me ask a few questions which are not entirely
rhetorical.
Why has EPA's thermal policy, which was enunciated
in Mr. Quarles1 letter of May 12, 1972, and in his speech
of May 16, 1972, been completely ignored insofar as Lake
Michigan is concerned?
If a case-by-case approach is appropriate for the
rest of the United States, why is it not also appropriate
for Lake Michigan? After all, the first thermal finding,
which was set forth in the summary of the last session of
this conference, stated that, and I quote: "The lake as a
22 i whole will not be warmed except in localized areas by the
discharges of waste heat from existing and presently proposed
powerplants." This is a finding which, I believe, was con-
curred in by EPA, and which dictates a case-by-case evaluation
-------
10
11
12
13
14
16
17
id
19
20
A. Dowd
for Lake Michigan.
In March of 1971, the Third Session of this con-
ference was called by EPA for the express purpose of consid-
i
i
ering the recommendations of a Technical Committee on thermal
i
discharges. The conference was held and the Technical Com- j
mittee's recommendations were almost totally ignored.
Today we are attending the Fourth Session of this
conference. EPA stated in its written report, which was
publicized in advance of this session, that its thermal
policy involved a case-by-case approach.
On the basis of EPA's performance this morning, it
now appears that the publicized case-by-case approach will
be ignored in favor of the old and discredited across-the-
board approach.
We respectfully submit that this type of behavior
is most unbecoming and most inappropriate for a responsible
Federal agency.
Before closing, I would like to make brief mention
of the ecological studies of Lake Michigan which would have
21
relevance to the thermal question and to which the AEP System
22
either alone or in conjunction with other Lake Michigan
23
utilities is responsible. These are studies which have gone
or
forward since the conclusion of the conference workshop
25
almost 2 years ago.
-------
691
A. Dowd
First are the series of limnological studies,
Volumes 6, 7, $, 9, and 10 of which have been completed and
published since the conference workshop. These studies
relate to the immediate vicinity of the Cook plant as well
as to the effects of thermal discharges from existing Lake
Michigan powerplants.
They are funded by I £ M and are being carried
out by the Great Lakes Research Division of the University
10 of Michigan under the direction of Dr. John C. Ayers. All
11 of the volumes of this study have been furnished to the
12 conferees, including EPA, as they have been completed.
13 I would like to point out for the benefit of Mrs.
14 Voita, and to set the record straight, that these studies
1$ j do include studies of the effects which thermal discharges
i
16 from the Cook plant will have upon winter ice packs up
17 along the shore. These studies conclude that there will be
1$ ! no appreciable effect.
19 As you may recall, during the conference workshop
20 in 1970, we presented testimony and exhibits relating to an
21 j aerial survey which was being carried out for I & M by
22 j the billow Run Laboratories of the University of Michigan.
i
i
23 This work has continued since that time under the joint
sponsorship of I & M, Consumers Power Company and Northern
Indiana Public Service Company.
-------
1
2
7
8
10
11
12
13
14
15
16
17
19
20
692
A, Dowd
Mr. Petersen has entered into the record as an
exhibit a report containing black and white photographs.
We have what I believe is the same report, but it contains
the colored photographs, and we would like to offer this,
Mr. Mayo, as an exhibit for the record.
MR. MAYO: It will be received.
(The document above referred to is on file at
U.S. EPA Headquarters, Washington, D.C., and Region V
Office, Chicago, Illinois.)
MR. DOWD: In addition, I & M in 1970 commenced
a study of lake water temperatures in the general and
immediate vicinity of the Cook plant site. Daily maximum
values at the Benton Harbor and the St. Joseph city water
intakes have been obtained. Also thermistor sensors on
armored submarine cable were installed at the Cook plant
site and have been used to record temperatures at five dif-
ferent points in the immediate vicinity of the site.
Despite a number of problems caused by the
winter ice packs, lightning, sand movement, and even human
^•L \\ sabotage, we have been able to obtain a substantial amount
22 i
11 of data on lake water temperatures. This raw data has been
made available to the conferees in Volumes 7 and 10 of the
i,
2L i
I limnological studies.
I!
25
The work completed since the 1970 conference
-------
693
A. Dowd
workshop shows no significant adverse effects to the lake
resulting from ^owerplant thermal discharges. This work also
einphc-.v.Ess the dynamic and v'a^iable character of the lake.
For example, th?' liUge amoun^o of cold water exist which are
stirred about and oecasiona? •v come to the surface even dur-
ing the hottest months, and that the distributions of fishes,
phytoplankton, and zooplankton in the lake are very
irregular, occurring in nonuniform concentrations and
10 patches, all of which tends to confirm the appropriateness
11 of evaluating thermal discharges to Lake Michigan on a case-
12 by-case basis.
13 Mr. Chairman, this concludes our statement.
MR. MAYO; Any comments, gentlemen?
15 MR. PURDI: I have a question, Mr. Chairman.
16 MR. MAYO: Mr. Purdy.
17 MR. PURDY: Mr. Dowd, earlier Mr. Falls reported
1° his determination that certain scouring problems would occur
19 at the outfall structure. I am wondering if your modeling
studies have identified this, and if so have adjustments or
have remedial measures been incorporated into your project?
MR. DOWD: The answer to both questions is yes,
Mr. Purdy.
^ Our modeling studies recognize the distance of
scour, and we have taken measures to rip-rap to the extent
-------
694
3
4
6
7
8
10
11
13
16
19
<-) !
05
'
A. Dowd
necessary to take care of any scouring problem that might
occur.
MR. PURDY: That is all.
5 I MR. MAYO: Any other comments, gentlemen?
MR. McDONALD: I would like to make a comment,
Mr. Mayo, on Mr. Dowd's statement about the inconsistency
of the thermal policies issued by John Quarles, the
Assistant Administrator for Enforcement on May 12, 1972;
i.e., the inconsistency with the conference recommendations
that the EPA Administrator issued in May of 1971.
12 ! I think, Mr. Dowd, that you have to look at the
total findings that were announced in the summary of the
14 ! conference by Administrator Ruckelshaus in May of 1971 and
ii
15 ! not just one of those many findings. The cumulative weight
of those findings is very obvious and is recognized in the
17 || preamble to the recommendations where the conferees unani-
mously agreed to the fact — right under the recommendations
on page 10 of the issuance by the Administrator:
1 1
20 jj "In order to protect Lake Michigan, the following
21 !j controls to waste heat discharge are concurred in by the
22 !' conferees representing Indiana, Michigan, Wisconsin, and
•
the United States Environmental Protection Agency."
Illinois is not included. And then it goes on to name the
recommendations* That was after the findings were in.
-------
695^
1 A. Dowd
2 This thermal situation on Lake Michigan was con-
3 sidered as a whole in May of 1971 when those recommendations
were issued. When Mr, Quarles issued his thermal policy --
Mr. Quarles being, again, the Assistant Administrator for
Enforcement — he was luliy cognizant, thoroughly versed in
the issues of Lake Michigan. He was not trying to slip the
Lake Michigan recommendations into the wastebasket by issu-
ing this thermal recommendation. Not only would Mr. Quarles
10 not have any authority to do this, but this isn't the way
11 i; he does business.
1i
12 Also, in Mr. Quarles1 May 12, 1972, policy, he
i
i-3 talks about a case-by-case analysis. He also refers to
14 total cumulative heat loadings. By "total cumulative heat
15 loadings" — and that is in black and white, as you sug-
gested that the other parts aren't — he means just what
!7 he says: total cumulative heat loadings. This is the
situation in Lake Michigan; concern for the total lake.
19 We know and you know, on the basis of the record
of the last conference and this conference, too, that all
of the returns are not in by a long shot. Administrator
Ruckelshaus, when he made his recommendation and when he
addressed a letter to this conference, stated that if he
is going to err, he is going to err on the side of safety.
And I think that the inconsistency that you pointed out
-------
696
A. Dowd
in the Quarles* policy versus the Administrator's announce-
ment is, in fact, not an inconsistency at all.
MR. DOWD: Mr, McDonald, the inconsistency that I
am noting is not between the 1971 policy by the Administrator
6 and a May 1971 policy by Mr, Quarles. I am addressing
11
7 i myself to an inconsistency between what is stated here in a
8 li September 1971 report and what Mr. Bryson told us this
I
9 morning. This is a September 1972 report submitted to the
i
10 | Lake Michigan Enforcement Conference.
11
11
11 ji MR. McDONALD: Well, let me tell you — you are
12
13
14
21
talking about the last statement Mr. Bryson concluded on
the
MR. DOWD: I am talking about Mr. Bryson's state-
15 1 1 ment after reading this which talks about case-by-case with
16 |j some collective evaluations where necessary. Mr. Bryson
i ,
ii
17 j' then concluded his remarks with something that was not in
!•£ i here; he said that this does not represent any deviation from
the Administrator's position, as expressed in his May 1971
letter, and in the recommendations of the conference of
May 1971.
i j
22 ! MR. McDONALD: And Mr. Bryson is absolutely right;
93
"~J it doesn't., And the reason Mr. Bryson inserted that was,
'i again, I think, for a fairly obvious reason: some of it
2r> ;
" " relates to the newspapers, again.
-------
697
1 A. Dowd
2 MR. DOWD: Mr. McDonald —
3 MR. McDONALD: There has been speculation that
4 this conference recommendation does not stand. It does
5 stand.
6 MR. DOWD: — could I just ask one question? I
7 donft mean to be argumentative.
8 MR. McDONALD: Well, I don't either. But I think
9 this is a fundamental point.
10 MR. DOWD: This is a report of the Lake Michigan
11 Enforcement Conference. We are not directly concerned with
12 what the policy is with respect to other bodies of water in
13 the United States.
14 Now, if the EPA policy is still that every thermal
I
15 discharge into Lake Michigan should be confined to a mixing
zone of 1,000 feet with a 3° maximum at the edge, why in
17 heaven's name didn't you state this or reaffirm it explicitly
in your report?
MR. McDONALD: For a very, very simple reason —
20 and I am surprised that you raise this point. I am glad
that you raise it, from another standpoint.
22 The conference recommendation has been made. It
^ has been announced. It stands.
i
^ MR. DOWD: This could very well supersede the con-
25
ference recommendation, it seems to me.
-------
698
1
2
6
7
10
12
13
15
16
17
IB
19
20
21
22
A. Dowd
MR. MAYO: If Mr. Quarles intended that his policy
was going to supersede the recommendation of the Lake Michi-
gan Enforcement Conference or any other conference, Mr.
Dowd, I think he would have said so.
MR. McDONALD: Well, I think additionally that
Mr. Ruckelshaus who had issued it — he is the one that
changes any recommendations in the conference, not Mr.
Quarles.
MR. HENRI: Well, I think it is perfectly clear
11 ji you are trying to supersede Mr. Quarles.
MR. McDONALD: I think we have spoken to this
point, and I am glad you brought it up from the standpoint of,
if you think there is an inconsistency, there is certainly
no inconsistency on our part. The recommendation was made
in May of 1971 when the Administrator, who is the one who
has the authority to make the recommendation, made it.
The Administrator has not changed his recommendation, and
the recommendation is in toto, that is the entire conference
summary that he issued in May of 1971, which includes the
1,000 feet and the 3°.
MR. DOWD: And your statement, on page IB of this
' report, which is only a few weeks old, says that: "To
24
Quarles1 policy — "on thermal discharges to Lake Michigan,
determine the impact of this policy" — that has to be Mr.
25 ^
-------
699
1 A. Dowd
2 one must conduct a thorough assessment of each major heat
o source individually and collectively ..." —
MR. McDONALD: I fail to see any problem in that
5 statement.
6 MR. DOWD: Why conduct these surveys if you have
already decided that all plants have to be confined to a
1,000 foot radius, as far as the mixing zone is concerned,
9 ! and that all future plants, and possibly those under con-
10 struction, must be constructed with closed cooling systems?
11 MR. McDONALD: One of the reasons this conference
12 session was reconvened, again, was a very elemental reason:
13 There has been a good deal of controversy on the recommenda-
14 tion that the Administrator issued in May of 1971. This is
j
15 a matter of public record. Three of the four States do not
16 agree with the recommendation.
17 The conferees, the States were called back into
session to give not only them but the Federal Government,
19 and to give obviously affected parties,such as your com-
20 j pany, an opportunity to come back into this session, so we
21 can look at the total record again.
22 j in the meantime, this recommendation still stands.
23 MR. DOWD: I am glad we have clarified that,
24 Mr, McDonald. Thank you.
25 MR. MAYO: I have one comment. I think, Mr. Dowd,
-------
700
3
4
6
7
B
9
10
11
12
13
14
15
16
17
20
21
A. Dowd
it is appropriate, when you are making reference to the
findings of the conference, not to be as selective as you
were. Because it seems to me you implied that, on the
5 j basis of Finding No. 1, that there was adequate justifica-
tion for considering the large thermal dischargers into
Lake Michigan on exclusively a single-plant-by-single-plant
basis.
I think perhaps you overlooked and maybe you
ignored the Binding No. 16 which says: "Discharges from a
single large plant located in a spawning ground or across
a migratory route could significantly disrupt the balance
of the affected species throughout the lake." And I think,
on the basis of that finding, if there was no other finding
made, you just have to take the time to look at the plants
in some collective fashion.
MR. DOWD: Mr. Mayo, that strikes me as looking at
the effect of an individual plant and determining whether
its thermal effluent goes into a spawning ground. We have
no quarrel with this at all.
MR. MAYO: Any other comments, gentlemen?
22 ; MR. McDONALD: I would like to add one thing.
00
It relates to Mr. Purdy's testimony. If I understood his
testimony right, he is looking at the total lake also and
not on strictly a case-by-case basis, but for total
-------
701
1 W. Blaser
2 protection of that lake, even though all of the parameters
3 aren't in, in terms of his ability to assess that.
4 MR. MAYO: Any other comments, gentlemen?
5 MR. PURDY: That completes, to my knowledge, those
6 that wish to make statements for Michigan.
7 MR. MAYO: Gentlemen, if I could have a word with
8 the conferees for a minute, off the record, if I may.
i
9 (Discussion off the record.)
10 (Short recess.)
11 MR. MAYO: May we have the conferees at the head
I
12 table?
13 Ladies and gentlemen, in keeping with the agenda,
14 the next presentations will be those of the State of Illinois
15 and the Illinois interests.
!6 Mr. Blaser.
