Volume 5
 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

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     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  3  of 3 Parts)
            Bal Tabarin Room
              Sherman House
            Chicago, Illinois
           September  21, 1972


            dronmeatel Protection /,
          &••,--a V, Library
           §b '> "h U-earborn Strsr-v
              go, minoig socrty
         
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ECTIONA-

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                                                             750a
4
                             W. Pipes
     the second ±s Dr. Verduin, who has, a class of young ecologistsi
     to teach in the morning, and my experience over the last 2
     years is that we are badly in need of well trained young
    ecologists.
              with that preface, I wilJL ask Dr. Pipes to begin
  I  with his presentation.

 9
10
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                   STATEMENT OF DR. WESLEY 0. PIPES,
                    PROFESSOR OF CIVIL ENGINEERING,
                 AND PROFESSOR OF BIOLOGICAL SCIENCES,
                       NORTHWESTERN UNIVERSITY,
                         EVANSTON,  ILLINOIS

              DR. PIPES:  Before I start, I would like to say
    that I am just as proud as I can be of Eileen Johnston.
    She is one of my neighbors at Wilmjette, and she is also
    known as the "sixth member" of thei Water Pollution Control
    Board.  (Laughter)  She attends ail their meetings.
              Mr. McDonald asked a question earlier about who is
    checking on the surveillance people.  Eileen is checking on
    us; she is also checking on the Illinois Board; and she is
    checking on the Illinois EPA, and I think she does a won-
    derful job of that.
              MR. McDONALD:  Well, I know Eileen is placed in a

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   	                        	751
   |                "         """  "  *     ——   _    -••

 1                            W. Pipes

 2   very unfortunate position because that makes the Board

     without a majority*  I don't know how David Currie is going

 4   to react to that.  I am sure they will have a lot of three-

 5   to-three votes now.  (Laughter)
   !
 6             DR. PIPES:  Do the members of the conference have

 7   copies of the testimony that was submitted on Tuesday to
   i
 fcj   the EPA?  Has this been distributed?  There are some extra

 9   copies of the prepared testimony.

10             MR. BRYSON:  These were distributed to the con-
   i
   i
11   ferees.  There should be a package somewhere in that forest

12   on their desk.

13             DR. PIPES:  Mr. Chairman, members of the confer-

14   ence, ladies and gentlemen.  I last testified before this

15   conference in September 1970.  Since my curriculum vitae

16   was made a part of the record of this conference at that

17   time, I will not further burden the record with my personal

18   history other than to state that I am still a Professor of

19   Civil Engineering and a Professor of Biological Sciences at

20   Northwestern University, and that I am still a consultant to

21   Commonwealth Edison Company.

22             The thrust of my testimony in 1970 was that,

     although there was no proof that the condenser cooling

     water discharge from any powerplant into Lake Michigan had

 ^   caused pollution, enough questions had been raised about

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     ______________________  _________________ _ ________ 752

                              W. Pipes

     mechanisms by which  such discharges might cause pollution,

     that  it behooved the Enforcement Conference to take a con-

     servative approach to recommending temperature standards

     for Lake Michigan.   The conservative approach which I sug-

 ^ j|  gestea a. a 1970 was to allow a limited number of condenser
   i
   j
 7 ji  cooling water discharges to Lake Michigan and to require
   !j
 $ j  that  these discharges be studied intensively to determine
   , j
 ,-  !'  if any did cause pollution.

               Today I am here to discuss with you some of the
11
12
15

16

17

18
19
20
21
      studies which have been carried out, which are presently

      under way, or which are planned for the Waukegan-Zion area

      of Lake Michigan.  This is the area of the lake which has

      received the condenser cooling water discharge from Waukegan

      generating station for almost 50 years now and which will

      receive the condenser cooling water discharge from Zion

      Station when it goes into operation.

               I am not going to report either that we have found

      proof of pollution due to the discharge from Waukegan station

      or that we have found proof that the discharges in question

      will not cause pollution in the future.  The overall picture
22 i!  of our experience to date is that we have learned a great

23 j  deal about the environment in this part of Lake Michigan

24   and we have tested a number of the mechanisms by which
   i
   , !
25 jj  induced water temperature changes might cause pollutional

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    	753
                             W.  Pipes
2   effects and, as a result,  are somewhat more confident that
    such pollutional effects are not occurring and will not
    occur.  However, in 1970 we  were talking about possible
    long-term effects (some of the government witnesses were
    actually talking about effects which they thought might occur
    by the year 2000) and about  studies of 1- to 5-years
    duration.  Obviously we have not completed any 5-year
    studies since 1970 and obviously we have not studied the
    Zion Station discharge itself since that plant is not yet
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
    in operation.
              In 1970, I submitted a document for the record
    which was entitled "Study Plan for Determination of Thermal
    Effects in Southwest Lake Michigan."  This document described
    the general approach and rationale of the studies and pre-
    sented the plans for eight projects which were then either
    under way or contemplated.
              I requested comments on the Study Plan related
    to the questions which we were investigating and the methods
    which we were using.  Early in 1971 we received comments on
    the Study Plan from Drs. Mount, Tarzwell, and Powers of the
    U.S. Environmental Protection Agency, and Dr. Linduska of
    the Fish and Wildlife Service, U.S. Department of the
    Interior.  We found many of these comments quite helpful
    in modifying some of the projects and in developing new

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     	734

                              W. Pipes

     projects.

               I do believe that it would be wise for the con-

     ference to create a more permanent group of scientific

     representatives of Federal and State agencies to be concerned

     with the studies of condenser cooling water discharges to

 7   Lake Michigan.  Such a group meeting periodically could

     greatly facilitate the flow of information between the con-

 9 !  cerned governmental agencies and those of us who are in-

10   volved in seeing that the studies are carried out and that
   I
11 |  the data collected are properly analyzed and interpreted.
   i
12 !            I would now like to present the Study Plans which

13   have been developed for Projects IX through XVII of the

14   studies of the Waukegan-Zion area of Lake Michigan.  Again,

1$   we would like to request official (and unofficial) comments

16   about these plans and the methodologies which are being

17   used.

13            Projects IX through XVII are written up in the same

19   format which was used for the projects included in the 1970

20   Study Plan and the entire series of projects represents a

21   continuing development.  Some of the projects have been

22   completed, some are currently under way and some have not

23   yet been initiated.  For ease in obtaining an overall

24   perspective of the projects I have included Table I with

     this statement.  (See p. 755)  This table gives the starting

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                                                              756
 1
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 6
11
   !!
13
14
15


16
17
19
20
                              W. Pipes



      date  for the various projects and indicates the expected



      duration.



               Although this is not in the prepared testimony,



      I would like to  insert a figure here, since Mr. Coraey



      brought up the question of the funding of Study Plans.  I
 7    am informed by  Commonwealth  Edison  Company that the studies



      that  have  been  carried out on Lake  Michigan over the last



      3  years  — essentially starting early in 1970 — according



10    to the present  time  have  been running at a rate of $1.$
     million per year involved in studies in monitoring work in



     this area of the lake.



               Now, in this table I  have also included Project



     XVIII, which will be a study to define the location, extent,



     and area of the actual discharge plume from Zion Station.



     Preparation of the Study Plan for this project was started



     in August 1972 and we will have the Study Plan developed



     and equipment ready before the end of the year.  This



     project is included in the table because we would very much



     like to have input to the development of the Study Plan from



     all interested agencies.
22 '
               In the role of consultant to Commonwealth Edison


23
      Company, I have been concerned with studies of condenser
24




     the University of Michigan and Dr. Donald W. Pritchard of
     cooling water discharges since 196$.  Dr. John C. Ayers of


25 ''

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     	757_



                              W» Pipes


      The Johns  Hopkins University  started consulting with Common-


      wealth  Edison  Company in 19&9.  Dr. Edward R. Raney of


      Cornell. University  (now emeritus), Dr. G. Fred Lee of the


      University of  Wisconsin, and  Dr. Andrew Robertson of Okla-


      homa University  (now with the National Oceanic and Atmos-


      pheric  Administration) started  consulting on the studies in


      1970.   Dr.  Donald C. McNaught of the State University of


 9    New York at Albany  was added  to the group of consultants


10 !   in 1971 and Dr.  Jacob Verduin of Southern Illinois Univer-
   I

11    sity in 1972.


12              Although  brief studies of the Waukegan-Zion area


13    of Lake Michigan were supported by Commonwealth Edison


14    Company in 196£  and in 1969,  the intensive study related to


1$    condenser  cooling water discharges in this area now repre-


16    sents about 2-1/2 years of  effort.  During this period, we


17    have successfully completed some projects and we have also


      had some disappointments.   We have found that in some in-


      stances it was necessary to develop new methodologies or


2(-)    new equipment  in order to get at the questions we wanted to


21    answer.  (We have also lost a fair amount of sampling equip-


      ment in Lake Michigan and I hope that the Enforcement Con-


 ^    ference will not consider these additions to the lake sedi-


      ment to be pollutional effects.)  I would like to  comment

? c
      briefly on some  of  our disappointments,  some of our  changes

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 1                             W.  Pipes



 2    in methodology,  and some  of  the positive results we have



 3    obtained.



 4              One of our biggest disappointments was Project IV,



 5    the laboratory study of fish physiology.  In this study, we

   \

 6 |   were able  to  verify the Harvard Law  of Animal Behavior

   i


 7    which states  that:   "When held under carefully  controlled



 $    laboratory conditions, organisms do  as they damn well



 9    please."   Actually,  what  we  found is that it requires a



10    talented fish culturist to keep many species of fish alive



11 |   in the laboratory and that in our project excessive mortality



12    among the  control group prevented us from carrying out a



13    sufficient number of valid experiments to achieve our ob-



14    jectives.   We also  discovered that the laboratory method-



15    ology for  determining some of the physiological responses



16    (particularly changes in  haematology) are inadequate for



17    our purposes.  As a  result of our experiences with this



1°    project, we completely revised the Study Plan and greatly



19    modified the  laboratory,  design of new equipment, and



20    installation  and testing  of  the equipment.  The design of



21    new equipment, and  the installation  and testing of this


22 !
      equipment  took a good part of 1971.   The new laboratory


23
      study with fish  (Project  XII) is presently under way, but



      the results have not  yet  been evaluated.  Dr. Raney will


25
      present to  you some  additional material which relates

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     	;	759



                              W. Pipes



      especially  to  the  Zion type of high velocity discharge.



               Our  intake-discharge study at Waukegan Station to



      determine the  effects of condenser passage on the zooplankton



      population  has been  quite  successful.  Initially we dis-



 5 j!   covered  that small sampling pumps and drift nets tended to
   11


 7    mash up  many of the  zooplankters. We tried several modifi-



 # j.   cations  of  the sampling techniques in order to avoid this



 o, j   mechanical  damage  during sampling.  Our techniques improved



10    over a period  of months and ultimately resulted in the
   | j

11    development of an  isokinetic sampling pump which treats the
   i
   i

12    zooplankters very  gently.  Dr. McNaught will discuss some



13 {   of  these results describing thermal effects and mechanical



14    effects  on  zooplankton passing through the condensers.



15             Our  phytoplankton sampling program has resulted in



16    the collection of  a  large  number of data on the numbers of



17    algae which occur  in this  part of the lake.  This year we



      have adopted a technique developed by Dr. Verduin which allow,



19    us  to estimate phytoplankton biomass as well as obtain counts
   I

20 j   of  the various species present.  We expect that this tech-

   i

21 |   nique will  allow us  to develop better quantitative relation-



22    ships between  phytoplankton populations and other environ-



23    mental factors. Dr. Verduin will describe some of the
   i

24    information we have  been able to derive from our previous



25    phytoplankton  sampling projects.

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                                       	760



                              W. Pipes


 2             We have also accumulated large amounts of data on


 3   the  chemical substances and physical conditions in the


     Waukegan-Zion area of the lake.  Dr, Lee will discuss some


     of the  conclusions he has reached about the chemical sub-


     stances,  especially as they relate to the effect a cooling


 7   tower would have on water quality.  While it is not part of


     our  study program, Commonwealth Edison gave you cost


     estimates on cooling towers in 1970, and I understand that


10   Mr.  Butler will reappear at this session to update that


11   material. Shortly after I finish, Dr. D. W. Pritchard


12   will discuss some of the often misunderstood physical con-


13   ditions in the lake, both existing and as expected after


14   Zion begins operation.


15             Earlier in this statement, I stated that we have


16   learned a great deal about the environment in that part of


17   Lake Michigan which borders the Zion-Waukegan area.  I


     would like to elaborate in a  general way on this topic.


19             Lake Michigan is a  very large lake and its large-


20   ness alone requires a massive data collection effort to


21   characterize the environment. However, there is very little


     habitat diversity in the area we are studying.  The benthic


 3   community does vary with depth but the components of the


     benthic community are much the same at all the depths we

OC
 '   have studied.  The variation  is in the total community and

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    	761


                               W.  Pipes

     in the relative abundances of the different components.   There

     are rare pockets of different types of sediment but usually

     the variation is continuous without large discontinuities.

     Likewise the organisms making up the plankton communities

     are essentially the same throughout our study area.  The

     counts and the relative abundances of specific components

     of these populations do change in a rather "patchy" manner

 9   with depth and with the season of the year, but we are deal-

10   ing with the same community in all parts of the area.  The

11   fish appear to be free to select the particular location

12   which is dictated by their behavioral pattern at a particular

13   season of the year without being blocked off from any loca-

14   tion in this area.  The periphyton community is present only

15   in shallow water where there are suitable substrates and the

16   area available for its growth is very limited in relation to

17   the total study area.  The chemical substances dissolved in

IB   the water vary from the shore outward as would be  expected

19   since the shore receives land runoff and the discharges

20   from some cities and industries; however, the variation is

21   continuous without any large discontinuities,

22             What I am saying is that it really is just one big

23   lake and a lake with continuous rather than discontinuous
   i
   11
24   variation in the chemical and biotic  components of the

25   ecosystem.  Throughout the study area we are dealing with the

-------
     	762



 •^                            W. Pipes


 2   same components.  We have found no evidence to support the


 o   hypothesis that there is a distinct "beach water zone" at
   i

 i  I  depths less than 30 feet separable from the rest of the lake
 ^ i

 c   nor to support the hypothesis that there is an "inshore


 6   zone" at depths less than 100 feet.  An understanding that


 y   the water depth is only one factor interacting with a large


     number of other environmental factors to determine the nature


     of the ecosystem is thus one of the general propositions our


10   studies have affirmed.  The witnesses who follow me will


     elaborate on several of those factors.


12 !            Now, if I could make a small addition.  We were


13   very pleased to have Mr. Barber's laundry list of concerns


14   this morning.  We have been asking for input and information


15 !  of this type for some time — for 2 years, I would say.


16   And we greet these concerns as hypotheses describing


17   mechanisms about how these dischargers or about how the


18   powerplants might cause damage to the lake's ecology; and


19   treating them as hypotheses, they can be treated in a


20   scientific manner.


21 j            Actually six of the seven witnesses who follow me


22   with their prepared testimony will describe studies which


23   relate to many of the concerns which Mr. Barber expressed


24   this morning.


               i/fe have been trying for this period of time really

-------
    	763





                              W. Pipes




    to get input or to try to get ideas from the Federal agencies




    and from the State agencies about the type of things which




    should be studied and which should be monitored out here.




    We have made several requests for comments for some type of




    scientific group that we could talk to about our studies
  , i



7 I;  and report our findings to and go over the data with them.




              Last year, in the summer of 1971, a group of us




    made two trips into Washington to talk with people in the
10
11
12
13



14



15



16
17
19
21
00
 3



 ^
    Federal EPA, talking through Mr, Quarles.  We met both times




    in Mr. Quarles1 office and met with him briefly one time,



    and met with Dr. Everett, a member of his staff.



              At one of these meetings in Washington, I remember



    Mr, Barber was present at the meeting which ran over an



    hour's time, and at that time we were talking about the



    things that we should study.  Mr, Barber has very little to



    say about the type of things we should study.  This was in



    the summer of 1971.  And we have continually asked for



    information about the type of thing we should be studying




    and the methodology we should be using.



              I think that Mr, McDonald's question which he



    raised about a mechanism of who was going to make an over-



    all evaluation, who is going to take a look at the lake,



    is a very important question,  and I think it is a mechanism
^   that  should be established so we have really somebody to

-------
    	764





                              W. Pipes



     talk with about what we are doing and the data we are




     getting.



               MR. MAYO:  Are there any questions or comments,




     gentlemen?



               MR. BRYSON:  Yes, I have a few comments and ques-




     tions.



               On page 10 of your statement,  there is a rather




     lengthy laundry list of projects that are under way or con-



10   templated or in various stages of completeness.



11             What is the general availability of the data



12   gathered from these studies?  How much has been released



13   to the general public, or is generally available?



14 I            DR. PIPES:  Well, in answer to your question:  I



15   would cite the document that the EPA made available at this



16   conference, the review document that was prepared by



17   Argonne Laboratory under contract with the Federal EPA.



     There are 135 references cited in that document and out of



     those 135, 13 of them are based on data which we have



20   collected in these studies.



21             MR. BRYSON:  Have those 13 been made generally


oo I
     available?  The Argonne report is a summary document that


23
 J   hits the high points.



               DR. PIPES:  Well, yes, the data from these studies


25 '
     have been made generally available.  We have not spent a

-------
    	765


 1                            W. Pipes

 2   great  deal of time as yet preparing fancy reports, final

 2   publications on these; but the information is generally

 4   available to various scientific groups.

 5             For instance, on Project XII — pardon me —

 6   Project IX, a field sampling program, the group who has

 7 || been carrying out this study} has participated in the

 8  j deliberations of the Lake Michigan Study Commission of the

 9   Great  Lakes Fisheries Commission the last 2 years,and reported

10   to that group about their finding.  I talked with the fellow

11   who was in charge of this project last week and he told me

12  ! that he gets calls from the Great Lakes Fisheries Commis-

13   sion on the average of about once every 2 weeks asking what

14   kind of information he is getting, what kind of data he is
   jl
15   collecting on the fisheries up there.

16             And so in terms of its availability to the

17   scientific community and for examination and interpretation

     of data, I think this has been very good.

19             MR. BRYSON:  With respect to the study outlines and

20   the comments by Federal agencies, if my memory serves me

21   correctly, has not Dr. Mount of the National Water Quality

     Laboratory met with you a couple of times to go over  study

     outlines and general details of desirable studies?

               DR. PIPES:  We had a good deal of correspondence

2 5   with Dr. Mount in the winter of 1970-1971 and the spring of

-------
     	766


                              W. Pipes

      1971»  and found  his  comments  very helpful, and he helped us

      a great  deal  in  giving  us  guidance and technology on the

      things we should be  studying.

 5              We  haven't  really had much  communication with him
   i
 6 l!   since  the summer of  1971.

 7 !             MR.  BRYSON:   I was  under the impression that there
   ' i
 8    have been some exchanges of information between yourself

 9 i   and Dr.  Mount.

10              DR.  PIPES:  There,  I believe, have been some ex-

11 {   changes  of data  information between some of the people

12 j   involved in actually carrying out the study and some of the

13    personnel in  his laboratory,  but we haven't been getting any

14    kind of  official communication from him.

15              MR.  BRISON:   I was  also under the impression that

16    subsequent to  your Washington meeting with Mr. Quarles and

17    Dr. Everett of Mr. Quarles' staff, that there was some com-

      munication back  and  forth  between the two of you and that

19    it was left subsequent  to  that communication that you would

      get back to Dr.  Everett with  some of  the revised study out-

      lines, and that  he was  awaiting for the receipt of that

      information.

                DR.  PIPES:  Well, quite recently this is true.

      In August of  1971 —  just  last month  — we received some

25
 '    additional comments  and requests for  additional Study Plans

-------
     	76?





                              W. Pipes



     from Dr. Everett of his office to supply these, and I under-



     stand there is a Dr. McErlean who is now working in his




     office.    I was able to meet Dr. McErlean yesterday here



     and caat with him briefly, and from my conversation with him



     I understand there is an intention to establish  some type




     of continuing relationship with him so we can supply him




     with information about what we are doing and get comments



 9   from him.



10             MR. BRI30N:  I have one final question.  On page



11   8 of your statement, the first sentence in the last para-



12   graph — can you elaborate in greater detail on what you mean



13   by that statement?  That is page 8, the first sentence of the



14   last paragraph that reads:  "What I am saying is that it



15   really is just one big lake and a lake with continuous rather



16   than discontinuous variation in the chemical and biotic



17   components of the ecosystem."



               DR. PIPES:  Well, I think I would have to agree



19   that I probably got a little over-enthusiastic when I wrote




20   that particular sentence.



21             The study area that we have been concerned with



     is the Waukegan-Zion area of Lake Michigan, and we have gone



23   something in the neighborhood of about 6 miles in either



     direction down the shore and roughly 6 miles out in the lake



 '   in our sampling program, and my comments should really be

-------
                               	768




 1                            W. Pipes


 2    confined to this area of sampling which we have been in-


 3    volved  in.


 4             I understand that the conferees heard some reports,


 5    information on algal forms on Tuesday, which showed a con-


 6    siderable difference between inshore and offshore forms,


 7 l|   Although I wasn't here to hear Dr. Stoermer's presentation,


 &    my understanding is — in his terminology talking about
   i

 9    inshore and offshore — he was going back to perhaps the


10    older terminology.  This has been a terminology used in


      Lake Huron and Lake Michigan going back some decades between


      inshore samples and offshore samples, and the usage tradi-


13    tionally has been related to a distance of 10 miles from


      the shore.


               In other words, any sample collected more than 10


      miles from the shore was considered to be an offshore sample.


      Any sample collected less than 10 miles from shore was


      considered to be an inshore sample.

1Q
 7             I think there is perhaps some scientific basis for


      this type of a designation between offshore and inshore

21
      sampling.

22
               The argument here is related to the inshore

23
      existence — well, the geologists call this a littoral shelf

24
      that is formed by certain geological processes when the lake

25
      is formed. There is offshore in the southern basin of Lake

-------
    	769





                              W. Pipes



     Michigan at a depth somewhere  like  250  or  300  feet a ridge




     that shows up on the contour and  this is roughly 10 miles



     from shore.




               Some of the older literature  —  some of the



 6 |  19th   century literature interprets this  as being the  edge




     of the littoral shelf,  and I think  this is where the 10-



     mile inshore-offshore idea came from.   That is the best I




     can tell.  Some of the more recent  geological  interpreta-



10   tions tend to indicate that this  ridge  may even be caused



11   by the existence of another lake  — Lake Chippewa — some



12   several thousand years ago.  It may not have been related



13   to the formation of the littoral  shelf  at  all.



14             In Hutchinson's book — Hutchinson's "Treatise on



15   Limnology" — he has quite a discussion on the formation of



16   the littoral shelf, and he cites  Lake Michigan as an example



17   of a lake which has an extremely  wide littoral shelf.



               Well, anyway — I am wandering here  — the point I



19   am trying to get at is:  There was  an older usage of "on-




20   shore" and "offshore" and "inshore" samples which was  10



21   miles from the shoreline.  Now,  this definition was picked



22   up by the Public Health Service  and the Great  Lakes Illinois



23   River Basin Project, and they  used  this designation in their



     sampling program.



25             in 1970, the group  from the  Department of Interior

-------
     	770





                              W. Pipes



      who  prepared  the  "white paper" — "Physical and Ecological



      Effects  of  Waste  Heat  on Lake Michigan" — for some reason



      came up  with  a  different definition of "inshore zone" and



      "beachwater zone,"  for which we haven't been able to find



      any  historical precedent, and our studies since that time




 7    have been related to trying to test this as a hypothesis.



      You  can  consider  any definition to be a hypothesis.  We can




      hypohesize  that there  is an inshore zone at 100 foot depth,



10    and  what I  am saying here  is that we really found no data




11    to substantiate this hypothesis.



12             MR. McDONALD:  Dr. Pipes, I would say — you say



13    that your enthusiasm got the better of you — I think one



14    of the points we  have  been developing here today is that it



15    is one big  lake,  and if your enthusiasm got the better of you



16    I think  that  was  a  good move.



17             DR. PIPES:   Good.



IS             MR. McDONALD:  What do you think is the most



19    significant piece of information that has come to your



20    attention regarding these  problems since the spring of



21    1971 session  of the conference?




22             DR. PIPES:   The  most significant single piece of



23    information?




               MR. McDONALD:  Is there an outstanding piece of



      information that  you would identify to support the Illinois

-------
     	771_



                              W. Pipes


      position?


               DR. PIPES:  Well, we have an awful lot of pieces


      of  information.  I really don't carry all of the conclusions


      of  all these  studies around in my head; it would be very


 6    difficult for me to make a selection from the available —


 7             MR. McDONALD:  Well, I bring it up in this cori-


 8 j   text.  This morning we asked Mr. Bryson if he thought there


      was anything really new on the basis of the Argonne informa-


10    tion.  He indicated that there was nothing outstandingly


li    new.


12 I            And in that Argonne summary there is some — what?


      —  13 pieces of information from your studies, and I am


14    wondering if Mr. Bryson was on target with this, or if you
   I

15    would in any way change that?


16             DR. PIPES:  Well, this is really not the way that


17    science usually progresses.  It normally is a long-term pro-


      cess of accumulating a great many bits and pieces of


19    information, and of testing a great many hypotheses.


      And we have looked at this, looked at many things.  One of


      the more interesting things that I might throw out — althoug


      we  are still in the process really of analyzing the data —-


 ^    there is a study there which is described as a study on

2L
 *    the spring thermal bar, which was carried out in March,


 ^    April, and May.  There have been a good many allegations and

-------
     	                         772

                              W. Pipes
      questions about this being some kind of a barrier to mixing,
 o    And we  collected a great deal of data last spring.  As I
 A    say, we are  still very much in the process of analyzing this
 5    data.   I imagine this could be a few months before we have
      the things fully put together; although, again, most of the
      data is available to the people who are scientifically
 g    interested in looking at it.
 9             I  think that some of our spot checks on data show
10    that we have, I think, pretty clear evidence that the thermal
11    bar is  no barrier whatsoever to the advection of heat from
12    the shoreward side and the offshore side of the bar.  And
13    so there is  a question coming up in many respects in terms
14    of the  water quality matters of Lake Michigan.  I really
   I
15    think I think of this because I have been looking at those
16    data most intensively quite recently.
17             MR. MAYO:  If there are no other questions,
IB    gentlemen, thank you, Dr. Pipes.
19             MR. FELDMAN:  Dr. Verduin is next, Mr. Mayo.
20             MR. MAYO:  May I presume that, for purposes of
21    the record,  we would have the study that Dr. Pipes presented
22    to us introduced as an exhibit?
23             MR. FELDMAN:  Would you please?
24             Document, "Evaluation of Thermal Effects in South-
25    western Lake Michigan, January 1970—April 1971" is on file
      at U.S.  EPA  Headquarters, Washington, D.C., and Region V

-------
 2
 3
 4
 5




 6




 7



 &
 9
10
11
12
13




14




15



16
17
19
20
21
23
	773





                         J. Verduin




 Office,   Chicago,  Illinois.



          MR.  FELDMAN:  I might say that Dr. Verduin's



 piece  is  the  first of a series which will present new data.




 I  suppose that the conferees have to arrive at their own



 conclusion  about the significance of the new data.
                   STATEMENT OF DR. JACOB VERDUIN,




                       PROFESSOR OF BOTANY,




                    SOUTHERN ILLINOIS UNIVERSITY,




                       CARBONDALE,  ILLINOIS
                DR. VERDUIN:  My name is Jacob Verduin.  I am a



      Professor  of Botany at  Southern Illinois University at



      Carbondale, Illinois.   I obtained a Master of Science and a



      Doctor  of  Philosophy Degrees  in Plant Physiology under the



      direction  of Dr. W. E.  Loomis at Iowa State University at



      Ames.   In  194&, I  joined the  staff of the Franz Theodore



      Stone Institute of Hydrobiology at Put-in-Bay, Ohio.  This



      is a station of The Ohio State University, and is  located



      on South Bass Island in western Lake Erie.  I have continued



      an active  research program in the Great Lakes ever since




      that time.



                I was one of  the first to point out the  spectacular



      increase (450$) in phosphorus concentrations which occurred

-------
                                                              774


 ,                             J. Verduin


 2    in western  Lake  Erie  between  194$ and 1955*  I am convinced

 o    that  this is  the singlemost important factor in the undesir-


 i     able  enrichment  that  Lake  Erie has experienced during the


 c    past  20  years.   A twofold  increase in phytoplankton photo-


      synthesis was correlated with this increase in phosphorus,


 7    and I have  continued  to monitor the photosynthetic rate in


      western  Lake  Erie every summer.  During the past summer, two


      of my graduate students worked on this project, pursuant to


10    &n Environmental Protection Agency Training Grant in Aquatic

      Ecology  which I  administer through Southern Illinois


12    University.


13             I have a mobile  limnological laboratory (a pontoon-


14    tyP6  houseboat)  which is now  based at Memphis, Tennessee,

15    where we will investigate  the effect of Memphis discharges


16    on the Mississippi River.  This mobile laboratory was con-

17    structed with the aid of a National Science Foundation

IB    Grant (1967)  and it is subsidized partly by the same EPA

19    Training Grant that I mentioned previously.

20             During the  last  2 weeks of August just past (1972),

21    I carried out a  study of photosynthetic rates in Lake
   i
   i
22    Superior, on  board the University of Michigan research ship


23    "Inland  Seas."   I also spent  6 weeks on board that ship in


24    1969,  studying both Lake Michigan and Lake Superior.


25             During the  summer of 1971, I traveled from Chicago

-------
   n	775





 j_                            J. Verduin




 2    to  Hamburg,  Germany, and returned to compare photosynthetic



 o    rates  in the Great Lakes, the St. Lawrence River, and the




 2j.    Atlantic Ocean.  The diatoms collected on this trip are now



 5    being  identified and their biomass is being calculated by



 6    a graduate student at Southern Illinois University.




 7             I  have published 47 papers during the past 26



      years  on various aspects of aquatic ecology and plant



 9    physiology.



10             My testimony today concerns the phytoplankton data



11    gathered by  Industrial Bio-Test Laboratories in the Zion and



12    Waukegan areas, as they relate to the concept of changes



13    between nearshore and offshore areas in western Lake



14 I   Michigan.  I will confine my remarks today primarily to



15    data gathered  between May 1970 and March 1971, which are



16    contained in a Bio-Test Report prepared by J. M. Piala.  The



17    data are less  complete than will be available for the 1971-



      1972 studies,  but they appear sufficient to support some



19    tentative conclusions.  This study included monitoring the



20    phytoplankton  at three locations one-half mile from shore



21 I   (Waukegan, Zion, and Dead River) and at one location 6



22    miles  offshore from the Zion station.  The three inshore



23    stations represent waters from the so-called "inshore" zone




      and the 6-mile station is within the zone designated by



      some as "open  water."

-------
            	776



                              J. Verduin


                When  the  three "nearshore11  zone  stations are  com-


      pared,  it  is  evident  that  their  average  phytoplankton popu-


      lations are closely similar both in the  level of population


 5    and in  the species  composition.   There is  one minor  exception


 6    to  this statement:   The Waukegan station showed a slightly


 7 !   higher  (10 to 20 percent)  average phytoplankton population


      than the other  two  nearshore  stations.   This statistic  prob-


 9    ably reflects nutrient enrichment from the city of Waukegan,


10              However,  when the average phytoplankton data  from


11    the three  nearshore stations  are compared  with the 6-mile


12    offshore Zion station, a large difference is evident.  I have
   i
   j
13    prepared a graph to demonstrate  this  comparison.  (See


14    Figure  1,  p.  777)   In this graph,  I have combined the data


15    from the three  nearshore stations into a single curve for


16    comparison with the data from the 6-mile station.  The


17    graph shows two interesting features:


1$              1.  The nearshore populations  show their highest


19    values  during winter  and early spring, and their lowest


20    values  are observed during the periods of  warmest temper-


21    ature (August to September).


22              2.  The nearshore stations  are about threefold


23    higher  in  phytoplankton population during  the winter and


24    spring  than the 6-mile station,  but when the low values are


      observed in August  and September,  the nearshore and  the

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-------
     	77S




                              J. Verduin



     6-mile station data are practically identical.  I should say,



     also, that a threefold difference is less than some have



     projected and certainly does not indicate that the offshore



     area is incapable of supporting productive growth.  Based



     on my experience elsewhere, I had expected, in fact, that



 7 !|  there would be about a sixfold difference.  Furthermore,



     although the Figure 1 curves do not show it, the species



     composition shows the same kind of convergence in August
10
11
12
13



14



15



16



17



IB
19
20
21
     and September as is evident in the population levels of



     Figure 1.  The fact that a threefold difference in phyto-



     plankton population is established between the nearshore



     and the 6-mile station during winter and spring suggests



     that the nearshore area has a higher nutrient supply and



     greater energy supply per unit of water volume available,



     so as to allow a higher population to develop.  During



     August and September, relative nutrient supply is so nearly



     the same at the five stations that the phytoplankton popu-



     lation levels converge.  Indeed we could reasonably say



     that the distinction between nearshore and offshore areas is



     obliterated under these conditions.
op
   1            Given these data, what kinds of conclusions can
23




     often raised in discussions of Lake Michigan, but sometimes
     one draw?  I should like to examine briefly two questions


24
25
     misunderstood or misused.  The two questions relate to the

-------
   	779



 1                            J. Verduin


 2   rate of exchange of nearshore and open waters and relative


 3   productivity of those waters.  The first question I would


 4 I  like to examine is this;  What kind of mixing rates are


 5   present, when a threefold higher population is found in the


 6   nearshore zone?  To discuss this question, I wish to intro-.


 7   duce the concept of "Mean Residence Time," and I will phrase


 8   the question in this way:  "How long does a parcel of water


 9   take to move from the nearshore area to those 5 miles off-


10   shore?"


11 |            Let me discuss briefly here the situation that


12 |  prevails in western Lake Erie, because we know the average


13   residence time in the western basin and we have compared


14   the waters in lower Lake Huron with the waters of western
   i

15   Lake Erie.  As the waters  from Huron enter Lake Erie they


16   experience an eightfold increase in phytoplankton popula-


17   tion and they experience an almost total displacement in


     major  species composition, and this is accomplished during


19   a residence time of 2 months.  Consequently, I believe that


     if the average residence time in the nearshore area of


     western Lake Michigan were as long as 2 months, then we


22   would  find a  similarly  spectacular difference both in popu-


     lation level  and in species  composition there.  Because the
                          "

     population differences  are smaller and because the species


2 ^    composition in the nearshore area and the 6-mile  station  are

-------
                                      	                   730





                               J. Verduin




 2    closely similar,  the mean residence time in the nearshore



 3    must  be considerably less than  2 months,
 J


                Studies of the  generation time in inshore zones



 5    and in western Lake Erie  have shown that a doubling of a



 6    phytoplankton population  occurs in about 1 week, compared




      to a 3- to  5-week  generation time in offshore waters.  If



      doubling of a population  occurs in 1 week, then a threefold



 9    difference in phytoplankton could arise in a period of less



10    than  2 weeks.   Therefore,  on the basis of these considera-



11    tions,  I would like to  estimate the mean residence time in



12    the nearshore area of western Lake Michigan during the




13    periods when a threefold  distinction is observed between

   i

14    nearshore  and the 6-mile  station populations.  I estimate



15    that  this  mean residence  time is less than 2 weeks.



16              Finally, I wish to comment on phytoplankton pro-



17    ductivity  in the  nearshore as compared to a zone several



      miles from shore.  There  is a concept, rather widely accepted



19    that  the nearshore zone is considerably more productive than



20    the areas  farther offshore.  In the case of the area we are



21 j   considering here  it is  obvious  that during much of the year
   I


22    the nearshore has a phytoplankton concentration about three-



      fold  higher than  the zone 6 miles offshore.  This means that




      a  small fish,  or  a given  zooplankter, grazing nearshore,



 5    will  need  to expend only  one-third as much effort to graze

-------
    	731


                              J. Verduin

     his fill as would such an organism in the 6-mile zone.

     However, this is not a result of greater phytoplankton pro-

     ductivity, but a result of a higher population density per

     unit volume.  When we consider total phytoplankton produc-

     tivity it is necessary to express production, not in terms of

     a unit of water volume but, in terms of an integrated value

     that contains a summation of all the water in the vertical

     column.  This fact has been recognized by most limnologists

10   and oceanographers.  Consequently, they usually express

11   phytoplankton productivity in terms of yield per square

12   meter of water surface.  During the summer of 1969, I made

13   such computations from my Lake Michigan data.  We repeatedly

14   occupied two stations, one about one-half mile from shore

15   and another about 5 miles offshore, near Grand Haven,

16   Michigan,  The yields were expressed as millimoles of carbon

17   dioxide fixed per square meter per day.  The comparison

13   revealed the following -result:

19          Table 1,  Comparison of Inshore and Offshore
                      Phytoplankton Photosynthesis in Lake
20                    Michigan (Millimoles/M  Day)

21                     Inshore (1/2 mile)     Offshore (5 miles)

22                             200                    280

23             This comparison reveals that the 5-mile station

24   actually had a higher yield per square meter than the station

25   one-half mile from shore.  This is a result of the fact that

-------
                                      	 732



                              J. Verduin


     we were  integrating the yield from a considerably longer


     vertical water  column at the 5-mile offshore station.  Notice


     however, that this is a realistic situation.  The organisms


 5   that  live  on the bottom at a depth of 30 meters of water have


 5 i  access to  all the materials settling out of the 30-meter


 7 j  column,  while those living beneath 5 meters of water have


     access only to  the materials that settle out of that 5-meter


 9   water column.


10              Let me now summarize the principal conclusions in
   ll
   ! j
11 !  this  testimony:

   i
12              1.  The mean residence time of water in the so-

   I
13 j  called nearshore of western Lake Michigan is relatively


14 [  short — probably less than 2 weeks — and the nearshore


15 j  distinction is  apparently obliterated during the summer


16 !  months.  Therefore the concept of the nearshore as a dis-
17
19
20
21
22
23


24
25
crete zone that does not exchange with the rest of the lake


is not a valid concept.


          2,   The phytoplankton productivity in the nearshore


when compared on a unit  area basis with offshore productivity


is not higher but may even be somewhat lower than the off-


shore productivity.


          Thank you.


          MR. MAIO:  Any questions or comments, gentlemen?


          MR. BRYSON:  I do have a couple.

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   	763





 1                            J. Verduin



 2             On page 6, when you are discussing the dynamics



 3   between or making a comparison between the dynamics in Lake



 4   Michigan and Lake Erie, I have trouble with a concept that



 5   the dynamics of both lakes are the same — the western basin



 6   of Lake Erie and the nearshore-offshore of Lake Michigan.




 7             Can you elaborate somewhat on that, on that



 8   comparison?



 9             DR. VERDUIN:  Well, I am using western Lake Erie



10   as a reference because it is an area in which we have about



11   a 30-foot depth, and we have a known residence time as a



12   result of through-flow information, and we know what happens



13   there.  And in comparison of Lake Huron, the water goes from



14   Lake Huron into Lake Erie in just a few days and then it



15   resides there for 2 months and we see these spectacular



16   changes.



17             I think that as far as injections per mile of



1^   shoreline are concerned, they aren't comparable.  In other



19   words, I rather doubt if the rivers that flow into Lake




20   Michigan carry a lot less in the way of input thar the



21   rivers that flow into western Lake Erie, you see.



22             MR. BRYSON:  You say you doubt they do?



               DR. VERDUIN:  Yes.  I rather think the farming



 ^   communities of Wisconsin and Illinois, and the cities of



2 ^   Wisconsin and Illinois inject along the shore of Lake

-------
 -,                            J. Verduin
 2
 9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
     Michigan similar  inputs to  those that  flow from Michigan
 o    into  Lake  Erie.   I  think  the main  difference between them is
      the  fact that  the water is  held in the western basin, and
      the  injections go in  there  and the water  is held there for
      2 months.   And if the inshore zone of Lake Michigan were
      actually held  fairly  stable for a  period  of 2 months, we
      would see  the  same  kind of  thing in the inshore zone that
we see in Lake Erie.
          That is my assumption.  That is the assumption on
which this computation is based.  And if you don't want to
accept that assumption, then, of course, the computation
also falls apart.
          MR. BRISON:  How deep were these samples taken at
the half-mile station and at the 6-mile station; and also
how deep was the water at those points?
          DR. VERDUIN:  Well, the water at the half-mile
station is between 2$ and 35 feet deep, and we have samples
from both surface and depth which show that you cannot detect
a vertical difference in phytoplankton distribution, so it
wouldn't matter whether we took them, from the bottom or the
top; they are the same.
          MR. BRYSON:  Which was the next question I had.
Is that the  case with the 6-mile station also?
          DR. VERDUIN:  Well, no.  At the 6-mile station you

-------
                          	735




                              J. Verduin




 2   do get some vertical differences, but we have both surface



 o   and depth, and the data are the average of the two.  The



     points that appear at the 6-mile station are the average of



     the two depths.  We just averaged them because we thought



     they were more representative than either one of them would



     be independently.



               MR. BRISON:  I am not too sure I understand.



 9   Page 3 —



10             DR. VERDUIN:  Yes.



11             MR. BRISON:  — the bottom paragraph, 5 lines up



12   from the bottom, this says:  "The organisms that live on



13   the bottom at a depth of 30 meters of water have access to




14   all the materials settling out of the 30-meter column .»."



15   hence you integrated over the full depth.



16             DR. VERDUIN:  I am talking there about benthic



17   animals.  I am talking about the benthic animal food supply,



     which is an integrated supply from a vertical column.  This



19   should not be confused with my sampling of the phytoplankton,



20   I am simply saying that integrating the vertical column is



21   a realistic integration, it isn't just an academic exercise.



22   so that when I express phytoplankton productivity as milli-



23   moles per square meter, this is a better way of expressing



24   productivity than millimoles per cubic meter.  That is



25 I  essentially what I am saying there.  And then I also point

-------
                                                              7S6


 -,                              J.  Verduin


 2    out  that  the  organisms  on the  bottom  are all of the time


 -    integrating their food  supply  in the  same  fashion by hatch-


 ,     ing  it  as it  settles  from the  whole vertical column.  The


 c    only exception  to that  statement is the poor organism


      that has  to graze per unit volume and he,  of course, has


      the  big advantage inshore where the concentration per unit


      volume  is greater.


 o,              MR. MAYO:   Any  other questions,  gentlemen?


10              Thank you,  Dr.  Verduin.
   i

11              Mr. Currie, I would  like to suggest that we con-


12 I   sider interrupting the  Illinois presentation at this time


13    in order  to take  a break.


14              MR. CURRIE:   That  suits me  just  fine, Mr. Chairman.


1$              MR. MAYO:   Pardon?


16              MR. BLASER:   Was there going to  be another presen~


17    tation  in this  —

IB              MR. CURRIE:   Mr. Feldman, I believe —


19              MR. MAYO:   Excuse me.

20              Mr. Feldman.


21              MR. FELDMAN:  Yes.   We have five more people.
   |l
22    They are  available for  as long as the conferees are avail-


23    able.   I  am told  that one can  lose a  lawsuit by keeping the


24    jury past its dinner  hour, and I do not want to run that


25    risk.   You people handle  it as you wish.

-------
                                                	787




 1                            J. Verduin


 2             MR. MAYO:  You had  indicated that you had Dr.


 3    Pipes and Dr. Verduin who  needed  to  leave.


 4             MR. FELDMAN:  Right.


 5             MR. MAYO:  Okay.  Then, I  would like to acknowledge


 6    that that has been accommodated,  and I think we should take


 7    a break.     I  would like  to  get  some expression from the


 B    conferees on what  they  think  would be a reasonable time,


 9    and from  Mrs, Hall whether she has some suggestions on how


10    long it would take her  to  recover.


11             MRS.  HALL:  I'm  beyond  recovery*


12             MR. MAYO:  Let's ask Mr. Feldman how long he


13    thinks it will  take?


14             MR. FELDMAN:  It is a little hard to estimate


15    Dr.  Pritchard's piecej  and I  think Dr. McNaught and Dr. Lee


16    can probably summarize  their  material and  do it quite


17    quickly.  I  think  the Pritchard thing is already boiled


1#    down so that it is hard to understand without being longer.


19    I don't think it can be summarized.   Dr. Raney is a direct


20    response  to  Mr. Barber, and I think  you ought to hear that.


21    Mr.  Butler is cooling tower costs and not  very long, and


22    maybe that could be summarized some.  Done that way, it is


23    a minimum of another hour  and probably more.


2^-             MR. MAYO:  A  minimum of another  hour for Illinois.


25
               You have approximately  a half hour for

-------
 ,                             J. Verduin



 2    Wisconsin, Mr.  Frangos?


 3             MR.  CURRIE:  There  are  several  additional  Illinois


 4    citizens on  the Illinois list, Mr. Chairman.


 5             MR.  MAYO:  Any estimate of  how  much time they


 6    would require?


 7             MR.  CURRIE:  Forty  minutes.


 8             MR.  MAYO:  We are faced with  something  in  the


 9    neighborhood of 2  to 2 and a  half hours.


10             MR.  MILLER:  Two to 2 and a half hours  is  going


11    to  result in about 5 hours before we  get  through.


12             MR.  MAYO:  Well, the alternative, gentlemen, is


13    to  try to meet tomorrow.


14             MR.  MILLER:  We  can't meet  tomorrow.


15             MR.  MAYO:  I would  suggest, then, that  we  stick


16 I   with it,  take  a break now  of  a half hour  to 45 minutes.


17    I would suggest, gentlemen, we try to finish up this


      evening.  We will  break now and come  back at 7:30.


^9             (Short recess.)


20             MR.  MAYO:  Ladies and gentlemen, I believe Mrs.


      Johnston has returned, so  it  would be appropriate for us to

op
 *    get back into  sessionj


               Mr.  Feldman.


               MR.  FELDMAN:  Dr. Pritchard is  ready, Mr.  Mayo.


25             MR.  MAYO;  Thank you.   Dr.  Fritchard.

-------
                                            	739
                              D. Pritchard

               STATEMENT OF DR. DONALD W. PRITCHARD,
                DIRECTOR, CHESAPEAKE BAY INSTITUTE,
 5   '               PROFESSOR OF OCEANOGRAPHY,
 6                 THE JOHNS HOPKINS UNIVERSITY,
 7                      BALTIMORE, MARYLAND
 8
 9             DR. PRITCHARD:   Members of the conference and
10   audience, my name is Donald W, Pritchard,  I am the Director
11   of the Chesapeake Bay Institute and also Professor of Ocean-
12   ography, Department of Earth and Planetary Science, The
13   Johns Hopkins University,  I appeared before the conference
14   in 1970.
15             Departing briefly from my prepared statement, I
16   presume that my curriculum vitae that appeared in the record
17   at that time will be a part of the record, and so I donft
     have to further qualify myself
19             I would refer just briefly to two aspects of that
20   testimony which the Four-State Conference might again con-
21   sider.  Both of these deal with my own long term concern
22   with obtaining information pertinent to management of the
23   environment for the benefit of man; and the second is some
     rather  extensive testimony dealing with the subject of the
25   large-scale effects of heated discharges versus the small-

-------
     	790
                              D. Pritchard
     scale, local effects of heated discharges,  I will not
     repeat any of that testimony.
               Today I am going to speak about two additional
     features.  The first concerns mixing and exchange between
 6 !!  lhe open waters of Lake Michigan and the so*-called "inshore"
 7 i  zone,
 6 i            A concept originally set out in the 1970 FWQA "white
     paper" postulates that certain zones exist in Lake Michigan
10 i!  which have insignificant exchange with the major volume of
11 I  the lake.  Specifically, the FWQA "white paper" defined two
12
13
14
16
17
19
20
21
23
zones:  one, called the beach zone, included all waters
shoreward of the 30-foot depth contour; the second, called
the inshore zone, was defined as extending from the outer
edge of the beach zone to the 100-foot depth contour.  These
are quite arbitrary divisions.  No physical barrier exists
which would limit the advective transport or turbulent
mixing of waters between the offshore waters of the lake
and the inshore zone, or between the inshore zone and the
beach zone.
          There are a number of processes which promote
advective exchange and turbulent mixing between these
artificial zones and the offshore waters of the lake.  One
is the motion set up by the direct stress of the wind on
the water surface.  The wind stress induces a motion in the

-------
                                                               791_





                              D« Pritchard



 2   surface layers of the lake which,  in the offshore waters of



 3   the lake, flows in a direction slightly to the right of the



 4   wind direction, and at a speed of about 2-1/2 percent of the



 5   wind speed.  Thus, along the western coastline of the lake,



 6   any wind coming from the sector NNW to about ESE would have



 7   an onshore component.  Surface water from the offshore lake



     would pass shoreward past the 100-foot depth contour into



 9   and through the inshore zone, and into the so-called beach



10   zone.  This flow cannot, of course, continue through the



11   shoreline and, in fact, will not, as a direct advective flow,



12   move all the way to the shore.  Continuity is maintained



13   by two processes.  Within a few thousand feet of the shore-




14   line the flow turns and runs essentially parallel to the



15   coast, in the direction of the longshore component of the



16   wind.  This does not account for all of the surface water



17   which moves into the inshore and beach zones, since the



     shoreward directed surface flow is in part compensated for



     by an offshore flow of water below the surface layers from



20   the inshore and beach zone out into the offshore lake area.



21   The wind is never uniform  in speed and direction along the



22   entire coastline, or even  any major segment of the  coastline



     of the lake.   The longshore  current in the beach  zone induced



     by a strong wind  in one  sector of the lake will dissipate



     the move offshore again  in regions of weaker winds.

-------
                                                              792
 1
 2
 3
 9
10
11
12
13



14



15



16
17
19
20
21
                         D. Pritchard
          A 15-knot wind blowing from the quadrant North to



East would produce an advective flow of offshore lake water



into the inshore zone of about 500,000 c.f.s., over a 10-



mile stretch of coastline.  There would be an equivalent flow




out from the inshore zone resulting from the combination of



a subsurface countercurrent, and a return of water flowing



alongshore into the offshore lake area from regions having



lower onshore wind stress.



          Similarly, along the western coastline of the lake,



a wind from the sector SSE to about WWW produces a surface



current with an offshore component, which carries water



from the beach zone into the inshore zone, and from the



inshore zone out into the offshore lake area.  In this case



there is a compensating subsurface current directed from



the offshore region toward the coast.



          Basically the lake, including both the so-called



beach zone and inshore zone, is a dynamic, not a static,



system as implied in the FWQA "white paper."  Not only does



the wind induce relatively steady advective flows between



the offshore lake waters and these two zones for short
   ! '
O O j I

     periods (a few hours to a few days), but the periodic



oo

 J   fluctuations in wind speed and direction produce large



2.L.
 *   horizontal current shears, and transient eddies which result



25
 '   in large-scale turbulent exchange of water and of dissolved

-------
 1
 2
 3
 4
 5
 6
 7
 9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
                                                              793
                         D.  Pritchard
and suspended materials between the beach and inshore zones
and the offshore lake area.
          Another mechanism  for exchange of water between
the nearshore and offshore areas is one also related to
the wind, but in a more indirect way.   During periods of
vertical stratification the  wind fluctuations can induce
internal seiches which, in addition to vertical motion in
the layers of maximum vertical density gradient, often pro-
duce an influx of cold water from offshore up over the
inshore shelf region.  These massive movements of water
between the offshore lake area and the nearshore shelf
region have been well documented by a  number of investiga-
tors, notably Clifford Mortimer*  Though such seiche-induced
exchanges between the offshore and nearshore regions of the
lake are aperiodic events (i.e., occurring from time to time
with no set pattern), they do contribute a significant,
though at present an unquantified, addition to the other
modes of exchange.
          The shoreline is the source  of all of man's
chemical input to the lake,  plus the major part of the
natural chemical input via rivers, streams, and surface
runoff.  The basic physical  laws require that there be a
gradient in concentration of such dissolved and suspended
material from the shoreline outward.  Thus the fact that

-------
                              	794


 ,                             D. Pritchard


 2   nearshore waters have higher concentrations of dissolved and


     suspended material does not imply a lack of exchange of these


     waters with the rest of the lake.  Based on the chemical


     data available, it is possible to make an estimate of the


 6 jj  mean exchange rate of water in the inshore zone with the


 7 I!  waters of the offshore lake area.  This is accomplished by

   ii
     comparing the total mass of a given chemical resident in the


     inshore  zone at any given time with the rate of introduction


10   of that  constituent into the lake at the shoreline.  Such a


11 j|  computation indicates that the long-term exchange of water


12 |i  between  the inshore zone along the southern half of Lake


13 ij  Michigan and the offshore lake area represents a flux of
14
about 1.5 million c.f.s.  This represents about 75 times
15 {   the  volume rate of water usage by all existing powerplants,
16
17

18
19
20
21
22
23


24
25
plus all those now under construction or announced as being


planned, on Lake Michigan.


          A much maligned villain in the fantasy of isola-


tion of the inshore zone from the offshore waters of the


lake is the thermal bar.  The misconception that the thermal


bar is a barrier which confines the water and all of the


introduced wastes to the shoreward side probably arises


from a misunderstanding of the meaning of the term "bar."


As used in the phrase "thermal bar," the "bar" simply means


an elongated region identified by some readily recognizable

-------
                                                               795




                              D. Pritchard



      feature.  In the present case, the identifying feature is



      the 4° C, isotherm, the temperature of maximum density for



      freshwater.   On one side of this isotherm is water which



      is colder, and hence less dense, than the 4° C. water*  On



 6    the other side the water is warmer, and also less dense,



 y    than the 4° C. water.  The use of the term "bar*1 in the



      phrase "thermal  bar" has a connotation similar to the use



 9    of this term in the phrase "oyster bar,*1 which is used to



10    designate elongated oyster beds in tidal estuaries.  Depart-



11    ing, sometimes this indicates an elongated table from which



12    one gets fresh oysters.



13             The main point to be made about the thermal bar is



14    that it is a strongly dynamic phenomenon.  It is a region



15    of minimum stability and is consequently associated with



16    strong convective stirring.  In early springtime the thermal



17    bar forms near shore as the increased solar radiation



      increases the temperature of the nearshore waters more



19    rapidly than the deeper offshore waters.



20 j            Prior to this warming period, the waters of the



21    lake in the upper 100 feet or so have had temperatures close



22    to 0° C.  As the nearshore waters are progressively warmed,



23    there develops a transition region between the  shallower



24    waters having temperatures greater than 4° C. and the off~



2 5    shore waters having  temperatures less than 4° C.  This

-------
 7
 o
10
	796


                         D. Pritchard

 transition region, or thermal bar, generally moves in an

 offshore  direction.  Even when, for short periods of time,

 the  bar does not  show much movement, turbulent exchange does

 occur  across this region of minimum stability*  When the

 thermal bar is  in motion it is obvious that the basic prin-

 ciple  of  mass continuity requires a transport of water

 through the bar from the offshore area into the nearshore

 zone,  thus increasing the rate of exchange between nearshore

 and  offshore waters.
11 ij            In late April of 1970 and again in 1971, measure-
   J i
12 il  ments made off the Zion nuclear powerplant site showed an
   !
13 j  average rate of movement of the thermal bar in an offshore
   i
14   direction past the 100-foot depth contour of about 0.02

15   f.p.s*  This corresponds to a transport of water through

16   the bar of about 118,000 c.f.s. for a 10-mile long stretch

17   of the coastline.

13             Thus there are several mechanisms which, though

!9   aperiodic and variable in intensity, when taken together

20 i  are more than adequate to provide for the effective 1.5
   i
21 |  million c.f.s. steady-state exchange rate between the waters

22   of the inshore and beaca zones and the waters of the offshore

23   lake area as estimated from available data on chemical

2^   inputs and concentration distributions.

               The second subject I would like to discuss

-------
    	797^


                              D.  Pritchard


     concerns the winter sinking thermal plume.   As indicated in


     the previous and my just—completed discussion of the thermal


     bar, freshwater  has a number of physical properties which


     make it a unique fluid,  including the fact that the density


     of water is maximum at a temperature above the freezing


     point.  Thus pure water (i.e., water containing no dissolved


     solids), which freezes at a temperature of 32° F. (0° C.),


     attains maximum density at 39.2° F. (4.0° C.).  The temper-


10   ature of maximum density of water decreases as the concen-


11   tration of dissolved solids increases.  However, for the


12   range of dissolved solid concentrations found in Lake


13   Michigan, the temperature of maximum density is for all


14   practical purposes the same for lake water as for pure


15   water.

16             Thus the density of lake  water decreases as the


17   temperature decreases from 39.2° F. to the freezing point, artel


13   also  decreases as the temperature increases from 39.2° F. to


19   the boiling point.  The density of water at 39.2° F. is about


     t).013 percent greater than the density at 32° F., the


21   freezing point.  The density  of water at 46.65°  F.  is the


22   same  as the density at 32° F.


23             During wintertime when the temperature of the lake
    i

24   water is less than 39.2° F.,  and often at or  near  32° F., a


25   heated  effluent with a temperature,  say,  20°  F.  above the

-------
             	      _          	798

                              D. Pritchard

 2 !   lake water  temperature will initially be less dense than the
   i
 o I   receiving waters  and will  spread into the lake as a surface
   i
 ^ ||   plume.   However,  as mixing and  surface  cooling cause the
   11
 5    temperature of  the dispersing thermal plume to decrease, the

 6 i   density of  the  plume will  increase.  When the temperature

 7 !   of the  plume has  been reduced to 46.6°  F. or lower (depend-

 c, jj   ing on  the  ambient lake  temperature) the density of the

 9    thermal plume will become  just  equal to the density of the

10 i   ambient lake water.  Further decrease in temperature of the
   i
11 ij   plume due to mixing and  cooling results in a plume density
   |
12 i!   greater than that of the ambient lake waters.  If the heated
   |i
1> |j   effluent is discharged to  the lake at low discharge
   |
14 |   velocities,  so  that at the point where the density of the
   [
15 |   thermal plume exceeds the  density of the ambient lake watpr
   i
16    there is little excess horizontal momentum in the plume,

17    the water in the  plume will sink or, more properly, bottom

      out, and spread over the oottom as a thin layer of water

19    having  temperatures somewhat warmer than the ambient lake

20    water.   The rate  of mixing of the water in this bottom

21 |   thermal plume with the colder lake water is much slower

22    than in the case  of a surface plume, and since the warmer

23    plume water is  separated from the surface no loss of excess

      heat to the atmosphere can occur.  Consequently, the area

2 5    covered by  the  winter sinking plume may be much greater

-------
                                                              799





                              D. Pritchard



     than the area covered by the thermal plume during the rest



 3   of the year when it remains in the surface layers.



 4             If the thermal plume has sufficient excess hori-



 5   zontal momentum the sinking plume phenomenon described above



 6   will not occur at the point where density of the plume first



 7   exceeds the density of the ambient lake waters.  Instead,



     the plume will continue to spread horizontally, mixing



 9   rapidly with the cooler lake waters and losing excess heat



10   by surface cooling, until the excess horizontal momentum



11   has been decreased to some critical value which permits the



12   higher density water of the plume to sink through the cooler



13   ambient lake water and to spread out over the bottom.  Thus



14   the temperatures in the sinking plume and in the spreading



15.  bottom plume are determined by the excess horizontal



16   momentum (or, simply, the excess horizontal velocity) of



17   the thermal plume.  Other things being equal, the higher the



     speed of discharge of the heated effluent, the lower the



     temperature in the winter plume at which sinking occurs.



               Theory is not yet adequate to provide estimates



21   of the value of the excess horizontal velocity at which the



22   sinking plume phenomenon occurs.  However, on  29 February



     1972 and again on 16 March 1972 Bio-Test made very extensive



     field  surveys of the thermal  plume from the Waukegan power



      station.  On both these occasions a  strongly developed

-------
     ___________     _    _   __ aoo



                             D. Prit chard


     sinking plume was observed.  Each of these surveys involved


     the measurement of the vertical temperature profile at over


L ||   140 stations in Lake Michigan waters adjacent to the Waukegan
  !

5 J   power station.  To my knowledge, no other such intense


6    temperature surveys of the winter sinking plume phenomenon
 7
 3
 9
10
11
12
13
14
15


16
17
19
20
21
22
23


24
25
    have  been  carried out.


               During the  29 February survey, the ambient lake


    temperatures decreased slightly with distance offshore,


    being 34°  F. at the shoreline, 33° F. at a distance of


    between  2,000 and 5,000 feet offshore, and 32° F. at a


    distance of between 3,500 and 12,000 feet offshore.  The


    ambient  temperature in the vicinity of the sinking plume was


    close to 33° F.  The  temperature rise across the condenser


    in the Waukegan powerplant was 13° F., but because of re-


    circulation of some of the plant discharge back into the


    intake canal, the temperature of the heated effluent was
    about  50°  F. , or 17° F. above the ambient lake temperature.


    Water  at  50° F. is less dense than water at 33° F., and


    hence  the  thermal plume initially extended horizontally out


    into the lake from the mouth of the discharge canal.


    Because of the small density difference between the thermal


    plume  and  the receiving waters, the rapidly mixing heated


    effluent extended from suriace to bottom in the relatively


    shallow waters off the Waukegan power station.  The density

-------
 1                           D. Pritchard



 2    of the water in the  thermal plume became just equal to the



 3    density of the  33° F. ambient lake water at the point where



 4    the temperature of the  thermal plume had decreased to 45.6°



 5    F.  At plume temperatures less than 45.6° F. the density of



 6    the thermal plume should have been greater than the density



 7    of the ambient  lake  water, and conditions favorable for a



 #    sinking plume should have existed.  However, sinking of the



 9    plume did not occur  until the temperature of the plume had



10    been reduced to about 37° F,



11              On 16 March 1972 the ambient lake temperature in



12    the vicinity of the  sinking plume was 32.5° F»  As a result



13    of recirculation of  some of the heated discharge back into



14 |   the intake canal, the temperature of the effluent was about



15 !   16.5° F. above  the ambient lake temperature.  In this case,



16    the density of  the heated plume would be equal to the



17    density of the  32«5° F. ambient lake water at the point



13    where the temperature of the thermal plume had been reduced



19    to 46,1° F,  However, sinking of the thermal plume did not



20    occur until the temperature of the plume had been reduced



21    by mixing and cooling to 39° F.



22              fhe fraction  of the 1949 c.f. s. condenser cooling



      water flow which was being recirculated on these two occa-



      sions is not precisely  known.  A conservative estimate of



      the volume rate of flow of the heated effluent discharged

-------
     		aoa


                            D. Pritchard

     to the lake is 1,500 c.f.s., which would result in an excess

     horizontal velocity at the point of discharge of the thermal

     plume of 3»0 f.p.s.  At the po.int in the thermal plume on

     29 February where the temperature had been reduced from 50° F

     to 37° F., the excess horizontal velocity in the plume would

     have been reduced to 0.71 f.p.s.  At the point in the thermal

     plume on 16 March where the temperature had been reduced

     from 49° F. to 39° F., the excess horizontal velocity in the

10 I  plume would have been reduced to 1,1$ f.p.s.
   i
11 |            On the basis of these data it can be concluded

12 |!  that in Lake Michigan sinking of the thermal plume will not

13   occur in that part of the plume in which the excess hori-

14   zontal velocity exceeds 1.2 f.p.s.

15             At the Zion nuclear powerplant of Commonwealth

16   Edison Company the speed of the heated effluent at the point

17   of discharge to the lake will be 9.3 f.p.s.  The excess

     temperature in the thermal plume where the excess horizontal

19   velocity will have been reduced to 1.2 f.p.s. will be less

20   than 2.6° F. (for an initial temperature rise of 20° F.).

21   Thus any sinking plume which might develop at Zion will have
   i
22   excess temperatures less than 3° F.

               I would add just two comments that are not in my

     written testimony.  There was an earlier question addressed

     to Dr. Pipes concerning whether studies conducted in recent

-------
 1                          D, Pritchard



 2   years and since the last meeting of this group had resulted



 3   in new  findings,



 4             I would suggest that the presentation I have just



 5   made concerning the sinking plume is new.  Also there have



 6   been some very good new work and results concerning entrain-



 7   ment of phytoplankton and zooplankton, their survival ratesj



 3   on fish behavior with respect to avoidance behavior; and. on



 9   time-temperature exposure relationships for species which



10   might be entrained in the plume and into the intake or en-



11   trained in the plume*     Some of these results will be



12   reported by speakers who follow me,



13             That is all,



14             MR. MAYO:  I would like to suggest to the con-



15   ferees  that we consider holding our questions in connection



16   with the remainder of the Commonwealth Edison presentation



17   until we have gotten each of the speakers, in order to avoid



13   any redundant questioning,



19             If that is all right with the conferees, may we



20   proceed that way?



               MR. BRYSON:  Assuming the speakers stay around*



22             MR. MAYO:  Yes.



               I do have some questions of Dr. Pritchard.



               DR. PRITCHARD:  I am spending the night.



25             MR. FELDMAN:  Dr. McNaught is next, Mr. Mayo.

-------
 2
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14
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IB
19
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                                                              £04

                              D. McNaught
           STATEMENT OF DR. DONALD C. McNAUGHT,
        ASSOCIATE PROFESSOR OF  BIOLOGICAL  SCIENCES,
              STATE UNIVERSITY  OF  NEW YORK,
                    ALBANY, NEW YORK
          DR. McNAUGHT:  Mr. Chairman, ladies and gentlemen.
I am very happy to say that we do have some new and exciting
information on condenser passage.  So before I give you ray
11 [I  prepared statement, I would like to give you the main con-
   i
12 |l  elusions so that you can look, during my presentation of
data, for the evidence that will be used to make these con-
clusions.
          1.  We have discovered that zooplankton mortali-
ties* during condenser passage, are roughly a magnitude lower
than many statements that we see in the literature today.
          2.  We have discovered that most of this mortality
is due to mechanical effects and not to thermal effects.
          With these conclusions, then, I will proceed to
my prepared testimony.
          I am Donald McNaught, Associate Professor of
Biological Sciences at the State University of New York at
Albany.  Previous to the 4 years I have been in this
position, I was Assistant Professor of Zoology at Michigan

-------
                              D. McNaught



     State University.  I hold B.S. and M.S. Degrees in Fisheries



     Biology from the University of Michigan and a Ph.D. from



 4   the University of Wisconsin in Zoology (limnology).  Attached



 5   hereto is a complete list of my professional experience,



 6   awards, memberships in professional societies, and publica-



 7   tions. (See pp. &Q6-&Q8)



               My own studies have included an investigation of



 9   the zooplankton of Lake Michigan beginning in 1964.  More



10   recently we have been examining zooplankton production in



11   Lake Ontario, with emphasis on the effect of waste heat on



12   such production (see publications listed in vitae).



13             The Commonwealth Edison Company has invited me to



14   present this statement and I welcome the opportunity to



15   express my views regarding the potential effects of con-



16   denser passage on zooplankton, specifically as we predict



17   for the Zion nuclear plant.



               Zooplankton constitute a portion of the ecological



19   basis for fish production in Lake Michigan.  To seriously



20   reduce the production of zooplankton would be to interfere



21   with fish production.  However, it is  obvious from investi-



22   gations by personnel from Industrial Bio-Test that  zooplank-



23   ton mortalities during condenser passage never approach



24   100 percent and are, in  fact, usually  closer to 10 percent,



25    even  following return to ambient temperatures for  24 hours

-------
            CURRICULUM  VITAE  OF DONALD C.  McNAUGJIT
                                                                 806
Per sorial:

a.  Born:  Detroit,  Michigan,  1  May 193'i
b.  Married:  Mary E.  Flach  Mcuaught,  29 December 1962
c.  Children:  Four  (196't, 1967,  1969,  1971)
d.  Residence:  Willow and Pineview,  Rt  1,  Box 370A,
                Guilderlarid ,  Hew  York   1208*(
e.  University Address:   Department of  Biological Sciences
                          State University of  Hew York at Albany
                          Albany,  Hew  York  12203
Ac ad emi c
a,
b.
c.
    B.S. ,
    M.S.,
    Ph.D.,
1956,
1957,
Fisheries, University of Michigan, Ann Arbor
Fisheries, University of Michigan, Ann Arbor
Limnology (Zoology), University of Wisconsin,
  Madi son
Training and Experience •'

a,  1953-1956:  Michigan  Department  of Conservation; 1953 (summer),
    Fish Division,  Stream Improvement  Crev;  1955 (summer),
    Institute for  Fisheries  Research,  Stream Survey Crew; 1956
    (summer), Institute  for  Fisheries  Research, Lake Survey Crew.
b.  1957-1965:  university of  Wisconsin
    1,  1957-60, Research Assistant, research for Ph.D.
    2.  1960-65, Project  Assistant,  research for Ph.D.,
        administrative  duties,  Laboratory of Linnology.
    3.  Jan.-Sept.  1965,  Project  Associate,  post-doctoral
        research,  zooplankton  of  Lake  Michigan.
c.  Sept. 1965-Sept.  1968:   Michigan State University, Assistant
    Professor, W.  K.  Kellogg Biological Station and Department
    of Zoology.
d.  Kept. 1968-present :   State  University of Mev York at Albany,
    Associate Professor  and  Director of Cranberry Lake Biological
    Stat ion.
e.  1971:   Consultant,  Commonwealth  Edison,  Chicago, on  problems
    of thermal discharge.
                                                              (1965)

                                                           $lt8,300.
Award s:

a.  ASLO Travel Award, l6th  Congress  Limnology,  Warsaw,
b.  All-University Research  Grant,  MSU ,  1965,  $1*00.
c.  Research Grant, National  Science  Foundation, 1966-68,
d.  Renewal from iJ. S . F. ,  1968-71,  $35,300.
e.  U.S. Lake Survey, 1969-70,  $10,000  (joint  award).
f.  Research Foundation,  State  University  of New York,  1969-71»
    $7,870.
g.  National Science  Foundation,  U.S.  International  Biological
    Program, 1970-71, 019,078.
h.  Renewal from N . S . F. -I . B . P . ,  1971-72,  $22,1*50.
i.  ASLO Travel Award, loth  Congress  Limnology,  Leningrad, $600 (1971)
J.  Environmental  Protection Agency,  1972-7 *"*,  lli9,665 (contract
    1972-73 for 79,758).

-------
                                                                    307
MeIIaught, page 2


5 .  Pro_fess iona 1 Sociejt ie_s_:

    a.  American Society of Limnology and Oceanography
    b.  Ecological Society of America
    c.  International Association of Theoretical and Applied Limnology
    d.  American Society of Zoologists
    e.  Michigan Academy of Science
    f.  American Fisheries Society
    g,  Wisconsin Academy of Science


6.  Research Interests :

    a.  State University of New York at Albany, 1968-present.

        Eutrophication of lakes of Nev York State, including studies
        of secondary production using acoustical techniques and
        effects of thermal loading on production of zooplankton;
        adaptability of Cladoceran zooplankters to extreme photic
        environments; evolution of visual systems of planktonic
        cladocerans .

    b.  Michigan State University, 1965-1968.

        Physiological ecology of the zooplankton; migratory behavior
        and photochemistry of the visual pigments of the Cladocera
        and Copepoda; use of acoustical methods in the study of
        zooplankton distributions.

    c.  University of Wisconsin, 1957-65.

        Ecology of Daphnia,  including studies of migratory behavior
        and the role of vision in depth control; investigations of
        zooplankton scattering layers in Lake Michigan; studies of
        relationships between a planktophage fish and its zooplankton
        prey.

    d.  University of Michigan, 1956-1957-

        Studies of comparative food habits of brook trout and burbot.


7•  Committee Activities:

    1968-present:  Site Committee, Inter. Biol. Program; 1970-
    present :  Coordinator, Secondary Production, Deciduous Forest
    Biome , IBP; 1969-present:  Chairman, Subcommittee on Biology  in
    Public Affairs, Committee on Biology for SUNY; 1970-1972:
    President's (SUNYA) Advisory and Steering Committees on Environ-
    mental Studies; Environmental Decisions  Comm.  ',SUNYA Campus):
    1971-; Coordinator, U.S.-I.E.P. team to  International I.B.P.
    Conference, Reading, England  (Sept.  1972).

-------
McNuught, page 3                                                                #07a

8.  Publications ;

     1.  Lake Mendota and the science of limnology.  Wis. Acad. Rev., 7(l):l-^
         (i960) (with R. M. Horrall).

     2.  Surface schooling and feeding behavior in the white "bass, Roccus chrysops^
         (Rafinesque) , in Lake Mendota   Limnol. Oceanogr. , 6 ( 1 ) : 5 3- 60 ( 1961 )
         (with A. D. Hasler) .

     3.  The fishes of Lake Mendota.  Trans. Wis. Acad. Sci., 52:37-55 (1963).

     k.  Rate of movement of populations of Daphnia in relation to changes in
         light intensity.  J. Fish. Res. Bd. Can., 2l(2) :291-3l8 (196H) (with
         A. D. Hasler).

     5.  Depth control by planktonic cladocerans in Lake Michigan.  Proc. 9th
         Conf. Great Lakes Res., Great Lakes Res. Div. , University of Michigan,
         Pub. 15:98-108 (1966).

     6.  Photoenvironments of planktonic Crustacea in Lake Michigan.  Verh.  Int.
         Ver. Liranol., 16:19^-203 (1966) (with A. D. Hasler).

     7.  Fishing potential of inland lakes.  Papers 12th Conf. Mich. Nat.
         Resources Council (1968):8-11.

     8.  Acoustical determination of zooplankton distributions.  Proc. llth Conf.
         Great Lakes Res. 1968:76-85.

     9,  Short internal waves near their high-frequency limit in Central Lake
         Michigan.  Proc. llth Conf. Great Lakes Res. 1968: k^h-h69 (with C.  H.
         Mortimer and K. M. Stewart).

    10,  Developments in acoustic plankton sampling,  Proc.  12th Conf. Great Lakes
         Res. 1969:61-68.

    11.  A mathematical analysis of the niches of Lake Michigan zooplankton.
         Proc. 13th Conf. Great Lakes Res. 1970:^7-57 (with P. A.  Lane).