17
18 STATEMENT OF WILLIAM L. BLASER,
19 DIRECTOR, ENVIRONMENTAL PROTECTION AGENCY,
20 STATE OF ILLINOIS
21 SPRINGFIELD, ILLINOIS
22
2^ MR. BLASER: In order to help clarify the situa-
01
tion with the Illinois regulations on thermal as compared
25
to the conference recommendations, I have a statement here.
-------
702
1
2 I Copies are available.
3
4
6
7
10
11
12
13
14
15
16
17
IB
19
20
W. Blaser
The Illinois Environmental Protection Act requires
that all regulations, including thermal standards, be set
by the Illinois Pollution Control Board, of which David
Currie is the Chairman.
It is further required, under the Act, that this
be done based on facts established by open public hearings
with sworn and recorded testimony, rules of evidence, right
of cross examination, and Board-written decisions and sup-
porting reasoning.
No matter how strongly the Federal Government
recommends a thermal standard through this conference,
Illinois can only adopt enforceable standards through pre-
sentation of evidence to the Illinois Pollution Control
Board.
This fully-recorded process was followed in a
series of open hearings, and participation in workshops
held in early 1971 to establish "Thermal Standards for Lake
Michigan11 (PCB R-70-2). Copies have been made available to
all conferees and are available to members of the audience.
oo
In this opinion, our Pollution Control Board has
23
! spoken quite eloquently to the concern that Illinois has
o i '!
** ; on thermal enrichment of Lake Michigan. Details of the
[ Illinois position on the thermal standards and that of our
-------
703
W. Blaser
2 regulations follow.
o The recommendation of the 1971 conference was
that each discharger shall complete preliminary plans for
appropriate facilities by December 31» 1971; final plans
5 by June 30, 1972; and place such facilities in operation by
7 December 31, 1973, for off-lake cooling.
Our Board concluded after extensive public hear-
9 j ings that there was insufficient evidence of significant
10 ecological damage to require the existing heat sources to
11 j backfit cooling devices. The Board does require, however,
I
12 i that the source of heated effluent demonstrate in a hearing
13 before the Board within 6 years that the discharge from
14 that heated source has not caused and cannot reasonably be
15 expected to cause significant ecological damage to the lake.
i
16 The regulations also provide for the requirement
17 of backfitting of alternative cooling facilities, if it is
found at any time that any heated effluent causes significant
19 ecological damage to the lake.
20 As far as new heated effluents, our Board has
21 spoken to its concern on the matter of siting of additional
22 large heat sources on the shores of Lake Michigan. Our
regulations require in Rule 206e (3) (A) that no source or
heated effluent which was not in operation nor under con-
struction as of January 1, 1971, shall discharge more than
-------
4
5
6
7
9
10
11
12
13
14
15
704
W, Blaser
a daily average of 0.1 billion B.t.u. per hour. We are aware
plans to locate an additional heated effluent on the Illinois
shores of the lake.
As to mixing zone, the recommendation of the con-
ference was: "... at a maximum distance of 1,000 feet from
a fixed point adjacent to the discharge."
The Illinois regulations, Rule 206e (1), identi-
fied the mixing zone as "... shall be no greater than a
circle with a radius of 1,000 feet or an equal fixed area
of simple form."
The concept of mixing zone is further explained
in our Rule 201a which requires case-by-case evaluation with
the following items to be considered: The character of the
body of water: the present and anticipated future use of
1° i< the body of water; the present and anticipated water quality
17 ;j of the body of water; the effect of the discharge on present
1° | and on anticipated water quality; and the dilution ratio
i!
19 jj and the nature of the contaminant.
^° ;] The 1971 conference further recommended that the
^1 l receiving water not be more than 3° F. above the existing
]
2^ i natural temperature nor should the maximum temperature
2^ :| exceed the monthly maximum limit. The Illinois regulations
Q I
. do reflect this requirement.
25 "
': Water Intake: "Design to minimize entrainment
-------
70J>_
1 W. Blaser
2 and damage to desirable aquatic organisms." This requirement
3 is reflected in Rule 206e (2) (F) which states: "... all
4 reasonable steps shall be taken to reduce the number of
5 organisms drawn into or against the intakes."
6 The existing Commonwealth Edison Company, Waukegan
7 Works, has an intake bay and channel with fish nets. The
8 Zion facilities are being designed to comply with these
1
9 i requirements.
10 Recommendation: "Thermal plumes shall not over-
11 lap or intercept."
12 The Illinois regulations reflect this requirement
13 in Rule 206e (2) (E) which states "... heated effluents
14 from more than one source shall not interact."
i
15 Recommendation as to temperature and flow
16 1 records: Operating reports are required from the existing
17 Commonwealth Edison Company facility and are submitted on
l^ a monthly basis.
19 Finally, the intake structure design: We have
20 compiled some data on the design of the intake structures
21 at existing water plants and industries utilizing Lake
22 Michigan water. We have no evidence of "significant
23 ecological damage" to the lake as a result of withdrawing
[
^ organisms from the lake.
25 Any questions?
-------
706
W. Blaser
MR. MAYO: Any comments or questions, gentlemen?
MR. McDONALD: Mr. Blaser, what type of temperature
flow records do you require? Do you have a special form that
5 is filled out?
6 MR. BLASER: We have a requirement. We have spent
7 a good period of time — I will turn to Mr, Blomgren, who is
more familiar with that detail.
9 MR. BLOMGREN: We require them to report the daily
10 minimum and the daily maximum temperatures for each day of
j j
11 i| the month and submit reports monthly.
i
12 j MR. McDONALD: And these are all company reports?
13 MR. BLOMGREN: Yes, sir. As every discharger in
14 Illinois is required to submit operating reports, so is
I
15 ' Commonwealth Edison. We supplement their reports with our
16 surveillance and monitoring data.
17 ! MR. McDONALD: In regard to the Zion facility,
will the Zion facility have the same reporting requirements
19 as the city of Waukegan facility now has or will they be
20 additional?
21 | MR. BLOMGREN: We see no reason to ask for any
more at Zion than we now do in Waukegan.
, McDONALD: Could you itemize what you have
^ ji asked? Do you have a form that —
MR. BLOMGREN: No. They are reporting currently
-------
707
1 W. Blaser
2 daily minimum and daily maximum temperatures.
3 MR. McDONALD: And that's it.
4 MR. BLOMGREN: And flow.
5 MR. McDONALD: What about special monitoring
requirements in the lake itself? Will any monitoring requiref
ments be imposed upon the company or have such requirements
been imposed?
9 MR. BLOMGREN: They are currently engaged in an
10 operating report survey, yes.
11 MR. McDONALD: Is that a survey that was designed
12 j by the State of Illinois, or was it formulated by the
13 company?
14 MR. BLOMGREN: It was company-formed.
15 MR. McDONALD: Did the State participate in the
16 design of the monitoring —
17 MR. BLOMGREN: We reviewed them with them.
13 MR. McDONALD: Is that in a special write-up or do
19 you have criteria against which you assess that, or what
20 was the developmental process of the monitoring?
21 MR. BLOMGREN: Something like that is reviewed in
22 Our permit section. The proposal was submitted by Common-
23 wealth Edison and reviewed in our permit program and con-
2k I curred with.
!!
2 5 MR. McDONALD: And how far does the monitoring
-------
70S
, J. Blaser
2 extend into the lake?
MR. BLOMGREN: I am sorry. I do not know that
right offhand. We could get that information for you.
5 MR. McDONALD: Do you know of any source of
6 information that you will be receiving to assess the total
effect, say, of the Zion discharge if it doesn't have
8 polluting power into and upon Lake Michigan, similar to
what Mr. Purdy suggested he might want to look at?
10 I MR. BLOMGREN: Yes, sir, certainly. Our regula-
11 tions do require pre- and post-operation surveys. They are
12 engaged in pre-surveys right now*
|
13 MR. McDONALD: In terms of total impact on the
14 lake, do you know of any data that you will be receiving
15 I from the Federal Government or the other States, or whoever,
16 i to make this assessment?
17 j MR. BLOMGREN: I do not, no, sir. I don't; not
1° ; on the total lake.
!9 | MR. McDONALD: Do you think this is important?
20 j| MR. BLOMGREN: It certainly has to be taken into
21 ;i account.
22 !i MR. McDONALD: Do you think it is an essential
2*5 !
J \' ingredient of information that the State of Illinois should
•o i i,
^ ;| have to assess the large volume heated discharge into the
25
i lake — a volume such as represented by the Zion plant? Or
-------
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
709
W. Blaser
do you think, in the alternative, this should be decided just
on local environmental damage?
MR. BLOMGREN: I think from what we know today
it has to be handled on the basis of local improvements,
but there is no doubt that the total effect has to be con-
sidered.
MR. BLASER: May I add to that? As I understand
it, if there is local — first of all, we do have the
requirements that if there is local damage, we would require
of the plant backfitting. Second, we have the survey going
on — not the physical but the aquatic biology — to give
us a benchmark against which to measure. We have proceeded
to do that and we anticipate doing that.
Should we find local damage, obviously backfitting
would be required. If anyone has evidence to lakewide
damage, obviously that would also require backfitting.
MR. McDONALD: When you say you would require
backfitting, Mr. Blaser, what do you mean? What would be
your criteria for assessing that backfitting would be
required at Zion if the plant proceeds without damage?
MR. BLASER: I think the heart of your question
is: What is significant ecological damage; what is, in
effect —
MR. McDONALD: No. My question is: What criteria
-------
7
710
-, i W. Blaser
ii
j __. what parameters are you going to use so that you can make
a judgment that would trigger a backfitting directly to the
company?
MR. BLASER: Well, I may not have made clear the
limitations of our agency. Essentially what evidence we
have would relate to the Pollution Control Board.
MR. McDONALD: I am sorry, I didn't understand
9 | that. Would you repeat that, please?
10 MR. BLASER: The evidence that we would have would
11 ;, be laid in front of the Pollution Control Board. It is
12 I1 their judgment as to whether it represents significant
13 enough damage to cause backfitting to be required.
|
14 j MR. McDONALD: Well, let me ask Mr. Currie. Maybe
15 he can comment on what criteria or what parameters the Board
1,6 could take under consideration to make this type of judgment
17 || since this appears to be a one-of-a-kind type of judgment
!!
j
18 | that would be made in time.
i j
19 j; MR. CURRIE: The opinion that the Board wrote, in
20 |] adopting the standards, goes into some detail in discussing
j
21 the types of damage which can occur from the input of heat
I
22 ji to the lake. We would, of course, be looking for evidence
23 j] of that kind of damage or any other kind of damage that
might be presented if a case were brought to us under this
provision.
-------
711
W. Blaser
2 I don't think it is possible, at this point, to
3 speculate with any degree of concreteness as to exactly how
many fish would have to be found to be killed, over what
period of time, or what degree of increase in the production
of undesirable algae in order to trigger a backfitting re-
quirement. For this reason, the regulation was left very
general. It speaks in terms of significant ecological
9 | damage. We would want to know the number of fish killed.
I
10 We would want to know the amount of effect on algae. We
11 would want to know the size of the area affected. Any
12 facts which would be brought before the Board would be con-
13 ! sidered by the Board in determining whether or not the
damage done was significant.
MR. MCDONALD: Was it the Board's intent at the
time you passed that regulation to impose some of these
17 self-monitoring requirements, such as fish kills, entrap-
ments, upon the company itself to report to the agency?
Was that part of your hearing consideration?
MR. CURRIE: What the regulation says on that is
O"I
that the company shall submit such reports as will be re-
II
22 l
quired by the agency because we felt they were in a better
23
position to determine than we were precisely what kinds of
2L
reports they needed in order to help them perform their
25
surveillance function. We certainly contemplated that the
-------
7
3
10
11
12
13
14
712
W. Blaser
agency itself would conduct whatever surveillance on its own
it felt necessary to see to it that the company was giving
all of the relevant information.
MR. MCDONALD: Does the Board itself in Illinois
have any responsibilities on a question like this regulation
to ensure itself that the agency will accumulate the
necessary evidence, or is your responsibility done when you
pass your regulation?
MR. CURRIE: I think one could say that the Board
has a continuing responsibility to consider whether or not
the regulation is adequate, and if there is some way it
comes to our attention that inadequate information is being
gathered as a result of some provision of the regulation
15 ; not being strong enough, then we would undertake, on our
16
17
IB
19
20
21
own, to the extent that we have had the necessary informa-
tion, to change the regulation.
But, basically, once the regulation is passed,
the enforcement of it is left in the agency's hands and we
don't act again until and unless someone brings a case
before us for enforcement of the regulation.
22 | MR. McDONALD: Is there any ability to act on your
70
"~J ' own initiative in a case of sufficient magnitude?
?L
; ME. CURRIE: Not with regard to enforcement, no;
25 !i
, with regard to the amendment of the regulations, yes.
-------
713
1 W. Blaser
2 MR. McDONALD: Thank you, Mr. Currie.
3 MR. BLASER: Might I add that the Board can
4 request information from the studies and they have done
5 so in the past in other matters.
6 MR. McDONALD: Would it be possible for your
7 agency, Mr. Blaser, to make available to the conferees
8 within the next week, the full extent of the monitoring
9 program and reporting program that you have imposed upon
10 the Zion facility and the Waukegan plant?
11 i MR. BLASER: This can be done. Some requirements
12 are built into the permit that we issue for the discharge;
i
13 others on an informal basis. We can consolidate both types
14 and provide the information to you.
15 MR. McDONALD: I would be interested in one
16 other item also and that is whether there is any mechanism
17 by which the company will report damages that they discover
as far as the official reporting procedure — that is fish
19 kills that would occur in the vicinity of the plant dis-
charge and any entrainments that might take place — whether
you have any requirements along this line.
22 i MR. BLASER: I would like to review the permit
•* requirements and the informal agreements and consolidate
^ them for you.
2^ i MR. McDONALD: Very good. Thank you.
-------
714
1
2
3
4
7
a
21
D. Comey
MR. MAYO: Any other comments or questions,
gentlemen?
Please go on, Mr. Blaser.
5 || MR. BLASER: All right. The next speaker we have
l!
6 I' is David Comey representing the Businessmen for the Public
Interest. He is going to have to leave. Here he is,
Mr. Comey.