    12.  Plasticity of Cladoceran visual systems to environmental changes.  Trans.
         Amer. Micros.  Soc. 90(l) :113-llU (1971 ).
    13.  Measurements of zooplankton production compatible with ecosystem analysis.
         Trans. Amer. Micros. Soc. 90(l) :107-108 (l97l).
    ll».  Influences of thermal effluents upon aquatic production.  Proc.
         Conf. Great Lakes Res. 1971:21-26 (with M. W. Fenlon and G.  D.  Schroder).

    15.  "Notes on the Clarke-Bumpus Sampler", pg. 11-12 in A manual on methods
         for the assessment of secondary productivity in fresh waters.   Blackwell
         Scientific, Oxford, 1971.

    16.  A niche analysis of the Gull Lake (Michigan, U.S.A.) zooplankton community.
         Verh. int. Ver. Limnol. 18 (in galley) (with P. A. Lane).

    17.  The effects of thermal effluents upon secondary production.   Verh.  int.
         Ver. Limnol. 18 (in galley) (with M. Fenlon).

-------
                              D. McNaught



 2   to  illustrate the insignificance of delayed mortality.



 3             Results of Waukegan Studies



               Estimates of zooplankton motility, used as an



 5   indicator of survival, were made following condenser passage,



 6   as  well as at 4- and 24-hour intervals, so as to estimate



 7   either recovery or later death.  Effects of condenser passage



     were  examined at a maximum A T of 12° to 13° G. to imitate



 9   passage at Zion, as well as a normal Waukegan A T of 4« 5°



10   to  9*5° G.  Furthermore, mechanical effects of passage were



11   separated from thermal effects by pumping water and sampling



12   at  the discharge when the plant was not operative,



13             Zooplankters passing through any condenser and



14   associated pumps suffer both mechanical and thermal stress.



15   For the period of the Waukegan study, 0.7 i 3»0 percent of



16   entrained zooplankton suffered immotility due to thermal



17   stress, while 6.5 i 4.2 percent were rendered immotile due



     to  mechanical abrasion.  (Figure 1)  (See p.  8o8a)



19             These figures are illustrated at Figure 1 which



20   was inadvertently left out of my testimony and is available



21   on  the floor at this time.



22  I           While those who have not carefully examined the



     effects of  condenser passage might assume increased  A T's



     to  be the critical  factor, it is now obvious that mechanical



2 5   abrasion  is the most important cause of  immotility,

-------
 o


 UJ
 o;
   20
tr
UJ
D.  10


u
     0
                                AMBIENT TEMPERATURE
                                                          20
                                                          15
                                                           10
                                                           0
         —i	r~	1	1	1	1	1	1     i     i
     MAY  JUN  JUL AUG  SEP  OCT  NOV  DEC  JAN  FEB MAR  APR
    100
                NORMAL A1


           	NO AT
                          MECHANICAL EFFECT ( NO AT)
          —I	1	1	1	1	1	1	1	j	1	(0

          JUN  JUL  AUG  SEP  OCT  NOV  DEC  JAN  FEB MAR  APR
                                                           ilOO
  u.
  o
     10
  O

  CC   5
  UJ
  Q.
                MAXIMUM  AT

                NO AT
                            AL'^ EFFECT! MAX/AT}
                 r^Z-/  MECHANICAL  EFFECT INO AT)
                                                          15
     MAY  JUN  JUL  AUG  SEP  OCT  NOV  DEC  JAN  FEB MAR  APR

                    •9*1    *T*ik4r~  /i*/™\Ki"Tiio\          1972
                          TIME (MONTHS)
i   Effects of condenser passage on zooplankton with maximum

    A T of 12-13 C,  normal AT of 4. 5 - 9. 5 C, and no A T

    (ambient temp. )  at Waukcgan generating station,  May 1971 .

    April 1972.

-------
        •	309





 1                            D. McNaught



 2    accounting  for the mean of 6.5 percent mentioned above.



 3    Mechanical  effects fluctuate seasonally, likely with



 4    changes  in  species composition and size.  The number of



 5    immotile organisms resulting from abrasion and other factors



 6    was  less than 3.1 percent (± 4.5) from May to August when



 7    copepod  nauplii and  small cladocerans were abundant.



 8    Immotility  due to mechanical effects increased to 7,2 per-



 9    cent from September  to January when larger cladocerans



10    (Daphnia and Diaptomus) and copepods predominated.  When



11    the  large relict copepod Limnocalanus macrurus appeared,



12    mortality due to mechanical abrasion jumped significantly



13    (P70.05) to 11 percent.  Thus one important challenge for



14    the  future  will be to construct pumps and condensers to



15    reduce this mortality resulting from the mechanical effects



16    we have  observed.



               Tests at Waukegan illustrate clearly that a second



      effect of condenser  passage, immotility from thermal stress,



      does not significantly increase with the /\ T across the



      condenser.  If an animal is warmed but remains below its
21
22
lethal temperature, it doesn't matter if it is warmed 5.5° C



(9.9° F.) or 12.5° C. (22.5° F.)  above ambient.  Approxi-
23
 J   mately 7.2 ± 2.3 percent of the zooplantcton are rendered
      immobile at a A T of  5.5° C., while 7.7 1 3.5 percent are



      immobilized at a A T  of 12.5° C.  That is, the increase in

-------
   	aio


 1                             D.  McNaught

 2    temperature change ( /J\ T)  is not  harmful  as  long as  discharg

 3    temperatures do not surpass the upper lethal  temperature.

 4    It is not expected that Zion discharge temperatures will

 5    exceed lethal limits;  if this is the  case  it  doesn't  matter
   j
 6    to the zooplankton whether  the /£\  T experienced is 5° C.  or

 7    12° C.
   j
 B !             Thus we have examined two basic  concepts.  First,
   i
 9    we have illustrated that mechanical effects are minor,  lead-

10    ing to mortalities of  about  6.5 percent of zooplankton pass-
   I
11    ing the condensers. Secondly,  thermal effects  are even more

12    insignificant,  causing immotility  in  0.7 percent of animals.

13    Now we want to examine the  seasonal aspects of  condenser

14    mortalities of zooplankton.
   l
15              In recent Bio-Test studies it has been demonstrated

16    that the upper lethal  temperature  limits for  most Lake Michi-

17    gan zooplankton are higher  than the maximum summer lake

IS    temperatures of 23° to 25°  C.  (73° to 77°  F.).   Thus  it is

19    not surprising we found no  severe  thermal  effects at  the

20 |   Waukegan discharge at  32° C.  (98.6° F.)  In fact,  seasonal

21    immotility following passage is highest in February and

22    March (Figure 1),  and  we have  already attributed these

2^    thermal effects to large size  (Limnocalanus).   The summer

2L
 ^    months are not  critical at  Zion, for  we are dealing with a

25
 ^    mechanical problem.

-------
 1                            D. MeNaught



 2             Thus far we have discussed immotility as a measure



 3   of mortality.  However, all immobile organisms leaving the



 4   discharge do not perish.  We have demonstrated a total im-



 5   mobility of 7.2 percent, based on animals observed imme-



 6   diately after passage.  But after 24 hours, less than 6



 7   percent are immobile indicating a decrease of l.S percent;



 8   i.e.,  25 percent of the organisms initially immobilized



 9   have recovered after 24 hours.



10             Estimate of Zooplankton Immobility at Zion



11             At this point we have predicted that immotility,



12   and likely the mortality, of zooplankton due to condenser



13   passage at Zion is on the order of 7»7 percent for tempera-



14 I  ture increases expected across the Zion condensers.  How



15   many pounds of zooplankton would be immobilized in a given



16   year at Zion?  From a careful analysis of Bio-Test data on



17   zooplankton abundance at Zion, and conservatively assuming



1$   that dry weight is 5 percent of wet weight, we have calcu-



19   lated  that 1.21 x 10  Ib. of zooplankton will be immobilized



20   at the Zion plant in a year  (Table 1).  Parenthetically,



21   I give you the necessary figures to make these calculations.



22             I will not read the review of the literature.



23   This review, which you can read, essentially says that the



2^   literature substantiates the Bio-Test findings of Waukegan



25 I  and, as I said, you can read that yourself.

-------
                                         	312




                              D. McNaught



               At this time, then, I would like to comment on the



     AEG  draft Environmental Statement and the EPA reply.  Cer-



 4   tainly  the most  recent results from intensive Bio-Test



 5 j  investigations at the Waukegan station are inconsistent
   i


 6   with the draft Environmental  Statement of the AEG, which



     suggests a 15 to 30  percent kill at Waukegan, with a 100



 8   percent kill most likely for  invertebrates.  In intensive



 9   studies at Waukegan, investigators  at Bio-Test have pre-



10   dieted  that Zion will experience a  kill  of 7.7 ~  3.5



11 !  percent.



12             Likewise,,  these  same Bio-Test  investigations refute



13   the  EPA comments to  the effect that excessive losses of

   I

14   fishfood  organisms  will occur if intake velocities are not

   j

15 j|  reduced to 1 f.p.s.  It is highly unlikely that reduced



     intake  velocities would, in any way, reduce  these already


     low  levels of likely zooplankton mortality.


               For the future,  then, I feel it is vital that the


     Commonwealth Edison  Company examine the  effects of condenser


     passage on zooplankton once the Zion plant is operative.


     Such investigations  will support or refute Bio-Test esti-
   l
22 i
     mates of minimal environmental damage.


2^             Thank  you.


2.L '
 4             (Dr. McNaught's  presentation follows in its


25
 '   entirety.)

-------
          THE POTENTIAL EFFECTS OF CONDENSER PASSAGE



         ON THE ENTRAINED ZOOPLANKTON AT ZION STATION






                                By Donald C. McNaught






     I am Donald McNaught, Associate Professor of Biological



Sciences at the State University of New York at Albany.  Pre-



vious to the four years I have been in this position I was



Assistant Professor of Zoology at Michigan State University.



I hold B.S. and M.S. degrees in Fisheries Biology from the



University of Michigan and a Ph.D. from the University of



Wisconsin in Zoology (limnology).  Attached hereto is a complete



list of my professional experience, awards, memberships in pro-



fessional societies, and publications.



     My own studies have included an investigation of the zoo-



plankton of Lake Michigan, beginning in 1964.  More recently



we have been examining zooplankton production in Lake Ontario,



with emphasis on the effect of waste heat on such production



(see publications listed in vitae).



     The Commonwealth Edison Company has invited me to present



this statement and I welcome the opportunity to express my views



regarding the potential effects of condenser passage on zoo-



plankton, specifically as we predict for the Zion nuclear plant.

-------
                            -2-
The Problem



     Zooplankton constitute a portion of the ecological basis for



fish production in Lake Michigan.  To seriously reduce the pro-



duction of zooplankton would be to interfere with fish p-roduction.



However, it is obvious from investigations by personnel from



Industrial Bio-Test that zooplankton mortalities during condenser



passage never approach 100% and are, in fact, usually closer to



10%, even following return to ambient temperatures for 24 hours



to illustrate the insignificance of delayed mortality.



Results of Waukegan Studies



     Estimates of zooplankton motility, used as an indicator of



survival, were made following condenser passage, as well as at



4 and 24 hour intervals, so as to estimate either recovery or



later death.  Effects of condenser passage were examined at a



maximum  ^ 1 of 12 - 13 °C to imitate passage at Zion, as well



as a normal Waukegan  ^ T of 4.5 - 9.5°C.  Furthermore, mechanical



effects of passage were separated from thermal effects by pump-



ing water and sampling at the discharge when the plant was not



operative.



     Zooplankters passing through any condenser and associated



pumps suffer both mechanical and thermal stress.  For the period



of the Waukegan study, 0.7 +_ 3.0% of entrained zooplankton suf-



fered immotility due to thermal stress, while 6.5 + 4.2% were



rendered immotile due to mechanical abrasion (Fig. 1).



     While those who have not carefully examined the effects of



condenser passage might assume increased  £ T's to be the critical



factor, it is now obvious that mechanical abrasion is the most

-------
                            -3-






iraportant cause of immotility, accounting for the mean of 6.5%



mentioned above.  Mechanical effects fluctuate seasonally, likely



with changes in species composition and size.  The number of im-



motile organisms resulting from abrasion and other factors Wcis



less than 3.1%  (+_ 4.5) from May to August when copepod nauplii



and small caldocerans were abundant.  Immotility due to mechanical



effects increased to 7.2% from September to January when larger



cladocerans (Daphnia and Diaptomus) and copepods predominated.



When the large relict copepod Limnocalanus macrurus appeared,



mortality due to mechanical abrasion jumped significantly



(P^  0.05)  to 11%.  Thus one important challenge for the future



will be to construct pumps and condensers to reduce this mortality



resulting from the mechanical effects we have observed.



     Tests at Waukegan illustrate clearly that a second effect of



condenser passage, immotility from thermal stress, does not



significantly increase with the ^ T across the condenser.  If an



animal is warmed but remains below its lethal temperature, it



doesn't matter if it is warmed 5.5°C (9.9°F) or 12.5°C  (22.5°F)



above ambient.  Approximately 7.2 + 2.3% of the zooplankton are



rendered immobile at a £ T of 5.5°C, while 7.7 + 3.5% are im-



mobilized at a  ^ T of 12.5°C.  That is, the increase  in temper-



ature change  ( ^  T) is not harmful as long as discharge temper-



atures do not surpass the upper lethal temperature.  It is not



expected that Zion discharge temperatures will exceed lethal



limits; if this is the case it doesn't matter to the zooplankton



whether the  ^  T experienced is 5 C or 12 C.



     Thus we have examined two basic concepts.  First we have

-------
                            -4-

illustrated. that mechanical effects are minor/ leading to mortal-
ities of about 6.5% of zooplankton passing the condensers.
Secondly, thermal effects are even more insignificant, causing
immotility in 0.7% of animals.  Now we want to examine the seasonal
aspects of condenser mortalities of zooplankton.
     In recent Bio-Test studies it has been demonstrated that the
upper lethal temperature limits for most Lake Michigan zooplankton
are higher than the maximum summer lake temperatures of 23 - 25°C
(73 - 77°F).  Thus it is not surprising we found no severe thermal
effects at the Waukegan discharge at 32°C (98.6°F).  In fact,
seasonal immotility following passage is highest in February and
March (Fig. 1), and we have already attributed these thermal
effects to large size (Limnocalanus).  The summer months are not
critical at Zion, for we are dealing with a mechanical problem.
     Thus far we have discussed immotility as a measure of mortality,
However, all immobile organisms leaving the discharge do not perish.
We have demonstrated a total immobility of 7.2%, based on animals
observed immediately after passage.  But after 24 hours, less than
6% are immobile indicating a decrease of 1.8%; that is, 25% of
the organisms initially immobilized have recovered after 24 hours.
Estimate of Zooplankton Immobility at Zion
     At this point we have predicted that immotility, and likely
the mortality, of zooplankton due to condenser passage at Zion
is on the order of 7.7% for temperature increases expected across
the Zion condensers.  How many pounds of zooplankton would be im-
mobilized in a given year at Zion?  From a careful analysis of
Bio-Test data on zooplankton abundance at Zion, and conservatively

-------
                            — 5 —
assuming that dry-weight is 5% of wet-weight, we have calculated

that 1.21 x 10  Ib. of zooplankton will be immobilized at the

Zion plant in a year (Table 1).


Table 1.  Calculation of loss of zooplankton in condenser waters
          from Zion plant.

1.)   Mean yearly biomass of zooplankton, grams per meter            _
     dry-weight                                            .116 gm/m

2.)   Mean yearly biomass of zooplankton, pounds per
     gallons X 1CT                                    1.0 Ib/gal X 106

3.)   Zion Capacity:  1.5 X 10  gal/minute or

                     7.88 X 1011 gal/year

4.)   Dry-weight zooplankton per year                  7.88 X 10  Ib.

5.)   Wet-weight zooplankton per year (dry-weight               7
                                        X 20)         1.57 X 10  Ib.

6.)   Wet-weight zooplankton immobilized (7.7% of total)
     per year at Zion                                 1.21 X 10  Ib.


Review of Literature Concerned with Effects of Condenser Passage

     A review of the literature reveals relatively few controlled

studies of zooplankton mortality in condenser waters.  It appears

that students of thermal effects have not determined precise

mortality curves (TL  )  for zooplankton.  However, it is important
                    •J \J
that results reported in the literature tend to support the results

of Bio-Test investigations.

     Casual observations of the conditions of zooplankters follow-

ing condenser passage suggest strongly that an increase in temper-

ature alone has little effect on survival.  Flemer e_t al. (1971)

found only slight mortality of 10% for one copepod (Eurytemora).

Staining techniques were used to tell live animals from dead.

Adams (1968) quoted Dryer and Benson, who found no significant

-------
                             -6-



changes in numbers of zooplankters in the discharge of the



Johnsonville (Tenn.) steam plant.  Protozoans are an important



component of many aquatic communities.  Lorton et al.  (1971)



discovered that condenser passage does not reduce the diversity



of protozoan populations.



      It is not known how many observations of mortality due to



temperature are effected by compounding factors.  Mihursky  (1969)



has observed at the Chalk Point fossil fuel plant that copepods



(as Acartia) are particularly susceptible to chlorine; temper-



ature increases accompanied by chlorine injections often cause



100% mortality.



      In a rather careful study Heinle (1969) has observed that



the upper thermal limits for marine zooplankters are near their



natural summer thermal maxima.  This observation may explain the



Bio-Test results previously discussed.



Comment on AEC Draft Environmental Statement and EPA Reply



      Certainly the most recent results from intensive Bio-Test



investigations at the Waukegan station are inconsistent with the



Draft Environmental Statement of the AEC, which suggests a 15 -



30% kill at Waukegan, with a 100% kill most likely for invertebrates.



In intensive studies at Waukegan, investigators at Bio-Test have



predicted that Zion will experience a kill of 7.7 + 3.5%.



      Likewise, these same Bio-Test investigations refute the EPA



comments ("Environmental Impact Statement Comments:  Zion Nuclear



Power Station Units 1 and 2", dated August 1972, EPA, Washington, B.C.)

-------
                            -7-





to the effect that excessive losses of fish-food organisms will



occur if intake velocities are not reduced to 1 foot per second.



It is highly unlikely that reduced intake velocities would, in



any way, reduce these already low levels of likely zooplankton



mortality.



Future Investigations at Zion



     I feel that it is vital that the Commonwealth Edison Company



examine the effects of condenser passage on zooplankton once the



Zion plant is operative.  Such investigations will support or



refute Bio-Test estimates of minimal environmental damage.

-------
                            — 8 —
                        REFERENCES
Adams, J. R. 1969.  Ecological investigations around some thermal
     power stations in California tidal waters.  Ches. Science,
     10(3/4):145-154.

Flemer, D. A., D. R. Heinle, R. P. Morgan, C. W. Keefe, M. C. Grote
     and J. A. Mihursky.  1971.  The effects of steam electric
     station operation on entrained organisms.  In Postoperative
     Assessment of the Effects of Esturarine Power Plants.  Ches.
     Bay Lab. Ref. # 71-24a, pp. 1-17.

Heinle, D. R. 1969.  Temperature and zooplankton.  Chesapeake
     Science, 10(3/4):186-209.

Lorton, E. D. and J. Cairns.  1971.  A preliminary report on the
     effect of simulated passage of potential colonizing proto-
     zoans through the condenser of a steam electric power
     generating plant upon downstream protozoan community
     development.  Revista de Biologia, 7 (3/4):215-227.

Mihursky, J. A. 1969.  Patuxent thermal studies.  Summary and
     recommendations.  N.R.I. Special Report 1:1-20.

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   	_813_

 1                            E. Raney
 2             MR. FELDMAN:  Dr. Raney.
 3
 4                STATEMENT OF DR. EDWARD C. RANEY,
 5                 PROFESSOR OF ZOOLOGY, EMERITUS,
 6                       CORNELL UNIVERSITY,
 7                         ITHACA,  NEW YORK
 8
 9             DR. RANEY:  My name is Edward C. Raney,  I am
10    Professor of Zoology, Emeritus, Cornell University, and
11    Director of Ichthyological Associates, Ithaca, New York,
12    I  hold the Ph.D.  Degree in Zoology from Cornell University.
13    My specialty is the study of ecology, behavior and system-
14 j   atics of fishes.   Details of my qualifications in the  field
15    of ichthyology and aquatic ecology were submitted to the
16    Four-State Conference held in September 1970 when I made  a
17    presentation entitled "Heated Discharges  and Fishes in Lake
13    Michigan."
19             Since I appeared before this conference in 1970,
20    I  have continued  to make and  direct literature and field
21    studies related to heated  discharges  and  fishes.  You  may
22 |   recall, in 1969 we published  a bibliography of 470 pages
      which included 1,870 references  dealing with this  subject.
      Continued  search  in the  last  3 years  has  produced more than
      2,200 additional  references which will be available  shortly

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                    	                  	814


                              E. Raney

 2   as a computer printout.

 o             Parenthetically, I noted that earlier some of the

     younger people have spoken and mentioned that there really

 5   wasn't very much known,  I think that there is a great deal
   11
 6   that is known, but you have to know where to go and find it,

 7   and we assume that these bibliographies will be used by these
   i
 g   people who really want to get at the truth.

 9             Field studies of aquatic habitats, including

10 !  reservoirs, rivers and ocean with reference to present or

11   potential heated plumes have continued in the eastern United

12   States*  I have either advised or have acted as director of

13   projects on the Connecticut, the Hudson, the Delaware and the

14   Susquehanna Rivers, the upper Chesapeake Bay, the Chesapeake
   I ;
15 !  and Delaware Canal and the Atlantic Ocean off New Jersey.
   i
16   Personnel of Ichthyological Associates have undertaken a

17   series of experimental studies which include determination

     of swim speed  and stamina of fishes, swim speed and guidance

     capacity of ocean fishes off southern California, laboratory

20 |  experiments dealing with temperature preference of fishes

21   and their temperature avoidance or attraction, and shock

22   experiments.   Similar experiments on preference, avoidance and

     attraction for a number of  chemicals and chemical bioassays

     are continuing.  The results of these studies have furnished

     insight with regard to the  potential problems in Lake

-------
                              J.  McNaught

     Michigan near Zion.

               During the past 2  years I have conferred with

     biologists and others associated with Commonwealth Edison,
                  t
     and have had an opportunity  to make suggestions  and  read

     progress reports of  studies  being done off the Zion  and

     Waukegan plants by Industrial Bio-Tests Laboratories,  Inc.

     Particularly I have  consulted with Peter H.  Howe,  Biologist,

     Commonwealth Edison, Dr.  Robert G. Otto,  who has been  doing

10   experiments on temperature preference of fishes  found  in

     Lake Michigan and have seen  reports by and conferred with

12   Michael C. Cochran of Bio-Tests who has studied  fish popu-

13   lations in southwestern Lake Michigan.

14             In my presentation made before this conference in

15   September 1970, I discussed  the history of the fish  popula-

16   tions of Lake Michigan and generally discussed temperature

17   requirements of fishes, preferred temperature, lethal

     temperature, winter  temperature,  avoidance temperature,  and

19   made a number of predictions regarding behavior  of fishes and

20   the effects on fish  populations in reference to  the  Zion

21   plume.

22             In this presentation, I will attempt to  bring you

23   up- to date with regard to the studies which have been  made

24   which will help in explaining my position in regard  to what

25   some environmentalists have  thought would be a serious

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                                                               316
 1
 2
 3
     problem.
                              E. Kaney
               Great changes have occurred in Lake Michigan
 7
10
11
12
13
     fisheries over the past 25 years.  Many of the changes


     accompanied the introduction of the landlocked form of the


     sea lamprey, the alewife and the smelt.  The major changes


     in fish populations were not associated particularly with


     the industrial activities of man but were mainly as a


     result of the interaction of fish species.  At times and


     with some species, commercial overfishing may have been


     important.  Monumental efforts appear to have brought the


     populations of lamprey under control.  Recently other


     species such as the coho, Chinook and kokanee salmon, which
     are native to the Pacific Coast, were introduced, and in

   i

15 |  1972 the Atlantic salmon was introduced.  The stocking
16
17
19
20
21
     programs also involve the lake trout and other trouts.


               i have included a short section on fish stocking


     in 1972 but in view of the lateness of the hour, I think


     that I will skip that because it is mostly of general


     information.


               I think also that I will skip reading the section
22   that I have prepared with regard to recent fishing in Lake



     Michigan.

01
 *             I just might say that fishery biologists are


25
     attempting to bring Lake Michigan back to a state where

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     	8l7_





                               E.  Raney



      it will be worthwhile  as a  sport  fishery.   It  seems highly



      unlikely that  it  ever will be  important  as  a commercial



      fishery in the future,  but that  remains  to  be seen,



                We go next  to a discussion of  the fish  fauna in



      the Zion area, or in  the area  of the Zion plant.   Studies



      were made by personnel  of Industrial Bio-Test Laboratories,



      Inc, of fishes which  occur in  the  Waukegan-Zion area,  Dur-



 9    ing the period from April through  December  1971,  those



10    captured include  the  alewife (66,$ percent) by  weight, lake



11    trout (12,4 percent), rainbow  smelt (10,8 percent), and



12    bloater (6,1 percent).   Fishes taken occasionally included



13    brown trout, lake whitefish, yellow perch,  carp,  white



14    sucker, Chinook salmon  and coho  salmon.  Those  which were



15    considered scarce were  slimy sculpin,  lake  herring, goldfish,



16    spottail shiner,  rainbow trout,  brook trout,  longnose



17    sucker, emerald shiner, trout-perch,  golden shiner, long-



      nose dace, ninespine  stickleback,  mud minnow, and johnny



19    darter.  Other species  taken rarely in the  area include



20    spoonhead sculpin,  mottled sculpin,  emerald shiner, lake



21    sturgeon and whitefish,



22              i pointed out in my  1970 presentation that a



23    section of Lake Michigan cannot  be all things to  all fishes



      at all times.   In other words, the distribution of species



      changes daily  and with  season.  Much of  this change appears

-------
 -,                              E.  Raney



 2    to  be associated with the preferred temperature of the



 o    species,  but  other variables are involved such as daily



 •     migrations, either vertically or inshore-offshore, the



 c    presence  and  abundance of food organisms  and the necessity



      for finding suitable spawning substrate.



                The inshore waters (that  is  up  to  possibly  20



      feet in depth),  we find,  is  an inhospitable  environment  in



      the winter when  water temperatures  approach  32° F. and other



10    factors such  as  bottom scour with high winds are adverse.



11              Off the Waukegan-Zion area,  Bio-Test has found



12    alewife in all months of  the year except  December.  Smelt



      have been found  during all months.  However  the abundance



14    may vary  with species from month to month and place to place



15    within the study area. The  lake trout is usually found  in



16    water 30  feet or deeper.   I  am talking now with reference



17    to  the Zion plant.  The coho salmon appears  to be in  the area



      mostly in June.   Alewife,  smelt and carp  seem to spawn to



19    a moderate extent in the  area. And parenthetically I have



20 j   information recently from Bio-Test  that they have found  some



21    slight evidence  of spawning  of yellow  perch.



22              For Lake Michigan  there is no lack of suitable



23    spawning  substrate and nursery for  these  species.  We are



24    talking now about Lake Michigan as  a whole.   The yellow



25    perch has been scarce in  recent years. Ultimately it may

-------
 1                             E.  Raney


 2    be found to spawn in the  Zion area,  as  it,  in  fact,  did


 3    this last year.   None of  the large  important fishes  appear


 ^    to spawn in this area.  For  some such as  the lake  trout the


 5    type of spawning substrate which is needed  is  a hard sub-


 6    strate — either rocks or hard clay —  and  this is absent


 7    or very limited.


 8              Fishes which are known to  overwinter in  the


 9    deeper water offshore,  such  as alewife, bloater, smelt,


10    salmon and trout,  undertake  spring  migrations  into the


11    shallows.  Actually  this  may be spring  or early summer.


12    The reverse type of  migration was noted for the slimy


13    sculpin,  which,  incidentally is used as food for the larger


14    salmonid fishes.


15              The heated plume from the  Waukegan discharge has


16    attracted,  at various times,  young  alewives and several


17    species of minnow, including the carp.


IS              Water  temperature  in the  depths offshore was  more


19    stable than those of the  inshore waters during the period


20    from April  through December  1971•   However  in  the  deeper

   i
21    water,  fluctuations  during a month  may  be as much  as 5.4°


22 I   p.  The water temperature is basically  the  same even in the


23    deeper water. This  is in a  90-foot depth.
   1

24              Water  temperatures, as measured from north to


      south,  in the shore  zones were similar  but  they had

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                      	820





                              E. Raney



 2   variations up to approximately 3*6° F»  I just want to



 o   emphasize here that you don't have constant temperature,



     the temperature can vary from top to bottom, from place to



     place, from time to time, and certainly with upwelling, which



 5   is a matter which Dr. Pritchard discussed briefly.



 7             I would like to reemphasize — and it is very



     important — my 1970 testimony that small differences in



     temperature, including those up to 5° F., have little or



10   fl° ecological significance to fishes found in temperate



11   regions



12             The thermal plume at Zion and its relation to



13   fishes:  The design of the cooling water system with a sub-



14   merged jet, as described by Dr. Pritchard in April 1970, is



15   such that the area inside the 5° F. isotherm is less than 6



16   acres.  I get back to my contention which is supported by



17   numerous field observations and by laboratory experiments



IB   that up to the 5° isotherm is not particularly significant.



19   But we might say that within 5° or higher, we have about 6



20   acres.  So that, basically, when we say this area would be



21   denied the fishes at the Zion plant — now, it is denied



22   not only because of temperature, but because of velocity.



23   in other words, the jet design is such that a fish, in order



24   to get inside the 6° isotherm would have to swim at approxi-



25   mately 4 f.p.s.  Some large salmonid fishes can do this

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   	                         321
   I                                                             ~



 1                            E. Rany


 2    easily  enough, but it is highly unlikely that they would, swim


 3    against this high velocity at the same time they would be


 4    going into a higher heat.  We have some evidence from experi-


 5    mental  evidence on this point.


 6             So, then, I reemphasize, it is obvious that oflly


 7    a  few acres would be denied to fishes by this combination of


 3    high temperature and high velocity.  Now there is a very


 9    great advantage to this system of having a high jet because


10    kills which have been known to occur because of high temper-


11    ature alone are highly improbable in this situation, because


12    the  fish would have to be swimming into very hot water at


13    a  very  high speed, and our experimental evidence is that they


14    know that the water is 5° or 6° and they turn around and get


15    out  of  there*  It is basically like, you know, walking or


16    running into a shower,


17             Basically, heat kills are a very rare occurrence


1&    when you consider all powerplants in the temperate regions


19    of the  world.  In a few cases, there have been kills, as


20    has  been pointed out here earlier today.  Most of these


21    have had to do with long discharge canals.  That is a very


22 j   important point,


23             The Oyster Creek kill of last winter was mentioned.


      Two  of  my people happened to be there at the time the kill


      occurred.  The water temperature dropped from approximately

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     	  	         	822





 1                            E. Raney



 2    70°  F. to approximately 36° F., and a lot of fish were



      killed.  A lot  of the fish continued to live in the area



      and  were not killed.  They fed on the dead fish.  We made



      some estimates  of the poundage of menhaden that were killed



 6    and  we estimated it might be about what an ordinary, success-



 7    ful  commercial  fisherman off New Jersey might catch in a




      half hour.



 9             Another thing that I think should be put in per-



10    spective, which was mentioned  earlier, was the kill at




11    Brunner Island.  It is located on the Susquehanna River.



12             The water temperature in the canal, again, was



13    #0°. Through a misfortune in  operation, one of the pumps



14    continued, and  in any event 36° of water was pumped into



15    $0°, and the $0° water very quickly cooled, and the concen-



16    tration of fishes in this canal were killed.



17             However, we estimated — and a chap who works for



      me happened to  be fishing there that morning, so we have



19    very good data  on this — that maybe a third of the fishes



20 [   were killed.  It has been estimated that maybe 15,000 game



21    fish were killed.  Most of these were small.  The company



22    paid something  in the order of $12,000 for this damage, and



23    the  State got a bargain.  It was a political bargain.  The



      fish people working for the State of Pennsylvania obviously



25 j   had  to get something because there was a great hue and cry.

-------
 1                            E. Raney


 2             However, this particular place is the only


 3    place  that you  can fish along the Susquehanna  in winter.


 4    It  is  a  great sport  fishery for muskellunge and bass, and


 5    has been for the last  20 years,


 6             The point  here is that these kind of kills that


 7    are overemphasized,  as I think they were this  morning, are


 &    basically not significant  in an ecological sense, and in


 9    most cases, these heated plumes add very significantly to


10    sport  fishery*


11             Now,  what  about  Zion?  The  situation for a winter


12    kill does not,  in my opinion, exist at Zion even if fishes


13    are found in the heated plume during  winter,   V/hy is this?


14    That outside the 5°  isotherm, or inside the 5° isotherm,
    j

15    you will have velocities of 5 or 6 f.p.s.  Outside the 5°


16    isotherm you may have  a concentration of fishes —— if you


17    drop below, what are you going to get?  You are going to get


      a drop of 5°.


19             Now,  our experimental evidence over  and over


20    again, with 30  different species of fish — and I could cite


      you evidence that was  given here earlier by Mr, Barber of


22    #°  or  more that it takes to cause a fish kill  of coho


 3    salmon — it is highly unlikely that  we would  ever get a


      winter kill in  the plume at Zion,

oc  i
 '  !|           Now,  a few words about the  movement  of fishes in

-------
     		#24


                              E. Raney

     relation to plumes.  Field observations and experimental

     data indicate that a species of fish which is acclimated to

     a given water temperature may move toward or away from a

     higher or lower temperature, depending upon its preferred
   i
 6 !  temperature.  This preferred temperature will vary with the
   i
 7 i  acclimation temperaturej the acclimation temperature varies
   |

 3 11  through the year.
   i
 9             Now, this has been illustrated by the results of
   i[
10   many experiments done  since my last presentation and, as

11 (  Dr, Pritchard mentioned, I think this is one of the real

12   significant contributions that we have been able to make to

13   the literature.  These results are published for estuarian

14   fishes.  Further tests are under way, at the present time,
   i
15   by Bio-Test and will be available shortly.

16             Fishes found in Lake Michigan may be divided

     roughly into three groups.  The so-called cold water fishes

     include the trouts, salmons, smelt, bloater, whitefish,

     ninespine stickleback, and slimy sculpin.  These fishes all

20   have preferred temperatures of something in the fifties or

     maybe low sixties.

               Then we have a group which we call warm water

     fishes.  These, in the Zion area, include fishes like the

     large mouth bass, spottail shiner,  central mudminnow, carp,

     mottled sculpin, and white sucker.  Also in the Zion area,

-------
                              E. Raney



     we have an intermediate group which, for want of a better



     term, you could call cool water fishes.  These include the



     alewife and the yiellow perch.  The smallmouth bass, which



 5   is not very common in this area and, as a matter of fact,



 6   I don't think it was taken by Bio-Test but ultimately will



 7   be, I am confident, and the burbot, which normally is a



     deep water fish, might be classified as intermediate.  In



 9   other words, smallmouth is somewhat intermediate in its



10   preference for warmer water, and the burbot is intermediate



11   in its preference for cold water.  So that the basic point



12   here is that each of these fish has its own preferred temper-



13   ature.



14             Now, all of these fishes may live in winter with



15   temperatures that are as low as 32° to 40° F.  It is very



16   important to remember this, however:  that all can tolerate



17   this range, but none of them prefer it, if other temperatures



     are available, and most importantly if there is a drainage



19   leading to a higher temperature.  In other words, there may



20  | be a lot of heated plumes in a given lake, but unless there



21   are gradients leading into those heated plumes, the fish



22   have no way of knowing this.



23             Now, in Lake Michigan, during the summer, the in-



     shore waters and the upper layers ~ surface layers — are



     warmer than is the deep water which is essentially 40° F.

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                                      	$26


 I                             E. Raney

 2              The  distribution of the  fishes in  spring and fall

 3 |   depend in large part  on preferred  temperature.  They are
   i
 4    usually found  fairly  within a range of temperature close

 5 j   to their preferred temperature.  Now this position may be
   I
 6 |   quantified to  some extent by the previous temperature

 7 j   experience or  its acclimation and  other factors such as

 8 i   water current,  oxygen — which is  not an important factor
   i
   i
 9    in Lake Michigan because the water is mostly saturated —•

10 [   availability of food,  and availability of spawning sub-

11    strate.

12              The  behavior of fishes in Lake Michigan toward a
   j
   j
13    heated plume is predicted to be basically the same as their

14    reaction to the water in the lake  as it changes with
   i
15 j   season.  There is nothing strange  and mysterious about

16    this, and biologists  have recognized this for 100 years.

17    The behavior of fishes of Lake Michigan toward a heated

      plume is predicted to be basically the same  as their re-

      actions to the water  in the lake as it changes with the

20    season.  Because they are able to  discern very small changes

*x I   in temperature,  they  move toward their preferred tempera-
22 !
      ture.  However,  if the change in water temperature is too
23
 J    great,  they may stop  or move away  from the higher or lower
 i
      temperature until a degree of acclimation is reached.  These
25
      reactions have been noted over and over again, I am told,

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                              E. Raney

 2 i|   by myself, and  it has been demonstrated by experiments recentl^

      by Drs. Meldrim and Gift in our- tests at Delaware Laboratory.

               For  example, we worked on 30 species of fish in
 5

 6
 7
 9
10
13

14

15

16

17

18

19

20

21

22

23

24
      this  connection but, for example, you take specimens of the

      largemouth bass which is classified as a warm water fish,

      and we  did, and we acclimated them to 77° on July S.  They

      were  given a  choice of higher temperatures*  They avoided

      a temperature of  $7° F.  In other words, they went up toward
      a  preferred  temperature; when they got to #7° they backed
   i.
11 II   off.

12 :             On July 16, at the same acclimation temperature,
      77°  F»,  they were  given a range of higher temperatures,

      they backed off when  it was 91°•

               Another  example:  The yellow perch, which may

      be classified  as a cool water  fish, although it goes in its

      natural  range  as far  south as  South Carolina — after having
      been acclimated to  77   on July 13, it avoided 93  water.
      And on July 21, when  acclimated to 77  , it avoided 92
      water.
                In other words,  they  go up  into or toward this
      heated water and when it  gets  too hot  for them they turn

      around and they get  out.   And  this  is  in accord with obser-

      vations that have been made  over and over again at thousands

      of different plants  in the temperate regions  of the world

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                               E.  Raney

      involving several hundreds of species  of fish.

                When we get  to  the alewife,  which  I view with

 4  |  mixed blessings,  as I  think  some of you do,  in  the lake —
   il
 5  I  obviously it  is a very important sports fish and also  it  is
    i

 6 il  a damned nuisance.
   i
 7 !|            We  have done a  series of experiments  on the  ale-

 8    wife,  and normally it  is  classified as a cool water fish,
   i
 9    Although the  sea-run alewife,  of course,  lives  in rivers
    I
10  I  during the first year  of  its life  and  it goes back to  sea
    i
11  i  where it lives 3 to 4  years  before returning to fresh  water

12 |i  rivers in order to spawn,
   i!
13 i             We  took alewife acclimated to 77°  and tested

14    them.   They avoided water of S6°,   I think these tempera-

15 j   tures are higher than  we  are going to  see in Lake Michigan
   i
16    at most times, but these  are mere  illustrations of an

17    important point.

                On  October  21, those acclimated  to  64°  avoided

19    water at 76°; and on November 3, those acclimated to 63°

20    avoided water of 79°.
   I
21              The important point here is:  the  avoidance
   i
   i
22 I  temperature or the attraction temperature can vary with the

      acclimation temperature,


 ^ !            Now the important  thing  to remember is illustrated

      by data from  these same fishes.  For instance,  in August,

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     	$29





                              £• Raney



     we took six specimens of alewife, acclimated them to 77° for



     4# hours, introduced them into an experimental apparatus



     where the water temperature was 74°, and they were offered



     two alternatives:  74° or 82°.  Well, what do you think they



     would do?  They proceeded to the area and occupied the



     water that was $2°.  Well, after a short period, these same



 8   six specimens were introduced into a similar experimental



     tank where the water temperature was $0° but where the al-



10   ternative temperature was #6°.  What did they do?  They

   j

11 i  avoided $6°.  In other words, they moved away from it,


   i|

12             I have another experiment listed in the paper

   i
   i

13 i  with similar results.  I won't repeat it.



14             I go into the matter of final preferred tempera-



15   ture and give a table showing the final preferred tempera-



16   ture of some of the fishes which occur in Lake Michigan,



17   but I am not going into a further discussion of that except



1& |  to say a few words about the plume and the behavior of fishes
   i


19   toward the plume, as I predict them, based upon what I have



20 |  seen, as I say, over the last 35 years in temperate



21   regions.



22             fhe plume will vary in temperature with the


90 I
° ;  seasons.  During the summer it will be attractive to warm



2^-   water fishes provided they come into contact with a gradient



25 j  which leads to it.

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                                              	330

 1                             E.  Raney

 2              In the  plume adjacent  to  the  Waukegan  discharge

 •D    during the summer,  fishes classified as warm water  and some
   j
      cool water species  have been found,

                Now,  I  have  predicted  with regard to the  plume  in

 6    the Zion area that  during late fall, winter, and early spring^
   i
 7 j   when the warmest  natural water in Lake  Michigan  is  close
   j|
 3    to 40° F., the so-called cold water fishes which prefer

 9    water in the 53°  to 63° F, range may be found around the

10    periphery of a heated  plume.  However,  they would be found

11    there only if their inshore-offshore migrations  were such

12 |i   that they had an  opportunity to  sense the  gradient  leading

13 |   to the plume.  This should allay the fears of some  who

14    might think that  all of the  salmonid fishes that are in the
   i
15    Zion-Waukegan area  are going to  pile into that  heated water

16    in the winter.  It  does not  work that way  in other  places

17    that have been observed over and over again, including

      stations on Lake  Michigan.

19              It is predicted that; the  heated  plumes from all
   j
20    large plants on Lake Michigan will  produce plume conditions
   i
21 !   that will concentrate  game fishes in areas where they may
   il
22 j   be more readily taken  by anglers.   This has been the almost
   :l
23 j   universal experience around  the  world in temperate  regions,

24-    and I regard this as one of  the  pluses  for a large  plume.

25    if you want to go fishing in the fall or the spring, a very

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   	  _	_831_


 1                            E, Raney

 2   good bet and an easy place to find them is a heated plume, anc.

 3 t  any place that you go in the temperate regions before the

 4   ice comes or goes, you could see people fishing in this

 5   area.

 6             Now, the matter of avoidance of plumes:  Some

 7   like to work on lethal maximum temperatures  of fishes.  It

 $   has no meaning as far as motile organisms are concerned —

 9   in particular fishes with relation to the Zion plant —

10   because they are inappropriate to predict the effects when

11   a  fish comes in contact with higher temperatures, because

12   motile organisms can and do react.  In other words, they

13   behave.  If the water is too warm for them, they avoid it;
   !
14   if it is toward their preferred temperature, they will

15   enter it,

16             So a far more appropriate measure for fishes is

17   the upper avoidance temperature, and these experiments are

     under way now by Bio-Test with the fishes that occur in

19   Lake Michigan,  The Ichthyological Associates have also
   i
20   done enough experiments on temperate fishes that we know
   i
21 j  and can predict what the effects would be,

22             Now, if we go into the literature just briefly

23 j  _ and, as I say, so far in this field, I have studied more

     than 4,000 references that have had to do with this subject,

     I  just point out a few of the results.

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                              _	332



                              E. Raney


 2              The effects of a heated reactor on — or of a


 3    heated effluent was studied at Hanford on the Columbia


      River,  Now,  the plant at Hanford has been in operation for


 5    25 years or more.  The heated plume goes to the center of
   i

 6    the river which, quite by accident, was a good place
   i

 7    to put it, because salmon and trout,  when migrating, take
   j

 8    their clues from along shore.  On the other hand,  shad,


 9    eastern fish  migrate in the  channel,
   i

10              Over that 25-year period, there were no  thermal


11    kills of any  significance observed according to the review
   I

12    by Nakatani (1969)*  Charles  Coutant, whose name was taken


13    in vain, I am sure, by someone this afternoon, also worked


14    out there for several years.   He drifted young chinook salmon^
   i!

15 i   which is a species that we have here, through the  heated


16    effluent at Hanford,  where as I recall the .A T is something


17    in the order  of 20° to 25°.   And the  heated effluent produced


1° !{   no direct or  latent mortalities.   However,  the upper temper—


19    ature was only 77°» which does not exceed the lethal limit


20    for chinook salmon,


21              In  England,  Alabaster made  studies of fish mortalities


22    for 20 years.   In 1969,  he reported that,  based upon field


      and laboratory experiments, kills are extremely rare and


      insignificant  in the population sense.   Now,  I will get back


      to this later  in connection with some of the — I  was going

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    	333_





 1                             E.  Raney



 2    to say propaganda that we have had today  about trout  fishing,



 3              Now,  another very  good example  that I  had the



 4    pleasure of being associated with,  as  far as the study is



 5    concerned,  is the Connecticut River.   The Connecticut Yankee



 6    plant, which was referred to this  afternoon, has been in



 7    operation for about 5 years*  Studies  have been  made  in



 8    depth in those 5 years and for the 2 years preceding  the



 9    operation of the plant, and  there  is a very extensive heated



10    plume there.



11              We have been able  to find no evidence  —• and we



12    have a lot of evidence — no evidence  of  any harmful  effect,



13    either on resident or anadromous species.



14              Now,  in summary, much of the sport fishery  for



15    large species is based on stocking.  It is slow* Much of



16    this work is done out of Ann Arbor.  Their labor sometime



17    will be productive and we will return  ultimately to a case



      where we nave a natural population of  lake trout.



19              i have lived on Cayuga Lake  for the last 40 years.



      Cayuga Lake is a minor edition of  Lake Michigan, and  we  have



21 |   lake lamprey and have had them since the  ice went out 12,000



22 |   years ago, and we don't have a very good  lake trout fishing



      and what we do have is based upon  stocking. So  I think



      you can expect probably what is going  to  happen  if you



2^ i!   want lake trout is to continue to  stock.   I hope not. I

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 2
 o
 i
 c
 7
12
13
14
16
17
13
19
20
21
23
                              __  _   ______ 334
                               E, Raney
      hope we have licked the lamprey  problem.   In the  natural
      experiment over 10,000 years it  was not licked in Cayuga  Lake
      nor was it licked in Seneca Lake, which is another small
      edition of Lake Michigan.
                There is little or no  spawning  of lake  trout  and
      other sport fisheries in the Zion area.   Now,  this is based
      upon several years work by Bio-Test.
                There are no tributaries that  serve  as  a spawning
10    area for large salmonid fishes which  occur in  the Zion  area,
   I!
11 I   I am thinking now of migratory species such as the coho,
      chinook,  sockeye salmon,  that is called — lacustrine
      samples which are called  kokanee,  and the newly-introduced
      1972 Atlantic salmon.
15 |i            You see basically what  you have  in Lake Michigan
      now is nothing like your original fishery.   lou are  dealing
      with a bunch of fish that have been brought  in and hope
      springs eternally and I  do,  too.   I hope it  is successful*
                Now,  most organisms,  including fishes,  because of
      -che Zion plant, will be  denied a  very  small  area close to
      the heated outfall.  We  admit  this —  up to  about 6  acres
                                             r
22    are going to  be denied.   However,  even during  the worst
      summer conditions,  the isotherms produced by using the
      jet effluent indicate that  outside  a  very small mixing
      zone of approximately 5 or  6 acres  most  summer temperatures

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                                                            835-83 6





                               E. Raney



 2    would be  below the upper lethal limit for the fishes and



 o    associated organisms normally found in the Zion Plant area



      in the summer.



                Another important point:  The shallow shore area



 5    located near  the Zion  plant will not be blocked by tempera-



 y    ture increase,  and the  fishes which are normal inhabitants



      of the habitat close to shore during the summer will be



 9    unaffected, in my opinion,



10              Now,  one of the things that people like to talk



11    about is  the  subtle effects in putting fishes under stress.



12    Well, most fishes most  of the time are under one kind of



13    stress or another and,  as one of the speakers this after-



14    noon mentioned 12 or 13 kinds of things that, if these



15    things happen bang, bang, bang, you will have no more



16    fishes.  Well,  you would have to have that happen over and



17    over and  over again.  In the Connecticut River, in the Hud-



      son River and the Delaware River — and I can take you



19    places in the Delaware  River where this has happened now



20    150 years, where you get 100 species of fish.



21              So  that my point is that even under very critical



22    conditions, near the Zion plant, I predict that the fishes



23    will not  be put under  stress, that will make them more



24    susceptible to the predations of gulls or other predators



25    that might be present,  with very few exceptions.

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     	      _  ___      	837-838





                                £«  Raney



                The area near  Zion, in  summary,  is not a unique



      spawning ground for anything; it  is  not an important  spawn-



 4    ing ground for any of  the  large saimonid fishes, and  except



 5 j   for a  few acres,  if it were,  if by chance  fishes chose to



 6 I   spawn  there,  they can  do so seasonally without  interruption,
   i!
   |!

 7 i!   I  predict that there will  be  no permanent  reduction in



 8    species diversity by reason of having these heated plumes



 9 j   in the lake,  including that at Zion,  As a matter of  fact,

   j

10    you are going to  increase  the diversity of fishes because



11 |   you are going to  increase  the potential number  of habitats



12    that you will have. And as far as down-to-earth utiliza-



13    tion of resources,  if  you  believe in using these things for



14    the good of man,  I  think that things will  be improved,
   i


15              One of  the kind  of things  that you must always



      realize when  we are dealing with  fishes is that they  are



17    subject to great  variations in year-class  strata.  You may



      get one yellow perch year-class,  which might arise from



19    very few spawners,  which would produce enough young to



      practically fill  the lake.   These fluctuations  in year-



21    class  are a natural phenomenon.   They will always be  with

   !l

22 '
      us. We are going to get variations  from year to year,


03
 J    This is one of the reasons that it makes base line studies
   [

2.L
      so hard to do;  this is the reason they need to  be done


25
   1   over such a long  period  of time.

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                               E, Raney



                I  am asked quite often by utility executives and



      others:   How long do you need to study  it?  As long as you



      can;  10  years or more.   There are  a lot of young biologists



 5    at work,



 6              One of the concerns that has  been expressed from



 7    time  to  time is that the heated plume from Zion might have



      an effect on the pier fishing for  yellow perch in Lake



 9    Michigan, and pier fishing in other areas.  This is utter



10    nonsense. As compared with the year-class fluctuations,



11    the natural  occurrence in the Delaware  River, any possible



12    effect from  the Zion plant would be miniscule,



13              Few eggs and larvae of fishes have been found in



14    the area. However,  even with the  utilization of this area



15    as it might  sometime be, as a spawning  ground, most of the



16    fishes will  spawn in this area —  all of the salmonid fishes,



17    all of the centrarchid fishes, sunfishes and bass, lay



      adhesive eggs that are emersive — that is heavier than



19    water — and it is highly unlikely that these fishes would



20    pass  through a condenser system,



21              All right.  What if they do?  Fishes vary in their



22    capacity to  stand this trip not only as far as the tempera-



      ture  is  concerned but because of turbulence, abrasion, and



      pressure changes.  Some are more sensitive than others,



2 5              one of the speakers this afternoon, without

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                                £. Raney

      knowing very much about  the background of the  study, indi-

      cated that at the end of a long  canal, the  Connecticut River,

 ^    all of the alewives and  blueback herring were  basically

 5    dead —• and these were larval  herring, basically a half an

 6    inch long.  This is absolutely true.  But immediately after

 7    the passage through the  condenser,  only about  30 to 35

      percent of them were killed in various tribes.  And we find

 9    in our experiments on the Delaware  that this is one of the

10    most sensitive of all larvae —  the clupeid larvae.
   j
11 i             Now I assume that the  alewife larvae Will be

12    there, and I assume that in many cases this will probably

13    be a blessing.   I mean I would regard this  as a plus if

14    some of these alewife larvae were so locked; they will be

15    utilized in the plume as food  providing fishes are there.

16              Now what about fishes  that are a  little bit

17    bigger?  Well,  we hope that the  chinook salmon will spawn

1&    in the lake by the third year, but  there isn't much chance

19    that this will come about, but we will assume that they do.

20              NOW chinook salmon were tested back in 1950 out
   I
21    on the Pacific Coast condenser passage, and it was found
   i
22    that they pass through a condenser  system which is not unlike

      that one at Zion,  with 95 percent or more survival 10 days

      after the trials were over.  They actually  were passed

      through the condenser system.  These were not simulated

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    	#41




 1                             E.  Raney



 2    experiments.



 3              Two final  points,  in summary:   Sudden  changes  in



 4    temperature when Zion drops  load in  the winter will not



 5    because of the jet discharge cause mortalities of fishes.



 6    This has occurred in other places like Oyster Creek, which



 7    I mentioned.



 &              Finally, because of the heated  plume,  the sport



 9    fishery is expected  to be extended in the fall and spring.



10              Now, many  speakers today have talked about in-



11    takes and the proper design  of intakes is a  very serious



12    matter.  I have been involved in consulting  on intake



13    structures for some  years.  I have had a  chance  to look  at



14    what has been designed in connection with Zion.



15              A net is going to  be placed in  such a  position



16    around the intake that the velocity  will  only be 0.29



17    f.p.s. — a very low velocity.  This, I predict, will  keep



13    the large fish out.   It is a one-inch mesh net.



19              Smaller fish will  no doubt pass in and go into



20    the forebay.   Now the problem of what to  do  with the fish



21    that get in there is under study.  There  are various types



22    of screening systems that are being  studied. We know  that



      a product can be developed which will guide  these fish to



      a given place where  they can be lifted  out using an



      elevator, or they can be pumped out  in  a  food-handling

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 5
 7
 1
 9
10
11
12
13
14
15
16
17
IB

                                           _ 842
                                E. Raney
      pump.
                Commonwealth  Edison will  be on top of this
      problem;  we are studying it.  They  are aware of what is
      going  on  in the rest  of the  country, and if there is a
 6    problem here,  I  feel  confident  that we  can  solve it.
                One final  remark  has  to  do with  some of the data
      that  we heard about  this afternoon, taken  out of context;
      Does  a fish kill  damage  the population?
                Now,  I  think that some of my colleagues in
      biology would say:   Well, you know, if the bass bluegills
      get out of balance in my farm pond, what do I do?  I go in
      and drain the pondj  I kill  them all off, and I start all
      over  again.
                The  same  thing  happens  in rivers.  Now, a  speaker
      this afternoon referred to  the  fact that 100,000 white
      perch would be killed in  a  day  in the  Hudson River on the
      screens at Indian Point,  and this is true.  It did happen.
19    That situation is being improved  by new structures that
20    are going to be —  that are being developed and will be put
21    in there.
                However,  and in my opinion — and I worked on
      the Hudson River for  more than  25 years — I think if it
      would kill 100 million white perch, that the other 100 millio:i
2S
 ^    that are in there *—  a 100  million plus or minus —  would

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                                E» Raney



      do  a  lot better.  Why?  Those that are in there now don't



      do  anything.  In other words, they are stuntedj they are



      runts;  they are stinkin'  small fish that at an age of 7 or



 5    S years are only 5 inches long.  These are good for nothing;



 6    they  are good to nobody;  they compete with the striped bass



 7    which is a noble fish.  So please remember when you are talk-



      ing about fish kills, these should be avoided at all costs



 9    because of public relations, but not necessarily because



10    of  the  good of Maw population,



11             I see my counselor is giving me the signal,



12    (Laughter)  He warned me  long ago, and I speak too long,



13 |            MR. FELDMAN:  Mr. Mayo, the last two presentations



14    deal  with cooling towers  and their blowdown and both Mr.



15    Butler  and Dr. Lee are prepared to summarize their state-



16    ments.  I think it will not be long.



17             (Dr. Raney*s presentation follows in its



      entirety.)



19



20



21



22



23



24



25




   L

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   REMARKS ON HEATED DISCHARGES AND FISHES IN SOUTHWESTERN LAKE MICHIGAN IN THE
                    VICINITY OF THE ZION NUCLEAR POWER STATION
                                        by
                                  EDWARD C. RANEY
                             Ichthyological Associates
                       301 Forest Drive, Ithaca, New York  14850

     This document was prepared for presentation to a meeting of  the Four State
Conference to be held  in Chicago, Illinois September 19-22,  1972.  This statement
is presented on invitation by  the Commonwealth Edison Company, Chicago, Illinois.
The  observations, opinions and conclusions presented herein  are mine and do not
necessarily represent  the views of Commonwealth Edison Company.

                           QUALIFICATIONS AND EXPERIENCE
     My name is Edward C. Raney.  I am Professor of Zoology, Emeritus, Cornell
University, Ithaca, New York and Director of Ichthyological Associates, Ithaca,
New  York.  I hold the Ph.D. degree in zoology (1938) from Cornell University.
My scientific specialty is the study of ecology, behavior and systematics of
fishes.  Details of my qualifications in the field of ichthyology and aquatic
ecology were submitted to the  Four State Conference held September 1970 when
I made a presentation entitled "Heated Discharges and Fishes in Lake Michigan."
     Since I appeared before this conference in 1970, I have continued to make
and  direct literature and field studies related to heated discharges and fishes.
In I .A. we have continued the  review of literature which appeared as a published
bibliography in 1969 as "Heated Effluents and Effects on Aquatic Life and
Emphasis on Fishes"  (Ichthyological Associates Bulletin No. 2, 1969, 470 pages,
1870 references).  Continued search has produced more than 2,200 additional
references which will be available shortly as a computer print-out.  Field
studies of aquatic habitats(reservoirs, rivers and ocean)with reference to present
or potential heated plumes have continued in the eastern United States.  I have
either advised or have acted as director of projects on the Connecticut, Hudson,
Delaware and Susquehanna rivers, the upper Chesapeake Bay, the Chesapeake and

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Delaware Canal and the Atlantic Ocean off New Jersey.  Personnel of IchthyoLogical
Ass eiates         have undertaken a series of experimental studies which include
determination of swim speed and stamina of fishes, swim speed and guidence capacity
si ocean fishes off southern California, laboratory experiments dealing with
!re.ttperature preference of fishes and their temperature avoidance or attraction,
and shock experiments.  Similar experiments on preference, avoidance and
£ t iction for a number of chemicals and chemical bioassays are continuing.
T.e results of these have furnished insight with regard to the potential problems
in Lake Michigan near Zion.
     During the past two years I have conferred with biologists and others
associated with Commonwealth Edison, and have had an opportunity to make sug-
gestions and read progress reports of studies being done off the Zion and
Waukegan plants by Industrial Bio-Tests Laboratories, Inc.  Particularly I
aave consulted with Peter H. Howe, Biologist , Commonwealth Edison, Dr. Robert
G. Otto who has been doing experiments on temperature preference of fishes
found in Lake Michigan and have seen reports by and conferred with Michael C.
Cechran of Bio~Te- ;s who has studied fish populations in southwestern Lake
Michigan.
                               PREVIOUS PRESENTATION
     In my presentation made before this conference in September 1970, I
discussed the history of the fish populations of Lake Michigan and generally
discussed temperature requirements of fishes, preferred temperature, lethel
temperature, winter temperature, avoidance temperature, and made a number of
predictions regarding behavior of fishes and the effects on fish populations
in reference to the Zion plume.  In this presentation I will attempt to bring
you up-to-date with regard to the studies which have been made which will help
in explaining my position in regard to what some environmentalists have
thought would be a serious problem.
                              FISHES OF LAKE MICHIGAN
     Great changes have occurred in Lake Michigan fisheries over the past
25 years.  Many of the changes accompanied the introduction of the landlocked
form of the sea lamprey, the alewife and the smelt.  The major changes in fish

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 populations were not associated particularly with the industrial  activities  of
 man  but were mainly as a result of  interaction of fish species.   At  times  and
 with some species commercial overfishing may have been important.  Monumental
 efforts appear  to have brought the  populations of lamprey under control.
 Recently other  species such as the  coho, chinook and kokanee salmon, which are
 native to the Pacific Coast, were introduced and in 1972 the Atlantic  salmon
 was  introduced.  The stocking programs also involve the lake trout and other
 trouts.

                               FISH STOCKING IN 1972
      Information supplied by the Great Lakes Fishery Commission (Commercial
 Fisheries Review for May-June 1972, Nos. 5 and 6, pages. 6-7), indicates
 some 18.5 million hatchery-reared fish will be placed in the Great Lakes in
 1972.  This will be about a million fewer than the 1970 stocking.  Salmon
 will be released in all Great Lakes.  The 9.7 million smolts or young  salmon
 will include 4.3 million chinook, about 4.1 million coho salmon,  over  1.3  million
 kokanee (which  are lacustrine stocks of the sockeye salmon, Oncorhynchus nerka)
 and  about 39,000 Atlantic salmon.   The latter came from Quebec and were released
 In the Boyne and Ausable rivers in  Michigan and in PikesCreek at  Bayfield,
 Wisconsin.  Nearly 5 million lake trout (the most since 1968) were planted in
 Lakes Superior  and Michigan during  the spring of 1972.  The planting of lake trout
 began in 1958 in Lake Superior and  at the same time, tributary streams began to
 receive lampricide treatment.  Including those stocked in 1972 the 15  year total
 for  Lake Superior will exceed 32 million.  Most of the stock is yearling lake
 trout and is largely from U. S. hatcheries.  Also stocked in the  Great Lakes in
 the  spring of 1972 were 3.8 million other trout which included brown,  rainbow,
 steel and splake,  The splake is a  hybrid(lake trout-brook)trout. The  rehabil-
 itation of the  lake trout fishery in Lake Michigan started in 1965 and plantings
 to date total more than 16 million.
     Lake Michigan received nearly  10.3 million stocked fish in 1972.  This
 included 2.9 million lake trout supplied by the U.S. Bureau of Sport Fisheries
 and Wildlife.  The state of Michigan released nearly 5.3 million game  fish in
Lake Michigan.   Wisconsin released about 1.8 million fish into Lake Michigan
during the same period.

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                                         A
                          RECENT FISHING IN LAKE MICHIGAN
     The following comments are modified after those attributed to Dr. Wayne H.
Tody, Chief of the Michigan Department of Natural Resources, Fisheries Division.
(See release of  the Great Lakes Basin Commission entitled "New Developments in
the Great Lakes  Fisheries").  In Lake Michigan in 1972 the lake trout dominated
the open water sports fishing catch during May and early June.  Catches of lake
trout 7 pounds or more were reported.  The coho salmon fishing was exceptionally
good in early spring.  The peak is usually about Labor Day near the parent streams,
The chinook salmon which is a species which is notably difficult to catch during
its life in the  lake, entered the southern Lake Michigan fisheries in markedly
increased numbers in 1972.  Specimens weighing 15 to more than 25 pounds were
caught in the early summer and those of more than 40 pounds are expected in
the fall runs.   Runs of steelhead trout (rainbow) are entering suitable Michigan
streams and Tody reports that rainbow and brown trout are found in many of the
inshore bays.  The yellow perch is increasing in numbers.  It declined after
the decrease in  numbers of the alewife was observed after 1968.  None of the
above generalizations may be specifically applicable to the 2'ion area, but
fishery biologists hope that salmonid fishes will utilize the alewife and
other forage fishes such as the smelt.  The expectation is that the sport or
recreational fisheries will continue to improve but that commercial fishing,
at least in southern Lake Michigan, will be greatly limited or non-existent
except possibly  for the alewife.
                            FISH FAUNA IN THE ZION AREA
   Studies were  made by personnel of Industrial Bio-Tests Laboratories, Inc. of
fishes which occur in the Waukegan-Zion area.  During the period from April
through December 1971 ,  those captured  include the alewife (66.8%) by weight,
lake trout (12.4%), smelt (10.8%), bloater (6.1%).  Those taken occasionally
included brown trout, lake whitefish, yellow perch,  carp, white sucker, chinook
salmon and coho  salmon.   Those  which were considered scarce were slimy sculpin,
lake herring,  goldfish,  spottail shiner,  rainbow trout,  brook trout, longnose
sucker,  emerald  shiner,  trout-perch, golden shiner,  longnose dace, ninespine
stickleback,  mud minnow and johnny darter.   Other species taken in the area
at other times include spoonhead sculpin,  mottled sculpin,  emerald shiner,
lake sturgeon and white  fish.

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      I  pointed  out  in my  1970 presentation  that a section of  Lake  Michigan
 cannot  be  all things to all  fishes at all times.  The distribution of  species
 changes daily and with season.  Much of this change appears to  be  associated
 with  the preferred  temperature of the species, but other variables are involved
 such  as daily migrations, either vertically or inshore-offshore, the presence
 and abundance of food organisms and the necessity for finding suitable spawning
 substrate.
      The inshore waters (up  to possibly 20  feet) is an inhospitable environment
 in the  winter when  water  temperatures approach 32 F and other factors  such as
 bottom  scour with high winds are adverse.
      Off the Waukegan-Zion area the alewife has been found all  months  except
 December.  Smelt have been found during all months.  However  the abundance
 may vary with species from month to month and place to place  within the study
 area.   The lake trout is usually found in water 30 feet or deeper.  The coho
 salmon  appears  to be in the  area mostly in June.  Alewife, smelt and carp  seem
 to spawn to a moderate extent in the area.  For Lake Michigan there is no  lack
 of suitable spawning substrate and nursery  for these species.   The yellow  perch
 has been scarce in  recent years.  Ultimately it may be found  to spawn  in the
 Zion  area, but  this'remains  to be demonstrated.  None of the  large important
 fishes  appear to spawn in the area.  For some such as the lake  trout the type
 of spawning substrate (hard bottom) required is absent or very  limited.
      Fishes which are known  to overwinter in the deeper water off  shore, such
 as alewife, bloater, smelt,  salmon and trout, undertake spring  migrations  into
 the shallows.  The  reverse was noted for the slimy sculpin.
      The heated plume from the Waukegan discharge attracted young  alewives and
 several  species of minnow, including the carp.
     Water temperature in the depths offshore was more stable than those of
 inshore waters during the period from April through December  1971.  However
 in the deeper water fluctuations during a month maybe as much as 5.4 F
 (August to September at 90-foot depth in the Zion zone).
     Water temperature at comparable depths at  three north to south zones  were
 similar and differences were normally 3.6 F or  less.   I reemphasize my 1970
 testimony that small differences in temperature,  including those up to 5 F,
have little or no ecological significance to fishes found in Temperate regions.

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                                         6
                         THERMAL PLUME AT ZION AND FISHES
     The design of the cooling water system with a submerged jet as described
by Dr. Pritchard (April 1970) is such that at the area inside the 5 F isotherm
is less than six acres.  The jet is designed so that within the 6 F isotherm,
the velocity approaches A fps.  It is obvious that only a few acres would be
denied to fishes by this combination of high temperature and high velocity.
An advantage of the jet system is that no kills are predicted to occur because
of high temperatures alone — the so-called heat kills.  Indeed such kills are
a rarity in nature with reference to cooling water at any power plants except
In situations with long discharge canals in which sudden and substantial
decreases in winter temperature occur.  Such a situation does not occur at
Zion and indeed the time of entrainment of an organism as it passes into the
condenser until it reaches the 5 degree isotherm is short (approximately four
minutes).  Because of the relative high velocity of the water within the 5
degree isotherm and because few fishes are predicted to be present in this
area close to the jet, sudden shutdowns in winter will not cause mortalities
(winter kill) of fishes.  The maximum temperature decrease would be 6 F or
less.  Even if it were a 10 F decrease the experimental evidence with fishes
indicates that this will not cause mortalities or undue stress.  Under the!
jet conditions even if stressed a fish would quickly be carried out of the
area of maximum temperature.
                     MOVEMENT OF FISHES IN RELATION TO PLUMES
     Field observations and experimental data indicate that a species of fish
which is acclimated to a given water temperature may move toward or away from a
higher or lower temperature, depending upon its preferred temperature.  This
has been illustrated by the results of many experiments done since my last
presentation.
     Fishes found in Lake Michigan may be grouped with regard to temperature
preferences into three groups.  The so-called cold water fishes include the
trouts. salmons, smelt, bloater, whitefish, ninespine stickleback and slimy
sculpin.  The contrast are those which prefer warm water such as large mouth
bass. spottail shiner, central mudminnow, carp, mottled sculpin and white
sucker. An intermediate group which prefer cool water include the alewife
and yellow perch.   The smallmouth bass and burbot may be classified with

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 cool water  fishes.  However  the  smallmouth is somewhat intermediate  in
 preference  toward warm water while  the burbot is intermediate  in  preference
 toward  cold water.
     All of the  fishes listed above live, in some part of its  range,  in
 water   where  the winter  temperature may vary between 32 and  40 F.  or,  all
 can tolerate  this temperature range, but none prefer it.
     In Lake  Michigan during the summer, the inshore waters  and the  upper
 layers  (epilimnion  and thermocline) are warmer than is the deep water
 (hypolimnion) which is essentially  40 F.
     The distribution of the various fishes in spring and fall depends in
 large part  on the preferred  temperature.  They usually are found  fairly
 within  a range of temperature close to their preferred temperature.  The
 position within  this range may be modified to some extent by the  previous
 temperature to which the fish had been acclimated, and other factors such  as
 availability  of  water current, oxygen, food, and suitable spawning areas.
     The behavior of the fishes  of  Lake Michigan toward a heated  plume is
 predicted to  be  basically the same  as their reactions to the water in  the
 lake as it  changes  with  season.  Because they are able to discern small
 differences , in temperature,  they move toward their preferred temperature.
 However, if the  change in water  temperature is too great they  may stop or
 move away from a higher  or lower temperature until a degree  of acclimation
 is  reached.   These  reactions have been noted in nature and have been de-
 monstrated  by experiments by Drs. John W. Meldrim and James  J. Gift
 (Ichthological Associates Bulletin  7).
     For example, specimens  of the  largemouth bass which is  classified as
 a warm  water  fish, were  acclimated  to 77 F on July 8, avoided  a temperature
 of  87 F, while on July 16 at the same acclimation temperature  they avoided
 91  F.
     The yellow  perch which may  be  classified as a cool water  fish,  after
 being acclimated to 77 F  on July 13 it avoid 93 F and on July  21 when
 acclimated  to 77 F  avoided 92 F.
     Experiments with the alewife, which is classified as preferring cool
water,  show that the avoidance temperature may vary with the acclimation
 temperature.  For example on 5 August specimens of the alewife acclimated
 to  77 J1 avoided water of 86 F.   On 21 October those acclimated to  64 F
avoided water at 76  F.  On 3 November those acclimated to 63 F avoided  79 F.

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                                        8
     A closer look at the same experiments illustrates attraction to a higher
temperature.  In August, six specimens of alewife were acclimated at 77 F for
48 hours.  They were introduced into an experimental apparatus where the water
temperature was 74 F, and they were offered two alternatives, 74 F or 82 F.
They proceeded to the area and occupied water of 82 F.  After a short period,
these same six specimens were introduced into a similar experimental tank
where the water temperature was 80 F, but where the alternative temperature
of 86 F was available.  The latter temperature was avoided.
     In another experiment in August, the results were similar.  Six specimens
were acclimated at 77 F, introduced into water of 75 F, and were attracted to
water 83 F.  A short time later the same fishes were placed in water of 80 F.
They avoided the alternative temperature which was 86 F.  In the above experi-
ments the water temperatures exceeded those generally expected in Lake Michigan.
However, it illustrates the expected reaction of a species,  such as the alewife,
if and when it comes close to a heated plume.  Anxiety with regard to an expected
large mortality of the alewife near heated plumes is unfounded and except under
unusual conditions such as crowding little mortality is expected.
     Knowledge of the final preferendum temperature, which is the temperature
to which a fish will go when given an unlimited time to acclimate , enables
predictions of what will happen near a heated plume in Lake Michigan.

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Table 1.— The final Preferred Temperature in degrees F for various Species
           of Fishes Found in Lake Michigan.  Modified after Ferguson, 1958.
Species
Carp
Smalimouth Bass
Yellow Perch
Muskel lunge
Burbot
Yellow Perch
Brown Trout
Brook Trout
Sockcye Salmon
Rainbow Trout
Whitefish
Lake Trout
Chinook Salmon
Final Preferendum
89
82
75
75
70
70
54-63
57-61
58
56
55
54
53
Authority
Pitt, Garside and Hepburn (1956)
Fry (Ms., 1950)
Ferguson (1958)
Jackson and Price (Ms., 1949)
Grossman, e± al_. (Ms., 1953)
McCracken and Sparkraan (Ms., 1948)
Tait (Ms., 1958)
Graham (1948), Fisher and Elson (1950
Brett (1951)
Garside and Tait (Ms., 1958)
Tompkins and Fraser (Ms.? 1950)
McCauley and Tait (Ms., 1956)
Brett (1951)

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                                        10
The plume will vary in temperature with the seasons.  During  the  summer  it will
be attractive to warm water fishes provided they come into contact with  a gradient
at the edge of the plume.  In the plume adjacent to the Waukegan  discharge during
the summer fishes classified as warm water and some cool water species have been
found.
     During late fall, winter and early spring when the warmest natural  water  in
Lake Michigan is close to 40 F, the so-called coldwater fishes which prefer water
in the 53 - 63 F range (see Table 1) may be found around the periphery of a
heated plume.  However, they would be found there only if their inshore-offshore
migrations were such that they had an opportunity to sense the gradient  leading
to the plume.
     In summer the alewife, yellow perch and other fishes which prefer warm
water would be found in the outer part of the plume.
     It is predicted that the heated plumes from all large plants on Lake
Michigan will produce plume conditions which will concentrate game fishes in
areas where they may be more readily taken by anglers.  This has  been the
almost universal experience with heated plumes in temperate regions of the world.
                                AVOIDANCE OF PLUMES
     Lethal maximum temperatures for motile organisms such as fishes are
inappropriate to predict the effects when such species encounter  higher
temperatures (plumes), because such a measure ignores the behavior of the
organisms and the period of time which an organism might be in contact with
such a temperature.  It is proper to use such a measure only for  organisms
which cannot avoid, and which remain, in the increased temperatures.  A  far
more appropriate measure for fishes is the upper avoidance temperature.
     Recent observations at large power stations discharging relatively  large
volumes of heated water confirm the absence or rarity of thermal  fish kills
or of serious biological change.
     The effect of the heated reactor effluent at Hanford on the  Columbia River
was observed on salmon and trout over a 25 year period.  No thermal kills of any
significance were observed according to the review by Nakatani (1969).   Live
box tests in the Columbia River by Coutant et al, (1968) with young chinook
salmon in a heated effluent produced no direct or latent mortalities, but the
temperature rises did not exceed the lethal limit for this salmon (77 F).