9
10 |l STATEMENT OF DAVID DINSMORE COMEY,
I ! *
i
11 jj DIRECTOR OF ENVIRONMENTAL RESEARCH,
12 11 BUSINESSMEN FOR THE PUBLIC INTEREST,
13 i| CHICAGO, ILLINOIS
14 j
i i
| j
15 !! MR. COMEY: A little while ago there was a voice
!i
16 ;j from the audience and when asked who it was, he said,
17 || "Henry." That was Henry the Eighth: (Laughter)
i
13 !• I would like to begin by correcting one item on
19 ! the record. On pages 14 and 15 of the EPA statement this
20 i morning, there is a lawsuit identified as Businessmen for
the Public Interest versus the Atomic Energy Commission.
22 jj The correct name of that suit is David Dinsmore Comey versus
-^ ij the Atomic Energy Commission. It has a nice David and
2^- i; Goliath ring to it. (Laughter)
2 S !
J i The last time I appeared before the conferees was
-------
715
D. Comey
in March of 1971, at which time we had just concluded an
agreement with the Consumers Power Company to install cool-
ing towers at the Palisades plant. At that time, I indicated
5 that it might be necessary for us to enter into further
6 proceedings, and we were obliged to, in the case of Wisconsin
7 Electric Power. We filed an intervention on the 5th of
8 April of 1971, That proceeding is still going.
9 The company received a 20 percent license in
10 June, which was stayed by the United States Court of Appeals
11 for the Seventh Circuit. The plant is now operating at 20
12 percent power since the end of July. However, the matter
13 is on appeal before the Appeal Board of the Atomic Energy
14 Commission, and based on recent oral argument, the license
15 may be removed,,
16 I bring this up because an outgrowth of the Pali-
17 sades case was the Calvert Cliffs decision. The briefs in
that case were written by the Palisades lawyers and, as you
19 know, the Atomic Energy Commission was severely called down
20 for its environmental policies with respect to not only
thermal pollution but the general effect or the environmental
effects of powerplants.
23 What we have found in the long protracted hearing
before the Atomic and Safety Licensing Board in the Point
* Beach case is that the power company there — Wisconsin
-------
716
1
3
4
5
6
7
8
9
10
ii
12
13
15
16
17
18
19
20
21
22
23
24
D. Comey
,, Electric Power —- like all of the other power companies
is stating and attempting to prove that "there is no evi-
dence of significant adverse effect" upon the environment
from the operation of the plant, at this point.
I would submit that a man sitting in a room with
his eyes screwed tightly closed also would be unable to
observe any evidence.
"Wisconsin Electric Power tried to prove that it
would have no significant — the plant would have no signi-
ficant adverse effect and was unable to do so at the hearing
in June in Milwaukee. They essentially depended upon a
$15,000~a-year study. And I might point out the reason I
mention the cost of the study was that at the same time, they
were spending over $1 million a year on advertising! and
one year they spent $26,000 for a political lobby; so this
gives you some idea of their priorities about Lake
Michigan.
The Atomic Safety and Licensing Board, on the
basis of the evidence, decided that no weight could be
given to that study; just wasn't enough. The Board, for
some reason, decided that the literature survey that the
Atomic Energy Commission staff had made was sufficient to
license the plant. That is now the subject of the appeal.
I would like to point out though that the Board
-------
717
1 D. Comey
2 did order the applicant to do surveillance, and the testimony!
3 that we heard in August in Milwaukee was that the cost of
4 that surveillance at the Point Beach plant for the first
5 year may approach the order of $1 million.
6 Now, there is a big difference between $15,000 a
7 year and $1 million. You can do a lot more research. But
the utilities, despite all of their protests about "there is
9 no evidence" have not been doing any significant funding of
10 research to determine whether or not there are any signi-
11 ficant effects.
12 Consequently, I find that much of the testimony
13 which comes in, in these cases, and which you are about to
hear from Commonwealth Edison — I have read it — really
15 has a very, very thin data base.
I think it is also interesting to notice that Dr.
Stoermer — although he testified at the Point Beach hearing
that as far as he was concerned the Point Beach study was
sufficient to warrant licensing of the plant — in a
!! memorandum, which was found later, that had been written
prior to the hearing, Dr. Schneider had recommended to the
22
1 Atomic Energy Commission that the study was not sufficient,
and had indicated also that he thought the AEC ought to
tell it like it is in its Environmental Statement. Dr.
25
Schneider's remarks were not incorporated into the
-------
D. Comey
Environmental Statement because generally no adverse comments
are included in these statements,
2. ' I have been reliably informed by people at Oak
" i
Ridge that Lester Rogers, who is the head of the AEG Division
of Environmental Surveillance — or whatever it is called —
7 systematically edits these things out. One of the most
frequently edited words is the word "not," such as in the
9 phrase, "The applicant's program is not sufficient."
10 (Laughter)
]
11 As a result of a decision which was reversed, or
12 | a decision which was actually on appeal from the Appeal
j
13 Board, we are now able to subpoena people from the National
14 Labs who prepared these reports for the Atomic Energy Com-
i
15 mission. If there are any Argonne people here, I would like
i
16 to tell you that in the case of Zion and Kewaunee we will be
17 seeing you
I might point out also that in the Palisades
-L9 Environmental Report, which was not prepared by Battelle or
20 t>y Argonne, but which was prepared by Oak Ridge — a truly
I
21 ; competent organization — that the Environmental Report said
that the environmental studies that had been done at
Palisades were clearly not sufficient. Now it was rather
interesting for the regulatory staff of the AEC to take that
! position in the Palisades case because Palisades had already
j i
II
-------
10
11
12
13
14
15
16
17
13
19
20
21
23
719
D. Comey
agreed to build a cooling tower, so that the staff was safe
in actually revealing the rather shabby study that was done
on that.
Now the AEG had the nerve today to say that they
welcomed input. 1 noticed that they confined it to the
Federal agencies and to the State agencies. I might point
out that they ignored the public.
wfhen we put in rather lengthy comments — I think
some 145 — rather specific comments on the Point Beach case,
on the Environmental Report, the Atomic Energy Commission
refused to print them and react to them, as they are
statutorily required. They said that they were litigation
documents, that they were not required to intervene.
That is what I would characterize as metahypocrisy,
that is a hypocrisy piled on top of a hypocrisy.
In effect, what I am saying is that if the con-
ferees sometimes think that the AEG can be trusted to pro-
tect the environment of Lake Michigan, they are dead wrong;
the record is quite the opposite. And I am not so sure
that we can trust the States either.
op
^ ' Mr. McDonald said that had the original mixing
zone criterion been 99# feet, it would have appeared that a
P i
great deal of thought had gone into that, which is why, when
25
I saw the 3»400 foot requirement in the Michigan order, which
-------
3
4
5
6
7
9
10
11
12
________________________________________ _ _______________ 720
D» Comey
was published December 17 of 1971, I thought, "That is a very
unusual figure." It says, "Waste discharges to Lake Michigan
shall be treated or controlled in such a manner and by means
of such facilities that they shall? Not increase the natural
temperature of the lake at the edge of the mixing zone, which
shall not exceed an area equal to the area of a circle 3,400
foot radius by more than 3° F. . ••"
I thought, "That is a very interesting number,"
i mean it is not a multiple of pi, and it is not a natural
number, and I thought I had seen it before. So I did some
looking around, and I examined the document entitled "The
13 I Donald C. Cook Nuclear Plant Supplementary Environmental
Report, Indiana-Michigan Power Company," and there in that
15 document I found at page QC 3-6 calculations showing that
the maximum area that the Cook Plant 3° isotherm would occupy
was the area of a circle with a radius of 3,400 feet.
--° ' So I draw my own conclusion about how Michigan's
jl
-l^ ;! thermal criteria was reached.
i I would like to point out also that I have noticed
today in Mr. 0. K* Petersen's testimony for Consumers Power
'^ ;i Company, on page 6, that they estimated the total cost of
93 'I
*"' equipping their 7,500 MW electrical system with cooling
*~>\
\
i
! $32,000 per MWE.
tower, and it comes out to $244 million. That works out to
i
25
L.
-------
1
2
9
10
11
12
13
14
15
16
17
19
20
721
D. Comey
I notice in Mr. Butler's testimony, which he is
about to give, that their cooling tower at Zion is going to
cost them $124 million for a 2,200 MW plant, and that is
about a $56,300 per MWE.
Since I think that both of those figures are
abominable, I would really suggest to the utilities that
if you are going to dispense money you ought to get together
on it.
I would like to end by saying I don't think there
is any evidence that no significant harm is going to be done
to the lake by the powerplants that are scheduled to go into
operation. That is one of the reasons we have intervened.
I am not so sure there is evidence that there is
going to be harm. All I would say is that I am not sure it
is a scientific decision.
Dr. Charles Coutant, of the Oak Ridge National
Laboratory, the AEC's expert on fish, appeared as our wit-
ness — the intervenor's witness — in the Point Beach
case. And he said that if you wanted t-o solve the thermal
21 I problems, that you should build closed-cycle cooling systems,
22
23
24
and he said it wasn't a scientific decision; it was a social
decision.
And I agree with that, and that is what these
conferees have got to wrestle with. Thank you,
-------
722
1 0. Comey
j j
2 I MR. MAYO: Any comments or questions, gentlemen?
I
I
3 Mr. McDonald.
4 MR. McDONALD: How many cases, Mr. Comey, has
5 BPI intervened on Lake Michigan?
6 MR. COMEY: Well, the Atomic Energy Commissioner
7 has not responded to our petition to intervene in Point Beach
1, Kewaunee, Zion 1, Zion 2, Cook 1, Cook 2, so I am not in
a position to say. "We filed a petition to intervene that
10 | ran to something like 300 specific contentions. My guess
i
11 is that we will be admitted.
12 [ We are presently involved in the Bailly Nuclear
i
13 j Generating Station construction permit hearing, and also in
i
14 the Point Beach Unit 2 operating losses hearing. The
15 - Palisades matter we are still a party to, but not active.
i i
16 ! MR. McDONALD: Is it BPI's intention to intervene
17 : in every case?
|
1^ li MR. COMEY: Well, in effect we have, yes. There
j i
11
-L9 i are no other reactors that we have located at least yet.
20 j: MR. McDONALD: Is the main thrust of your inter-
21 f vention what you summed up in your last minute or two?
22 MR. COMEY: Oh, no. The main thrust of our inter-
vention is that these nuclear powerplants are incredibly poorly
built| the applicants do not have sufficient technical
knowledge to operate them safely; and that the design of the
-------
723
1 D. Comey
2 plant is seriously deficient so that there is a grave risk
3 that there will be accidents which will kill millions of
people. That is the more important aspect of our inter-
5 vention.
6 MR. McDONALD: When you talk social risk, you
were talking about heated discharges. Do you have anything
else that you will be presenting at the interventions
9 | besides this social thrust?
10 MR. COMEI: Oh, yes. 1 think we will probably
11 have witnesses rather like we had at Point Beach, where we
12 brought in Dr. John Bardach from Hawaii, and Dr. John
13 Neess from the University of Wisconsin. And if Mr. Mayo
14 will authorize his use again, we will have Dr. William
15 Brungs of the EPA who, I might add, I'd like to thank the
EPA. He was a very convincing witness. He wouldn't say
17 all of the things we wanted him to say, but he sure was con-
l A
-1-0 i vincing.
19 | MR. McDONALD: Thank you.
i
MR. MAIO: Any other comments or questions,
gentlemen?
22 Thank you, Mr. Comey.
23 MR. COMEY: Thank you.
2.L
* MR. BLASER: The next witness we have from
i
25 I
Illinois is Mrs. Lee Botts of the Lake Michigan Federation.
-------
2
3
4
5
6
10
11
12
13
14
15
16
17
724
L» Botts
STATEMENT OF MRS. LEE BOTTS,
EXECUTIVE SECRETARY.
LAKE MICHIGAN FEDERATION,
CHICAGO, ILLINOIS
7
MRS. BOTTS: Thank you.
I would like to express appreciation to Common-
j wealth Edison for agreeing to allow the citizens of Illinois
j
to proceed this afternoon. We had a number of people here
yesterday who were not able to return from out of State,
but we appreciate being allowed to enter statements on behalf
of a number of people who have had to leave today.
I will submit for the record a collection of
letters received by Mrs. Angela Pieroni, who appealed
through Letters to the Editor in Chicago papers for expres-
sions of concern about the lake for her to submit to this
19 ;| Enforcement Conference.
20
21
4 *
25
I have also submitted written statements from
Jack Berghoff, an attorney, who lives in Chicago and has
i
i a summer home near the Cook plant in Michigan, expressing his
' concern about the potential thermal pollution of the lake;
and from Mrs. Gloria Bateman for the Conservation Committee
I
i of the South Shore Commission, a community organization in
-------
725
1 L. Botts
2 Chicago, which represents 90,000 residents. Copies of those
3 statements and of the letters have been made available to
4 the conferees.
5 (The documents above referred to follow in their
6 entirety.)
7
a
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
-------
„.. -"L.WIO;! OF POSIT ion PAPER OF SOUTH SHORE COMMISSION
Aj LAKE MICHIGAN EXFORC&lSllT COUFEEEI1CE ,,, September 211 1972
Tr.is statement is submitted or. behalf of the Conservation Committee of the
South Shore Conrmission^ which represents 90^000 residents of this lake front
community in the city of Chicago.
Lake Midriiywi has always shaped the d&»iiny and defined the quality of
life for- those persons living along its shores* and its influence has been
most dramatic at the southern tip of Lake Michigan where our community resides,
-------
of 2 pages ,,. (Presentation of Position Paper of South Sliore
We are well aware that atomic energy is the energy of the future, f/e are
not here to fight progress^ but we want assurances that technical progress
will not endanger the quality of our lives or the enjoyment of our natural
resources. We are much concerned about tne promiscuous use of these resources
by industry,
Ve would, there fore t present the following recommendations for your
consideration:
I - We request the banning of new power plants crn the lake,
2 - We urge State legislation and enforcement of the guidelines and
recommendations of the EPA banning thermal discharges in the lake
by existing power plants.
3 - We recommend the appointment of interstate agencies to ensure
formulation of uniform legislation protecting those areas and
resources commonly held and enjoyed by two or more States,
4 - fife request greater cooperation on the part of industries to seek and
implement ways to further their development without sacrificing
our natural resources.