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                                        11
     In England, Alabaster (1969) made studies of fish mortalities, both in
the laboratory and in the field, and reported that kills under field conditions
are extremely rare and insignificant in a populational sense.
     Neither have thermal kills or other harmful ecological effects been observed
on the lower Connecticut River in connection with the operations of the Connecticut
Yankee Power Plant, as reported by Merriman (1970).
     Field observations on young american shad in the Connecticut River have been
confirmed by experimental work done by Moss (1970).  Variations in temperature
up to 5 F elicit little or no response in young shad.  Temperature changes
greater than 5 F are avoided.
     Other extensive studies by Meldrim and Gift (1971) and Gift and Westman
(1971) indicate similar behavior for fishes.

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                                        12

                                      SUMMARY

     1.   Much of the present sport fishery for large species is based
on stocking.
     2.   There is no or little spawning of lake trout and other large
sport fishes in the Zion area.
     3.   No tributaries which serve as a spawning area for large salmonid
fishes occur in the Zion area.
     4.   Most organisms including fishes will be denied a very small area
close to the heated outfall at Zion.
     5.   Even during the worst summer conditions the isotherms produced by
using a jet effluent indicated that outside a small mixing zone of approximately
4-5 acres near the effluent most summer water temperatures would be below
the upper lethal temperatures for the fishes and associated organisms normally
found near the Zion plant in the summer.
     6.   The shallow shore area located near the Zion plant will not be
blocked by temperature, and the fishes which are normal inhabitants of the
habitat close to shore during the warmer summer months will be unaffected.
     7.   Even under the most critical summer conditions it is predicted that
the fishes or other biota will not be placed under serious stress, which would
affect the size or the quality of the populations.
     8.   The area near Zion is not a unique or important spawning ground but,
except for a few acres, the seasonal temperature requirements for reproduction
and other aspects of the life history of the fishes which are seasonally present
in the Zion area are predicted to be satisfactory.
     9.   Fishes which normally live in the Zion area are adapted to the changes
in temperature which occurs in the environment at the several seasons and may
avoid, be attracted to or not react to temperatures in various parts of the plume,
     10.  No permanent reduction in species diversity in fishes or associated
biota is predicted either in the vicinity of the plant or in the Lake in general
due to the operation Zion.
     11.  Compared to natural changes including year class fluctuations, any
change in fish populations which might be attributed to the effect of heated
effluents would be miniscule and insignificant to a commercial or sport fishery.
     12.  The heated effluents from nuclear power plants will not affect the
"pier" fishing for yellow perch in Lake Michigan.  The fishery has fluctuated
greatly over the years and is expected to continue to do so.

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                                        13

     13.  Few eggs and larvae of fishes have been found in the area.
The fast passage through the condenser system is expected to cause little
mortality to larvae.
     14.  Young fishes may pass through the condenser with a relatively high rise
(20 F) but fast passage (approximately 4 minutes) with little mortality.  In
experiments with chinook salmon, 95% or more survived for ten days after the
trials.
     15.  Sudden temperature changes when Zion suddenly drops load in winter
will not because of the jet discharge cause mortalities of fishes.
     16.  Because of the heated plume the sport fishery is expected to be
extended in fall and early spring.

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                                        14
                                    REFERENCES

Alabaster, John S.  1969.  Effects of heated discharges on freshwater fish
     in Britain.  In:  Biological Aspects of Thermal Pollution, Vanderbilt
     Univ. Pres, Chap.  11:354-370.
Alabaster, J. S., and A. L. Downing.  1966.  A field and laboratory investigation
     of the effect of heated effluents on fish.  Fish.  Invest. (Min. of
     Agr., Fish, and Food, U. S.)  Ser. I, 6(4):42 p.
Coutant, C. C., C. D. Becker and E. F. Prentice.   1969.  Biological effects
     of thermal discharges (Ann. Prog. Rep. 1968).  Battelle Mem. Inst.,
     Pacific Northwest Lab., Richland, Wash., Rep. No. BNWL-1050.  49 p.
Ferguson, R. G.  1958.  The preferred temperature of fish and their mid-
     summer distribution in temperate lakes and streams.  J. Fish
     Res. Bd. Canada.  15(4):608-624.
Gift, James J. and James R. Westman.  1971.  Responses of some estuarine
     fishes to increasing thermal gradients.  Dept. Env. Sciences Rutgers. 1-154.
Meldrim, John W. and James J. Gift.  1971.  Temperature preference and
     avoidance responses and shock experiments with estuarine fishes.
     Ichthyological Associates Bull. 7. 1-75.
Merriman, D.  1970.  The calefaction of a river.   Sci. Amer.  222(5):42-52.
Moss, Sanford A.  1970.  The responses of young American shad to rapid temperature
     changes.  Trans. Amer. Fish. Soc.  99(2):381-384.
Moyer, Stanley and Edward C. Raney.  1969.  Thermal discharges from a large
     nuclear plant.  Jour. Sanit. Eng. Div. A. S. Civil Eng. SA6:1131-1163.
Nakatani, R. D. 1969.  Effects of heated discharges on anadromous fishes.
     In:  Biological Aspects of Thermal Pollution.  Vanderbilt Univ. Press,
     Chap. 10:294-337.
Raney, E. C., and B. W. Menzel.  1969.  Heated effluents arid effects on aquatic
     life with emphasis on fishes.  A bibliography.  Cornell Univ.
     Water Res. Mar. Sci. Cent., Phila. Elect. Co., Ichthyol. Ass. Bull.
     No. 2. 470 p.

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                                                               344
 1                            0. Butler
 2
                     STATEMENT OF OLIVER D. BUTLER

                          GLEN ELLIN,  ILLINOIS
               MR.  BUTLER:  Mr,  Chairman,  conferees, ladies and
 7
      gentlemen.  My name  is Oliver  D, Butler,  I reside at 912

      Waverly Road,  Glen JEllyn, Illinois,
 Q
               I appeared before this conference in September

      1970 for the purpose of presenting  cost estimates for

      closed cooling system alternatives  for Commonwealth
12
      Edison's Zion  station,
13
               During the October 1970 and March 1971 conference
14
      proceedings, cost estimates were also presented by Dr.
15
      Tichenor of the Pacific Northwest Water Laboratory which
16
      he had prepared at the request of the Federal Water Quality
17
      Administration,
18
               Subsequent to Dr, Tichenor's first appearance, we
19
      contacted him  to obtain the detailed cost breakdown used
20
      in the Federal Water Quality Administration report.  This
21
      information was carefully analyzed  and a comparison of the
22
      Federal Water  Quality Administration and Commonwealth
23
      Edison figures was prepared.  This  cost comparison was
24
      forwarded to the conference in April 1971 for incorporation
25
      into the conference  record. This incorporation did not

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 1
 2
 3
 4
 5
 6
 7
 a
 9
10
11
12
13
14
15
16
17
18
19
20
21
                                                              845
                              0. Butler
     occur — at least not in our copy of the proceedings,  I
     have come back to put that material before you.  I also
     want to update those estimates.
               The first comparison I want to make is shown on
     Exhibit A and is a cost comparison relating to dry mechanical
     draft cooling towers,  (See p. 846)  Our figures are about
     8 times higher than the Federal Water Quality Administration
     estimates,  I can give you the reasons for that in detail,
     but I have a strong feeling that there is now general
     agreement that dry towers are out of the picture.
               The prepared paper lists some of the reasons of
     why our estimate is higher.  In the interest of time, I will
     omit reading that and go on to the other estimate.
               We have also prepared a cost estimate for round
     wet mechanical draft cooling towers.  That is shown in
     Exhibit B to ray paper.  (See p, 847)  It shows a total cost
     of $124 million.  This compares with the estimate that was
     submitted for the record in April 1971 of $116 million.
     The difference is inflation and some relatively minor
     changes each way in certain cost elements.  The following
      factors are relevant to the comparison of FWQA's results
      and ours:
                1.  Our costs are based on backfitting the
25 ''
24
      existing  Zion  installation.  Theirs were for optimum design

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 Costs (In Frccr.s of Once-Through)

 I. Capital Investment Costs
    a.  Punps & Recovery turbines
    b.  Basic Tower Units
    cf  Footings
    d.  Controls
    e.  Piping, Valves & Tanks
      .  1) Backfitting Piping6
    f.  Land Costs
    g.  Road & Track Work*
    h.  Earthwork5
    i.  Yard drainage, underground
          interference, & fence-
          work
    j.  Electrical
    k.  Contingencies
    j..  Tup Clio.A't,e5
        Subtotal
II. Operating & Maintenance Costs^
    a.  Loss of Capability
    b.  Increased fuel costs
    c.  Maintenance
        Subtotal
II.  Total Cost (Capital Inv.  &
                 Oper.  & Haint.)
COST CO;.TAPI:;ON'
ALTERNATE
Interior
Dollars
1,360,000
10,200,000
Included
510,000
1,700,000
-
-
-
—
-
Included in
3,230,000
•* .. ..•» .. .» . .1 t ..
J-liC-LUUC-U J.IJ
17,000,000
7,000,000
12,827,500
Included in
19,827,500
KSAJ!" 0? COOLIIIC
Dry Mechanical
DePt. Hcrort1'
Hills/
C/KW K'.s'HR
1.36 .03
10.20 .20
in b. above
.51 .01
1.70 .03
-
•-
-
mm •»
_
a,b,d,&e above
3.23 .06
.fxi. t"jlj v c
17.0 .33
7.0 .14
12.83 .25
b. above
19.83 .39
Exhibit A
Dated 9-72
Draft Coolin-t Tov;ers
C.E.Co
Dollars
Included
150,000,000
3,300,000
1,750,000
29,200,000
23,230,000
6,400,000
2,450,000
31,000,000
790,000
.49,201,000
7,125,000
33,056,000
342,502,000
90,043,000
22,294,000
9,043,000
121,380,000
. Studies2
S/KW
in e^ below
68.18
1.50
0.80
13.27
10.56
2.91
1.11
14.09
.36
22.36
3.24
17. 30
155.60
40.93
10.13
4.11
55.17
Mills/
KV/HR

1.79
.04
.02
.35
.28
.08
.03
.37
.01
.59
.08
.45
4.09
1.07
0.27
0.11
1.44
                                                   .72
                                   36,827,500    36.83
Kotes: 1.  Estimates based on 1,000 nw - fossil unit
       2.  Estimates based on 2,200 inw - nuclear unit  (Zion)
463,882,000   210.85    5.54
3.  Earthwork includes items such as overburden raroval,  dewaterin--;,  excavation for
    Circulating water piping L tover footings, and  compacted  fill  i'or ror.ds  & towers
4.  Land cost estimated at SlO,000/acre
5.
6.

7.
           Road £ track work includes relocation of exist:;-.,- ror.ds, protection  of circula-
           ting water piping at road crossings & alteration of track spur
           Backfitting piping includes such itcr.s as modification to cxist:ng service water
           eysten,  alteration of existing submerged circulating water intake piping, and  ne,
           booster pulping stations
           Cost breakdown reference - October ]6, 1970, Letter-Bruce Tichcnor,  Pacific llo~th-
           wcct Laboratory to 0. D. Butler, C.E.Co.
                                                                                           ew
       8.  Costs arc  listed  in  equivalent  invcstuent  dol^.ars.

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                                                                             Exhibit B
                                                                             Dated 9-72
                                     ALTERNATE I-MANS OF CCOLING
0-"ts (In Excess of Once-Through)
                                         Wet Mechanical Draft Coolinr  Towers
                                               Case II

                                       Interior Dent. Report
                                                      1
  I.  Capital Investment Costs

      a.  Condensers &, Pumps

      b.  Basic Tower Units

      c.  Footings

      d.  Piping & Valves

          1) Backfitting piping'

                   ,4

                          ,5
                               3,100,000    1.41

                               8,100,000    3.67

                              Included in b_._ above

                              Included in a. above
                                                          Kills/
                                                           K.;HR
.027

.072
e.  Earthwork

f.  Road & Trackwork

g
          Yard drainage, under-
          ground interferences &
          fencing
      h.  Electrical

      i.  Contingencies

      j.  Top-charges

          Subtotal

 II.  Operating & Maintenance Costs

      a.  Loss of Capability
                              •7
      b.  Increased fuel costs
                     7
      c.  Maintenance

          Subtotal

III.  Total Costs (Capital Inv. &
                  Oper. & Haint.)
                              Included in a. &'b_._ above

                              Included in a.&b. above

                              Included in a.&b. above

                              11,200,000    5.08    .099
                               1,010,000    0.46    .009

                              Included in b. above

                               1,010,000    0.46    .009
                              12,210,000    5.54
.108
                                                                      C.E.Co.  Studio
Dollars         £/KW



Included in d_._ below

 18,000,000     8.18

Included in b. above
0.236
  Notes
11,700,000
21,138,000
12,950,000
365,000
260,000
1,950,000
1,835,000
10,222,000
78,420,000
34,105 ,000
11,037,000
464 ,000
45,606 ,000
124,026 ,000
5.32
9.61
5.89
0.17
0.12
0.89
0.88
4.65
35.65
15.50
5.02
0.21
20.73
56.38
ff. (2.2 scale-up) (new
0.153
0.277
0.170
0.005
0.003
0.026
0.024
0.134
' 1.028
0.45
0.14
0.01
0.60
1.63
site)
         2.  Based on Zion 2200 mw nuclear 72;= cap. factor  33£  eff.  (backfit)

         3.  Backfitting piping includes such items as modification  to  existin,: service
             water system, chun/.ing of existing submerged circulating water intake piping,
             and new booster pucping stations

         4.  Earthwork includes such itcrss as overburden renoval,  dcv,ratering,  excavation
             for circulating water piping and tower footings, and  compacted fill for road-
             ways and to'./ers

         5.  Road & track.vork includes relocation  of  existing roa.;u, protection of circula-
             ting water piping at road crossings and  railroaJ spur alterations

         6.  C.E.Co. :stu--.y is based on uce ol a hybrid roun) mechr-.nic-al draft  tower with
             250' hyperoolic uircnarge stack for plume disper:al

         7.  Costo are listed in equivalent investment dollars.

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 7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
                                                	343

                         0, Butler
of a new plant,
          2.  We have calculated costs on the basis of using
250-feet high/ round, wet, mechanical draft cooling towers.
These towers have been considered because of the airport
height problem at Zion which 1 discussed in my 1970 testi-
mony.  The tower manufacturer does not predict satisfactory
performance of a 250-foot natural draft tower at the Zion
location.  We and the manufacturer feel that the new design
concept offers a better solution to fogging and height
restriction problems at the Zion location than either con-
ventional mechanical draft or natural draft towers.  This
design also disfigures the site less than the tall towers
would.
          The 250-foot  mechanical draft towers, which would
use fans in a hyperbolic shell, are considerably more expen-
sive than conventional mechanical draft cooling towers but
not appreciably different in cost than our estimate for
natural draft towers.  The soil conditions and grotmd load-
ing requirements of these structures increase the cost of
their installation over conventional mechanical draft towers
at the Zion location.  It should be noted that although we
have compared to Federal Water Quality Administration figures
for conventional wet mechanical draft towers, our cost
25
     estimate considerably exceeds the Federal Water Quality

-------
    „	$49




  1                             0,  Butler



  2    Administration's natural draft tower cost estimates*



  3              3»  The Federal Water Quality Administration report



  4    does not consider a charge for loss of capability for any



  5    of the "wet" cooling alternatives.  Compared to once-through



  6    cooling on Lake Michigan, this charge is substantial  and



  7    should be considered*  Our turbines at Zion were specifi-



      cally designed to fully utilize the effect of the relatively



  9    cool Lake Michigan water



10              4*  Our charges for loss of capacity utilize the



11    average cost of Zion, which  is $207 per kilowatt*  It seems



12    clear to me that the real cost, when you lose part of a



13    base load plant, is in base  load,  rather than peaking



14    capacity, and that the Zion  cost is the one that we should



      use.  Later plants have had much higher costs per kilowatt



16    of capacity and to replace base load nuclear capacity lost



17    by a cooling tower installation, starting today, it would



      cost nearly twice the cost I have used,



19              We originally pointed out that it was necessary



20    -fcO recognize the substantial extra costs of backfitting when



21    adding a closed cooling system to an existing plant.   Our



22    original estimate of $116,855,000, which is now $124,026,000,



23    has been confirmed by estimates and actual experience of


9L
 *    other utilities which are in the process of trying to back-



25    fit stations on Lake Michigan,  I refer to pages 103  and 109

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                                                               a 50

 I                             0.  Butler
 2    in the "Summary of Recent Technical  Information   Concerning
 3    Thermal Discharges to Lake Michigan,"  which  is part of the
 4    Environmental Protection Agency  presentation to you,  I
 5    read that actual cost experience is  indicating that the  esti-
 6    mates I have just given you  may  be low,  and  are unlikely to
 7    be high.
 8              I would also point out that  Dr.  Tichenor is quoted
 9    in that report as now agreeing that  backfitting will cost
10    three times as much as building  a plant  designed  for towers.
11    He has increased his original estimate from  0.2 mill per
12    kilowatt hour in October 1970 to 0.6 mills per kilowatt
13    hour (referring to page 105  of the previously referenced
14    report).  His old estimate for an optimized  plant designed
15    for cooling towers was 12 times  less than my estimate.   He
16    is now only one time less — i.e., just  about half of our
17    figure.  I am pleased to see that he has become more
      realistic, and I am sure that if he  could take up the
      invitation we have repeatedly extended to EPA to  come see
20    the Zion site, and to determine  with us just how  hard it is
21    to turn a plant entirely around  in order to  cool  it by  dif-
22    ferent means, he would take the  last step and raise his
      estimate one more multiple.   We  would, then, be in agree-
      ment.
                In the interest of time,  I will confine ray

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   	851
 1                            0, Butler
 2   discussion of Exhibit B to point out some of the significant
 3   differences between the FWQA estimates and the estimates
 ^   that I  submit:
 5             1.  Referring to Exhibit B, the costs in dollars
 6   in  column 1 are taken from Dr. Tichenor*s 1970 figures,
 7   His figures, however, were costs for a 1,000 m  nuclear
 8   unit.   The fourth  column is for Zion station, a 2,200  MW
 9   nuclear unit*  Because Zion is 2.2 times the size of the
10   plant  estimated by Dr. Tichenor, we have multiplied Dr.
11   Tichenor's costs by  2.2 to make the figures more easily
12   comparable.  I do  not know if he would agree that a straight
13   multiplication was the way to do it.  One can also compare
14   the two estimates  by looking at the last line entry at the
15   bottom of the page,  where  both dollar costs are converted
16   to  mills per kilowatt hour.  That  figure has not been
17   multiplied  by  2.2,
IS              2.   Item I(b)  is the cost of the basic tower unit.
19   We are less far  apart here than  in some  other areas, and,
20    as I said earlier, the  actual  figures  coming  in on other
21    plants are  roughly like our  figures,  not the  Federal  Water
22    Quality Administration's.
23 |             3.  items I(c),  (d),  and (e)  represent  backfitting
      and site work not included in the Federal Water Quality
      Administration estimates.   They come to somewhat more than

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                                                               352
 «!_                            0. Butler
 2   twice the basic tower cost, a figure not too far removed
 3   from Dr. Tichenor's estimate, quoted by the Argonne
 4   Laboratory, that backfitting triples the cost.
 5             4.  Finally, Item II(a) gives our cost estimate
 6   for loss of capacity, a  factor which the Federal Water
 7   Quality Administration omitted.  This loss is $34 million
 8   in the case of  Zion.  That is a  factor which would largely
 9   not occur in  a  plant originally  designed for cooling  towers.
10   It is both a  very  large  dollar amount and one we feel
11   strongly about.
12             I hope that this data  will help you make your
13   judgments based on the real  costs  to a real plant.
14             That  is  the end of my  prepared testimony.
15             MR. MAYO:  Thank you,  Mr. Butler.
16              (Mr.  Butler's  presentation follows in its
17   entirety.)
IB
19
20
21
22
23
24
25

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                                         September 1972

                  STATEMENT OF OLIVER D. BUTLER

          My name is Oliver D. Butler.  I reside at 912 Waverly
Road, Glen Ellyn, Illinois.
          I appeared before this conference in September 1970 for
the purpose of presenting cost estimates for closed-cooling system
alternatives for Commonwealth Edison's Zion Station.  In April
1971 cost estimates for back-fitting closed-cooling systems to
our Waukegan and State Line generating stations was submitted to
the conference for the record.  During the October 1970 and
March 1971 conference proceedings, cost estimates were presented
by Dr. Tichenor of the Pacific Northwest Water Laboratory which
he had prepared at the request of the Federal Water Quality
Administration.
          Subsequent to his first appearance, we contacted
Dr. Tichenor to obtain the detailed cost breakdown used in the
Federal Water Quality Administration report.  This information was
carefully analyzed and a comparison of the Federal Water Quality
Administration and Commonwealth Edison figures was prepared.  This
cost comparison was forwarded to the conference in April 1971 for
incorporation into the conference record.  This incorporation did
not occur, at least not in our copy of the proceedings.  I have
come back to put that material before you.  I also want to update
those estimates.
          The first comparison I want to make is shown on Exhibit A
and is a cost comparision relating to dry mechanical draft cooling
towers.  Our figures are about 8 times higher than the Federal
Water Quality Administration estimates.  I can give you the

-------
                              - 2 -






reasons for that in detail, but I have a strong feeling that



there is now qeneral agreement that dry towers are out of the



picture.  I would point out that dry towers really need a direct



contact condenser.  We would have to delay operation for about



two years in order to tear out our present condensers and obtain



new ones of the direct contact type - if some manufacturer is



willing to undertake ones of this size.  For the record/ our cost



estimate, in equivalent investment dollars, is $463,882,000.



Exhibit A shows the breakdown of those costs.  These cost estimates



nave not been updated from the April 1971 data submission.



          Let me emphasize that, except for capacity losses, our



cost estimates are still design estimates.  These are not shelf



items, and it is difficult to know the cost of building a one of



a kind item until the project is completed.  This is especially



true if nothing comparable in size has ever been built before.



          We have also prepared a cost comparison for round wet



mechanical draft cooling towers.  It is shown in Exhibit B.  It



shows a total cost of $124 million dollars.  This compares with



the estimate that was submitted for the record in April 1971 of



$116 million.  The difference is inflation and some relatively



minor changes each way in certain cost elements.  The following



factors are relevant to the comparison of FWQA's results and ours:



          1.  Our costs are based on back-fitting the existing



              Zion installation.  Theirs were for optimum



              design of a new plant.



          2.  We have calculated costs on the basis of using



              250 ft. high,  round,  wet, mechanical draft



              cooling towers.  These towers have been considered




              because of the airport height problem at Zion which

-------
                    - 3 -





    I discussed in my 1970 testimony.   The tower



    manufacturer does not predict satisfactory per-



    formance of a 250 ft. natural draft tower at the



    Zion location.  We and the manufacturer feel that



    the new design concept offers a better solution



    to fogging and height restriction  problems at the



    Zion location than either conventional mechanical



    draft or natural draft towers.   This design also



    disfigures the site less  than the  tall towers would.





    The 250 ft. mechanical draft towers, which would



    use fans in a hyperbolic  shell,  are considerably



    more expensive than conventional mechanical draft



    cooling towers but not appreciably different irx



    cost than our estimate for natural draft towers.



    The soil conditions and ground loading requirements



    of these structures increase the cost of their



    installation over conventional  mechanical draft



    towers at the Zion location.  It should be noted



    that although we have compared to  Federal Water



    Quality Administration figures  for conventional



    wet mechanical draft towers, our cost estimate



    considerably exceeds the  Federal Water Quality



    Administration's natural  draft tower cost estimates.



3.  The Federal Water Quality Administration report



    does not consider a charge for  loss of capability



    for any of the "wet" cooling alternatives.  Compared



    to once-through cooling on Lake Michigan, this



    charge is substantial and should be considered.



    Our turbines at Zion were specifically designed to

-------
                              - 4 -

              fully utilize the effect of the relatively cool
              Lake Michigan water.
          4.  Our charges for loss of capacity utilize the average
              cost of Zion, which is $207 per kilowatt.  It seems
              clear to me that the real cost, when you lose part
              of a base load plant, is in base load, rather than
              peaking capacity, and that the Zion cost is the
              one to use.  Later plants have had much higher
              costs per kilowatt of capacity and to replace base
              load nuclear capacity lost by a cooling tower
              installation, starting today, would cost nearly
              twice the cost I have used.
          We originally pointed out that it was necessary to re-
cognize the substantial extra costs of backfitting when adding
a closed cooling system to an existing plant.  Our original es-
timate of $116,855,000 which is now $124,026,000 has been con-
firmed by estimates and actual experience of other utilities
which are in the process of trying to backfit stations on Lake
Michigan.  I refer to pages 108 and 109 in the Summary of Recent
Technical Information Concerning Thermal Discharges to Lake
Michigan, which is part of the Environmental Protection Agency
presentation to you.  I read that actual cost experience is
indicating that the estimates I have just given you may be low,
and are unlikely to be high.
          I would also point out that Dr. Tichenor is quoted in
that report as now agreeing that back-fitting will cost three
times as much as building a plant designed for towers.  He has
increased his original estimate from 0.2 mill kw/hour (October
1970) to 0.6 mills/kw hour (p. 105 of the previously referenced

-------
                              - 5 -





report).  His old estimate for an optimized plant designed for



cooling towers was 12 times less than my estimate.  He is now



only one time less - that is,  just about half of our figure.  I



am pleased to see that he has  become more realistic, and I am



sure that if he could take up  the invitation we have repeatedly



extended to EPA to come see the Zion site,  and determine with.



us just how hard it is to turn a plant entirely around in order



to cool it by different means, he would take the last step and



raise his estimate one more multiple.  We would then be in



agreement.



          I suspect I should take you through the cost comparison



shown on Exhibit B line by line, because it is complicated.  I



am willing to take you through the detail behind each of those



entries.  Perhaps it is appropriate, however, if I point out



some major differences.



          (1)  Referring to Exhibit B, the costs in dollars in



column  1, are taken from Dr.  Tichenor's 1970 figures.  Those,



however, were costs for a 1000 raw nuclear unit.  The fourth column



is for Zion station, a 2200 mw nuclear unit.  Because Zion is



2.2 times the size of the plant estimated by Dr. Tichenor we have



multiplied Dr. Tichenor's costs by 2.2,  to  make the figures more



easily comparable.  I do not know if he would agree that a



straight multiplication was the way to do it.  One can also



compare the two estimates by looking at the last line entry at



the bottom of the page, where  both dollar costs are converted



to mills per kilowatt hour. That figure has not been multiplied



by 2.2.

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                              - 6 -





          (2)  Item I(b) is the cost of the basic tower unit.



We are less far apart here than in some other areas, and as I



said earlier, the actual figures coming in on other plants are



roughly like our figures, not the Federal Water Quality



Administration's.



          (3)  Items I(c) (d) and (e) represent back-fitting and



site work not included in the Federal Water Quality Administration



estimates.  They come to somewhat more than twice the basic tower



cost, a figure not too far removed from Dr. Tichenor's estimate,



quoted by Argonne Laboratory, that back-fitting triples the cost.



          (4) Finally, Item II (a) gives our cost estimate for



loss of capacity, a factor which the Federal Water Qualit"



Administration omitted.  The loss is $34 million.  That is a



factor which would largely not occur in a plant originally



designed for cooling towers.  It is both a very large dollar



amount, and one we feel strongly about.



          I hope that this data will help you make your judgments



based on the real costs to a real plant.

-------
  Costs (in Prcors of Once-Through)

  I. Capital Investment Costs
     a.  Punps & Recovery turbines
     b.  Basic Tower Units
     ct  Footings
     d.  Controls
     e.  Piping, Valves & Tanks
       .  l) Backfitting Piping6
     f.  land Costs*
         Road & Track Work
     g«
     h.
Earthwork'
     i.  Yard drainage, underground
           Interference, & fence-
           work
     3.  Electrical
     k.  Contingencies
     1.  "op CJioi-^eo
         Subtotal
 II. Operating & Maintenance Costs8
     a.  loss of Capability
     \>.  Increased fuel costs
     c.  Maintenance
         Subtotal
III. Total Cost (Capital Inv. &
                  Oper. & Haint.)    36,827,500    36.83
  Notes; 1.  Estimates based on 1,000 nw - fossil unit
COST
ALTERNATE
Interior
Dollars
1,360,000
10,200,000
Included
510,000
1,700,000
-
-
-
-
-
Included in
3,230,000
laoluficfi in
17,000,000
7,000,000
12,827,500
Included in
19,827,500
COMPARISON
KKAfn 0? -COOT.1KC
Dry Mechanical
1 '7
Dent. Rerort '
Hills/
C/KW KWKR
1.36 .03
10.20 .20
in b_._ above
.51 .01
1.70 .03
-
-
-
-
-
a,b,d,&e above
3.23 .06
f', CkuGVC
17.0 .33
7.0 .14
12.83 .25
b_._ above
19.83 .39
Exhibit A
Elated 9-?2
Draft Coolin-7 Towers
C.E.Co
Dollars
Included
150,000,000
3,300,000
1,750,000
29,200,000
23,230,000
6,400,000
2,450,000
31,000,000
790,000
.49,201,000
7,125,000
33,056,000
342,502,000
90,043,000
22,294,000
9,043,000
121,380,000
. Studies2
S/KW
in e. below
68.18
1.50
0.80
13.27
10.56
2.91
1.11
14.09
.36
22.36
3.24
17. 30
155.68
40.93
10.13
4.11
55.17
Hills/
K'.YHR

1.79
.04
.02
.35
.28
.08
.03
.37
.01
.59
.08
.45
4.09
1.07
0.27
0.11
1.44
                                                  .72
463,882,000   210.85    5.54
         2.  Estimates based on 2,200 ir.w - nuclear unit  (Zion)
         3.  Earthwork includes itcras such as overburden r3r>oval, dewaterinn, excavation  for
             circulating water piping L tover footings, and compacted fill lor ror.ds &  towers
         4.  land cost estimated at SlO,000/acre
         5.  Road & track work includes relocation of exist Jr.,;: roads, protection of circula-
             ting water piping at road crossings & alteration of track spur
         6.  Backfittjng piping includes such itcr-.s as modification to existing service water
             Bysten, alteration of existing submerged circulating water intake piping,  and  new
             booster pulping stations
         7.  Coct breakdown reference - October 36, 1970, Letter-Bruce Tichenor, Pacific  llorth-
             wcst Laboratory to 0. 1). Butler, C.K.Co.
         8.  Costs arc listed in equivalent investment dollars.

-------
                                           COJT COMPARISON
                                     ALTERNATE KKANS OF CCOLIHG
                                                                             Exhibit B
                                                                             Dated 9-72
°*>sta (In Excess of Once-Through)
                                         Wet Mechanical Draft Cooling  Towers
                                               Case II
                                       Interior Dent. Report
  I.  Capital Investment Costs
      a.  Cond2i*.3ers & Pumps
      b.  Basic Tower Units
      c.  Footings
      d.  Piping & Valves
          1) Backfitting piping5
      e.  Earthwork
      f.  Road & Trackwork-'
      g.  Yard drainage, under-
          ground interferences &
          fencing
      h.  Electrical
      1.  Contingencies
      j.  Top-charges
          Subtotal
 II.  Operating & Maintenance Costs
      a.  Loss of Capability
                              7
          Increased fuel costs
                    ,7
                              Dollars

                               3,100,000
                               8,100,000
              1.41
              3.67
                                                          Mills/
                                                           K,;HR
.027
.072
                              Included in b. above
                              Included in a. above
b.
c.
          Maintenance
          Subtotal
III.

  Motes
Total Costs (Capital Inv. &
            Oper. & Maint.)
                              Included in a.&b.. above
                              Included in a.&b. above
                              Included in a.&b. above
                              11,200,000    5.08    .099
 1,010,000    0.46    .009
Included in b_._ above
 1,010,000    0.46    .009
12,210,000    5.54    .108
                                                                      C.E.Co.  Studies
                                                                                     2,6
                                Dollars
                         C/KW
Included in d_._ below
 18,000,000     8.18
Included in b_._ above
 11,700,000     5.32
 21,138,000     9.61
 12,950,000     5.89
    365,000     0.17
          34,105,000
          11,037,000
            464,000
          45,606,000
               15.50
                5.02
                0.21
               20.73
         124,026,000    56.38
                                                                                       Mills/
 0.236

 0.153
 0.277
 0.170
 0.005
260,000
1,950,000
1,835,000
10,222,000
78,420,000
0.12
0.89
0.88
4.65
35.65
0.003
0.026
0.024
0.134
1.028
   1.  Based on a 1000 mw nuclear unit - 82;i cap. fact. 33£ eff. (2.2 scale-up)  (new
   2.  Based on 2ion 2200 mw nuclear 72-^ cap. factor 33/» eff. (backfit)
   3.  Backfitting piping includes such items as modification to exis:tin,:  service
       water system, changing of existing submerged circulating water intake pipanj,
       and new booster punping stations
   4.  earthwork includes fiuch iteras as overburden removal, dcv/atcring, excavation
       for circulating water pipin/; and tower footings, and compacted fill for road-
       ways and towers
   5.  Road <£ trackwork includeo relocation of existing roa.is, protection  of circula-
       ting water piping at road crossings and railroad spur alterations
   6.  C.E.Co. stu:,y is based on use of a hybrid roun:! mechanical draft tower with
       250' hyperuolic tiifcharne stack for plume dispersal
   7.  Coeto are listed in equivalent investment dollars.
 0.45
 0.14
 0.01
 0.60

 1.63
site)

-------
 T                               G. Lee
 2
 3
               MR. MAYO:  Thank you.
 5
 6
 7
 9
10
11
12
13
14
15
16
17
19
20
21
22
25
               MR. FELDMAN:  The last statement, Mr, Mayo, is
     by Dr. G. Fred Lee.
                     STATEMENT OF DR. G. FRED LEE,
                     PROFESSOR OF WATER CHEMISTRY,
                        UNIVERSITY OF WISCONSIN,
                           MADISON, WISCONSIN
                DR.  LEE:  My name  is  G.  Fred Lee.  I am Professor
      of Water Chemistry  at the  University of  Wisconsin in
      Madison.  I am also a consultant  to  the  Commonwealth
      Edison Company.
                Thus far  this  afternoon and this evening,  we have
      heard about the rather minimal  effects  that the  Zion plant
      once-through cooling will  have  on water quality  in the
      region of Zion.
                We have just  heard about the  cost of backfitting
      cooling towers.  Now I  want to  return to the question of
      water quality and look specifically at what might be the
      effects of cooling tower blowdown on water quality in the
      region of Zion.
                A. report by the FWQA presented at the workshop
      back in 1970  concluded that cooling tower blowdown

-------
     	354
 •^                              G. Lee
 2    from  towers  located at  Zion would not  cause water quality
 3    problems in  Lake Michigan.  However, if you examine their
 4    report  you see  that there is real questions to be raised
 5    about the basis for their conclusions.
 6              First, the  FWQA assume that  the makeup water at
 7    Zion  would be equal to  the average  composition of the water
 &    in the  open  lake.  Well, it is  well known that the water
 9    near  shore often has  much higher concentration of chemicals
10    than  the open lake water and, in fact, the  composition of the
11    water near shore today  in the Zion  area  exceeds the  current
12    Illinois Pollution Control Board standards  for some  chemi-
13    cals.
14              The FWQA»  in  their 1970 report, assumed that the
15    criteria to  judge  adverse  effects was  the drinking water
16    standards of the U.S. Public Health Service of 1962.
17              Generally,  it is well known  that  the aquatic life
13    standards for fish and  aquatic  life are  much stricter than
19    drinking water standards.   In other words,  if a  fish can
20    swim in it and reproduce in it, generally man can drink it.
21              The FWQA assumed that the only process determining
22    the chemical composition in the blowdown is a fivefold
2^    evaporative concentration of this water,
24-              Actually there are a number of other processes
2 ^    that lead to chemicals in cooling tower blowdown,   such

-------
 1                              G. Lee
 2   processes as the addition of chemicals for water condition-
 3   ing.  Also you have the fact that a cooling tower of the
 4   wet  evaporative type is a very efficient air scrubbing
 5   device,  so you will scrub certain chemicals from the atmos-
 6   phere.
 7             Further you have the leaching of chemicals and the
 8   corrosion of the structure itself to consider in any cooling
 9   tower situation.
10             Since I feel that the FWQA assumptions are  un-
11   realistic with respect to the potential effects of  blowdown
12   from a Zion  cooling tower system, I have undertaken to
13   prepare a review of the potential effects of this blowdown
14   on the water quality  in the region of  Zion.
15             This review consists  of two  parts, both of which
16    have been given  to  the  conferees.  One of them  is a 50-page
17    literature  review,  in which I  have tried to put together
IS    what I have found over  the  past year,  in the  area of:   What
19    do we know about blowdown from cooling towers?
20              The second is a summary  of the specific  effects
21    that I predict for the Zion plant  should cooling towers be
22    required.
23              Now,  I will summarize a summary of the summary
2/f    this evening.  The other materials,  I assume,  can be
25    entered into the record without having to read them.

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 6
 b
 9
10
     	856


                                 G.  Lee

 2 II             Now,  the  differences between my approach to this

 3    situation of blowdown at  Zion  and  the previous approach  is

 4 ij   that I will actually use  water quality for  the region of

 5 I   Zion based on the chemical studies of Bio-Test Laboratories,

      where a 16-month study has been completed and we  do  have

      data now on the chemical  composition of  the water in this

      region, and this is water that would be  the makeup water

      for a cooling tower at Zion.

                Further,  I will judge the significance  of  chemi-
   i,
11 !'   cals in the blowdown, based on the State of Illinois Water

12    Quality Standards applicable to that region.

13              Also, I will assume that the  cooling towers at

14 i   Zion will operate with evaporative concentration  factors
   f j
15 i   of 4.24.  This is the design engineers'  criteria. And

16    that the only chemicals used for conditioning water  at
17 I   zion will be sulfuric acid or neutralization of alkalinity

13 j   and chlorine as a biocide.
   I
19 |j             The blowdown from cooling towers at Zion will be

20 !   in the order of 16 c.f.s., which is a pretty fair stream of
21
22 !
23

24
25
      water.
                Now, let's take a look briefly at the various
      chemicals which will be at or near the critical concentra-

      tions in the blowdown from Zion.

                First, the ammonia content of blowdown from the

-------
   	357
 -^                              G, Lee
 2   cooling towers located at Zion would likely exceed the
 3   Illinois Pollution Control Board standard for lake water
 4   at the point of discharge*
 5             Boron.  The boron concentration in the blowdown
 6   will be about one-half of the Illinois Pollution Control
 7   Board for the lake water standards,
 g             Cadmium,  Cadmium in the blowdown will meet the
 9   Illinois Pollution Control Board lake water standard but
10   it is expected to be much higher than the cadmium standards
11   that have been recommended for other waters of the Great.
12   Lakes,
13             Chromium,  Blowdown will meet the chromium stan-
14   dard at  Zion,  It should be  noted, however, that 'many
15   cooling  towers located throughout the State of Illinois
16   will not meet this  standard,
17              Chloride,  The  blowdown will likely exceed the
1#    Illinois Pollution  Control Board lake water standard at
19    the point of discharge  for  chloride,
20 !             Copper and Iron.   Copper  and iron in the  blowdown
21    will be approximately  equal  to the  Illinois Pollution Control
22    Board lake water standard,
23              Mercury.   The mercury content  of lake  water from
      the Zion area of Lake Michigan is already above  the
25    Illinois Pollution Control Board standards.   Evaporative

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  2
  3
  4
  5
  6
  7
  <5
  9
10
11
13
14
15
16
17
19
20
21
23
                           Q* Lee
concentration of that water by 4,24 would cause the mercury
in the blowdown to exceed the Illinois Pollution Control
Board standard by 6 times.
          Oil,  Oils in the blowdown due to the evaporative
concentration of the makeup water are expected to be about
equal to the Illinois Pollution Control Board standard,
          Phjos£horus,  Evaporative concentration of the
makeup water by 4,24  results  in  a phosphorus blowdown  of
approximately 20 percent of the Illinois Pollution Control
Board lake standard without any use of phosphorus in the
12  '<  cooling tower as a corrosion or scale-controlled chemical.
The blowdown from Zion would stimulate algal growth in the
region of Zion due to the phosphorus present as the result
of simple evaporation of the water,
          Sulfate,  The sulfate in the makeup water at
Zion, when concentrated by evaporation, will exceed the
Illinos Pollution Control Board standard by 4- to 5-fold.
Furtheri since sulfuric acid will be needed to neutralize
the alkalinity to prevent scale, it is expected that the
blowdown from a cooling tower at Zion would have a
sulfate concentration 7 times the Illinois Pollution
Control Board standard.
o i  I
 ^ !             Suspended Solids,  The makeup water at Zion already
25
 '    exceeds the Illinois Pollution Control Board standard for an

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   	359	

 2_                              G. Lee

 2   effluent discharge to Lake Michigan with respect to suspended

 3   solids.

 4             Evaporative concentration of cooling water will

 5   cause the blowdown to greatly exceed the effluent standard*

 6             Zinc*  The concentration of zinc in blowdown will

 7   be  expected to be less than the Illinois Pollution Control

 8   Board standard.  However, a recent EPA study has shown that

 9   zinc in cooling tower blowdown is toxic to aquatic life at

10   levels  considerably less than the current Illinois Pollution

11   Control Board standard  and the expected concentration of

12   zinc in the blowdown from Zion.

13             Conclusions,  The expected composition of blow-

14   down from a cooling tower at Zion, without any  direct addi-

15   tion of chemicals  for water  conditioning will exceed the

16   Illinois Pollution Control Board  standard for many  chemi-

17    cals,

IB             Contrary to the  statement made by  the FWQA in

19    1970,  cooling tower  blowdown at  Zion will have  adverse

20    effect on water quality in the region of  Zion.

21              Further,  it  is reasonable to predict  that as  a
   i
22    result of new water quality  criteria  that  are being de-

      veloped today,  where we are  emphasizing the chronic sub-

      lethal effects of chemicals on aquatic organisms,  that

      the current water quality standards will be even made more

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 •,
 1
 2
 3
 6
 7
 H !
 
-------
                                	861
                                 G.  Lee
 2    with discharging large volumes of concentrated chemicals
 3    from cooling tower blowdown into  the  lake.
 4              Thank you.
 5              MR. MAYO:  Thank you, Dr. Lee.
 6              (Dr. Lee's  presentation follows in its entirety.)
 7
 9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25

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The   University  of   Wisconsin
                                            WATER CHEMISTRY LABORATORY
                                            MADISON, WISCONSIN 53706
                                            262-2470
                                            AREA CODE 608

                     September 27, 1972

 Francis Mayo
 U.S. Environmental Protection Agency
 Region V
 33 East Congress Parkway
 Chicago, Illinois 60605

 Dear Mr. Mayo:

    On Thursday, September 21, I testified before  the Lake
 Michigan Enforcement Conference on the effects of  cooling
 tower blowdown on receiving water quality.  Subsequent to this
 testimony, I found several minor editorial changes  that should
 be made in the material incorporated into the record.  For
 example, when the tables on page 8 were typed, the  "less
 than" signs were omitted.  These corrections, however,
 do not change the conclusions in the paper.

    I suggest that you incorporate the enclosed copy  of the
 "Estimated Potential Problems with Cooling Tower Blowdown
 at Zion Thermal Electric Generating Station" into  the record
 rather than the material that I submitted previously.
                              Sincerely
                              G. Fred Lee
                              Professor of Water Chemistry
GFL/lm
Enclosure

-------
                         Estimated Potential Problems with
                          Cooling Tower Slowdown at Zion
                       Thermal Electric Generating Station*

                       G. Fred Lee1 and Charles Stratton2
                             Water Chemistry Program
                             University of Wisconsin
                               Madison, Wisconsin


     A report published by the Federal Water Quality Administration (1970) conclud-

ed that cooling tower blowdown water from a thermoelectric plant such as the Zion

plant of the Commonwealth-Edison Company, located on Lake Michigan, would not cause

water quality problems. However, careful examination of this report raises questions

about the basis for this conclusion. For example, the average composition of south-

ern Lake Michigan offshore water was used as an approximation of the composition of

the makeup water that would be used in a cooling tower at Zion. Commonwealth-Edi-

son's data (Bio-Test Industrial Laboratories, 1971) for nearshore waters off Zion

indicated somewhat different values. The concentrations of certain chemicals in the

makeup waters is close to and occasionally exceeds some of the water quality cri-

teria that have recently been adopted by states bordering on Lake Michigan.

     The authors of the FWQA report also assumed that the only process leading to

increased concentrations of chemicals in the blowdown water is a five-fold evapora-

tion concentration. No corrections were attempted for such factors as chemicals

added for water conditioning, chemicals derived from air scrubbing, or chemicals

derived from corrosion or leaching from the structure of the tower.

     The most serious objection to the FWQA conclusion is based on the fact that

the authors of this report have assumed that the criteria by which cooling tower

blowdown water could be judged objectionable is the 1962 Drinking Water Standards

of the U.S. Public Health Service. In most cases, water quality criteria for aqua-
     1
      Professor of Water Chemistry
     ^Graduate student in Water Chemistry
     *Presented in essentially the same form at the Lake Michigan Enforcement Con-
ference, September, 1972.

-------
                                       - 2 -




tic life are much more stringent than the criteria for drinking water. It is inter-




esting that a federal agency uses aquatic life criteria when it wishes to show that




the current or proposed method of discharge is not acceptable, i.e., once-through




cooling. The same federal agency, however, uses drinking water criteria when they




wish to show that the alternative methods, proposed by the agency, are satisfactory.




     This paper presents the expected chemical composition of cooling tower blow-




down water from a thermoelectric plant similar to the proposed Zion installation,




and potential water quality problems that may exist, should cooling towers be re-




quired to meet the thermal effluent standards. Data gathered for Commonwealth-Edi-




son from the waters near Zion will be used as representative of the cooling tower




makeup water. Consideration will also be given to chemicals added for treatment of




the cooling tower water, to corrosion products from the system, to leaching of




chemicals from the structure, and to scrubbing of chemicals from the air passing




through the tower. It will be further assumed that a concentration of the makeup




water constituents by a factor of 4.24 according to the cooling tower design repre-




sents the minimum expected concentration of chemicals in the blowdown water. This




assumption will be somewhat in error as a result of the loss of chemicals by drift




from the tower.




     Lee and Stratton (1972) have recently completed a literature review on the




general aspects of the expected effects of cooling tower blowdown water on receiv-




ing water quality. This review should be consulted for further information on this



topic.




     Although it is impossible to make a precise estimate of the blowdown water




chemical composition, it should be possible to make a much more reasonable estimate




by the above approach than that taken by the FWQA (1970).




     The expected characteristics of the cooling towers that may be installed at




the Zion Station of the Commonwealth Edison Company are listed in Table 1.

-------
                                       _ O _

                                     TABLE 1

                Characteristics of Cooling Towers at Zion Station
                             of Commonwealth Edison

                                                     Amount
                                           Percent*         GPM**
                Evaporation                  1.9            28,600
                Slowdown                     0.5             7.400
                Drift                        0.1             1.470
                Makeup                       2.5            37,470

                *percent of total flow rate
               **gallons per minute
                        (Sargent and Lundy, 1971)

     The cooling towers would be operating on a 1,470,000 gpm per unit circulating

water flow rate and a temperature of 24.2°F. for both units at: Zion. An attempt

will be made to maintain 700 mg/1 total dissolved solids in the recirculating water,

which results in a concentration of the makeup water by a factor of 4.24. It is ex-

pected that 1 mg/1 of chlorine for a 30-minute duration three times a day will be

fed to the recirculating water. Further, it is expected that sulfuric acid will be

needed to neutralize 90% of the bicarbonate alkalinity. It is assumed for the pur-

poses of this paper that it will not be necessary to add other chemicals such as

phosphates, zinc, etc. that are normally used in cooling tower water conditioning.

Should any of these chemicals be needed at the Zion plant cooling towers, their

respective concentrations would be increased significantly over those predicted in

this paper.

     The volumes presented in Table 1 are based on both nuclear units operating at

Zion. It is estimated that the drift from the Zion cooling towers would be in the

order of 1,470 gpm, which amounts to about 0.1% of the recirculating water flow.

The blowdown will be 7,400 gpm or 16 cfs from the two units.

     In order to judge the potential significance of the blowdown water, the esti-

mated concentration of those chemicals that are considered to be potential problems

will be compared to the State of Illinois Water Pollution Regulations, adopted by

-------
                                      - 4 -




the Illinois Pollution Control Board  (1972). These standards are listed in Table




2. Both effluent and lake standards have been established.




     Table 3 presents the average and maximum chemical composition of the nearshore




waters in the region of the Zion thermoelectric generating station, based on a 16-




month study conducted by Bio-Test Industrial Laboratories (1971) on behalf of the




Commonwealth-Edison Company. These data are based on studies conducted on the Lake




County water supply intake in the period January, 1970, through April, 1971. During




this period, samples were obtained at approximately bi-weekly intervals.




     Ammonia.  The Illinois Pollution Control Board (IPCB) has not adopted an ef-




fluent standard for ammonia. However, a lake standard of 0.02 mg/1 as nitrogen has




Deen adopted. The studies by Bio-Test Laboratories (1971) show that the average con-




tent of ammonia in the waters in the region of Zion is 0.04 mg/1 ammonia nitrogen.




An evaporative concentration by a factor of 4.24, as proposed for the Zion plant,




zesults in 0.17 mg/1 ammonia nitrogen. However, studies have shown (Lee and Strat-




ton, 1972) that evaporative type cooling towers tend to promote nitrification reac-




tions in which the ammonia present is converted to nitrate.  Further, the chlorina-




tion of the recirculation water will tend to reduce the ammonia content through




oxidation by chlorine. To counter this, precipitation in the liidwest typically con-




tains 0.5-1 mg/1 of ammonia nitrogen. Studies currently being conducted by the au-




thors show that cooling towers tend to scrub ammonia from the atmosphere, showing




a higher concentration in the recirculation water than in the makeup water. There-




fore, even though the exact ammonia content of the blowdown water is impossible to




estimate at this time, it is reasonable to expect that the concentration at the




point of discharge would be in excess of the IPCB lake standard.




     Boron. Bio-Test Laboratories (1971) found that the average boron content of




the waters in the region of Zion was 0.10 mg/1.  The IPCB established a total boron




lake concentration of 1.0 mg/1.  It is evident that the evaporative concentration of

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- 5 -
TABLE 2


Water Quality Standards Applicable to Slowdown Water From
A Cooling Tower at Zion Commonwealth Edison Plant
Parameter Effluent Standard
Ammonia as N
Arsenic (total)
Barium (total)
Boron (total)
Cadmium (total)
Chromium (total hexavalent)
Chormium (total trivalent)
Chloride
Copper (total)
Cyanide (total)
Fluoride
Iron(total)
Iron (dissolved)
Lead (total)
Manganese (total)
Mercury
Nickel
Nitrate plus Nitrite Nitrogen
Oil (hexane soluble)
Oxygen
pH
Phenols
none**
0.25
2.0
none
0.15
0.3
1.0
none
1.0
0.025
2.5
2.0
0.5
0.1
1.0
0.0005
1.0
none
15
none
5 to 10
0.3
Lake Standard*
0.02
0.01
1.0
1.0
0.01
0.05
1.0
12.0
0.02
0.01
1.4
0.3
0.3
0.05
0.05
0.0005
1.0
10.0
0.1
not less than 90%
saturation except
due to natural
causes
7 to 9
0.001

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                                      - 6 -

Parameter                   Effluent Standard              Lake Standard

Phosphorus                       1.0                            0.007

Selenium (total)                 1.0                            0.01

Silver (total)                   0.1                            0.005

Sulfate                          none                           24.0

Suspended Solids (Inorganic)     15                             none

Suspended Solids (Organic)       5                              none

Total Dissolved Solids           3500                           180

Zinc (total)                     1.0                            1.0

All concentrations expressed in mg/1

*mixing zone permitted, not to exceed area of circle with 600 ft. radius
**No effluent standard established for this parameter

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- 7 -
TABLE 3
Chemical Composition of the Water
Area of Zion Thermoelectric Generating
Commonwealth-Edison Company
Parameter
DO
BOD
COD
TOG
NH3-N
NO--N
NO~-N
2
Turbidity
Total Phosphate as P
Total Dissolved Solids
Total Suspended Solids
Specific Conductance at 25
umhos/cm
Total Hardness as CaCO
Total Alkalinity as CaCO^
Total Coliforms/100 ml
Fecal Coliforms/100 ml
Fecal Streptococci/100 ml
Ca
Mg
Na
K
Cl"
Average*
11.8
2.0
8
9
0.04
0.23
0.007
11
0.038
174
13
°C
282
138
110
74
12
3
36
12
5
1.1
8.7


in the
Station for
Maximum*
8.8 (min.)
4.0
13
24
0.08
0.52
0.02
39
0.068
211
73
321
155
123
267
68
9
39
12.4
7
1.4
11.6

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Parameter



SO"



F~




sioz




pH



Total organic Carbon




Oil (hexane soluble)




Color (true)



MBAS




Phenols



Cyanide




Hg



As



Cd



B




Fe



Cu



Cr



Zn



Ni



Pb



Mn



*all concentrations in mg/1



After Bio-Test Industrial Laboratories (1971)
-8-
Average*
20.7
0.15
1.1
8.1
10
2.3
3
<0.025
<0.001
< 0.005
0.00075
0.0014
^0.001
0.10
0.24
0.003
0.002
0.04
0.002
0.003
0.0062

Maximum*
24.7
0.29
2.2
8.2
20
5.3
6
-10.025
^0,001
^0.005
0.0026
0.0031
<0.001
0.16
0.45
0.007
0.009
0.1
0.004
0.006
0.024

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                                      - 9 -




Lake Michigan water in the region of Zion would cause the boron content of the ef-




fluent blowdown to be approximately half of the lake water standard.




     Cadmium. The IPCB has established a total effluent cadmium concentration of




0.15 mg/1 and a lake cadmium limit of 0.01 mg/1. These limits are considerably




higher than the limits which have been proposed by the FWQA (1969) for Lake Super-




ior, where it has been found that cadmium levels in excess of 0.0005 mg/1 have an




adverse effect on some aquatic organism reproduction. The Bio-Test studies have




shown that the cadmium content of the waters in the region of Zion is less than




0.001 mg/1. If it is assumed that the concentrations of cadmium in Lake Michigan




are similar to those of Lake Superior, that is 0.0002 to 0.0004 mg/1, then the ex-




pected evaporative concentration of this water could lead to the cadmium content




in the blowdown being in excess of the recommended limit for Lake Superior. However,




it would meet the IPCB criteria for Lake Michigan.




     Chromium. Bio-Test Leboratories reported the average total chromium content




of the waters near Zion to be 0.002 mg/1. The IPCB established a total hexavalent




chromium standard for effluent of 0.3 mg/1 and a total trivalent chromium standard




for the effluent of 1.0 mg/1. If the IPCB standards are compared to the data from




various Illinois state institutional cooling tower effluents (Illinois State Water




Survey, 1971, see Lee and Stratton, 1972), it is seen that the chromium content of




these blowdown waters is often 12 to 60 mg/1. Of course, all of these plants are




using a chromate treatment for corrosion control. While it is doubtful that any




chromium would be used in the treatment of an evaporative type cooling tower at




the Zion plant, such use would necessitate the installation of facilities to re-




move chromium from the blowdown water.




     Chloride.  The IPCB established a 12 mg/1 chloride limit for lake water,,  The




average content of chloride in the region of Zion is 8.7 mg/1,  with a maximum value




of 11.6 mg/1.   Evaporative concentration of this water by a factor of 4.24 would

-------
                                     - 10 -
cause the chloride content of the blowdown to exceed the established lake criteria




and would necessitate rapid dilution of this water in order to meet these criteria.




The chlorine used as a biocide in the cooling tower recirculating water would




tend to increase the chloride content of the blowdown water to a small but measure-




able degree; however, it could also cause other detrimental effects in the blow-




down water.  Recent studies by the EPA Duluth laboratory have shown that chloramines




which would be formed upon the reaction of chlorine and ammonia are toxic to




aquatic organisms at concentrations of a few ug/1.  While a large part of the




added chlorine would be consumed as chlorine demand, it is possible that some




of the chloramines would be present in the blowdown water.




     Copper.  The survey by Bio-Test Laboratories indicates the average copper




content of the water near Zion is in the order of 0.003 mg/1.  The IPCB has




established a total copper limit in the effluent of 1.0 rag/1 and a lake limit of




0.02 mg/1.  A concentration of the makeup water by a factor  of 4.24 would result




in the copper content in the blowdown approaching that of the lake water limit.




Many of the cooling towers examined by the Illinois State Water Survey (1971) show




copper concentrations on the order of 0.01 mg/1 or greater.  Since most makeup




waters generally contain copper in amounts considerably less than this value, there




is an indication that copper is accumulated within the recirculating system,




possibly derived either from corrosion of the system or from scrubbing of copper




from the atmosphere.   Available data show that copper exists at levels of 27 ug/1




in precipitation across Canada (Thompson,  1971).  This indicates that scrubbing




of copper from the air may be a significant factor in cooling towers.




     Iron.  The IPCB established a total iron standard in the effluent of 2.0 mg/1.




Bio-Test Laboratories has found that the average total iron in this region is




0.24 mg/1.  This is very near the IPCB lake standard of 0.3 mg/1.   Examination of

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                                       -li-
the data obtained from Betz Laboratories (1971; See Lee and Stratton, 1972) shows




that some of the cooling towers examined had iron concentrations in excess of




the IPCB standard.  It is, therefore, possible that the iron content of the blow-




down water from a cooling tower located at Zion would approach the IPCB standard




for this element and might on occasion exceed this standard.  Studies currently




in progress by the authors indicate total iron levels well in excess of 2 mg/1




from the cooling towers under study.




     Mercury.  An effluent and a lake standard of 0.0005 mg/1 total mercury have




been set.  Lake water in the Zion region is reported to contain 0.00075 mg/1




mercury and is therefore currently in excess of both the effluent and lake standards.




The blowdown would be concentrated to a level of about 0.003 mg/1 mercury.




     Nitrate.  The lake standard for nitrate plus nitrite nitrogen is 10.0 mg N/l.




Nitrites and nitrate compounds are occasionally used as corrosion inhibitors in




cooling towers.  When these compounds are used, the blowdown nitrate concentration




can be quite high (62 mg/1 for one tower studied by Fisher and Jeter as reported




by Savinelli and Beecher, 1966), hence it must be assumed that the permitted




mixing zone is sufficient to accomodate the necessary dilution of the blowdown




effluent.




     Oil, hexane soluble.  A limit of 15 mg/1 in the effluent and 0.1 mg/1 in the




lake has been set for hexane soluble oils.  The hexane soluble material in the




region of the Zion intake has been found by Bio-Test Laboratories to be in the




order of 2 mg/1, with some values as high as 5 mg/1.  Therefore, it is possible




that at times the amount of hexane soluble material in the blowdown from a cooling




tower would approach the IPCB effluent standard, based on an evaporative concen-




tration of 4.24 times the intake waters of Lake Michigan.  It should be further




noted that the increasing tendency to substitute organic chemicals for potentially

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                                       —12—
toxic inorganic chemicals such as zinc and chromium in cooling towers for corrosion




control may significantly increase the amount of hexane soluble material present




in blowdown.




     Phenols.  The IPCB has established an effluent standard of 0.3 mg/1 for




phenols and a lake water standard of 0.001 mg/1.  Existing phenol levels in the




region of Zion are less than 0.001 mg/1.  However, chlorophenols are used in many




cooling towers as biocides.  Such practice leads to the presence of these compounds




in the blowdown water.  Chlorophenols at ug/1 concentrations are known to cause




taste and odors in drinking water and the tainting of fish flesh.




     Phosphorus.  A maximum phosphate concentration of effluent waters of 1.0 mg/1




and a lake concentration of 0.007 mg/1 as phosphorus has been established.  Bio-




Test Laboratories found that the total phosphate in the region of Zion intake is




approximately 0.04 rag P/l.  An evaporative concentration by a factor of 4.24




would result in the phosphate concentration in the blowdown being approximately




20 percent of IPCB effluent standard.  Available evidence indicates that the




algae growth in the region of the Zion plant is most likely limited by the phos-




phorus content of the water.  Therefore, the discharge of large volumes of blow-




down water which contained phosphate in order of a few tenths of a mg/1 would




tend to stimulate algal growth in the region of the discharge.  Phosphates are




used in many cooling towers for control of corrosion and scale.  For example,




several of the cooling towers analyzed by the Illinois State Water Survey (1971)




have a phosphate content in the blowdown water of 3-8 mg P/l.  Many of the cooling




tower blowdown waters shown in data compiled by Betz Laboratories have phosphate




concentrations of 0.2-2.0 mg/1.  These levels are such that the blowdown from




cooling towers of such a size as those required for the Zion plant would likely




stimulate algal growth in the region of the discharge if any form of phosphate,

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                                       -13-






including polyphosphate, phosphonates or polyol-esters, are used in the treatment




program, even if this discharge met the IPCB limit of 1.0 mg P/l.



     Sulfate.  A maximum sulfate content in the receiving lake water of 24 mg/1




has been established by the IPCB.  Bio-Test Laboratories found an average sulfate



concentration of 21 mg/1 with a maximum of 25 mg/1 in the lake water near Zion.



An evaporative concentration of the makeup water by a factor of 4.24 would cause




the blowdown water to exceed the lake water standard by approximately four to




fivefold.  Further, it is expected that sulfuric acid would be added to the recir-




culation water to neutralize about 90 percent of the bicarbonate alkalinity.  This



would result in a 75 to 100 mg/1 increase in the sulfate content of the makeup




water.  There can, therefore, be little doubt that the waters in the region of the



discharge of blowdown would greatly exceed the IPCB standard for Lake Michigan



water and would have to be diluted by diffusion or treated.  As I will show later,




neither technique will work here.




     Suspended Solids.  Bio-Test Laboratories found that the water in the region



of Zion has an average suspended solids concentration of 18 mg/1.  IPCB allows an



effluent suspended solids concentration of 15 mg/1 for inorganic solids.  This



means that the makeup water does not presently meet the IPCB effluent standards.



An evaporative concentration coupled with atmospheric scrubbing and possible pre-



cipitation within the system will certainly cause the blowdown water to exceed



the IPCB standards for inorganic suspended solids.  Treatment of the blowdown to




remove suspended solids will, therefore, be required.



     Zinc.  The IPCB limit for total zinc is 1.0 mg/1 in the effluent.  The zinc



concentration in the region of Zion averages 0.04 mg/1 which would still be con-




siderably less than the 1.0 mg/1 after evaporative concentration.  Many cooling



towers, however, discharge zinc at concentrations considerably in excess of the

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                                       -14-
IPCB standard because it is added for corrosion inhibition.  Further, there may




be a significant uptake of zinc from the atmosphere.  Relatively large concentrations




are present in precipitation.  Also, it should be mentioned that the IPCB standard




of 1.0 mg/1 is considerably in excess of the standard which has been proposed by




the FWQA (1969) for Lake Superior.  A study recently conducted at the Corvallis




EPA Laboratory concerning biological effects of cooling tower blowdown indicates




that zinc may be toxic to young trout at 0.09 mg/1 (Carton, 1972).  The zinc content




of influent water and its effect on the amount of zinc present in Lake Michigan




waters is currently under study by the senior author.








                        CONCLUSION AND OVERALL APPRAISAL




     In this paper, the nature of chemicals that may be present in cooling tower




"•lowdown water and the possible effect of these chemicals on the quality of the




receiving water have been briefly discussed.  The Zion nuclear power plant has




been used as a discussion model.  This evaluation has been prompted by the fact




that the use of cooling towers may be greatly increased in the near future in order




to meet proposed thermal discharge criteria.




     This investigation has been conducted in light of the fact that the concepts




of the critical concentrations of chemicals in natural waters have changed signif-




icantly during the past few years.  In the past, the primary focus of water quality




standards has been on the concentrations of chemicals in natural waters which would




have a deleterious effect on aquatic life, as measured by the acute toxicity of




the chemical to a particular organism.




     Recently adopted IPCB standards which are used for evaluation of the Zion




plant reflect, to some extent, the much stricter water quality standards necessary




for protection of aquatic life against sub-lethal effects.  It is likely that

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                                      - 15 -




within a few years the critical levels of chemicals which have been established to-




day will have to be revised downward even more in order to protect aquatic life as




more information on chronic toxicity becomes available. Such revisions will result




in the necessity of large expenditures by users of cooling towers to meet the new




criteria.




     It is clear that many of the chemicals, present in the blowdown which would have




expected concentrations slightly less than the IPCB effluent standards would not




meet IPCB or other water quality criteria for the lake. Therefore, there will be a




region in the vicinity of the discharge of the blowdown where excessive concentra-




tions of these chemicals will occur. The FWQA (1970) proposes an approach that it




is proper to dilute toxic chemicals in order to meet a standard, but it is not proper




to dilute heat on a similar basis. This appears to be a somewhat contradictory ap-




proach in that the deleterious effects of heat are short-lived, reversible, and on-




ly affect the water in the immediate region of discharge. On the other hand, chem-




icals can have effects that extend over considerable distances. This is especially




true today when the concepts of the critical concentrations of chemicals are being




revised drastically downward as additional information becomes available.




     It  should be  obvious  from  the  above  review  that  the  conclusion  drawn by  the




FWQA (1970)  that blowdown  from  an evaporative type  cooling  tower  at  Zion would not




cause any water quality problems  is  in error. It  could be argued  that  such problems




can be readily corrected by  treatment of  the blowdown water. While treatment  is




technically  possible,  some of the materials of concern,  such as sulfate, are  not




being removed from waste waters at  any location  in  the U.S. today. The only feasi-




ble methods  for removal of such species are the  very  expensive techniques associat-




ed with  saline water  conversion (viz. ion exchange, reverse osmosis, evaporation).




The relatively large  volume  of  blowdown at Zion  of  16 cfs would entail enormous




cost to  treat this blowdown  so  it would meet IPCB standards and not  cause any ad-

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                                       -16-




verse effects on water quality in the region of the discharge or in the lake itself.




Certainly, the  cost of this treatment must be included in any appraisal of the po-




tential economic aspects of using cooling towers versus once-through cooling at




large electric generating stations located on the shores of Lake Michigan.




     In situations such as the Commonwealth-Edison Zion plant where the design of




the discharge works effects very rapid cooling of the water within a minimum area




and has a minimal effect on the ecology of the region, it is somewhat diffucult to




understand why anyone would propose to trade a problem of a heated discharge which




is rapidly cooled for one involving the discharge of a large volume of chemicals




which are known to have adverse effects.  Cooling towers must be used in many in-




stallations where large amounts of heat are to be dissipated to relatively small




bodies of water.  In the case of Lake Michigan, however, it appears to be in the




best interest of the public and a sound ecological practice to utilize the heat




assimilative capacity of Lake Michigan by allowing a limited number of thermal




electric generating stations to use this lake for once-through cooling purposes




rather than accept damage by discharging large volumes of chemicals.






                                  Acknowledgemen t




     This paper was supported by the Commonwealth-Edison Company of Chicago,




Illinois, the Environmental Protection Agency Training Grant No. 5T2-WP-184-04,




and the University of Wisconsin Department of Civil and Environmental Engineering.




     We also wish to acknowledge the assistance of Betz Laboratories, Illinois




State Water Survey, and M.  Thompson of the Canada Centre for Inland Waters.

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                                       -17-


                                    References

Betz Laboratories, Personal communication (1971).

Bio-Test Industrial Laboratories, Report to Commonwealth-Edison Company on Deter-
     mination of Thermal Effects on Southwest Lake Michigan,  Project II, IBT No.
     W8955 - Inshore Water Quality Evaluation (January,  1970fApril,  1971).

Federal Water Quality Administration,  Lake Superior Enforcement Conference (1969).

Federal Water Quality Administration,  Feasibility  of Alternative Means of Cooling
     for Thermal Power Plants near Lake Michigan,  pp.  VI-l-VI-41 (1970).

Carton, E.E., Biological Effects of Cooling Tower  Slowdown, Presented at American
     Institute of Chemical Engineers Meeting, (February, 1972).

Illinois Pollution Control Board, Water Pollution  Regulations of Illinois,
     Illinois Environmental Protection Agency (March 7,  1972).

Illinois State Water Survey, Personal  Communication (1971).

Lee, G.F. and Stratton, C.L. Effect of Cooling Tower Slowdown Water on Receiving
     Water Quality - A Literature Review.  Presented at  the Lake Michigan Enforcement
     Conference  Sept. 1972. University of Wisconsin Water Chemistry Program
     (1972).

Sargent and Lundy Company, Inter-office memorandum (August 27,1971).

Savinelli, E.A. and Beecher, J.S. "Laboratory and  Field  Evaluation of Corrosion
     Inhibitors for Open Circulation Water Systems"  Selected Papers on Cooling
     Tower Water Treatment. Illinois State Water Survey  Circular No. 91, Urbana,
     Illinois 5-23 (1969).

Thompson, M.E., Personal Communication, Canadian Centre  For Inland Waters (1971).

-------
            EFFECT OF COOLING TOWER SLOWDOWN WATER
       ON RECEIVING WATER QUALITY - A LITERATURE REVIEW*
              G. Fred Lee and Charles L. Stratton
                    Water Chemistry Program
                    University of Wisconsin
                   Madison, Wisconsin 53706
                         INTRODUCTION
     In the past few years, federal and state regulatory
agencies have been adopting thermal discharge standards which
prohibit direct discharge of large volumes of cooling water
to natural waters.  These regulations will force the  installation
of a large number of the evaporative type cooling towers in
order to dissipate the heat directly to the atmosphere.  The
nature of the evaporative type cooling tower is such that
approximately one percent evaporation is necessary to achieve
a 10°F temperature reduction.  This evaporation results in
the build-up of large concentrations of salts and other
chemicals in the recirculation water.
     The cooling tower heat exchange system has five basic
problems associated with the recirculation water.  These are:
(1) scaling of heat transfer surfaces and recirculation piping,
which decreases system efficiency; (2) corrosion, which results
in shortening the useful life of the materials of construction;
(3) general fouling of the system and components by precipitation
and sedimentation from the water- (4) biological fouling,
which results in accelerated corrosion and interference with
heat transfer and flow; and (5) deterioration of wood structure
by chemical and biological attack.  In order to attempt to
*Presented before the Lake Michigan Enforcement Conference,
     Chicago, Illinois, September, 1972.

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                              -2-
minimize these problems, the amount of evaporative concentration
that normally takes place in a cooling tower is held to a
minimum.  In addition, various chemicals are added to the
recirculation water in order to reduce the magnitude of these
problems.  Eventually, however, evaporative type cooling towers
must discharge a substantial volume of the recirculation
water to the environment if they are to continue to operate
effectively.  This discharged water is called blowdown.  This
paper considers the potential detrimental effects of cooling
tower blowdown water on the receiving waters.
     The volume of blowdown is highly variable and depends
on many things including:  makeup water quality, design and
construction material, location and size of the tower and heat
exchangers.  The volume can be very large.  For example, the
installation of evaporative type cooling towers at the
Commonwealth Edison Zion 2200 MW nuclear electric generating
plant would result in a blowdown water volume of approximately
16 cfs.  It is possible that under certain conditions, the
chemicals present in cooling tower blowdown water could have a
much more significant deleterious effect on water quality in
a receiving water than the use of the water for direct once-
thorugh cooling without chemical addition.
     The chemical composition of cooling tower blowdown water
is also highly variable depending on the chemical characteristics
of the makeup water, the degree of evaporative concentration,
the amount of drift (atmospheric loss of salts), the amount
of corrosion of the cooling system, types and amounts of chemicals
added to minimize water quality problems within the recir-
culating water system, amounts of materials scrubbed from the
air passing through the tower, and biological activity within
the tower and recirculation system.