We join with the Lake Michigan Federation and other conservation
organizations in insisting that the public be kept fully informed and included
as a participating body in future planning of nuclear power plant installations
in the Midwest,
Respectfully submitted by
The Conservation Committee of the
SOUTH SHORE COMMISSION
pert Mrs, Harry Goldert Chairman
6843 South chappel
Chicagot Illinois 80849
(DO 3-8288)
-------
LAKE MICHIGAN ENFORCEMENT CONFERENCE
STATEMENT OF JOHN C. BERGHOFF
THERMAL STANDARDS
SEPTEMBER 20, 1972
My name is John C. Berghoff. I have spent most of my
years living near or on the shoreline of Lake Michigan, in the
States of Illinois, Indiana, Wisconsin and Michigan. For the
past ten years I have owned lakeshore property in Michigan and
have spent ray summers there. I speak on my own behalf and on
behalf of many other shore property owners in and near Bridgman,
Michigan.
I wish to record my strong feeling in support of the
proposed thermal discharge standards adopted at the March 1971
Conference. I strongly support the effort to prevent deteriora-
tion of the quality of our natural resources rather than later
seeking to repair the damage done.
I have no quarrel whatsoever with the nation's need
for more electrical energy nor with the concept of nuclear plants
as a means of providing this additional energy. I do strongly
object to the way in which the power companies seek to use
natural resources such as Lake Michigan as private industrial
waste ponds. I resent their arrogating the waters of the Great
Lakes to themselves as though they had bought and paid for them,
as though there were no future generations with which to be
concerned.
The nuclear plant with which I am most familiar is the
one now being built on the lake shore at Bridgman, Michigan - the
Donald C. Cook plant. To permit a plant the size of this one to
draw two billion gallons of fresh, cold Lake Michigan water each
day, use it as a,coolant in its nuclear processing, and spew it
back into the lake daily some 20 degrees warmer than when it was
withdrawn is simply unthinkable in this day and age. The American
Electric Power Company has announced that this plant will cost
almost $600 million, yet this company is resisting the obligation
to spend an additional fraction of that investment to moderate the
extreme elevation of its proposed waste waters, or for that matter,
to assure zero or near-zero radioactivity of the water which it
will pour into the lake.
Those of us who have enjoyed the clear waters of Lake
Michigan through the years and xvho have noted the unmistakable
decline in its quality recently are shocked that the federal and
state authorities are seriously considering surrendering their
public responsibility before the arrogant demands of the power
companies. No plant the size of the Cook plant should be per-
mitted to commence operations without reasonably moderating its
thermal discharge.
-------
-2-
In my view the interests of the little people will be
best served, and I believe of the power companies as well, long-
range, by adopting and enforcing uncomplicated, reasonable but
firra thermal standards. These should apply to all power companies,
includin/l those who have balligeren/cly proceeded with plant
con"s_t_ruction in total disregard of the ecological dimensions and
aespite the clear warnings raised at least two years ago that
thermal standards would be adopted. In this way the government
will have lived up to its responsibility to meet the need for
expanding electrical energy without permitting irreplaceable
natural resources to be ravaged in the process .
Thank you.
Respectfully submitted,
sfvf~~\/)
* /
-------
LAKE MICHIGAN FEDERATION
53 West lackson Blvd. Chicago, Illinois 60604 I (312)427-5129
September 28, 1972
Mr.. Lee Both
Executive Secretory
Chicago, Illinois
EXECUTIVE COUNCIL
Vance Van Laanen
Prefi'denf
Green Bay, Wisconsin
Harold B. Olin
Vlce-PresJaW
Beverly Shores, Indiana
John K. Langum, Ph.D.
Vice-President- Treasurer
Chicago, Illinois
Lewis Batli, Ph.D.
Secretory
Kalamazoo, Michigan
Mrs. Jean Bonynge
Wilmette, Illinois
Gordon Carr
Grand Rapids, Michigan
Mrs. Louise Erickson
Racine, Wisconsin
Paul Goodman
Evanston, Illinois
William A. Kern
Fort Wayne, Indiana
Mike Love
Chicago, Illinois
Ted MacDonald
Lafayette, Indiana
Charles E. Olmited, Ph.D.
Chicago, Illinois
Mrs. Louise Rome
River Forest, Illinois
John P. Sharon
St. Joseph, Michigan
Mrs. Sylvia Troy
Munster, Indiana
Steven Winter
Two Rivers, Wisconsin
Glenn Pratt
Enforcement Division
Region V EPA
1 North Wacker
Chicago, Illinois 60606
Dear Mr. Pratt:
Enclosed are copies of statements to be included in the
Lake Michigan Enforcement Conference record (as verbally
indicated in the record — these are private citizen statements) ,.
As indicated to Mrs. Botts' letter of this week, we may
have additional input in the form of technical statements.
If we do, that information will be sent prior to your
one-week extended deadline on closing the conference record.
Thank you for your cooperation in connection with these
statements ,
Sincerely,
Miss Nancy Flowers
Information Director
HF:lm
encl.
Alternates
'•alls
eler, Indiana
Arnold Leder
Kalamazoo, Michigan
Contributions are tax deductible
-------
Sept.
LAAJ 1'ilCiiIGAN
Sherman Hotel - Clark & Randolph., Chicago, 111.
Bac Arabrian Room - 6th Floor
Gentlemen:
wish to take this opportunity today, to ask some questions which are
pertinent, not only to me, but to thousands of other people who are deeply
concerned with our total environment.
Hot water by the billions of gallons is the main issue today. The environ-
mental problems, and supposed progress is one of the questions!
Not what government and state officials wants the public to believe, but
the actual truth. Especially for water pollution.
A lot has been said since 1970, but very little has been done. Lake Michigan
for instance. We still have most of the same old inadequate laws.
Lake Michigan does not appear to be any better today, than a year ago, yet;
state and federal officials say it has improved. To what! To becomming
a sewer?
At last years conference the people from the federal government publically,
tool-: a tough stand on the thermal question, asking states to adopt strict
standt3rds. Only Indiana of the four states around the lake agreed with
the federal proposal. Now the federal government must go to court to
enforce its proposal, or try for state agreement on a different version.
At that time, the federal government proposed one, new regulation, "keep waste
heat from nuclear plants out of the lake".
Uimt happened? Now the federal government is trying to back down from the
orq_ new regulation itself proposed. Why?
Today, federal & state officials are here to reopen the argument over waste
lioat, that the public was lead to believe, was settled back in March, 1971.
At that time, you people said, "waste heat from nuclear plants ought to be
kept out of the lake to avoid any risk'of adding to lake pollution".
But now, the Atomic Energy Commission, & the Utility companies, seem to think
that Lake Michigan should be used as a heat sink, and dumping grounds for
all its wastes. Why?
J?or instance, the Zion Illinois Nuclear Power Plant. Construction is almost
completed, but no provision for cooling towers or lakes are in the building
lans. '.Thy?
A Thermal standard for today is a question for the future. Most conservation-
ists believe the future of Lake Michigan is at stake, and far too important
to risk with thermal pollution.
An ounce of prevention, is worth a pound of cure.
True, we cannot protlfe absolutely that the heat will damage the lake, but
the power companies cannot disprove it. _eit her.
-------
There is little conclusive evidence about the effects of thermal pollution
in the lake. But the question is, "should we go ahead and discharge heated
water in nuch greater quantities into the lake, and take a "wait and see
what happens attitude"? Or should we wait until conclusive evidence is in,
one way or the other?
The little evidence that is available on the effects of thermal pollution
has been financed by the power companies, and their findings are biased to
their benefit, and not the benefit of the public at large.
Are we to accept this evidence as absolute fact, without government studies
to check its accuracy?
The federal government has known for some time now that there is a great
need for this kind of evidence, and since they admit the need, why has'ent
the government taken it upon themselves to do the research?
I wish to read a statement made by our Pre.sident, which was printed in Pocus—
Chicago Today newspaper, Sunday, March 1, T970.
Quote—"Here is one area where we cannot wait...if we do not act now it will
be too late, possibly ever to act again".
President Nixon in a keynote speech to the National Governors conference
in Washington on the importance of improving environmental conditions,
especially the pollution dilemma.
The question of 'money always arisesi Our President signed several bills
that allocated millions of dollars, and entrusted the states with these tax
dollars, to help eradicate the pollution problems that are besetting us all,
as soon as possible.
Yet, how much is really being done?
I cannot, and am not, qualified to discuss other states, but I wish to discuss
uy own State of Illinois, not only from what I read about, and what I hear
about, not only from people in my own city, but from people throughout
the State.
"Je are taxed beyond endurance. But yet, if our tax dollar was spent for
what it was deemed for, that would be another story.
The 77th General Assembly, of the State of Illinois, passed House Appropria-
tions Bills Wo. HB-1670, 16?1, 16?2.
Tne Environmental Protection Agency was awarded 49,4-17,900.00 - Pollution
•Joutrol Board - ^673,300.00 - Institute for Environmental Qualtiy -
,?2,045,000.00,, for pollution control enforcement, for the year July 1st, 1971
ending June 30th, 1972. This money not only included the pollution enforce-
ment programs, but also salaries, etc. A total of $12,136,200.00.
Also; in addition, House Bill #1754, to thetune of #1,000,000.00 was
-appropriated to Attorney General Scott's Environmental Protection Division,
from the state, in addition to a federal grant of $250,000.00.
Of course the $1,000,000.00 includes salaries, travel expense, etc.
But, Atty. Genl. Scott, spends the federal grant money how he sees fit, and
accounts t,o no one as to where this $250,000.00 goes.
-------
Page - j> -
As a taxpayer I have the right to know just how and where my tax money is
going.
I was appaljed to see how the Attorney General wastes the taxpayers money,
he who is chiefly responsible for initiating, filing, and prosecuting
.aw suits, to halt the desecration of our environment by the offending
polluters.
~ii the last three years, he spent $650,000.00 of the taxpayers money on
"urniture and fixtures. Over $110,000.00, for carpeting alone. Is this
what you call money wisely spent?
But most important, we taxpayers who believe we are paying for work being
done to correct the horrendous pollution problems of our state, also pay
for his public relation expenditures in excess of $120,000.00 a year.
This is ludicrous.1
These facts are a matter of public record in the State Auditor of Public
Accounts Office, and the Bureau of the Budget, in Springfield, Illinois.
With the millions of dollars spend in our State alone for pollution programs,
etc., why is it that we still are plagued with the problem?
This is a sad state of affairs.
Atty. Genl. Scott was elected by the people to serve their interests,
and it is his sworn duty as Attorney General to protect the public's
interest, and serve the people of this state.
In conclusion, I suggest that the politicians stop serving their own
selfish interests, stop catering and pussy footing with industry and
businesses at large, and correct the pollution problems, before it is
to late. Without the life sustaining elements of air and water, we
shall all perish from this earth.
The time is now, for the tomorrows might never come.
Thank you,
0
-------
-\
Ray Lending • Illustrator- 407 Sherman Ave. • Evanston, Illinois • GReenleaf 5-0313
&.< lives, Pcc«Wi '
j
x'»^c
A
V)N)
-V
s
A
— v
-Vo
f *
^
4U.IS
-------
-------
Stl&>~^4/^
' ,^-v~—»_-i*-V
\J <&-»'iJ
-------
0.73V
JUr«rvvx vUXCJU^w-
-------
Sherman Avenue
Evanston, Illinois 60202
August 27, 1972
Dear Mrs. Eieroni:
We have read your letter dated August 21, 1972 regarding
waste heat from nuclear plants dumping directly into Lake
Michigan and agree with you that such continued action is
a serious threat not only to the Lake, but to each of us as
well.
The Federal government's proposal to "keep waste heat
from nuclear plants out of the lake" must not be compromised.
Responsible representatives of local, state and federal gov-
ernments must look to the future, and protect this vital
resource on which so many depend.
Very tnuly yours,
rs. Jonathan R.
-------
*J^~es A^t*f£
%.
/
,
-------
\O
\l
-------
T*
/t<-4r
-------
-------
726
1 L. Botts
2 MRS. BOTTS: I am Executive Secretary of the Lake
3 Michigan Federation, a four-State coalition of citizen and
4 conservation organizations in Wisconsin, Illinois, Indiana,
5 and Michigan.
i
6 My statement has been submitted in full to the
7 conferees, and I have tried to abbreviate it in the interest
of time, and I will not read the statement in its entirety.
9 (Mrs. Botts1 statement follows in its entirety.)
10
11
12
13
14
15
16
17
IB
19
20
21
22
23
24
25
-------
LAKE MICHIGAN FEDERATION
53 West lackion Blvd. | Chicago, Illinois 60804 | (312)427-5129
September 18, 1972
Mrs. Lee Bolts
Executive Secretary
Chicago, Illinois
EXECUTIVE COUNCIL
Vance Von Laanen
President
Green Bay, Wisconsin
Harold B. Olin
Wee-President
Beverly Shores, Indiana
John K. Langum, Ph.D.
Wce-Pre*/denf-Trea«urer
Chicago, Illinois
Lewis Baits, Ph.D.
Secretory
Kalamazoo, Michigan
Mrs. Jean Bonynge
WilmeMe, Illinois
Gordon Carr
Grand Rapids, Michigan
Mrs. Louise Erickson
Racine, Wisconsin
Paul Goodman
Evanston, Illinois
William A. Kern
Fort Wayne, Indiana
Mike Love
Chicago, Illinois
Ted MacDonald
Lafayette, Indiana
Charles E. Qlmsted, Ph.D.
Chicago, Illinois
Mrs. Louise Koir.3
River Forest, Illinois
John P. Sharon
St. Joseph, Michigan
Mrs. Sylvia Troy
Munster, Indiana
Steven Winter
Two Rivers, Wisconsin
A/ternafet
'•alls
.jeler, Indiana
Arnold Leder
Kalamazoo, Michigan
STATEMENT REGARDING CHICAGO-SOUTH END OF LAKE MICHIGAN
REGIONAL WASTEWATER MANAGEMENT STUDY, ARMY CORPS OF ENGINEERS
I am Mrs. Lee Botts, executive secretary of the Lake
Michigan Federation, a four state coalition of citizen and
conservation organizations in Wisconsin, Illinois, Indiana,
and Michigan. This summer I have been serving as chairman
of the Citizens Advisory Committee on Conservation and En-
vironment for the Chicago-South End of Lake Michigan regional
wastewater management study, a position to which I was elected
by members of the committee.
The views expressed here are not given on behalf of the
citizens committee; rather they are my views stated here be-
cause of the impossibility of raising such questions within
the context of the advisory committee under the Corps of En-
gineers prodedures. My views are based on long-term exper-
ience with the Army Corps of Engineers, several years of
acquaintance with the land disposal concepts of Dr. John
Sheaffer „ advisor to the Corps of Engineers, and informa-
tion obtained in connection with the C-SELM study in recent
months.
I am here to question again, as I have at every previous
opportunity, the motives and capability o.f the Army Corps of
Engineers for planning on the scale involved in the C-SELM
study. For the reasons outlined below, I believe that the
citizens of the C-SELM study area should insist that Congress
retuse either to authorize further regional wastewater manage-
ment studies elsewhere or to extend the C-SELM study in parti-
cular beyond its present stage until the essential condition
of local agreement and participation is met. The need for this
condition will be amplified after discussion of my objections
to the C-SELM study as it has been conducted so far. There are
three bases for my objections:
1. The regional wastewater management studies represent
the effort of the Corps to reinforce and extend its authority
over the waterways in spite of the costly, destructive and often
ineffective consequences of use of previous authority.
2. Application of land disposal as the principal means
of waste disposal on the scale advocated by the Corps is at
best premature and at worst involves deliberate deceit to
Congress and the nation.
3. Failure to obtain approval for the study in advance
at the state, regional and local levels demonstrates the Corps'
Contributions ore tax deductible
111
-------
?age Two
greater concern, for perpetuating its own bureaucracy than
genuine concern for dealing with wastewater problems, and
may even impede the national effort in this regard. Let me
elaborate on each of these points.
1 . EXTENSION OF_ CORPS AUTHORITY
Faced with mounting objections to their activities in
flood control that seem more often than not to cause more
problems than they solve and invariably cost more than esti-
mated, and with growing public resistance to pork barrel pro-
jects of all kinds, in 1969 the Corps policy makers eagerly
responded to the idea that they might be able to keep them-
selves in business by taking over the planning necessary to
clean up pollution of the nation's waterways. The possibility
was offered that they could not only keep themselves in busi-
ness by planning for waste disposal on a scale that would
necessarily keep them in the the construction business but
also, according to the author of the scheme, take advantage
of public concern about pollution to fortify the Corps against
possible intrusion by the newly organized Environmental Pro-
tection Agency.
Notably absent from the Corps decision to intrude it-
self into the wastewater planning field was any considera-
tion for the fact that EPA had been set up because of the
failure of previous agencies, including the Corps, to deal
with the problem.
The source of the inspiration for the 'Corps to become
pollution abatement experts overnight was Dr. John Sheaffer,
a water and waste disposal expert who left the University of
Chicago Center for Urban Studies to become science advisor to
the Corps of Engineers.
Sheaffer had gotten his ideas about the possibility of
land disposal of sewage effluents from an experiment under-
way at Penn State University. Throughout the middle sixties
he had been working with William Bauer of the Bauer Engineering
firm in Chicago in designing a large scale application of the
approach in Muskegon County, Michigan. About the time the
Muskegon project received the go ahead, Sheaffer convinced
the Corps they could apply the same approach on a national
scale, and five metropolitan areas were selected, including
Detroit, Boston, San Francisco, Cleveland and Chicago.
In Chicago, out of the strength of their conviction that
they, and they alone, ought to save Lake Michigan and its
tributaries from pollution, the Corps did not bother to wait
for Congress to give its approval, as required by law. In-
stead of getting Congressional authorization for the study
before beginning it, the Corps convinced itself that waste-
water management ought to involve flood control and invoked
their general authority for that purpose. Apparently to make
some link to pollution, however, they took advantage of the
-------
existence of previous authorization for another study Dr.
Sheafferhad also proposed in the name of fighting pollution
and used it as authorization to begin the regional waste-
water management study. Thus the Corps used a 1969 reso-
lution requested from Congress to authorize a feasibility
study for a dike system across the lake to begin a 1971
feasibility study of application of land disposal to waste-
water management. Eventually the Corps did obtain authori-
zation for this specific study, but not until it was well
along. How they obtained the authorization brings me to the
second point.
2. MISLEADING CONGRESS
The Corps says now, whenever aksed why they are making
the regional wastewater management studies, that they are
only doing what Congress asked them to. In their version,
Congress asked the Corps to determine whether zero discharge
of pollutants into waterways could be obtained by any means,
and to compare the costs.
Congress was and is, of course, concerned about the
public demand for cleaning up the waterways. Both Congress
and the White House, and especially the latter, are worried
about the cost of meeting the public demand. They provided
a willing audience to Dr. Sheaffer's assurances that an
almost magical solution was at hand and that the Corps of
Engineers could provide the means of achieving it.
To some members of Congress, those who were most critical
of the Corps' use of previous authority, Dr. Sheaffer argued
that putting the Corps into the pollution abatement business
would somehow transform the agency. Even many conservationists
were convinced by his rhetoric about recycling wastes and
failed to protest writing
funding and authority to support Corps develop-
ment of land disposal plans into proposed water pollution control
legislation.
To Congress, the White House and the conservationists,
Dr. Sheaffer cited the existence of the Muskegon County
project as proof that land disposal is a viable idea. What
he neglected to tell them except when pressed was that the
Muskegon County system was and is in the process of construc-
tion. Above all, he failed to make clear that conclusions
about the success of Muskegon County are premature to say
the least.
Later, that is more recently, in response to questions
about that fact, Dr. Sheaffer and the Corps have sought
confirmation of their approach from other sources, looking
world-wide for examples of land disposal of sewage to which
to point. Most conspicuous among the examples cited is a
municipal project at Melbourne, Australia, but here as well
as elsewhere, Dr. Sheaffer and the Corps do not dwell on
the difference in scale between what has already been done
successfully and what they are proposing to do.
-------
Page Four
At Pe^n State, for example, the treated sewage from the
university containing no industrial wastes has been sprayed
on several hundred acres for 10 years, with careful monitoring
of the results. There, it is interesting to note, and
unlike in the C-SELM study, the sites for spraying were
carefully selected after extensive geological and hydrological
studies. Results have been most encouraging, while suggesting
some fr.ctors that must be given careful consideration.
The Penn State experiment shows, for example, that zero
discha^^e of pollutants canrot be achieved with spray irriga-
tion, lor soluble nitrates do get through the so-called
living filter of the soil. At a recent technical symposium
which I attended, this factor was mentioned again and again
as one needing the most careful management. Nor has the
Penn State sudy provided assurances that heavy metals and
toxic substances can be dealt with more easily in such a
system, for the effluent contains onlv ft aces of either.
In Melbourne, raw .sewage, not treated effluent, is
flooded onto publicly controlled farm land in a region where
the annual rainfall is approximately 20 inches. This
experience surely does not answer
how to determine the ability of soil in Indiana and Illinois
to deal with urban effluent, a question that the Corps did
not determine in selecting or proposing the sites designated
in its C-SELM study. Indeed, this fundamental qestion was
treated in one meeting of the Citizens Advisory Committee
for Industry and Commerce as question of technique and not
of feasibility; in other words, such essential questions
would be answered later and the study was proceeding on the
assumption that suitable answers would be found. This,
unfortunately, is all too reminiscent of the Corp of Engineers'
approach in the past. It does not suggest that the anti-
pollution Corps is any different from the dam-building Corps,
which brings me to the third point.
3. CORPS HINDRANCE OF WASTE TREATEMENT PLANNING
The fact that the Corps is carrying on its wastewater
management studies out of concern for its own perpetuation
is demonstrated by the failure to obtain the most essential
ingredientfor any planning effort, that is, local agreement
to participate. What is happening with the C-SELM study now
in Indiana shows how such a short-sighted approach can actually
hinder progress toward planning for broader and better sewage
disposal systems.
The C-SELM study was launched unilaterally by the Corps
of Engineers, without agreement to participate much less
invitation to do so by the states of Indiana and Illinois, by
reigonal planning agencies like the Northeastern Illinois
Planning Commission, or by operators of municipal sewage
treatment facilities. Further, the Corps disregarded other
or on-going pollution abatement plans except to indicate that
-------
Page five
the Corps' plan would supercede them, such as the NIPC regional
waste disposal system and the water quality standards adopted
by the Illinois Pollution Control Board.
While it might appear to one who reads the Corps reports
but has no first hand acquaintance with the actual situation
that the Corps is consulting local authorities through its
steering and advisory committees, in fact the activities of
these committees appear to be a paper exercise. Consider,
for example, the fact that the steering committee did not
meet between February and early summer, and the fact that
the Corps called a meeting for tomorrow morning when the
Lake Michigan Enforcement Conference is being convened. No
consideration was given to the participation of the state
and many municipal officials in the enforcement conference.
The disregard for the local planning efforts is parti-
cularly flagrant in the C-SELM study area among the five
now underway, for in truth, land disposal is being tested by
another major agency, the Metropolitan Sanitary District
of Greater Chicago. In this area, at least, the Corps cannot
claim that it was justified in undertaking the study of land
disposal to show that it could be done. The
Sanitary District is already showing how it is possible to
work with local interests in the land disposal site in its
Prairie Plan in downstate Illinois.
By its willingness to accept limitations imposed by the
local authorities in Fulton County, including willingness to
pay local taxes, the Metropolitan Sanitary District may, indeed,
demonstrate the feasibility of land disposal for at least a
partial solution to the problem.
By its headlong and heedless push to impose land disposal
as the all-purpose solution, the Corps of Engineers may delay
its acceptance through the hostility it arouses by its failure
to take first steps first. By failing to determine the
suitability of the major site, it proposes to use in the
C-SELM project, the Corps has aroused opposition to the idea
of land disposal anywhere at all throughout the State of Indiana.
Last week 1,250 persons demonstrated their unwillingness
to accept the Corps' idea of land disposal and their intention
to reject altogether any experiment with land disposal as a
technique. Some of them are here tonight out of their deter-
mination to protect their homes and their land by opposing
water pollution control legislation that would fund exploration
of land disposal as a technique.
For myself, as the result of investigations of the possibi-
lity of land disposal that have gone far beyond any information
made available by the Corps, I urge that it not be rejected
out of hand. I have learned nothing that convinces me that we
are ready yet to apply this approach nation-wide when we do
not even know yet whether Muskegon County will work. But I
-------
Page Six
am convinced that the Corps' use of land disposal for its
own short-sighted goals is at fault more than the idea itself,
an idea that is almost as old as agriculture itself.
Therefore, I urge that our friends in Indiana who fear
the consequences for their land of the C-SELM study and
member of the public who share my unwillingness to put water
resource planning into the hands of an agency as heedless
of local concerns as the Corps of Engineers to join together
to make certian that the C-SELM study does not proceed
beyond the end of its present stage. That is, Congress
should not fund implementation or more studies until and IF
the states, the counties, the regional planning agencies and
the municipalities all agree that they need and want them and
believe the Corps can solve their problems, The Office of
Management and Budget has already directed that such local
approval is a necessary ingredient for any future regional
wastewater management studies. In my opinion Congress ought
to make it a requirement for furthering any implementation
or additional study in the areas where the Corps has already
acted on its sole initiative.
Finally, in conclusion, I urge that the Corps' clumsiness
not mislead us premeturely to discard land disposal altogether.
Rather let us urge our other federal, state and local agencies
to assist and allow those communities that want to try it
on their own to do so, so that we may profit from their exper-
ience. From a few hundred acres at Penn State to the most
industrialized and one of the largest nations in the world is
too big a jump for application of any technology.
-------
LAKE MICHIGAN FEDERATION
53 West Jackson Blvd. I Chicago, Illinois 60604 I (312)427-5129
(v~.. lee Botlt
Executive Secretory
Chicago, Illinois
EXECUTIVE COUNCIL
Vance Van Laanen
Prnldent
Green Bay, Wisconsin
Harold B. Olin
Vlce-Pretfdent
Beverly Shores, Indiana
John K. Langum, Ph.D.
Vie»-Fr»tidtnt-Tr*aiur»r
Chicago, Illinois
Lewis Batts, Ph.D.
Secretary
Kalamazoo, Michigan
Mrs. Jean Bonynge
Wilmette, Illinois
Gordon Carr
Grand Rapids, Michigan
Mrs. Louise Erickson
Racine, Wisconsin
Paul Goodman
Evanslon, Illinois
William A. Kern
Fort Wayne, Indiana
Mike Love
Chicago, Illinois
Ted MacDonald
Lafayette, Indiana
Charles E. Olmsted, Ph.D.
Chicago, Illinois
Mrs. Louise Rome
River Forest, Illinois
John P. Sharon
St. Joseph, Michigan
Mrs. Sylvia Troy
Munster, Indiana
Steven Winter
Two Rivers, Wisconsin
STATEMENT TO LAKE MICHIGAN ENFORCEMENT CONFERENCE,
SEPTEMBER 20, 1972
Alternates
'•alls
Jler, Indiana
Arnold Leder
Kalamaioo, Michigan
I am Mrs. Lee Botts, executive secretary of the Lake Michigan
Federation, a four state coalition of citizen and conservation
groups in Michigan, Indiana, Wisconsin and Illinois.
I am here today to express the dismay of citizens I represent
about the continuing federal policy of evasion on the thermal
question for Lake Michigan. The truth is that this enforcement
conference was called with no intention of making a final
decision on whether waste heat from large power plants should
be dumped into the lake. This enforcement conference was
called in the same spirit in which the thermal question has
been dealt with in the past — not to do it.
In this spirit the Environmental Protection Agency purports to
be considering whether it is necessary to protect the lake
against thermal pollution but actually is weighing the political
pressures. Twice previously it has appeared to the public
that the EPA was taking a decisive, firm position in favor of
protecting the lake. Each time subsequently the EPA has failed
to back up a position made political by failure to support it
with scientific evidence. Thus here again we are confronted
with a most familiar situation: evasion of dealing with an
issue and an almost farcical procedure where the evasion is
confirmed and acted out.
In 1970 and again in 1971 the EPA announced to the world the
means by which Lake Michigan would be protected from possible
thermal pollution, a thermal standard requiring closed cycle
cooling systems. Both times the agency's decisive posture
ended with the announcement of intention. Consider the thermal
report offered by the regional EPA office for this enforcement
conference. It consists of a historical review of the past
failure of the enforcement conferences to deal with the issue
up to the March 23, 1971 proclamation. A supplementary
commissioned report is itself confirmation of the failure to
seek scientific confirmation of the proposed standard. The
report consists of a catalogue of research that in instance after
instance was undertaken by and for the vested interest that
has most at stake in the decision, the utilities themselves.
The evidence and speculation offered by the utilities may be
valid, but the fact of their vested interest puts such research
in a political context. The independent confirmation or dispu-
tation with results of utility research has not been sought.