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                              — 3 —
     Even if good data is available on the chemical composition
of the makeup water and the amounts and types of chemicals
added to the tower, it is still very difficult to predict the
concentrations of many potentially significant chemicals in
the blowdown water due to the inability to estimate the con-
tributions from corrosion'-products, chemical and bio-chemical
reactions that occur within the heat exchange system, fractional
loss of chemicals in drift, air scrubbing, and leaching from
construction materials.  A review of the cooling tower lit-
erature will show that very little information is available
on the chemical composition of cooling tower blowdown water.
Generally, where data is available it is restricted to those
chemicals such as calcium, magnesium, chloride, sulfate, bicar-
bonate, etc. which have, in general, very little effect on
water quality except at very high concentrations.  Little, if
any  data is available on the concentrations of some of the
more significant chemicals which are known to have adverse
effects on water quality at levels near a ug/1.
     A few years ago, generally the only water quality problem
that was thought to exist with cooling tower blowdown water was
the toxicity of excessive amounts of chromate present in the
blowdown which had been added to the tower for corrosion
control purposes.  In the past five to ten 'years, it has become
generally recognized that other corrosion inhibitors must be
used or the blowdown water must be treated for chromium
removal prior to discharge to the environment.  Today, however,
coincident with the increased use of cooling towers, especially
the anticipated use at large electric generating stations, it
has become realized that many of the chemicals which were
once thought to be safe at mg/1 levels are actually toxic
to aquatic organisms at ug/1 levels.  Serious questions are
therefore raised about the advisability of switching from

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                              -4-
once-through cooling operations in those instances where
little or no harm is anticipated to the environment by the
discharge of heated natural water to evaporative type cooling
towers where large volumes of blowdown water would be dis-
charged to the environment.
     A review of the cooling tower literature shows that,
in general, zinc salts have been added to supplement or replace
chromates as corrosion inhibitors in many cooling towers.  The
justification for this is generally that zinc at several
mg/1 is safe to discharge to the environment.  However, this
"safe concentration" is based on a short-term acute toxicity
of zinc to fish.  It is now realized that zinc at a few ug/1
may have a sublethal chronic effect on fish which prevents
them from reproducing.  The fish or other aquatic organisms
are not killed from the zinc.  They simply do not reproduce,
or reproduce as well, and therefore, in the end, it has the
same detrimental effect as the higher levels of zinc.  Today,
a complete reappraisal is being made of the significant con-
centrations of many chemicals in waste waters.  Generally,
it is being found that the chronic sublethal effects of many
chemicals occur at concentrations ten to a thousand times less
than the acute lethal effects for fish and fish food organisms.
Before discussing this point in further detail, it is appropriate
to review the factors influencing the composition of blowdown
water and the expected composition of that water.
  FACTORS INFLUENCING CHEMICAL COMPOSITION OF BLOWDOWN WATER
Drift (Aerial Blowdown)
     Another problem of the evaporative type cooling tower
that can result in environmental degradation is drift.  Drift
is the formation of small droplets of the recirculating water
that are carried from the tower and spread on the nearby
landscape.  Drift represents a form of aerial blowdown.  Under

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                              ™" O —
 severe  condition? ,these droplets or the evaporated salts
that are formed in the atmosphere can lead to serious corrosion
of metal, especially aluminum such as that used in house
trailers, aluminum siding, etc.  Depending on the types of
salts present and the amounts, there can be a severe problem
with respect to effects on terrestrial plants.
     The potf. tial significance of the drift problem is dem-
onstrated by several comments in the cooling tower literature.
Dalton  (1962) states that the chromates in drift tend to
discolor the landscape.  Waselkow (1969) relates the experience
of one  electric utility company that relocated their entire
main transmission line due to problems with flashover resulting
from drift.  This company then established a rule that
transmission lines would no longer be located nearer than
500 ft. to a cooling tower.  Thornley (1968) comments on the
drift problem by stating, "Don't place tower near a parking
lot where drift may spot paint on automobiles or adjacent to
a taller building where drift may stain the building."  Ford
(1969)  indicates concern for the total solids discharged
to the air by drift.  Crutchfield (1970) has mentioned that
the Southern California Edison electric generating station
is being placed on the Colorado River.  Cooling towers for
this station are designed for maximum aerial blowdown since,
"by agreement with the Department of the Interior, no
blowdown water can be returned to the Colorado River.  The
remainder of the blowdown water must go into evaporating
basins," according to Crutchfield.  In order to achieve a no
blowdown condition at this plant, extensive makeup water pre-
treatment  is necessary.  Christiansen and Colman (1970) discuss
how this is achieved by cold lime-soda ash softening pre-
treatment of the makeup water.  They further discuss the
reduction in water consumption effected by makeup pretreatment
and consequent increased concentration ratios in the cooling tower.

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     The Atomic  hnevgy  Coramo-isaor-,  ir 'die.!': evaluation of
potential effects of  eooT.ing  lowers at the Palisades Plant of
Consumers Power  Company lAiX,  i9V2), noted xhal there ara
several sand dunes  in the" "proposed area of cooling  towers
which are over 100  feet h -s'fi •>  w;i.f.j.e The cooing -t-cv^rs
which are propccod  foi1  this plant will be only 50 feet high.
Further  many ol the  trees on the site reach 50-80 fe«t.  Much
of the time the  plume from the cooling towers will impinge and
spread over the  nearby  sand dunes.   This could have a signifi-
cant effect on the  terrestrial vegetation near the plant.
It is expo-:ted that the types  of vegetation in the ^rca of
impingement of xhe  cooling tcw^? plurre with the sand dunes
would revert to  shrubs  ind grv.jses  and n^y oven result in
the complete Icsr c.  c.li" "' .^station dao to b^.o^'Out areas.
Another potently ^^-cl'i^^ vi th thv.  cooling tower0 cited by
the AEG (1972) is the presence of lin ; uud other toxic
elements .in the  drift which would tani.; to accuir.ulate on the
ground and :'.n vegexation.  The AEG  feels that the concentrations
sn.I total losses of cert?.i.n chemical j suc.h as sulfd'i'-. a\?d zinc
could have a sev_',:e impact or  plant c.nd .-inirual communities in
the areas surrovuiJi.-g The ccolir;: towers.
     The F^d^ral water  Quality Adnini^ trntion (FWC-A, .1870)
stated that d^ift ib  a  normal  problejii tliat can be solved by
the purchase of  additional land to  provide a greater degree
of separation of the  coolirg  tower  and other activities of
man.  '.'."nile these statements  are correct with respect
to suggesting a  method  to eliminate The problems of drift,
namely, purchase additional land, cle-i^iy such land purchases
must be considered  part of the initial capital and operating
cost cf evaporative 'type cooling towers due to the. loss of
revenue fc  more productive land use.

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     Fr-oxi  «.  wate^ chemistm poire  of view, it wculc' be  expected
that the ar.ount of drif- would be  highly dependent on the
design of  The coding tower1.  The  c/iernic-v.?. composition  of
drift should relfect to some degree the Chemical composition
of the, recircuj.ating water.  However,, it has beer. ?hown that
the chemical composition of ocean  sprey arising iTrom wind
ovsr the open ocean results in a fraetionation of the dissolved
salts present in the spray which form air-borne, salt crystals
that have  a  different composition  than the sea water from
which  bhey were derived.  To some  ex-cent} a similar pre-
ferential  fractional""on should oc :ur in the, formation of
drif'T in en  eetT<*atTrcnt ,  lic'w:-vs.i-, '< r  .c>:'t  : ^stcillr.tacn'?, pretreatment
is practiced.   '.'':a.y pr><-, Lrc•"!::.•.:.:/.t ^enfira 11\  oons.iv4-? of
softer-ing tc remove hardness,  Ccccx^iorcij ly, SiaTements will
be made  -criat water- quality ir.  3 iio^."1.: .IP, COKT/J'  c not a critical
factor,  citing as p.vicle ice fo" xho.a;  tre f^cc "'.hat F--«awe
effluent hr-.s been used in so^c- cooling lowers ror the- re-
circulairir.g  waters.  However., a ca/'eful review of the liteiature
xjill show that the use of domestic raste water effluents  in
cooling  toT'.°rt3 is not v/ithout  significant problems.
     CU'wir^s  (TS6U) cliscuss^o *his  aituatior ^7ith respect
to the use  vc  tli^. mu;iicjpal sewage  eftluenr in  -oollng towers
in several inftallaticns in JJex^r.   He ncrcs th-.t extensive
pretraa-'-merxt of c'io ^ater is n«.ooosar/ in ord^r to remove
phosphates,  hardness and other ^ate^oYils  which cause scale,
corrosion ^nd  biological fouling.   Furthermore, continuous  side
stream filtration 7.3 itec^.ssary ir the  ooo?.i;T.rr tovcr1 recircalating
system xo :uinimize the build-up of  excessi";e amounts of

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                              -8-
precipitates.  He notes that prior1 to the time of the conversion
from the slowly degradable detergents to the readily bio-
degradable detergents that took place in the mid-1960's,
the cooling towers using sewage effluent had severe foaming
problems.
     Terry (1966) reports on his experiences in the use of
sewage  plant effluent as makeup water for cooling towers.  He
also cites other instances where domestic waste water effluents
have been used for this purpose.  It was found that in order
to avoid excessive scale problems due to phosphates and silica,
a cold lime treatment of waste water was necessary.  Also, it
was necessary to add sulfuric ^cid to prevent calcium car-
bonate precipitation in the cooling tower system.  He noted
that relatively large concentrations of chlorine must be
added to the systtm at various times in order to control
excessive accumulation of slime forming organisms in the
system.  The organisms would tend to accelerate the rate of
corrosion of metals in the cooling tower system.  Smith
(1964) discusses case histories of towers using municipal
and  industrial wastes, and mentions the pretreatment
necessary for this type of makeup water.  The Mohave Generating
Station located on the Colorado River was mentioned earlier
to have a> cooling tower system designed for no blowdown.
As discussed above this is achieved by extensive pretreatment
of the makeup water.
     It should be noted, however, that at most installations
the makeup water is used without any pretreatment and that
most of the water conditioning is accomplished by the addition
of chemicals directly to the recirculating water.  It is likely
that side stream filtration will be used with increasing
frequency on cooling towers where there is a tendency to
build up excessive amounts of precipitates and particles

-------
scrubbed  from the axrospLere T.A the rF.circu'Ldtin,? water,   Side
stream  f il tr.-tf.on DnvOJ.:/vr '"•.king a .small L;art of the  re--
circulating  water c.r-'l passing it through s^ud or diatomaceous
earth filters designed to remove small particles from  the  water
and returning this filtered water to the recirculating system,
Chemical  Add it Jar's
     The  primary method of water treatment for coo]ing tower
recirculal ing water is by the addition of chemicals  to min-
imize scale, fouling, corrosion, biological growths, and
wood deterioration.   Generally, th^se waters ar.i treated by
the e.duition of cu'fvric acid and chlorine as the minimum
treatment.   Other treatment'-; <-vt~:nI +0 mixtures of highly
toxic metallic salt", ^Cjaulex p>.os7xhaxe'i, and biocidep.  Table 1
lists u^.nv of ^h'o Idvsu rifled compounds which are used.  There
arc few general ., ••>„' c£ UP th° typcr, ^nd ".^^unts of ctiemicals
used in cooling 'jovier recircvL'.r.loa wa^er treaxir-^nt.   A large
number of proprietary ccnpounds are i/. co7i.r:"xi use.   The e;:act
composition  of th^-.ie compounds ic> ^ot >i'i.o'.>,.! cu respect >"Lo the ioiig-term,
subletbal, chronio toxicity or. fish aac1 o'iher aquatic
organibns o   Cooling tower re^irculation we.i-er treatment is
usually Described by professional c^r-or^iec that specialize
in iniustri">1  water- conditioning, r^ny of whirii have rheir
own proprietary compounds x^hich are U3ed :n their treatment
specif icaf'ons.   While it is not poc-s-Iblp er this time to
discuss in detail the many chemicals that ere added  to cooling
tower recirculation water, it is possible to discuss the
general nature of these compounds.   The various types  of
chemicals  o.sed ir> cooling tower r^circulation waters are
briefly discussed below.   It should oe emphasised, however,
thaT this  is  a highly charging field today, in which r«=w
chemicals are  being  introduced for tris purpose by firms that
specialize in  coolimi tower water treatment,

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                             -10-
                            TABLE 1

          Various Identified Chemical Compounds Used
           in the Treatment of Cooling Tower Water
Scale and/or Corrosion Control

     Sulfuric acid
     Chromate salts
     Bichromate salts
     Zinc salts
     Polyphosphate
     Hexametaphosphate
     Pyrophosphate
     Polyol-esters
     Phosphonates
     Silicates
     Polymeric silicates
     Nitrites
     Amines
     Amides
     Pyridines
     Sulfamic Acid
     Polyelectrolytes
General Fouling Control

     Lignins
     Tannins
     Lignosulfonates
     Starch
     Sodium silicofluoride

Biocides

     Chlorine
     Hypochlorite
     Chlorocyanurate
     Polychlorophenols
     Dichloro-naphthoquinone
     Mercury compounds
     Acrolein
     Copper sulfate
     Arsenic acid
     Tri-butyltin oxide
Organic esters
Carboxylic acids
Molybdate
Fluoride
Ferrocyanide
Copper
Mercaptobenzothiazole
Palyacrylamide
Carboxy methyl cellulose
Aminomethylene phosphonic acid
Borax
Potassium hydroxide
Sodium Hydroxide
Manganese
Nickel
Trivalent chromium
Benzotriazole
Aromatic nitrogen compounds
EDTA
Citric acid
Gluconic acid
Polyacrylate
Polyethyleneimine
Thiocyanates
Bromides
Creosote
Cupric chromate
Zinc chromate
Bolinden
Erdalith
Quaternary ammonium sompounds
Chloromethylsulfones
Tertiary butyl hydrogen peroxide

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                             -11-
Sulfuric acid.  Generally, the conditioning of cooling tower
makeup water for large industrial cooling towers involves the
adjustment of the alkalinity  (carbonate content) of the water
with sulfuric acid in order to achieve a certain degree of
calcium carbonate solubility  in the recirculating water.
Normally, the degree of calcium carbonate solubility or
saturation is determined based on the calcium content that
builds up in the recirculation water due to evaporative con-
centration and that added ih  the makeup water; the pH of the
recirculating water; and the  carbonate concentration, which
is determined by the alkalinity and pH.  This adjustment
is generally made to some value on either the Langelier or
Ryznar index.  Normally, an attempt is made to achieve an
index value which is near the point where the ion activity
product of calcium and carbonate are just about equal to the
solubility-product of these species.  The theory behind
this approach is one of maintaining a thin film of calcium
carbonate in order to reduce  corrosion, yet at the same time,
adjust the composition of the water such that large amounts
of calcium carbonate scale do not form.  While this is the
generally accepted approach for cooling towers, there are
questions about the validity of this approach for some waters
since a number of investigators have shown that the corrosion
tendency of a water may be independent of the stability index
of the water with respect to calcium carbonate solubility.
The operator of a cooling tower should conduct in situ tests
on the corrosiveness of the recirculation water to try to
condition this water in such a way as to minimize scale form-
ation and corrosion based on empirical testing rather than
on the somewhat arbitrary saturation indices that are frequently
used.  The addition of sulfuric acid is usually made in
sufficient amounts to achieve a recirculation water pH near

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                             -12-
neutrs.1^  This addition converts eartcnabt* vad bicarbonate
to C02 which is scrubbed from the tower by air.  Therefore,
carbonate salts are replaced by sul.fn.te salts.  Sulfates
may have an adverse effect on water quality as discussed
later.  Furthermore, the operator of the cooling tower must
operate it in such a manner as to avoid sulfate scale problems
that might arise from the use of HjSO^ in the tower.
Chlorine.  The second most commonly used chemical in con-
ditioning of the cooling tower recirculatior water is chlorine.
It is widely used as a biocide.  Motley and Hoppe (1970) mention
that chlcrina is an effective biocide for the control of algae
and bacterial slimes at 1.5 ng/'l frtc available chlorine
on a once or twice riaily shock application.  They point out
that concentrations higher xhan this level t x-e likely to
cause deterioration of tower .Ivmh^r-.  Generally, continuous
addition of chlorine is not needed, anc\ t'r><-~. period of treatment
is generally for the time it takes for o/j.e complete recycle
of the water through the tower and heat exchange system.
In these cooling towers where large amounts ol; hydrocarbons
or other organic constituents are presenc, the application of
chlorine irr-»y have to be increased considerably in order to
satisfy the chlorine deirand.  It is likely ~chat because of the
concentrations of ammonia typically preacnt in cooling tower
recirculating water, chloramines would be formed with the
addition of chlorin^.  Some of the free chlorine as well as
the chToramines may be present in the cocli.ig tower blowdown
water thereby creating potential water quality problems in the
receiving water.
     The environmental impact statement prepared by the AEC
(AEC, 1972) for the Palisades Plant of Consumers Power Company
states that cooling towers at this plant would utilise

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                             -13-
chlorine which would result in a blowdown discharge of chlorine
of about 1 mg/1 for one hour per day.  The residual chlorine
discharged to the lake would be 0.022 mg/1 after dilution of
blowdown water by 60,000 gpm and the area affected by the
chlorine will be less than that for once-through cooling.
However, they note that the period of chlorine discharge will
be thirty times longer than for once-through cooling.
Phosphates.  Various types of phosphate compounds are widely
used in cooling tower recirculation water.  These compounds
act to reduce corrosion and to prevent scale and sludge formation.
Polymeric phosphates act as nucleation inhibitors and thereby
minimize the deposition of various types of precipitates on
the heat exchanger, as well as other surfaces in the cooling
tower heat exchanger recirculation system.  Frequently, the
polyphosphates are used at the 1-10 mg/1 phosphorus level.
Recently, some relatively new organic phosphates, the polyol-
esters and the phosphonates, have been introduced for use in
cooling towers.  These compounds are claimed to be highly
effective for scale inhibition.  The manufacturers report
that these compounds, which are P-O-C bonded compounds, do not
revert to orthophosphate in natural waters.  However, examination
of the information available on the testing that has been
done on this lack of reversion shows that additional stydy
is necessary to be certain that reversion does not in fact take
place in natural waters at a relatively slow rate due to enzymatic
processes.   The situation with respect to the polyol-esters
and phosphonates may be somewhat similar to that to NTA
(nitrilotriacetic acid) where an acclimatized group of micro-
organisms was shown to be able to readily degrade NTA; however,
non-acclimatized organisms could not bring about this
reaction.  These polyol-esters of phosphate and the phosphonates
are recommended for use in the 2-100 mg/1 range in the re-

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                             -14-
circulation water of a cooling tower.  Since there is a
possibility of their reversion to orthophosphate, their use
in cooling towers on a large scale basis should be preceeded
by careful studies on this reversion process.  These potential
problems have not been investigated by the manufacturers
(Zecher, 1970a).
     According to Motley and Hoppe (1970), the discharge
of any phosphates from cooling tower installations into the
Ohio River is now prohibited.  It is very likely that restrictions
on phosphate discharges will be in effect throughout the country
in the near future.
Chromates and Other Corrqsj.on Inhibitors.  Cone (1970)
discussed the various types of chemicals that are frequently
used to control corrosion in cooling towers, emphasizing
some of the problems associated with the chemicals used.  This
review should be consulted for a fairly recent discussion
of the chemicals that are likely to be present in cooling
tower blowdown water from industrial type cooling towers.
     Chromate salts are generally found to be the most effective
inhibitors.  Usually corrosion control can be secured by a
100-300 mg/1 chromate content in an open recirculating system
and 390-500 mg/1 chromate in a closed recirculating system.
Sometimes concentrations in excess of 500-1000 mg/1 are
necessary to prevent pitting, according to Cone (1970).
     Cone notes that the addition of zinc to a chromate
inhibitor results in corrosion control or minimization at
lower chromate concentrations.  Certain organics, such as
lignosulfonates and synthetic polymers are added to the chromate-
zinc-phosphate formulation to reduce pitting tendencies.  Cone
notes that the use of silicates for corrosion control requires
fairly careful control of pH.  It is reported that usually

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                             -15-
20-40 mg/1 of silicate are sufficient to obtain desired
protection in the cooling system and that the addition of
polyphosphates enhances  corrosion inhibition.
     Nitrites as anodic inhibitors for corrosion control are
used at 200-500 mg/1 or more.  pH in the recirculation system
must be alkaline in order to prevent localized decomposition
of the nitrites.  In some cases, fluoride is added with the
zinc-chromate-phosphate system to treat waters which contain
large amounts of aluminum.  The fluoride complexes the aluminum
to prevent it from reacting with phosphates which are added
for corrosion control.
     Cathodic inhibitors include various multivalent metals
such as zinc, nickel, manganese, and trivalent chromium.  Again
the addition of phosphates to the system often allows the
cathodic inhibitor to be effective at lower concentrations.
Cone notes that organic inhibitors have been receiving increased
use in recent years.   Some of the commonly used organic
inhibitors are amines, amides, pyridines, carboxylic acids,
esters and macaptans.
     The organic phosphorus compounds mentioned above, the
polyol-esters and the phosphonates, are receiving increased
use along with some of the aminomethylene phosphonic acids.
Most of the formulations containing multi-component mixtures
of these various compounds are proprietary and the exact
composition is not readily known because of the proprietary
nature of the compounds.  Cone (1970) claims that the most
widely used corrosion inhibitors for cooling water systems
are polyphosphates, zinc-phosphates, s.ilicates, and the zinc-
chromate-phosphate combination.
     Zecher (1970b) discusses the difficulties encountered
in replacing chromate as a corrosion inhibitor in cooling

-------
                             -16-
tower systems.  Other treatment programs are evaluated
from the standpoint of corrosion 'inhibition and potential
pollution of water receiving the tower blowdown.
     Thornley (1968) discussed the various problems that occur
in cooling towers and the commonly used methods for evaluating
these problems.   He notes that chromate is still one of the
most satisfactory chemicals for controlling corrosion in
cooling tower systems.  The chromates are used in either
the high chromate treatment, concentrations of 200 to 2500 mg/1
of sodium chromate, or the low chromate treatment at con-
centrations on the order of 50 mg/1.  With the latter,
normally it is combined with phosphates, zinc, and other chemicals
     Donohue (1969) notes that the general tendency today in
cooling tower water conditioning is to reduce the use of
chromate for corrosion control and increase the zinc and
phosphate use.  He predicts that eventually because of the
problems which are being created by zinc-phosphate systems
in natural waters receiving the blowdown, many plants will
go back to the chromate system coupled with the removal of
chromate from the blowdown water.  He discusses a system
which enables the removal of chormate from the blowdown
water as well as reviewing some of the applications, various
types of chemicals used for water conditioning in cooling
towers, and the problems associated with their use.
     Kelly(1968) has reviewed the procedures that can be used
to remove chromates from cooling tower blowdown.  He notes
that effective chromate removal can be achieved by the use
of an ion exchange process; however, the cost of this process
is in the order of $0.511/lb of chromate removed.  He
states that a very careful control of pH is essential to
produce a chromate free effluent and also, an adequate
feed of reducing agent is important.

-------
                             -17-
     Schieber (1971) has discussed the removal of chromates
from cooling tower blowdown water, including consideration of
the cost of various types of processes that can be used for
this purpose, as well as chromate recovery.  Hesler (1964)
further discusses the removal of chromates by the ion exchange
process noting some of the more important parameters that must be
carefully controlled in order to achieve good removal.
Puckorius and Farnsworth (1964) discuss a process which can
be used to recover the chromate and reuse it as a cornrosion
inhibitor in the cooling tower.  They point out the
economic advantages of such a recovery process, as well as
the advantages of minimizing potential water quality problems
to the blowdown water discharge containing chromates.
Organics.  There is an increasing tendency to use organic
compounds in cooling tower water conditioning.  Motley and
Hoppe (1970) mention that the basic '^conventional" chemical
conditioning for cooling towers for electric generating
stations is the use of sodium hexametaphosphate for corrosion
and stabilization, sulfuric acid for control of pH and alkalinity,
aiid chlorine as a biocide.   They predict that the organic
phosphate compounds will eventually supplant the sodium
hexametaphosphate treatment and may reduce the amount of acid
needed for alkalinity reduction.
     Donohue (1967) discusses the use of organic topping
agents in cooling towers for water conditioning purposes.
Organic topping agents are organic based compounds added to
cooling water for the purpose of supplementing corrosion
inhibition, maintaining heat exchange surfaces as free of
deposit as possible, and preventing scale formation.
     Typical materials used for this purpose are EDTA
(ethylenediamine-tetraacetic acid), citric acid, gluconic

-------
                             -18-
acid, as well as various types of dispersants and coagulants.
He notes that many types of organic compounds are being explored
today for this purpose.
     Lees and Twiford (1969) have discussed the theoretical
and practical aspects of the use of various types of
polyelectrolytes for water conditioning in cooling towers.
Their paper should be consulted for additional details on
this topic.  Puckorius (1971) has reported on the use of a
combination of organic polymers with the more traditionally
used inorganic polymer, such as phosphates and silicates in
minimising corrosion in cooling towers.  The nature of the
organic polymers is proprietary at this time; however, they
are classified as organic polyelectrolytes.  The potential
effects of these compounds on water quality in natural waters
is unknown at present, although similar compounds have been
used for treatment of municipal water supplies. Hwa (1968)
discussed the replacement of chromatss with synthetic organic
compounds for corrosion control.   Weisstuch, et al. (1970)
have discussed the use of complexing agents such as EDTA for
corrosion control in cooling towers.  According to these
authors, there is a relatively strong bond formed between
the complexing agent and the metal which forms a tenacious
film and tends to inhibit further corrosion.  Their paper
reviews the general nature of this process.
     A new series of organic nitrogen corrosion inhibitors
are now being used in cooling towers.  Von Koeppen, et al.
(1972) describe the mode of action and the effectiveness of
these aromatic compounds.  They are used with a phosphate and
zinc mixture.  Towers using this type of treatment will
discharge relatively  large concentrations of organic nitrogen
and perhaps nitrate.

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                             -19-
     Carter and Donohue (1972) discuss the use of nitrogen-
based compounds in conjunction with phosphonates to eliminate
the requirement for either chromate or zinc in certain cooling
towers.
     Another potential problem with some of the organic
proprietary compounds used in cooling towers which eventually
will be discharged to natural waters through blowdown is the
fact that some of them are essentially non-biodegradable.
For example, the use of complexing agents such as EDTA in
cooling towers, which is s.ometimes recommended, could result
in this compound being dispersed into the environment.  Since
EDTA appears at this time to be non-biodegradable, it would
cause significant problems in the environment as a result of
its strong complexing tendencies for potentially toxic
transition metals that are present in the sediment of natural
waters.  The polyol-esters that were mentioned earlier may also
present problems by complexation of toxic metals.  This area
should be thoroughly investigated.
Other Biocides.  In order to minimize the delignification of
cooling tower lumber by fungi, Motley and Hoppe (1970)
state that normally inorganic chemicals or creosote is used
as a fungicide.
     Willa (1965) discusses the use of polychlorophenates
as a means of controlling fungus attack on wood in cooling
towers.  The chlorophenates are also used to control algae
and other slime growths.   They may be fed continuously or inter-
mittently.  There is considerable concern today among some water
chemists about the possibility of the chlorodioxin being con-
taminants in the chlorophenates used in cooling towers.  The
chlorodioxins have been found to be one of the most toxic
compounds isolated by man.   These were the compounds that

-------
                             -20-
caused the temporary suspension of the use of the herbicide,
2,U»5-T.  Based on the manufacturing conditions that led to
the contamination of 2,U,5-T, it is possible that the chloro-
phenates may also be contaminated.  This is an area of active
investigation at this time.   The chlorodioxins are highly
mutagenic, showing toxicity at ug/1 levels.  Furthermore,
the chloropheuolb are notorious for causing tastes and odors
in water supplies and the tainting of fish.  Willa (1965)
notes that these compounds have been used at concentrations
up to 300 mg/1 as a shock treatment in some cooling towers.
     Thornley (1968) presents an extended discussion of the
problems with various types of organisms in cooling towers and
the method for their control, noting that the chlorophenates,
acrolein, tri-butyltin oxide, certain thiocyanates and
quaternary ammonium compounds are used as biocides in cooling
towers.  It should also be noted that while Thornley mentions
the fact that mercury compounds are excellent biocides, they
are rarely  used because of toxicity in the blowdown water.
Based on the authors' experience, organic mercury compounds
have been discharged to surface waters and have been rer-
sponsible in part for some of the buildup of mercury in aquatic
food web in some areas.
     Donohue (1971) mentions a new approach that may be
taken to avert the problem of toxic biocide residues  in the
blowdown-, biocides that can be detoxified.  Acrolein, tertiary
butyl hydrogen peroxide and bromo nitro styrene are effective
and stable as biocides in the tower but they may be readily
detoxified upon disposal by stoichiometric quantities of
sulfite.  He suggests that these may eventually replace
all other non-oxidizing biocides.
     Another source of chemicals that may be found in cooling

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                             -21-
tower blowdown water is the preservative chemicals leached
from the wood when the tower is first operated.  At the
present time, little information is available on the nature
of these chemicals or the rates of leaching of these chemicals
from the wood.  Puckorius (1970) mentions the condition
known as ''black water" resulting from the leaching of natural
organic materials from untreated redwood in newly  constructed
or rebuilt towers.  He also discusses the leaching of arsenic,
chromium, and copper salts (at levels exceeding WO mg/1),
and the creosote "slick" that results from treated lumber
early in operation of a tower.
     Hoppe (1971) claims that the wood preservative salts
frequently used are cupric chromate and zinc chromate
Boliden or erdalith are used which are mixtures of copper
chromatoarsenite and in some instances, ferris salts.
General.  Marshall (1971) has presented a general review
of some of the various types of chemical treatments used for
conditioning cooling tower waters.  Freedman and Boies (1960)
have reviewed the problem of corrosion in cooling towers
and the various methods that  can be used to reduce corrosion
rates.  Parker and Krenkel (1969) have provided a general
review of the potential detrimental effects that can be
caused by the discharge of blowdown water on surface water
quality.  Troscinski and Watson (1970) have reviewed the
various methods that are normally used to control deposits
within cooling tower systems.
     Motley and Hoppe (1970) have discussed cooling tower
design criteria and water treatment.  Their paper should be
consulted for further discussion of this topic.  They point
out that much closer scrutiny of the constituents that may
be used in cooling tower water conditioning will have to be
given in order to meet the increasingly stringent water

-------
                             -22-
quality criteria that are being developed today.
Operating Practices for Cooling Tower Water Conditioning.
     Kelly and Puckorius (1966) discuss the typical con-
centrations of various chemicals that are used for control of
corrosion, scale, and microbial growth in cooling towers.
It is of interest to examine some of these treatments (see
Table 2) in order to possibly ascertain what might be the
concentrations present in some cooling tower blowdown
waters.


                           TABLE 2*
Treatment Type                               Dosage (mg/1)
Polyphosphate-based (POLf)                       20-tO
Organic-polyphosphate-based (PCL)               10-20
Chromate-phosphate (CrO^)                       15-30
Chromate-based (CrO^)                           15-20
Organic-chromate (CrO^)                          5-15
Organic-based (Total Treatment)                    50
     *after Kelly and Puckorius (1966)

     In an attempt to gain information on existing practices
with cooling towers located at electric generating stations,
T.C. Hoppe of Black and Veatch Consulting Engineers of Kansas
City was contacted regarding his experiences in water con-
ditioning in cooling towers.  He (personal communication, 1971)
cited five different situations at cooling tower systems for
turbine generators in the range of 50=-850 MW.  He states that
the majority of these stations use chemicals in addition to
sulfuric acid and chlorine.  He provided five examples and
these are presented below:

-------
                             -23-
             Water Conditioning at-Cooling Towers
        for Electric Generating Stations (Hoppe, 1971)
     a.  Polyphosphate a   -3 mg/1 (P00) , sulfuric acid,
                                      o X
         chlorine;
     b.  Sodium chromate at 25-30 mg/1 CrO^, polyphosphate
         4-8 mg/1 (POQ) , sulfuric acid, chlorinej
                     o 5C
     c.  Organic phosphate at 25 mg/1 without zinc, sulfuric
         acid, chlorine5
     d.  Organic zinc at 25 mg/1 without phosphate, sulfuric
         acid, chlorine;
     e.  Sodium chromate at 5 mg/1 CrO  without sulfuric acid.
On the other hand, T.A. Miskimen reports (personal communication,
1971) that all of the American Electric Power Company cooling
towers, except one, operate with just the addition of sulfuric
acid and chlorine.
     A drive through the countryside of England generally
reveals  large numbers of cooling towers at various thermal
electric generating stations.  Superficially, it would appear
that the use of cooling towers in England is the preferred
method of disposal of water heat, based on the fact that
large numbers of cooling towers are present.  However, further
examination of this situation reveals cooling towers are" used
in England only under those circumstances where once-thorugh
cooling cannot be readily practiced.   Even where installed,
the cooling towers are generally used only on a limited
basis during low flow periods.
     Another important difference between the English
practice in cooling towers and that of the U.S.  is with respect
to the use of chemicals for water conditioning.   The English
towers tend to operate on a 1 to 2 recycle ratio, while
in the U.S. , much higher recycle ratios are used.  The low

-------
                             -24-
recycle ratio being used in England is designed to minimize
the problems of scaling, corrosion, etc. that often occurs
because of the chemicals present in the waters used for cooling
purposes.  Often, in the more industrialized areas, water
quality available for use in cooling towers is such that higher
recycle ratios would require extensive water conditioning.  In
general, the English cooling towers operate with little or
no water conditioning.  They tend to be used to some extent
as a modified once-through cooling operation where very large
volumes of water are run through the cooling tower prior to
discharge.  It is almost as though the cooling towers are
being used as part of the once-through cooling operations.
On the other hand, in the U.S., much higher recycle ratios
are used, thereby minimizing the amount of water discharged
from blowdown, necessitating much greater use of chemicals
for cooling tower water conditioning purposes.
Air Scrubbing
     An evaporative type cooling tower represents a large
air scrubbing device, whereby materials which are contained
in air would be washed from it as part of the heat exchange
process.  These various chemicals would tend to accumulate in
the recirculating water and would be discharged in the blowdown.
While to our knowledge no studies of this type have been
conducted thus far, this problem has been noted in the past.
For example, Thornley (1968) comments:  "Don't place towers
next to boiler smoke stacks.  The stack fumes will be drawn
into the tower and cause corrosive acid solutions."  He
goes on to comment about the fact that cooling towers should
be located in a dust-free area because of the problems of
contamination of the recirculating water.  The data on the
chemical composition of the atmosphere with respect to
potentially hazardous chemicals is quite limited.  Some recent

-------
                             -25-
studies conducted at the Canadian Centre for Inland Waters
(CCIW), under the direction of Mary Thompson (1971), have
shown  that the concentrations of potentially significant
chemicals in the air are quite large.  The CCIW studies
represent, in many cases, approximately 100 analyses taken
at various locations in Canada, representing both urban and
rural  environments.  Table 3 presents the results of these
studies for the chemical composition of rainfall.  While at
this time it is almost impossible to equate the composition
of rainfall and other precipitation to the composition of
blowdown water that might result from evaporative type cooling
towers, the rainfall water does provide an indication that
there  are sufficient concentrations of various trace metals,
aquatic plant nutrients and other potentially toxic substances
present in the atmosphere to cause problems in water quality.
In fact, examination of Table 3 chows an average concentration
of phosphate, inorganic nitrogen, lead, copper, zinc, and
cadmium which would be considered excessive compared to the
new water quality standards that are being developed by
various states and the federal government.  In other words,
often  precipitation would not meet the new standards such
as those proposed for Lake Superior by the FWQA (1969) and the
State  of Minnesota (Minnesota, 1970),
     Glover (1970) considers the air-borne contamination
of cooling tower water.  He presents the following formula for
calculating the absorption of soluble gases and suspended
solids from the air:
                 BC = RC = (AC)(WE)(SF)|^|
where    BC = concentration of air-borne contamination in
              blowdown water, Ib contaminant/lb water

-------
                               -26-
                               TABLE 3

                Chemical Composition of Precipitation
             Data from Canada Centre for Inland Waters*
Parameter


Total PO^

Soluble Re-
active PO^

Nitrate - N

Ammonia - N

Chloride

Sulfate

Sodium

Potassium

Magnesium

Calcium

Bicarbonate

Lead

Copper

Iron

Zinc

Cadmium
  Mean
  Standard
  Deviation
  Maximum
  Minimum
292.00 ug/1   542.00 ug/1   380x10 ug/1    5.00 ug/1
180.00 ug/1

  1.32 mg/1

  1.03 mg/1

  3.05 mg/1

  9.23 mg/1

  3.10 mg/1

  0.59 mg/1

  0.64 mg/1

  4.50 mg/1

  6.20 mg/1

 25.00 ug/1

 27.00 ug/1

 58.00 ug/1

 98.00 ug/1

  2.00 ug/1
449.00 ug/1

  1.60 mg/1

  1.20 mg/1

  4.72 mg/1

  5.11 mg/1

  4.70 mg/1

  0.78 mg/1

  0.69 mg/1

  3.90 mg/1

  9.50 mg/1

 29.00 ug/1

101.00 ug/1

 61.00 ug/1

 51.00 ug/1

  3.00 ug/1
340x10 ug/1

 10.80 mg/1

  9.25 mg/1

 25.80 mg/1

 26.10 mg/1

 24.20 mg/1

  6.00 mg/1

  4.10 mg/1

 24.00 mg/1

 50.10 mg/1

160.00 ug/1

800.00 ug/1

310.00 ug/1

272.00 ug/1

 16.00 ug/1
 0.00  ug/1

 0.07  mg/1

 0.00  mg/1

 0.11  mg/1

 0.80  mg/1

 0.10  mg/1

 0.08  mg/1

 0.00  mg/1

 0.00  mg/1

 0.00  mg/1

 1.00  ug/1

 0.00  ug/1

 1.00  ug/1

10.00  ug/1

 0.00  ug/1
-After Thompson (1971)