Contributions ore tax deductible
-------
Almost incredibly, there is still no indication of intention to do
so. If talk and talk alone., or even with chest pounding, would solve
the thermal question, it would have been resolved within the enforce-
ment conference long ago, and we could be moving on to other critical
matters. My purpose today is to urge action on both immediate and
long term aspects of the thermal question.
The first aspect is whether existing power plants, including those
constructed but not yet operating, should be allowed to discharge
their waste heat into the lake. The second is whether additional
power plants should be located on the lake and allowed to discharge
their waste heat into the lake in the future.
PRESENT POWER PLANTS
Whether or not the delay in enforcement action on the federal standard
has been intended to make existing plants a fait accompli, that is
the result, The public is not misled that the federal government
has been powerless in this situation; it is the federal unwillingness
to act for which it will be held responsible. Thus, the Kewaunee,
Point Beach, Zion and Cook nuclear plants have all reached the operating
license stage with once-through cooling systems intact. Any cost of
altering these plants by basic changes now is necessarily enormously
greater that it would have been even two years ago when the federal
government first told us (and already late then) that their waste
heat would be kept out of the lake.
It should now be clear that the enforcement conference failure on
the thermal question leaves the public with the necessity to seek
other ways to resolve it. The Atomic Energy Commission regulations
put the burden of proof for the absence of detrimental effects of
operation of nuclear plants on the applicant. The Calvert Cliffs
decision confirmed the obligation of the AEC to consider thermal
pollution as a possible deterimental effect in its license procedures.
What I am saying is that if the thermal question cannot be resolved
here, it can and will be raised in interventions in the public interest
in operating license procedures. Through the regulatory procedures
of the AEC the inadequacy of environmental studies to date for the
Point Beach Two plant in Wisconsin was confirmed, with the result
that the company is greatly expanding its efforts in this regard.*
The enforcement conference should decide now in this meeting whether
it is more appropriate to deal with the thermal question for the lake
as a whole or whether it must be left to be decided on a case by case
*While the enforcement conference succeeds in passing the buck to the
public and the AEC, its failure to act in its area of responsibility
for water quality will not be forgotten.
-------
basis through interventions in license proceedings.
In demanding resolution of the thermal question within the enforcement
conference, my organization has been accused by many, including
fellow conservationists, of making the thermal question seem to be
the only matter of public concern for nuclear plants. The fact is
that the enforcement conference is the appropriate place under present
law to resolve a water quality question but reactor safety and land
use questions cannot be raised here. Worry about the future of the
lake aroused the public's concern not only about present plants but
even more so about future plants.
FUTURE POWER PLANTS
A decision that the cost to society of back fitting existing plants
is not justified will not answer the question of whether decisions
to locate future power plants ought to be made in the same way
-------
would constitute evidence of damage nor how bad it has to be to cause
a requirement for closed cycle cooling for Zion. Finally, both
Illinois and Michigan are apparently willing to let the utilities
decide not only what to monitor but how.
In this situation the Lake Michigan Federation has attempted in
recent months, as the evasiveness of the federal EPA has made operation
of existing plants with once through cooling almost inevitable, to
address the need for monitoring.
MONITORING FOR THERMAL EFFECTS
We are concerned with biological effects on the lake and with the
engineering of the plants. For help with the former, last spring
we circulated a questionaire to scientists requesting their advice
on the questions that seemed important. It was distributed at the
meeting of the Great Lakes Research Association in April, and also
sent to persons suggested through persons suggested through personal
contact.
We could offer no remuneration except the opportunity to assist
with an extremely public policy question. The results were suggestive
but not conclusive, and yet I hope that by sharing them with you we
can inspire the agencies represented here and the enforcement
conference to address itself to monitoring as the means to put the
thermal question on a scientific and not just political basis.
For help with the engineering questions, we have turned to the Illinois
Chapter of the American Society of Professional Engineers. This
summer their board agreed that it would be appropriate for members
of the society as individuals to offer services to the Federation in
this regard. The board stressed that only persons whose career and
employment were _not directly involved should answer the request, a
recognition of vested interest that was refreshing to say the least.
In this case some individuals have offered their services to us and
are in process of reviewing materials we have submitted. We do not
have results as yet of this effort, but you may be interested to know
that we have particularly asked for technical evaluation of the
predictions of Dr. Donald W. Pritchard based on his modeling of
discharge systems for the Zion plant. The reason for stressing
Dr. Pritchard's work was the questions raised about his assumptions
in the recent Argonne Laboratory report on thermal plume modeling,
and the reliance that has been placed on his predictions by the
Illinois Pollution Control Board.
As for our questionaire concerning biological effects, a copy is
attached with this statement, together with the memorandum and letter
that accompanied it. The single most important conclusion that can
be reached from the responses is that measuring thermal effects is
a complicated process that no one seems absolutely certain how to do.
-------
That is scarcely news, nor an excuse not to do it as the enforcement
conference seems to feel.
Not suprisingly, researchers working for utilities were more willing
than others to make definite statements about a time span needed
for study and to specify parameters. In short, they found answers
easier to come by, which is fortunate to say the least for those
with whom they consult. Mos responses stressed the need for research,
wihch makes it all the more difficult for us to understand why the
government agencies have failed to see that it is done.
One scientist who heads a state agency told us our questions were
ridiculous but did not reply when we asked him please to tell us
what question we ought to be asking. Another scientist confirmed
his ivory tower existence by informing us that we are not using the
service we are paying for from government, urging us to use the
Environmental Impact Statements of AEC and services of EPA scientists
on top of the situation! We have the same problem with AEC impact
statements as with utility-funded research, namely vested interest,
and unfortunately we have not met any EPA scientists we could
describe as on top of the situation.• We do recognize that it is
possible they exist and are muzzled by the apparent EPA determination
to let the thermal situation proceed without direction from that
source.
While no attempt was made to quantify results, the answers to the
questionaires did confirm our suspicions on the following points:
1. Sufficient answers to the important thermal questions
do not now exist in the scientific literature.
2. Most of the research now underway is being funded by the
utility industry.
3. A minimum of five, some believe 10 or more, years of obser-
vation will be required to ascertain the thermal effects.
4. In the short term damage to organd sms by entrainment will
be more obvious than the effects of heat.
5. In the long, term the cumulative effect of waste heat from
many power plants is likely to be subtle changes in the unique
biological character of Lake Michigan.
In conclusion, the Lake Michigan Federation urges that evasion of
action on the thermal question not continue within the enforcement
conference. This action should include establishment of monitoring
requirements for presently existing plants to provide the evidence
needed to deal with the question of future plants.
We asked Dr. Stoermer to come to the enforcement conference to
demonstrate to you that our fears about the lake have a foundation
-------
in fact. Your action now on the thermal question will determine now
whether in years to come we will be identifying results of increase
in the waste heat load on the lake as he identifies now the result
of increase in the phosphorous load. The purpose of the questionaire
was to determine whether we were right in the need for scientific
research. Answers confirmed that a decision cannot wait for final
results of research.
I ask you to consider whether you want to tell your grandchildren
and mine what you did to protect the lake or what you michg have
done. Thank you.
-------
LAKE MICHIGAN FEDERATION
S3 We*t Jackson Blvd. | Chicago, Illinois 60604 | (312)427-5129
A/rernoret
T
V
lilt
A»r, Indiana
Arnold L.d.r
Katamazoo, Michigan
March 30, 1972
M... Lee Boris
Executive Secretary
Chicago, Illinoii
EXECUTIVE COUNCIL
Vane* Van laan«n
President
Green Bay, Wisconsin
Harold B. Olin
Vfce-Pre«idenf
Beverly Shores, Indiana
John K. Langum, Ph.D.
Vice-president-Treasurer
Chicago, Illinois
Lewis Batts, Ph.D.
Secretary
Kalamazoo, Michigan
Mrs. Jean Bonynge
Wilmette, Illinois
Gordon Carr
Grand Rapids, Michigan
Mrs. Louise Erickion
Racine, Wisconsin
Paul Goodman
Evanston, Illinois
William A. Kern
Fort Wayne, Indiana
Mike Love
Chicago, Illinois
Ted MacDonald
Lafayette, Indiana
Charles E. Olmsted, Ph.D.
Chicago, Illinois
Mrs. Louise Rome
River Forest, Illinois
John P. Sharon
St. Joseph, Michigan
Mrs. Sylvia Troy
Munster, Indiana
Steven Winter
Two Rivers, Wisconsin
Sir:
The Lake Michigan Federation is a coalition of citizen
groups in Wisconsin, Illinois, Indiana and Michigan.
It was organized to promote participation in public
policy decisions pertaining to Lake Michigan, its
tributaries and its shores.
The Federation will be grateful for your assistance
in connection with the enclosed materials.
Thank you.
lours very truly,
Charles Olmsted, Ph.D.
Biology Department
University of Chicago
h v^
/nn^^M
Vfrs. Lee^Botts
Executive Secretary
Lake Michigan Federation
Contributions arc tax deductible
III
-------
LAKE MICHIGAN FEDERATION
i*.... Lee Boris
Executive Secretary
Chicago, Illinoii
EXECUTIVE COUNCIL
Vane* Van laanen
President
Green Bay, Wiiconiln
Harold B. Olln
Vlct-Prtttdtnt
Beverly Shores, Indiana
John K. langum, Ph.D.
V/ce-rVeiWent-Treajurer
Chicago, Illinois
lewis Bolts, Ph.D.
Secretary
Kalamatoo, Michigan
Mn. Jean Bonynge
Wilmelte, Illinoii
Gordon Carr
Grand Rapids, Michigan
Mn. Louis* Erlcluon
Racine, Wisconsin
Paul Goodman
Evantton, Illinois
William A. Kern
Fort Wayne, Indiana
Mike Love
Chicago, Illinois
Ted MacDonald
Lafayette, Indiana
Charles E. Olmsled, Ph.D.
Chicago, Illinois
Mrs. Louise Rome
River Forest, Illinois
John P. Sharon
St. Joseph, Michigan
Mn. Sylvia Troy
Munster, Indiana
Steven Winter
Two Rivers, Wisconsin
Alternate*
ills
/er, Indiana
Arnold Leder
Kalamaxoo, Michigan
53 West Jackson Blvd. | Chicago, Illinois 60604 | (312)427-5129
TO: Great Lakes Scientific Community
FROM: Lake Michigan Federation
RE: Lake Michigan thermal standard
Guidance is requested from the scientific community concerning procedures for
for evaluation of thermal effects in Lake Michigan.
By 1974 several nuclear power plants are scheduled to begin using Lake Michigan
water for once-through cooling.
From 1968 to_1970, conservationists urged that the Lake Michigan Enforcement
Conference consider a thermal standard to prevent thermal pollution by the
nuclear plants. The debate revealed the paucity of pertinent past research
on the lake's ecological systems and of field data on thermal effects in the
Great Lakes. Utilities expanded their research programs, but to date few
results have been reported in the literature. At regulatory hearings consul-
tants to utilities predicted there would be little thermal damage on the basis
of laboratory studies and modeling techniques. Government experts, citing
effects of heat on fish elsewhere and in laboratory studies, said damage was
likely. The conservationists argued that, with the lake at such a critical
stage biologically, the heat whould be kept out of the lake or strongly limited
rather than risk possible irreversible damage.
In March, 1971, the federal Environmental Protection Agency proposed that
closed cycle cooling systems be required for all nuclear plants and some
large fossil-fuel plants. Subsequently, on economic grounds and lack of firm
evidence of potential damage, Wisconsin, Illinois and Michigan decided to let
existing plants and those under construction operate with once-through cooling;
only Indiana, where more advanced eutrophication inside an existing heat plume
was cited as justification, accepted the federal proposal.
In the spring of 1972, because of this disagreement, another enforcement con-
ference on the thermal question is likely. It is believed EPA will seek a
compromise to let existing plants operate but to prohibit additional plants.
The Lake Michigan Federation believes that any such compromise must include
a definition of ecological damage. Further, to resolve the thermal question,
the standard should state the methods for adequate monitoring long enough
for evaluation of subtle as well as gross effects. The monitoring should
not be left entirely up to the utilities which have investments of hundreds
of millions of dollars to protect.
Your comments will assist the Lake Michigan Federation formulate responsible
proposals on monitoring for the forthcoming enforcement conference.
Contributions ore tax deductible
-------
Note: No one who answers will be named in connection with any Lake Michigan Federation
activities without permission in advance. If you prefer, please comment in general
on the points raised in the questions below, rather than answering them individually.
Please return your comments to the Lake Michigan Federation, 53 West Jackson, Chicago.
Illinois, 60604.
1. What pertinent current research do you know of that relates to thermal effects
that might result from once-through cooling?
2. How is the research funded (government, utility support, other private sources)?
3. How can damage to ecosystems be adequately measured?
4. How long should operation of once-through cooling systems be monitored to determine
subtle effects on ecological systems?
5. How can effects of heat be distinguished from effects of other factors such as
chemicals or increased nutrients?
6. What effects other than thermal, such as physical damage or toxicity from chemicals,
can occur in aquatic systems with once-through cooling systems?
7. Can damage to aquatic ecosystems be stated in economic terms? How?
8. Is protection of fish, benthos or plankton most important in preventing damage to
aquatic systems?
9. It has been argued that fish can and will protect themselves by avoiding thermal
plumes; is this true of benthos and plankton?
10. What do you consider the most important question in evaluation of thermal effects/
-------
727
1 L. Botts
2 I MRS. BOTTS: I find myself in a somewhat embarrass-
ing position of agreeing with Mr. Dowd about something, and
that has to do with the inconsistency of the EPA in confront-
ing the thermal issue.
We do, however, disagree with him on another
matter, and that is that we consider any muscling that EPA
has been doing to be rather flabby. I am here today to
express a dismay of citizens about the continuing Federal
10 policy of evasion on the thermal question for Lake Michigan.
11 The truth is that this conference was called with no inten-
12 tion of making a final decision on whether waste heat from
13 large powerplants should be dumped into the lake. This
14 I Enforcement Conference was called in the same spirit in
1$ which the thermal question has been dealt with in the past,
16 which was not to do it.
17 In this spirit the Environmental Protection Agency
purports to be considering whether it is necessary to pro-
19 tect the lake against thermal pollution but actually is
20 weighing the political pressures.
21 The evidence and speculation offered by the
22 utilities may be valid, but the fact of their vested interest
23 puts such research in a political context. The independent
confirmation or disputation with results of utility research
2 5 has not been sought.
-------
723
L. Botts
The first aspect of the thermal question is whether
the existing powerplants, including those constructed but not
yet operating, should be allowed to discharge their waste
heat into the lake. The second is whether additional power-
plants should be located on the lake and allowed to discharge
their waste heat into the lake in the future.
Whether or not the delay in enforcement action on
9 j the Federal standard has been intended to make existing
10 plants a fait accompli, that is the result,
It should now be clear that the Enforcement Con-
12
13
14
1$
16
17
19
20
21
^
ference failure on the thermal question leaves the public
with the necessity to seek other ways to resolve it.
What I am saying is that if the thermal question
cannot be resolved here, it can and will be raised at inter-
vention in the public interest in operating license procedures
before the Atomic Energy Commission.
A decision that the cost to society of backfitting
existing plants is not justified will not answer the question
of whether decisions to locate future powerplants ought to
be made in the same way. The Enforcement Conference can
and ought to be the means for dealing with the thermal
question as part of the siting decision.
The need for monitoring is made more critical by
the desire of the Atomic Energy Commission to continue use
-------
729
L. Botts
of Lake Michigan as a heat sink — and that's their term,
not mine. Among the regulatory agencies for Lake Michigan,
only the Department of Natural Resources has addressed itself
to the need for guidelines for monitoring operation of
nuclear plants.
7 According to Illinois, my home State, there should
be no more powerplants on Lake Michigan — a cavalier atti-
tude indeed unless we are told why. While saying that
10 results of operation of Zion would be reviewed in 5 years,
11 the Illinois Board has not said what would constitute
12 evidence of damage nor how bad it has to be to cause a
13 requirement for closed-cycle cooling for Zion.
14 In this situation, the Lake Michigan Federation
15 has attempted in recent months, as the evasiveness of the
16 Federal EPA has made operation of existing plants with once-
17 through cooling almost inevitable, to address the need for
monitoring.
19 We are concerned with biological effects on the
20 lake and with the engineering of the plants. We have cir-
21 culated a questionnaire in an attempt to find out what
22 should be the questions. This Enforcement Conference until
i
23 today has not even defined the problem. It has been a matter
dealt with on a strictly expedient basis.
$6 also requested assistance from the Professional
-------
730
1 L. Botts
2 Engineering Society to evaluate engineering of the plants.
3 I am submitting with my statement a copy of the questionnaire
4 together with requests that we made, addressed to the
5 scientific community of the Great Lakes, and we did receive
6 a number of replies. However we have made no attempt to
7 quantify the results. The answers to the questionnaires did
8 confirm our suspicions on the following points:
9 1. Sufficient answers to the important thermal
10 questions do not now exist in the scientific literature.
11 2. Most of the research now under way is being
12 funded by the utility industry.
13 3. A minimum of 5, some believe 10 or more, years
14 of observation will be required to ascertain the thermal
15 effects.
16 4. in the short term, damage to organisms by
17 entrainment will be more obvious than the effects of heat.
1° 5. In the long term,the cumulative effect of waste
1° heat from many powerplants is likely to be subtle changes in
2^ the unique biological character of Lake Michigan.
In conclusion, the Lake Michigan Federation urges
22 '
that evasion of action on the thermal question not continue
23
within the Enforcement Conference. This action should in-
O I
elude establishment of monitoring requirements for presently
25
existing plants to provide the evidence needed to deal with
-------
B
10
11
12
13
14
15
17
_____________________ 731
L. Botts
the question of future plants.
We asked Dr. Stoermer — who presented his testi-
mony the first day of this meeting — to come to the Enforce-
ment Conference to demonstrate to you that our fears about
the lake have a foundation in fact. Your action now on the
thermal question will determine whether in years to come we
will be identifying results of the increase in the waste heat
load to the lake as he identifies now the result of increase
in the phosphorus load. The purpose of the questionnaire
was to determine whether we were right in the need for
scientific research. The answers confirmed that a decision
cannot wait for final results of research.
This morning the Federal EPA reported verbally
that its position regarding powerplants on Lake Michigan
remains that: 1) controls in the form of closed-cycle
cooling systems will be needed, and 2) proliferation of
powerplants on the lake needs to be prevented.
The statement did not say what the U.S. EPA would
20 I do to accomplish these ends within the Enforcement Conference,
21
22
23
We do not find comfort in the comments by another
Federal representative that the EPA could act outside the
Enforcement Conference under the Refuse Act Permit Program
O i I j
^ or intervene in the AEC licensing proceeding. The key
j
O C. '
is the use of the word "could" instead of "will."
-------
732
M. Carter
The least that can be done in light of the apparent
inevitability of operation of the present powerplants is to
record the results to add to the other autopsy records for
Lake Michigan. Let us recognize the real function of this
procedure we have endured here by giving it the proper name:
the Lake Michigan Coroner's Office
Thank you
MR. BLASER: The next witness from Illinois is
10 Mark Carter representing Northwestern Students for a Better
11 En vi r o nm ent •
12
13 STATEMENT OF MARK J. CARTER,
14 NORTHWESTERN STUDENTS FOR A BETTER ENVIRONMENT,
15 EVANSTON, ILLINOIS
16
17 MR. CARTER: My name is Mark Carter. I am a student
at Northwestern.
19 The Northwestern Students for a Better Environment
20 wish to express their appreciation for this opportunity to
21 testify. The narrow scope of discussion at this conference
22 i on the matter of thermal pollution distresses us. If we
23 are to be environmentalists in more than name only we must
analyze a problem from the broadest point of view. Proposed
laws and regulations must not solve one environmental problem
-------
, 733
2_ M. Carter
2 at the expense of creating another.
3 In short, we believe that the thermal problem is
^ only a part, but very much related to, the larger problem
5 created by the rapid increase in electrical power consumption,
6 It is like the tip of an iceberg. As we shall show, attempts
7 to deal with the thermal problem independently leads to some
$ very unsatisfactory results. It does no good to restrict
9 thermal inputs into Lake Michigan if provisions are not made
10 for ecologically sound alternatives. The heat must go some-
11 where.
12 The Federal Power Commission has predicted that
13 peak electrical demand will go from 277,921 MW in 1970 to
14 1,056,000 MW in 1990, with a similar increase in electrical
15 energy consumption. This is an average annual growth in
16 consumption of 7*1 percent or a doubling every 10 years.
17 This estimate like previous ones are not just predictions but
1# goals. The Federal Power Commission, the Atomic Energy
19 Commission, the Edison Electric Institute, and especially
20 the power companies will do everything they can to meet the
21 predictions.
22 There is no reason to assume the situation will be
any different in this four-State region. By 1990, with a
50 percent nuclear capacity, the thermal problem will be
5 to 6 times that in 1970. Whether the problem continues
-------
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
734
M. Carter
to double every 10 years thereafter depends on what approach
we take today.
Let's consider the heat balance of Lake Michigan.
Over thousands of years the lake has come to a median
temperature, after balancing the summer heat and winter
colds. Along with this median temperature are both daily
and yearly deviations. By natural selection the organisms
which inhabit the lake are best suited to its temperature
patterns. Substantial warming of local areas essentially
excludes those organisms which cannot live and reproduce in
the higher temperatures. This may be tolerable if it is
limited to small portions of the lake.
However, within several decades, the affected areas
will be substantial if once-through cooling, using Lake
Michigan water, is permitted. There has been much criticism
of the numbers in the Department of Interior 1970 report
on thermal effects of Lake Michigan. However, with a 10-year
doubling a 50 percent error is erased in only 5 years.
Unless we want a lake which is suitable only for catfish
and carp, then once-through cooling with Lake Michigan waters
is not a long-range solution to the thermal problem.
If the heat is not to be discharged into Lake
Michigan, then where? How about the Fox, Des Plaines, Illi-
nois , or Mississippi Rivers? Many of the same arguments
-------
735
1 M. Carter
2 listed above hold here, too. The United States Water
3 Resources Council has predicted that, by 19^0, one-ninth of
4 the mean annual natural runoff in the United States will be
5 needed for cooling in steam-electric powerplants if once-
6 through cooling is used. A much higher percentage will apply
7 in the industrial areas and during low flow periods. When
8 the cleanup of this region's rivers commences the added heat
9 would make a return to anything resembling a natural state
10 impossible.
11 One possible solution is to move the power gener-
12 ating facilities out of the region. This is the approach
13 being tried presently in the southwest. Don't waste your
14 time thinking, the idea is already past the study stage.
15 The proposed North Central Power Complex in Montana, Wyoming,
16 and the two Dakotas, will be twice the size of the Four
17 Corners project. All the power will be transmitted to the
13 midwest. Presumably the ecological results will be twice
19 as bad. If we foul up our remaining pristine areas we will
20 have no place to go to recover from living in our cities.
21 The kind of solution that trades the future for the present
22 is no solution at all. We must not force others to pay for
23 our sins.
2A- Another possible solution to the thermal problem
i
25 is the use of cooling ponds. Let's assume that in 1990 this
-------
736
M. Garter
four-State region will have an electrical generating capacity
in proportion to its share of the Nation's population —
roughly 15 percent. Furthermore, assume a 50 percent nuclear
capacity. The land area taken up by plant facilities and
cooling ponds alone will cover a minimum of 400 square miles.
All the land area of Illinois, Indiana, Wisconsin, and
Michigan will be covered with powerplants and cooling ponds
in less than 100 years with a continuation of the 10-year
10 doubling. Obviously the situation will not progress that
11 far. Even so, in the next several decades, where will the
12 land come from? When was the last time a powerplant was
13 built without siting problems? Remember, the problem will
14 continue to double every 10 years at the present rate.
15 A discussion of cooling towers was left for last
16 because, considering present designs, that is only when they
17 should be considered. It is a sham to call cooling towers
a solution to the heat discharge problem when they will
19 make matters worse. The reduction in efficiency they cause
20 I will necessitate additional generating capacity, increased
21 fuel consumption per kilowatt of electricity produced, and
22 increased thermal loads to be disposed of. Remember that
23 the heat must go somewhere.
Although we are developing means to control and
25
' dispose of the more deadly wastes produced in power pro-
-------
737
1 M. Carter
2 duction, the rapid growth rate aided by reduced efficiencies
3 will overwhelm these efforts. We may now be building plants
4 which put fewer sulfur and nitrogen oxides into the air, but
5 the growth rate in the power industry may result in a net
6 increase in these pollutants. Moreover, less dangerous
7 waste materials such as carbon dioxide will, through volume,
# become a difficult problem. Again we say one problem must
9 not be traded for another.
10 Let's look at the efforts of the power industry
11 to solve these staggering problems. In 1970, the industry
12 channeled a mere $46 million — only 0.23 percent of gross
13 revenues — into research and development. The President's
14 Office of Science and Technology called this "... a remarkably
15 small percentage by most industry standards," less than one-
16 tenth of the average for American industry as a whole.
17 In contrast, in 1970, the industry spent $395
13 million — 2 percent of gross revenues — on advertising
19 and sales. This is more than 8 times the amount spent on
20 research and development. How can the industry justify
efforts to increase electrical consumption with all the
present and future problems unsolved? Some power companies
23 claim they are concerned for our total environment. We
say they have contempt for our total environment. They
' should stand for conservation of energy.
-------
733
M, Carter
2 Research and development expenditures should be
3 increased tenfold. Ths four State pollution control agencies
represented here today in consultation with their respective
5 public service commissions should set this as a minimum for
6 allowing the power companies to continue operating. The
7 | bulk of this money should be spent in three major areas:
One, on methods of alleviating immediate problems,
9 such as S09, NO , and fine particulate control, methods to
/w U\.
10 eliminate the discharge of chemicals in cooling water, and
11 last but not least methods of water intake and discharge
12 which will minimize local ecological damage.
13 Second, ways to utilize waste heat must be investi-
14 gated seriously. There is not time today to discuss all the
15 possibilities. However, the productive use of waste heat
16 that substitutes for heat energy which would otherwise have
17 to be generated, results in a net improvement in our effi-
ciency of energy use, and in energy conservation. Even
19 though all energy ultimately appears in the environment as
20 heat, energy movement from a highly concentrated point source
21 to a widely dispersed geographic area will be environmentally
22 more acceptable. If we are going to reduce the electrical
^ efficiency of the generating plants, let's do so in order to
^ create a more marketable heat discharge. There are many
i
i
o c |
' ideas, a few experiments in progress around the country,
-------
. 739
11
1 M. Carter
2 but almost no money or commitments to try a full-scale plan.
o This must change.
^ Third, large sums must be spent immediately on
5 devising systems for generating electricity more efficiently.
5 This would have beneficial effects on all the problem areas
7 discussed in this paper. Whether topping cycles or new
g methods altogether are devised is immaterial. However, some
o, ideas like MHD have been around for decades but have died
10 on the vine for lack of attention.
11 It would be nice if there were technological
12 solutions available for these problems, but none are avail—
13 able today. Even if we embark on an ambitious development
14 program, it would be unlikely that we would have an opera-
15 tional solution in the next few decades. Look at the example
16 of nuclear power. The Atomic Energy Commission has spent
17 billions for nuclear development in the last 20 years.
1# Today nuclear power is producing less than 2 percent of our
19 electric power and it will be several decades more before
20 it is producing over half of our electrical needs.
21 It is exceedingly clear that the electric power
22 I industry cannot continue to grow at its present rate for
23 much longer. Our natural resources are finite; we have a
24 limited amount of land, water, and air to serve all of the
25 demands that society places on them. Electric power cannot
-------
740^
M. Carter
claim all of these resources. In fact it must be limited to
a small percent of them if we are to be able to enjoy the
many benefits of electric power.
The Lake Michigan Enforcement Conference must set
up a committee to investigate ways of using electrical power
more efficiently. We shall mention some suggestions shortly.
As these ideas are developed they must be made known to the
general public so they can be put into practice. Most of
10 the agencies represented here have done a very poor job of
11 public relations. In fact, the average citizen has probably
12 never heard of them. This must change as people cannot use
13 the information they do not have. Some of our ideas are as
i
14 follows:
15 For the present, ban the use of electricity for
16 all heating purposes where gas or oil would be more efficient,
17 It makes no sense to burn gas to produce electricity which
in turn is used to heat a home when the same thing could
19 be accomplished using one-third of the gas directly. It
20 has been said that the only less efficient way of heating
one's home than electricity was to burn it down. Building
codes should be changed to encourage increased use of
3 insulation, and natural light, heating and cooling. Once
2.L
* again it makes no sense to build buildings which have to
25
' be lighted, heated, and cooled, no matter what time of day
-------
741
1 M. Carter
2 or year,
3 Promotional practices and rate structures have to
4 be changed to discourage the wasteful use of electricity.
5 Consumers must be informed of the efficiency of all appli-
6 ances, especially the large ones. There are more ideas but
7 the point is clear. Our proposed solutions to the thermal
$ problem attempt to get at the roots of the problem because
9 only in this way can a long-term solution be fashioned.
10 We propose surgery not cosmetics.
11 In closing, we would like to paraphrase the late
12 Senator Robert Kennedy when he said that some people look
13 at things as they are and say why, but we look at things the
14 way they could be and say why not. We hope you see it the
j
15 same way and will set up the necessary machinery to get
some of these ideas going.
17 Thank you.
And I have one short further comment, as I just
19 got the report of the Federal EPA in the mail yesterday and
didn't have time to include it in my statement. But I
21 would like to point out a gross inconsistency among some of
the Federal administrators, and you can see what I mean.
3 This refers to the speech that — I think it is
^ John R. Quarles made to the Edison Electric Institute Eighth
2S
Biennial Financial Conference. And in it he said: "I wish
-------
. 742
M. Carter
to state my opinion that the future vitality of our country
demands continued large growth of the electric power
industry." And he goes on to say how this electricity is
5 going to be needed for mass transit and pollution control
5 devices.
7 Well, much work has been done by Professor
Levinson at Berkeley, and he finds that the increased
9 electrical consumption due to many of these devices will
10 add a small percentage to our electrical needs, In
11 light of what I have said in my main paper, I think that the
12 statement of Mr. Quarles with the statements of Mr.
13 Ruckelshaus, when he indicates that he doesn't want the
14 heat to go into the lake, the effect is this: Unless we
15 do something about the growth of the electric power industry,
16 we are going to be producing more and more heat, and it has
17 got to go somewhere, and whether it goes into the lake or
1$ not, or into the streets, it doesn't make any difference.
19 There is going to be a real problem.
20 Thank you.
21 MR. MAYO: Thank you, Mr. Carter.
22 Are there any questions, gentlemen?
23 Thank you again, Mr. Carter.
2L l
** MR. BLASER: The next witness for Illinois is
25
^ Mrs. Eileen Johnston. She wants only 2 minutes.
-------
743
E. Johnston
2
3 STATEMENT OF MRS. EILEEN L. JOHNSTON,
4 WILMETTE, ILLINOIS
5
6 MRS. JOHNSTON: I just want to state that I am so
7 proud of this young man who just spoke. I have been very
close to the Northwestern Students for a Better Environment,
9 and I come up before you gentlemen very humbly, following
10 in his footsteps here, and I appreciate the opportunity.
11 You know me well enough to know that I have no
12 technical background, but I have a great deal of concern.
13 I am real happy to see all of you gentlemen finally. It did
14 take a lot of letter-writing on the part of a lot of
15 citizens, and quite a bit of needling to get this conference
16 together, and now that you are all here I am most apprecia-
17 tive.
You know yesterday it occurred to me that probably
19 the reason it was so long overdue was that Carlos Fetterolf
was down in Washington writing his bluebook, and, of course,
we couldn't have a conference without Carlos. (Laughter)
22 MR. FETTEROLF: Thank you.
23 MRS. JOHNSTON: And I also want to admit to you
2^- in public that last year I made a mistake, and thanks to Dr.
i
^ Fred Lee — a man that I respect a great deal — I want to
-------
744
E. Johnston
apologize. I quoted a man, a professor at the University
of Minnesota by the name of Hoover, and I find that I really
shouldn't have quoted this gentleman. So I am sorry.
Now, as far as the thermal pollution position — I
mean thermal problem — all I want to say is that I still
have confidence in the Illinois position taken at the last
conference. I heard all of the testimony — and these
gentlemen heard it — and I realize why they made the
10 statement.
i
11 | Now I must admit I am a little bit sneaky because
12 my other comments are not on thermal, but that gentleman from
13 Illinois at the end of the table said I could be sneaky.
14 So, if Mr. Mayo doesn't stop me, I just want to go on here a
15 little bit about a couple of things that concern me.
16 I urge the consideration of the use of ozonation
17 instead of chlorination, in sewage treatment, and there
are several advantages of the ozone use:
19 1. Onsite generation eliminates the hazard of
transporting and handling large amounts of chlorine.
21 2. Tests have shown that ozone destroys both bac-
teria and viruses; chlorine is ineffective against viruses.
3 And this information came from Environmental Science and
Technology.
3. Also ozone is more effective against the major
-------
745
E. Johnston
2 taste- and odor-causing compounds in raw water.
3 4. Then, in November 3, 1971, Chemical Week, they
4 quote Clayton Wynne, Project Director of Airco; "A 1-year
5 trial at the Blue Plains treatment plant showed that 'ozone i,
6 as economical as any available tertiary treatment step.1"
7 Three-quarters cent per 1,000 gallons does not
seem costly to me if it kills off viruses.
9 And now here I am going again quoting people, but
10 the Illinois Lake Michigan and Adjoining Land Study Commis-
11 sion felt that these were competent men, so I feel that I may
12 quote them also.
13 Dr. Joseph L. Melnick of Baylor University College
14 of Medicine said at a hearing before this Commission: "It
1$ appears to me that as our population increases and the reuse
16 of water supply becomes more and more necessary, we must
17 increase our efforts to solve this problem of viruses in
water. We should monitor sewage and water treatment plants
19 effectively, so that the citizens of this Nation can be
20 assured that the viruses that are present in the sewage and
surface waters are completely removed before water is redis-
tributed for human use."
23 i think the time has come when standards should
be set of maximum allowable virus contamination of water.
It is astonishing to me that over all the years during
-------
746
E. Johnston
which I have been engaged in this work, that there hasn't
been a single government agency that has even considered
setting such standards. So I ask you gentlemen to consider
5 that.
6 At the same hearing, Dr. Frederich Deinhardt of
7 Rush Presbyterian St. Luke's Medical Center, Chicago,
8 stated: "It seems to me that a reasonable approach would
9 be 1) to stick to the established procedures; and 2) to
10 establish as quickly as possible more detailed studies on
11 the detection of viruses in our waters and on the removal
12 of viruses in various waters, s«wage and others. Once we
13 have these data we can think about setting new standards
14 and change in our procedures."
15 And I am sure you are familiar with the pilot
16 study in Louisville, Kentucky at the sewage treatment plant,
17 and I believe they had positive results. I have detailed
information on this.
19 And so I urge the conferees to make a study of
20 this method and to consider regulation of viruses in water
21 and I will do the same before the Illinois Water Pollution
22 Control Board when I make a statement before them.
3 I do realize that the Phosphorus Committee has
gone into the sedimentation problem, but with the serious-
' ness of this growing problem I believe that it warrants
-------
747
E. Johnston
continued in-depth study with a special technical group,
and I would hope that you might set one up as a steering
2,. technical committee.
5 One respected scientist I have recently talked
6 with feels that his research indicates that nitrogen is the
7 controlling nutrient. So, in spite of the excellent research
we heard yesterday — I mean Tuesday — do we really have
9 the answer?
10 It is very obvious to me that the Four-State Con-
11 ference must continue. We have many unsolved problems, much
12 on-going research to consider. The conference keeps everyone
13 on his toes, everyone works diligently to prepare for it.
14 It is truly the only way citizens can keep pace with
15 progress being made on the restoration of the water quality
16 of our huge well of the four States, Lake Michigan. My
17 only comment there is that I wish the citizens would come
and attend these conferences.
19 I urge you conferees to set a date for the next
20 conference before you leave.
21 I thank you for your good work. I think you are
22 highly competent men and I appreciate what you are doing.
23 MR4 MAYO: Thank you, Mrs. Johnston.
At least in terms of a partial response to your
25 commentary on viruses, essentially that same question was
-------
.E. Johnston
put to EPA by a member of the Illinois Water Pollution Control
Board some few months ago.
We can, I think, introduce a copy of that letter
and our response into the record in order to have at least
a partial reply to your point in the record.
As I recall, the essence of our response was
8 that we, along with many, many other people, recognize the
seriousness of the presence of viruses in wastewater
10 effluents and in our streams. We are aware that there
11 are some fairly exotic techniques for identifying viruses in
12 water, and we are aware of the need to establish standards
13 for viruses. But we are faced with a very serious major
14 problem of not having a sampling and analytical technology
15 that can be generally used in a fairly ordinary laboratory.
16 There are rather sophisticated components of analytical
17 equipment involved, and very large quantities of water are
1& needed for sampling purposes.
19 So, as a consequence, we are working on the tech-
20 nology to try to develop a much more reasonable or much
21 more easily applied capability for virus detection and
22 j analysis, as one of the building blocks on which the estab-
23 lishment of a standard could be based.
MR. BRYSON: One additional comment, Mr. Mayo.
Eileen, we have under way at the National Quality
-------
749
E. Johnston
Laboratory at Duluth some research into ozonation. The
results are not in yet but work is under way.
2f (The documents referred to by Mr. Mayo previously
5 follow in their entirety.)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
-------
U.S. Environmental Protection Agency
'i North Wacker Dr.ive.
Chicago, Illinois.6OS06
February 18, 1972
Mr* Jacob D. Uuwelle
Illinois Pollution Control Board
189 W. Madlccn Street, Suite 900
Chicago, Illinois 60602
Dear Mr. Dunelle:
We agree with you on the desirability of establishing a virus
standard for water. We have not roccowended standards for viruses
bccau°» the technology for virus identification ai*d enumeration has
cot advanced to the denroa where routine employment of the techniques
is possible. The status of. waete treatment technology with respect
to virus control or removal has alr^o been a consideration.
We realize that virus idontif i cation s enumeration and control inethaclo
ere under intensive study by workers in all quarters and that quite
promising r^Krarch data has been published. The enclosed "Proceedings
of the Thirteenth Water Quality Conference - Virus and Water Quality
Occurrence and Control,1' recently held in Illinois, its an excellent
corapilation of socie of this research. However, in view of the un-
certain correlation of virus occurrence with coliforra counts or other
indicators, and the lack of adequate monitoring techniques, we cannot
at the present time establish scientifically defensible criteria for
viruses in. water.
We would be 5>leased to participate in any hearing process the Board
may wlsti to conduct in considering cue detection and treatment of
viruses.
V7ith respect to the Water Quality Criteria draft revision, we will
make the draft available-, to you as soon as it is cleared for printing.
Be assured that our Agency will continue intensive research on water
borne viruses and will move to establish standards as soon as feasible.
Sincerely yours,
Francis T. >lnyo
Regional Administrator
-------
.VID P. CuRRiE, CHAIRMAN
^AMUEL R.ALDRICH
JACOB D. DUMELLE
RICHARD J. KISSEL
SAMUEL T. LAWTON,JR.
STATE OF ILLINOIS
P o ;u 1,1 TT i 'O iv «G o ;rcT 3* o :L B o A M jo
189 WEST MADISON STREET SUITE 9OO
CtH ICAGO, I LLI N Ol S 6O6O2
November 2, 1971
TELEPHONE
313-793-3620
Mr. Francis T. Mayo
Regional Director
Environmental Protection Agency
One North Wacker Drive
Chicago, Illinois 60606
Dear Mr . Mayo :
On October 29 I wrote to you regarding the possibility of your
suggesting a virus standard to us as part of our Water Quality
Standards Revision hearings (R71-14) .
I forgot to ask if it would be possible for us to obtain the
drafts of the new edition of the Water Quality Criteria Report
(the "green book") which we have been told will be ready about
January 1, 1972.
Since we have now completed hearings on the proposed revision to
the Illinois water quality standards we are ready to revise the
initial draft in the light of testimony received and latest
scientific findings. Because the new edition will contain the
latest scientific opinion on water quality criteria we would
like to have access to it as soon as possible and without
waiting for the inevitable delay for printing purposes.
Please let us know when we might expect to be able to examine
a draft copy of the second edition of the Water Quality Criteria
report.
yery tru^y yours,
A//;//-2^>t
Jacob D. Dumelle
Member
JDDrrj
cc : Board Members
Mr. Michael Schneiderman
Mr. William Blaser
-------
STATE OF ILLINOIS
,r"/
-------
Mr. Francis T. Mayo -2- October 29, 1971
recreational and drinking water supplies? Dr. Joseph L. Melnick,
^ virologist from Baylor College of Medicine is quoted in the
remission reports (p. 109, Vol. II) as follows:
"I think the time has come when standards
should be set of maximum allowable virus
contamination of water. It is astonishing
to me that over all the years during which
I have been engaged in this work, that there
hasn't been a single government agency that
has even considered setting such standards.
It is a question which has been ignored."
Dr. Melnick goes on to suggest that his virus detection equipment
be developed for use as virus removal equipment.
Would you at this time suggest we incorporate a proposed virus
standard in our water quality standards revision? It seems to me
a standard is desirable even though the technology may not be
available. If viruses are indeed a hazard then we ought to post
a limit for their concentration. Any suggested number you can
furnish us, hopefully backed by scientific study, would be
appreciated.
Sincerely yours-,-
JDD:rj
cc : Board Members
Mr. Michael Schneiderman
Mr. William Blaser
Dr. William Ackermann
-------
750
1 E. Johnston
2 MR. MAYO: Mr. Blaser.
3 MR. BLASER: Before we proceed with the next wit-
4 ness, Mr. McDonald asked us some questions about monitoring
5 — thermal monitoring as far as Zion is concerned. We had
6 some thoughts on it, but we needed verification.
7 Mr. Blomgren will address himself to that.
& MR. BLOMGREN: Mr. McDonald, the original proposal
9 for study at the Waukegan and Zion sites, and the monitoring
10 activities came from the original thermal committee from the
11 Four State Conference where indeed we recommended certain
12 monitoring programs, and that is the program we recommended
13 to Commonwealth Edison, and they started from and have
14 indeed expanded on it.
15 One of the witnesses from Commonwealth Edison
16 tonight will indicate the study program. They are both
!7 working on one — the Waukegan and the Zion study.
•^ MR. BLASER: The next witness we have is Mr.
19 Daniel Feldman from the firm of Isha^i, Lincoln and Beale.
20 Mr. Feldman.
21
MR. FELDMAN: Mr. Mayo, as you know, I am not a
22
witness at these things, because I am not qualified. I am
23
just going to call the sequence of the witnesses.
i
01
If you are thinking about breaking for dinner, I
25
would ask that you let us get through the first two, because
aU.S.Government Printing Office: 1974 — 751-197
-------
------- |