-------
                             -27-
     RC B concentration of air-borne contaminants in
          recirculating water, lb contaminant/lb water
     AC = concentration of contaminant in the atmosphere,
          lb contaminant/cu ft air.
     WE = washing efficiency
        _ lb contaminant entering water	
          lb contaminant in air circulated through tower
               (generally 0.95-1.0)
     AR = air rate in cu ft air/lb water recirculated
          through the tower- (generally about 10 cu ft
          air/lb water).
     BD = blowdown fraction = lb water blowdown/lb water
          recirculated.
     SF = suspended fraction
        _ lb contaminant remaining suspended in solution
          lb contaminant washed from.' aar
          (1.0 for- soluble gases and soluble dusts and
           0.1-0.5 for insoluble dusts).
According to Glover, the quantity of insoluble suspended
materials scrubbed from the atmosphere frequently dictates the
amount of blowdown required.
     Glover's formula may be used to approximate the expected
degree of contamination of blowdown water from atmospheric
sources.  In Table 4 the calculated mean and maximum contam-
ination of blowdown water is shown.  The ambient air-borne
levels of contaminants are highly variable, with generally
higher values in urban areas for most contaminants.   The ambient
mean and maximum air-borne values shown in Table U wer.e selected
from two sources.  The values for Pb, Cu3 Ni, and V are rep-
resentative of an urban particulate; those for the other species
are national averages except where noted.
     It is assumed for the calculations that the washing
efficiency is 1.0, the air rate is 10 cu ft air/lb re-
circulating water, and the blowdown fraction is 0.006 which
is the sum of the blowdown and drift  loss expected for

-------
                             -28-
cooling towers designated for the Zion Nuclear Power Station
of the Commonwealth Edison Company (Sargent and Lundy, 1971).
Since it is not known what portion of the air-borne particulate
may be soluble, a value of 0.5 is used for the suspended
fraction.  Hence, for the mean air-borne phosphorus value of
         3
1.43 ug/m ,
        BC = (8.86 x 10~1:L)(1)(0.5) n *°  = 0.0715 mg/1
                                    0 . UUb

     It is evident from Table M- that Fe, Pb, An, P, Cd,
      +      =                                            '
Hg, NH^ or SO^ could occur in the blowdown water at a level
that would create a disposal problem solely from atmospheric
sources.  This would be most likely to occur for a tower
located in an urban or industrial area.  Ammonia could become
a particular problem upon chlorination of the cooling tower
for control of microorganisms.  The chloramines that are
formed are highly toxic to fish at ug/1 levels.  When ammonia
is in the mg/1 range in the recirculating water, extreme care
must be taken to avoid fish kills from the discharge of
chloramines.
Loss of Volatile Material
     The stripping by air of volatile materials from cooling
tower recirculating water is another effect that influences
the chemical composition of the blowdown water.  Ammonia
and volatile organic contaminants in the recirculating water
would be the principal species affected and, as such, stripping
would not be expected to be of great significance unless
waste waters are used as the tower makeup.
     Roesler, e_t al. (1971) have devised a computer program
for determining the degree of removal of ammonia from waste
water by air stripping in a conventional cooling tower in-
stallation.  The Georgia Kraft Company (1971) investigated

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                                 -30-
    the use of a cooling tower for the removal of biological
    oxygen demand (BOD) from kraft mill wastes.  They found that
    25-30 percent of the waste water BOD could be removed by a
    cooling tower.  The primary mechanism of BOD removal was
    not biological consumption but the physical process of
    stripping of the volatile components in the waste water.  They
    recommended further investigation of the impact of this
    process on air quality.
                      COMPOSITION OF SLOWDOWN WATER
         Very little information exists today on the chemical
    composition of blowdown water in the U.S.  Davies (1966)
    reported on the chemical composition of several cooling tower
    blowdown waters located on streams in England.  He found that
    chloride and sodium sulfate concentrations build up in the
    blowdown water in proportion to the degree of concentration
    by evaporation and the concentrations in the makeup water.
    His discussion did not provide sufficient data to determine
    what concentrations of some of the more critical elements might
    accumulate in typical cooling towers operated in England.
    Hoppe (1966) discusses some of the problems associated with
    the use of various types of chemicals in water conditioning
    in cooling towers.  In particular, he examines the problems
    of corrosion control with the chromate-zinc treatment, the zinc-
    polyphosphate treatment, and the zinc-organic treatment.
    He presents a waste treatment removal scheme for the removal of
    chromate and zinc from blowdown waters, as well as a system
    for discharge of blowdown to deep disposal wells.  Hoppe
    presents a table in this paper for cooling tower blowdown
    water composition of an industrial type cooling tower which
    uses a zinc-organic based formulation for the cooling
    makeup water conditioning.  This table is reproduced in this
    

    -------
                                 -31-
    paper as Table 5 for comparison purposes.
         The cooling tower literature contains several papers which
    present a limited amount of data on the recirculation water,
    blowdown water or simulated recirculation water which would
    be used for various types of testing for corrosion control,
    etc.  Table 6 is a compilation- of selected data from the
    various papers from the literature.  Examination of Table 6
    shows that generally pH for these various cooling tower
    waters is near 7 with a hardness ranging from several hundred
    to over a thousand mg/1 as calcium carbonate.  The calcium
    and magnesium content of the water averages about 100-300 mg/1
    with a total alkalinity ranging from 5-M-M- mg/1 as calcium
    carbonate.  The chloride content is several hundred mg/1 with
    sulfate ranging from 250 to 14-00 mg/1.  The change in bicar-
    bonate and carbonate alkalinity to sulfate is quite evident
    from the table.  The dissolved solids content for the three
    samples given range from approximately 1000-2000 mg/1..  The
    one sample shows a chromate concentration of 280 mg/1.
         The rather meager data on the. chemical composition of
    cooling tower blowdown water prompted the authors to contact
    several firms and associates for unpublished data.  W.T. Betz
    Company of Trevose, Pennsylvania provided data of this type.
    Table 7 presents the characteristics of each of the cooling
    towers studied.  Data is given, on location, water source, and
    type of treatment used.
         The data in Table 8 from Betz Laboratories shows  approxi-
    mately the same characteristics as the data presented in
    Table 6 for the ten different cooling towers for the common
    parameters such as pH, hardness, calcium,  magnesium, and
    alkalinity.  Although it is of interest to note that typically,
    the alkalinity values in the Betz reports are considerably
    

    -------
                                 -32-
                                TABLE 5
                  Analysis of Cooling To-^er Slowdown
                      OA Zinc-Organic Treatment*
         pH                                         8.0
         Total alkalinity as calcium carbonate      146 rog/1
         Total hardness -as calcium carbonate        1327 mg/^
         Calcium hardness as calcium carbonate      347 mg/1
         Sulfare as calcium carbonate               1360 mg/1
         Chloride as calcium carbonate              134 mg/1
         Zinc as zinc                               1.2 mg/1
         Total dissolved solid*                     2728 mg/1
         Specific conductance                       3040 umho/cm
         Ammonia as N                               0*04 mg/1
         5 day DOD                                  1 mg/1
    The cost for suov tj.-eat-.ent was estimated by Hoppe to be in
    the order of $0.1275/1000 gallons of ajs
    *After Hoppe (1966)
    

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                                 -36-
    higher than those reported in Table 6, it is possible that
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    treating the cooling tower enables the operator of these
    towers to carry higher alkalinity values without having^
    severe scale problems.  This is also noted because of the fact
    that the sulfate levels in the Betz data tend to be somewhat
    less.   It is of interest that the phosphate levels of the
    various cooling towers for Betz range from a few tenths up
    to several mg/1.  Chromate typically runs 6-25 mg/1.  Zinc,
    when used, is approximately 0.5-7 mg/1.
         One additional source of chemical analysis data on
    cooling tower blowdown water was obtained from the Illinois
    State Water Survey (1971).  This data is presented in Table 9
    where analyses from November, 1971, are presented for six
    different nan-industrial cooling towers located in the State
    of Illinois.  The cooling towers are located at various
    State of Illinois institution buildings.
         Examination of the data presented in Table 9 shows
    that in general the chemical characteristics of these cooling
    tower blowdown waters are approximately the same as those
    presented in Table 6 from the literature.  It is of interest
    to note that    some of the Illinois State Water Survey cooling
    towers have several mg/1 of phosphate.  This data also
    gives an indication of the levels of trace metals, such as
    chromium, copper, lead, nickel, and zinc in these cooling towers
    Generally, the concentrations of these various metals range
    from less than 50 ug/1 to several hundred ug/1, except for
    chromium which ranges from 20-60 mg/1.  It is obvious that all
    of these cooling towers receive a chromate treatment.  The
    lead and nickel concentrations are uniformally less than
    50 ug/1, with zinc typically ranging in the order of a few
    tenths of a mg/1.  The cadmium levels in all samples were
    

    -------
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    less than 10 ug/1.
         Carton (1972) has assembled information on typical values
    for the concentration of certain chemical species commonly
    found in cooling tower blowdown.  Table 10 is taken from
    Garto'n^s paper.  The values are similar to those quoted from
    other authors-, in addition, several specific organic species
    are listed.
    
         The AEC (19/2) considered the possible detrimental
    effects of utilizing cooling towers at the Palisades Nuclear
    Generating Plant of Consumers Power Company.  Mechanical
    draft wet type cooling towers would be utilized at this
    plant.  These towers would have blowdown of 1,320 gpm.
    The recirculating water in the tower would be treated inter-
    mittently with sodium hypouhlorite as a biocide.  Also
    phosphate and zinc compounds were to be added to the re-
    circulating water as corrosion inhibitors.  It was estimated
    that the phosphate content in the blowdown would be 0.27 mg/1 P
    and 0.036 ing/1 of zinc.  These concentrations were to be
    achieved in the water discharged to the lake after dilution
    with 60,000 gpm of dilution water.  It was further estimated
    that sulfuric acid would be added to the system recirculating
    water to give a sulfate ion concentration of 48.9 mg/1 in
    the discharge water.
    Blowdown Water..Toxicity
         There is little information available concerning the
    toxicity of cooling tower blowdown water to aquatic organisms.
    The measured tolerance level values (TL,-n) for minnows for
    certain selected cooling water treatment chemicals are pre-
    sented by Donohue (1971).  These values, which ware apparently
    determined by Betz Laboratories, are listed in Table 11.
    

    -------
                                 -uo-
                               TABLE 10
    
             Conunon Chemicals and Concentrations Found in
                   Recirculating Cooling Tower Water
                          After Garton, 1972
    
              Treatment                  Chemical Concentrations
    Chromate-zinc                  2-15 mg/1 CrOr as Cr
                                   1-5 mg/1 Zn
    
    Chromate-zinc-phosphate        2-15 mg/1 CrO^ as Cr
       (organic or inorganic)      1-15 mg/1 Zn
                                   0.3-1.5 mg/1 PO^ as P or
                                   0.3-1.5 mg/1 organic phosphate as P
    
    Zinc-inorganic phosphate       2-10 mg/1 Zn
                                   3-10 mg/1 P04 as P
    
    Zinc-organic phosphate         1-10 mg/1 Zn
                                   1-5 mg/1 organic phosphate as P
    
    Organic phosphate scale
        inhibitor                  0.3-6 mg/1 organic phosphate at P
    
    Silt control polymers          0.1-5 mg/1 acrylamide, polyacrylate,
                                   polyenthyleneimine, or other
                                   synthetic organic polyelectrolytes.
    
    Natural liquin-tannin type
        dispersants                1-50 mg/1 as sodium liquosulfonate
    
    Non-oxidizing organic biocides 1-25 mg/1 sodium polychlorophenol,
                                   quaternary amine, organo-metallic
                                   methylene bis-thiocyanate, etc.
    
    Specific oxygen corrosion      1-5 mg/1 sodium mercaptobenzo-
        inhibitors                 thiazole or benzotriazole
    

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                               TABLE 11
    Toxicity of Certain Selected Cooling Water Treatment Chemicals
                              to Minnows*
                         After Donohue (1971)
                Chemical                                  TL5Q
    Phosphonate (amino trimethylene phosphonate)         ^1000 mg/1
    Mercaptobenzothiazole (MET)                              3 mg/1
    Benzotriazole (BZT)                                     UO mg/1
    Hexametaphosphate                                     ^500 mg/1
    Sodium nitrate                                         500 mg/1
    Zinc sulfate                                            15 mg/1
    '•species not designated
         The acute toxicity of the phosphate species is quite
    low.  It is interesting to note, however, in Table 10 that
    the concentration of mercaptobenzothiazole used in some
    treatment programs is at the level of acute toxicity quoted
    in Table 11 for this compound.  A "safe" level of contaminant
    is generally considered to be 1/100 of the TL  .  If the
    blowdown is not diluted in this case by a factor of at least
    100 it may be toxic to fish.
         Carton (1972) working at the Environmental Protection
    Agency Laboratory, Corvallis, Oregon, conducted a series of
    bioassays on simulated cooling tower blowdown water.  The
    simulated blowdown water was prepared to approximate the
    maximum proposed chemical composition of cooling tower blow-
    down water from the Trojan Nuclear Power Plant of the Portland
    General Electric Company as reported in the company's discharge
    permit request.   The company planned to use a chromate-
    zinc-phosphate treatment.
    

    -------
                                 -42-
         Two different organisms were used in the bioassay:  a
    green alga, Selenastrum capricornutum Printz, and the young
    steelhead trout, Salmo gairdneri.  Test solutions were the
    original strength simulated blowdown and dilution of the
    simulated blowdown by factors of 10, 100, and 1000.
         The results of the bioassays indicate that zinc and
    chromate in the simulated blowdown are toxic to the  alga at
    0.064 mg/1 and 0.14 mg/1, respectively, as measured  by re-
    duction in algal productivity.  The juvenile steelhead trout
    showed no lethal effects in 96 hours at 31 mg/1 CrO^, but
    the 96 hour LC,-0 (lethal concentration for 50 percent of
    individuals) for zinc was 0.09 mg/1.  Using the recommended
    application factor of 1/100 of the 96 hour TL^r, (LC5Q) determined
    by this investigation, safe stream standards become  0.0009 mg/1
    Zn for steelhead trout.
         If zinc standards are lowered in the future to  levels
    proposed by the EPA for Lake Superior or to levels indicated
    by the above report, it is unlikely that even the more conventional
    blowdown treatment, that is, lime or alum precipitation, can
    render the blowdown water as free of zinc as necessary for
    discharge if zinc is used in the treatment program.   The
    removal by dispersant chemicals added to the tower.   Ion
    exchange or other advanced treatment systems may become
    mandatory at a substantial increase in cost.
         The AEG (1972) , in their evaluation of the potential
    impact of cooling towers at the Palisades Nuclear Electric
    Generating Station, concluded that phosphate, zinc,  chlorine
    and sulfate present in the blowdown waters may have  an impact on
    phytoplankton in Lake Michigan.  The phosphate would tend to
    stimulate algal growth in the region of the discharge.  The
    

    -------
                                 -43-
    zinc in the blowdown would likely enter into the food web
    and be concentrated to a much higher level in aquatic organisms«.
    Further, the AEC felt that there may be a toxicity problem
    due to zinc on the algae where the presence of zinc would
    inhibit photosynthesis.  The chlorine present in the blow-
    down water would, according to the AEC, likely cause some
    destruction of plankton near the point of discharge.
         The AEC also stated that the zinc may have an adverse
    effect on fish due to chronic sublethal toxicity of the zinc
    to various fish species.
    Treatment of Blowdown
         From the rather limited data available on the chemical
    composition of cooling tower blowdown water, it is apparent
    that in some instances, the blowdown water contains chemicals
    which would cause significant degradation of quality in re-
    ceiving waters.  Further, it should be noted that some of
    the most potentially important parameters with respect to
    causing chronic sublethal effects on aquatic organisms, such
    as ammonia, various trace metals and chloramines have not
    been analyzed at the concentrations which have recently been
    found to cause deleterious effects to aquatic organisms.
    It is reasonable to predict that as a result of further study,
    increasing attention will have to be given to the treatment
    of cooling tower blowdown waters.  While, in general, it is
    technologically possible to remove many of the chemicals present
    in cooling tower blowdown, the cost of such treatment should
    be considered in any assessment of the use of cooling towers
    versus once-through cooling as a means of disposal of waste
    heat.  Unfortunately, very little information has been
    published on these costs.  Glover (1970) presents a discussion
    of the cost of treatment of cooling tower blowdown water.   He
    

    -------
    estimates the cost of treatment by lime/alum precipitation
    with sulfur dioxide reduction of chromate, when it is used,
    to meet some of the more stringent water quality standards
    in effect at the time the paper was published.  He also lists
    the level of some of the treatment techniques that will be
    found in the blowdown under various treatment programs.  In
    Table 12 Glover's table is reproduced, except that the con-
    centration of chemical species in the blowdown water is com-
    pared to the current Illinois Pollution Control Board
    standards for Lake Michigan (IPCB, 1972) now in effect
    rather than to the Pennsylvania standards used by Glover.
    The ratio of the blowdown chemical concentration to the
    IPCB standard is listed for applicable chemical species.
    According to Glover, a ratio of ten or less of a particular
    chemical species does not require specific treatment since
    in-plant dilution of the blowdown may be assumed to be a
    factor of about ten.  This may not be the case for a thermo-
    electric power plant using only cooling towers for condenser
    cooling.
         The treatment costs shown in Table 12 were computed by
    Glover considering only chemical and sludge handling expenses.
    The residual levels of chromate, zinc, and phosphate after
    treatment are not given.  The cost of removal of the organics
    if it is required is based on one-time-use activated carbon
    adsorption.  Reactivation of the carbon may reduce the cost
    to 12{ to 24<:/1000 gal., according to Glover.
         It is evident from examination of Table 12 that large
    evaporative type cooling towers could require substantial amounts
    of funds needed for treatment of cooling tower blowdown
    waters in order to meet existing water quality standards.
    

    -------
                                         TAE1.E 12
      Uaste Disposal Characteristics and Cost of Treating Cooling Tower Slowdown
                                   After Glover (1970).
               Chemical Concentrations
    Treatment  in Blowdoim Water
    IPCB
    Lake
    Standard
    Ratio of
    Slowdown
    Concentration
    for IPCB
    Standard
    Disposal $ Cost
    per 1000 gal
    Slowdown
    chroiaate
    only
    zinc-chro
    mate
    zinc-chro-
    raate-phos-
    phate
    phosphate
    only
    zinc-phos-
    phate
    phosphate
    organic
    organic
    only
    organic bio-
    cide
    95-225 mg/1 Cr
    8-35 mg/3 Zn
    7-30 mg/1 Cr
    8-35 mg/1 Zn
    4-7 mg/1 Cr
    10-15 mg/1 P
    5-20 tng/1 P
    8-35 eg/1 Zn
    5-20 mg/1 P
    5-20 ig/1 P
    3-10 mg/1 "organic"
    100-200 mg/1 "organ-
    ic"
    10 reg/1 BOD (est.)
    100 mg/1 COD (est)
    50 mg/1 CCl^ extract-
    ed (est.)
    5 mg/1 MBAS
    30 mg/1 chlorophenol
    5 mg/1 sulfone
    1 rag/1 thiocyanate
    0.05 mg/1
    1.0 mg/1
    0.05 mg/1
    1.0 mg/1
    0.05 mg/1
    0.007 tpg/1
    0.007 mg/1
    1.0 mg/1
    0.007 mg/1
    0.007 mg/1
    none
    0.1 mg/1
    0.025 mg/1
    as Ci\T
    5000
    15
    200
    15
    100
    1500
    1500
    15
    10GO
    1000
    —
    300
    $0.70
    0.16
    0.13
    0.12
    0.14
    0.13
    1.25
    0.1-1.25
    

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                                 -46-
                               SUMMARY
         It is evident from the above review that a wide variety
    of potentially significant.chemicals are used in cooling towers
    in an attempt to minimize scale, corrosion, wood, deterioration,
    and general biological fouling.   Further, the operating
    characteristics of cooling towers can lead to excessive con-
    centrations of chemicals in blowdown which are derived from
    the makeup water, atmospheric sources, and the cooling tower
    and recirculating water structures.   It is entirely plausible,
    based "on the types and amounts of chemicals used in various
    types of cooling towers, that significant concentrations of
    these chemicals could be found in blowdown water which would
    cause significant deterioration of water quality in the waters
    receiving the bUowdown,
         It is difficult to obtain information on the actual
    chemicals used in various cooling towers because of the proprietary
    nature of these compounds, as well as the fact that cooling
    tower operators are reluctant to give  out this type of in-
    formation.  However, based on review of the literature and
    extensive discussions with various individuals in the cooling
    tower water conditioning field,  as well as those that operate
    the towers in various parts of the country, it can be con-
    cluded that cooling towers of the industrial type generally
    use a wide variety of chemicals  for water conditioning purposes.
    The larger cooling towers, especially those at thermal electric
    generating stations, of the natural draft type, sometimes operate
    with only the addition of sulfuric acid for neutralization of
    alkalinity and pH control, and chlorine as a biocide.
    Typically mechanical draft evaporative type cooling towers
    tend to use somewhat larger amounts and a greater variety
    of chemicals than natural draft towers, although this gen-
    

    -------
                                 -47-
    eralization would be dependent on location of the tower,
    characteristics of the tower, and other factors.  Therefore,
    as a minimum, one would expect  blowdown water from electric
    generating stations and other cooling towers to contain
    increased concentrations of sulfate, chloride, chlorine, and
    chloramines, as well as various chemicals that may be scrubbed
    from the air, arise from corrosion, or leach from the tower
    structure.  Under the worst possible conditions, with respect
    to the potential effect of Slowdown water on receiving water
    quality, the blowdown water could contain a wide variety of
    highly toxic inorganic and  organic chemicals which could have
    significant deleterious effects on aquatic organisms and
    man.  It is evident from this review that much greater attention
    must be given to potential deleterious effects of cooling tower
    blowdown on receiving water quality.
    

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                                 -48-
                            ACKNOWLEDGEMENT
         We wish to acknowledge the assistance given this lit-
    erature review by T.C.  Hoppe of Black and Veatch Engineers,
    Kansas City, the Illinois State Water Survey,  Urbana, Illinois,
    the Betz Laboratories,  Philadelphia,  Pennsylvania,  and M.
    Thompson of the Canada Centre for Inland Waters.
         This paper was supported by funds from the Commonwealth
    Edison Company, Chicago, Illinois and an Environmental
    Protection Agency Training Grant No.  5P2-WP-184-04.  In addition,
    support was given by the Department of Civil and Environmental
    Engineering at the University of Wisconsin.
    

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                                 -49-
                              REFERENCES*
    
    Atomic Energy Commission, Final Environmental Statement
         for the Palisades Nuclear Generating Plant, Consumers
         Power Company Docket No. 50-255 (June, 1972).
    
    Betz Company, Personal communication (1971).
    
    Carter, A.D. and Donohue, J.M. "New Protective Measures for
         Cooling Systems"  Mat'l. Prot. and Perf. (June, 1972).
    
    Christiansen, P.B. and Colman, D.R. "Reduction of Slowdown
         from Power Plant Cooling Tower Systems" in Industrial
         Process Design for Water Pollution Control, Vol. II.
         AICE (1970).
    
    Cone, C.S. "A Guide for Selection of Cooling Water Corrosion
         Inhibitors"  Mat'l, Prot, and Perf. (June, 1972).
    
    Crutchfield, H.C. "The Power Industry's Requirement for Cooling
         Towers"  Presented at Cooling Tower Institute Meeting,
         (January, 1970).
    
    Gummings, R.O. "The Use of Municipal Sewage Effluent in
         Cooling Towers1'  Presented at Cooling Tower Institute
         Meeting No. 41, (June, 1964).
    
    Dalton, T.F. "Cooling Water Treatment Chemicals Stops
         Pollution for Reusable Water"  Nat'l Eng.  66: 10-11
         (May, 1962).
    
    Davies. I. "Chemical Changes in Cooling Water Towers"
         Air and Water Pollution, 10_:   853-863 (1966).
    
    Donohue, J.M. "Organic Topping Agents1'  Southern Engineering
         52-54 (January, 1967).
    
    Donohue, J.M. "Changes in Cooling Water Treatment"  W.T. Betz
         Company, Trevose, Pa., mimeo.  (May, 1969).
    *Many of the papers which serve as the primary source of
    information for this review are unpublished in the technical
    literature.  Many of them have been presented at meetings
    of the Cooling Tower Institute.  This institute maintains a
    file of selected papers presented at their annual meetings.
    Copies of some of these papers may be obtained by contacting
    the institute in Houston, Texas.
    

    -------
                                 -50-
    Donohue, J.M. ''Pollution Abatement Pressures Influence Cooling
         Water Conditioning"  llat'l Prot and Perf (Dec., 1971)
         also Betz Laboratories Technical Paper 222.
    
    Ford, G.L. "Discussion."  Engineering Aspects of Thermal
         Pollution  Parker, F.L. and Krenkel, P.A., Eds.
         Vanderbilt Univ. Press, 272-281  (1969).
    
    Freedman, A.J. and Boies, D.B. "Cooling Water Corrosion
         Problems:  Causes and Cures"  Nalco Chemical Co.
         Reprint No. 101 (1960).
    
    F.W.Q.A. Lake Superior Enforcement Conference, Federal Water
         Quality Administration (1969).
    
    F.W.Q.A. Feasibility of Alternative Means of Cooling for
         Thermal Power Plants near Lake Michigan, Federal
         Water Quality Administration (1970).
    
    Carton, R.R. "Biological Effects of Cooling Tower Slowdown"
         Presented at American Institute of Chemical Engineers
         meeting (Feb., 1972).
    
    Georgia Kraft Company, Treatment of Selected Internal
         Kraft Mill Wastes in a Cooling Tower.  Water Pollution
         Research Series, U.1T Environmental "Protection Agency
         Washington, D.C. (1971).
    
    Glover, G.E. "Cooling Tower Slowdown Treatment Costs"
         in Industrial Process Design for Water Pollution Control,
         Vol. II. AICE (1970).
    
    Hesler, J.C.  "Recovery and Reuse of Chromatres from Cooling
         Tower Blowdown.  Part I."  Nalco Chemical Co. Reprint
         No. 150, Proc. Int'l. Water Conf. (September, 1964).
    
    Hoppe, T.C. "Industrial Cooling Water Treatment for Minimum
         Pollution from Blowdown"   Proc. Am. Power Conf. (1966).
    
    Hoppe, T.C. Personal Communication, Black and Veatch Engineers,
         Kansas City, Mo. (1971).
    
    Hwa, C.M. "New, Non-Chromate Synthetic — Organic Corrosion
         Inhibitor for Cooling Water Systems.i;  Presented at
         Cooling Tower Institute Meeting, (June, 1968).
    

    -------
                                 -51-
    Illinois Pollution Control Board, Water Pollution Regulations
         of Illinois (March, 1972).
    
    Illinois State Water Survey, Personal Communication (1971).
    
    Kelly, B.J. "Removing Chromates."  Nalco Chemical Co. Reprint
         No. 174, Ind. Water Eng.  (September, 1968).
    
    Kelly, B.J. and Puckorius, P.R. "Cooling Water Controls."
         Selected Papers on Cooling Tower Water'.Treatment
         Illinois State Water Survey Circular No. 91, Urbana,
         111., 77-90 (1966).
    
    Lees, R.D. and Twiford, J.L. "Polyelectrolytes as Cooling
         Water Antifoulants"  Presented at Cooling Tower Institute
         Meeting, (January, 1969).
    
    Marshall, W.L "Thermal Discharges: Characteristics and Chemical
         Treatment of Natural Waters Used in Power Plants"
         Oak Ridge National Laboratory Publication ORNL-U652 (1971).
    
    Minnesota, State of, Proposed Water Quality Criteria,
         Minnesota MPC 33 (1970).
    
    Miskimen, T.A. Personal Communication, American Electric/
         Power Service Co., New York, N.Y. (October 12, 1971).
    
    Morrow, N.C.  and Brief, R.S. "New York City Particulate
         Matter"   Environmental Science and Technology, 5,
         786-789  (1971),
    
    Motley, F.W.  and. Hoppe, T.C. "Cooling Tower Design Criteria
         and Water Treatment"  Presented at Cooling Tower  Institute
         Meeting, (June, 1970).
    
    Parker, F.L.  and Krenkel, P.A. Thermal Pollution:  State
         of the Art,  Report No. 3, Dept. of Environmental and
         Water Resources Engineering, Vanderbilt Univ., Nashville,
         Tenn.  (1969).
    
    Puckorius,  P.R.  "Tower as Part of Cooling System'"  Ind.
         Water Eng.  T_,  5:  U3-UU (May, 1970).
    
    Puckorius,  P.R.  ''Organic/Inorganic Polymers —•  A New Treatment
         for Cooling Water Systems"  Presented at Cooling Tower
         Institute Meeting, (January, 1971).
    

    -------
                                 -52-
    Puckorius, P.R. and Farnsworth, N.B.  "Recovery and Reuse of
         Chromates from Cooling Tower Slowdown.  Part II."  Nalco
         Chemical Co. Reprint No. 150, Proc.  Int'l. Water Conf.
         (September, 1964).
    
    Roesler, J.F., Smith, M.R., and Eilers,  R.G. "Simulation of
         Ammonia Stripping from Wastewater"   ASCE Sanitary
         Engineering Journal SA3, 269-286 (June, 1971).
    
    Sargent  and Lundy Company, Inter-office memorandum (August
         27, 1971).
    
    Savinelli, E.A. and Beecher, J.S. "Laboratory and Field
         Evaluation of Corrosion Inhibitors  for Open Circulation
         Water Systems"  Selected Papers  on  Cooling Tower Water
         Treatment.  Illinois State Water Survey Circular
         No. 91, Urbana, 111., 5-23 (196G).
    
    Schieber, J.  "The Chrcmate Removal Process"  Universal
         Interloc, Inc., mimeo,  (May, 1971).
    
    Sloan, L. and Nilrti, N.J. "Operating  Experiences with Ion
         Exchange Chroraate Recovery System"   Selected Papers on
         Cooling Tower Water ' Treatment,  Illinois State Water
         Survey Circular No. 91, Urbana,  111., 101-111 (1966).
    
    Smith, R.M. "Use of a Cooling Tower as a Trickling Filter
         in Pollution Control"  Presented at Cooling Tower
         Institute Meeting,  (January, 1964).
    
    Terry, S.L. "Use of Sewage Effluent as Cooling Tower Makeup"
         Selected Papers on Cooling Tower Water Treatment.  Illinois
         State Water Survey Circular No.  91,  Urbana, 111.,
         112-121 (1966).
    
    Thompson, M.E. Personal Communication, Canadian Centre for
         Inland Waters (1971).
    
    Thornley, J.L. "Water Treatment for Cooling Towers1'  Presented
         at Cooling Tower Institute Meeting,  (June, 1968).
    
    Troscinski, E.S. and Watson, R>.G. "Controlling Deposits in
         Cooling Water Systems"  Chem. Engr.  (March, 1970).
    

    -------
                                 -53-
    USHEW, Preliminary Air Pollution Survey of Iron and its
         Compounds (1969a).
    
    USHEW, Preliminary Air Pollution Survey of Zinc and its
         Compounds (1969b).
    
    USHEW, Preliminary Air Pollution Survey of Phosphorus and its
         Compounds (1969c) .
    
    USHEW, Preliminary Air Pollution Survey of Chromium and its
         Compounds (1969d).
    
    USHEW, Preliminary Air Pollution Survey of Cadmium and its
         Compounds (1969e).
    
    USHEW, Preliminary Air Pollution Survey of Mercury and its
         Compounds (1969f).  Range of 0.001-0.01 for Palo Alto,
         CA vapor only.,
    
    USHEW, Preliminary Air Pollution Survey of Ammonia and its
         Compounds (.19 6 9 g).
    
    USHEW, Preliminary Air Pollution Survey of Arsenic and its
         Compounds (1969h),
    
    von Koeppen, A. Pasowicz, A.F., and M^tz, R.A, "Mon-Chromate
         Corrosion Inhibitors"  Ind. Water Eng. 9_:  3, 25-29
         (April/May, 1972).
    
    Waselkow, C.  "Design and Operation of Cooling Towers'* Engineering
         Aspects of Thermal Pollution.   Parker, F.L. and Krenkel, P.A.,
         Eds., VAnderbilt Univ. "Press  249-271 (1969).
    
    Weisstuch, A., Carter, D.A. and Nathan, C.C. "Chelation
         Compounds as Cooling Water Corrosion Inhibitors"
         Presented at National Assn. of Corrosion Engineers
         Conf. (March, 1970).
    
    Willa, J. "Application Techniques for Treating Cooling Towers
         with Polychlorophenates71  Presented at Cooling Tower
         Institute Meeting, (January, 1965).
    
    Zecher, B.C. Comment in "Cooling Towers Q £ A"  Ind. Water
         Eng. 7_, 11: 19-21 (November, 1970a).
    
    Zecher, D.C. "Problems in Replacing Chromate as a Corrosion
         Inhibitor for Open-Recirculating Cooling Waters"  in
         Industrial Process Design for Water Pollution Control,
         Vol. II. AICE (1970b).
    

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                                                                  362
    
    
    
     1             Discussion - Commonwealth Edison Testimony
    
    
     2             MR. MAYO:  We had asked, gentlemen, that you hold
    
    
     3   the questioning until the completion of these presentations.
    
    
     4             Do you have any questions?
       |
    
     5             MR. FELDMAN:  Why don't I bring them all back up,
    
    
     6   Mr. Mayo?
    
    
     7             MR. McDONALD:  At the risk of inciting a riot in
    
    
         this endurance contest, I am going to ask a couple of ques-
    
    
     9   tions,
    
    
    10             I would like to address my question to Dr,
    
    
    11   Pritchard,
    
    
    12             Dr, Pritchard, I am interested in this sinking
    
    
    13   plume phenomenon, and I am particularly interested in your
    
    
    14   announcement of this sinking plume at this session of the
    
    
    15   conference, in that at least my understanding — and you may
    
    
         have to help me here because I wasn't at the previous
    
    
    17   session — that previous presentations by you indicated
    
    
         that the thermal plume dispersion was more of a hugging
    
    
    19   and outward flow rather than a sinking plume phenomenon
    
    
    20   And if I understand the sinking plume phenomenon in your
    
    
    21   presentation of it, this is a fact of physics that has been
    
    
    22   there and why, at this point, is it brought up for the
    
    
         first time?  What investigation, what set of factors led to
    
    01
     ^   the sinking plume not being recognized before by you?
    
    
                   DR. PRITGHARD:  Well, the conclusions that I come
    

    -------
               		363
    
    
     1             Discussion - Commonwealth Edison Testimony
    
     2   to right now with respect to Zion are not different than
    
     3   the conclusions that I had arrived at about Zion previously
    
     4   in the discussion of the sinking plume.  In fact, I don't
    
     5 !  think there was much recognition of a winter problem or a
    
     6   possibility of a winter problem in earlier considerations,
    
     7   I will readily admit that I did not consider winter in the
       i
     8   early stages of my analysis of the general subject of
    
     9   thermal effects.  I thought mostly of the warmer periods
    
    10   of time.
    
    11             The winter situation with the possibility of —
    
    12   well, with the fact that the natural temperatures of the
    
    13   lake dropped below the temperature maximum density, was
    
    14   raised during the Illinois hearings — the second — not
    
    15   the Illinois hearings on standards but the Illinois hearings
    
    16   related to Zion  itself.  And at that time I stated that my
    
    17   calculations at  the time indicated that the excess momentum
    
         in the Zion jet  would carry that plume through the critical
    
         region of having water sinking, which exceeded 3° above
    
    20   ambientj  and that if any sinking occurred, or if there
    
    21   was, let's say,  bottoming out — which is really a more
    
    22   proper term because it isn't a  diving plume, it  actually
    
         reaches a stage  when the momentum  settles down ~ there is
    
          essentially a  spreading out at  the bottom  (indicating)
    
         that this would  involve, that  small  temperature  differences
    

    -------
                   Discussion - Commonwealth Edison Testimony
     2   have no biological significance.   Whether or not  even above
     3   3° is another question.  But certainly at the temperatures
     4   that now appear and those that I  felt would occur then—
     5   we are talking about the possibility if overage of fish
     6   which overwinter do occur in the  region — we are only
     7   talking about changes in the incubation period of a matter
         of hours for temperatures that now appear likely  at
     9   Zion.
    10             The reason for bringing it up at this time, how-
    11   ever, is:  1)  the question was raised at the Illinois hear-
    12   ing; 2) Argonne has actually made some measurements of the
    13   phenomena; 3) during the course of investigation of Waukegan
    14   which  involved studies during the winter — and I might say
    15   that the winter plume, while physically there, the phenomena
    16   of  having temperatures exceeding 3° on the bottom had not
    17   really been  looked at  before the questions were raised and
         before people began  to look at plumes  in winter.  No one
         got out in the lake  and  measured plumes  in the wintertime,
    20   Argonne had  done  some, but  there had been no  real serious
    21   effort made  until it was deemed necessary  on the  basis of
    22   preliminary  evidence of  the observations to  go out and
         make a very  thorough study  of the  winter plume,  and  this
     ^   was done.
                    But,  in the end,  the analysis of the facts that
    

    -------
         	365
    
    
                   Discussion -  Commonwealth  Edison Testimony
    
    
     2 ;  I  stated previously during the  Illinois hearing that,  in
    
         fact, the excess momentum in the  Zion plume  should not make
    
    
         the winter  conditions a problem there are verified.
    
    
     5 il            MR. McDONALD:  Well,  since physicists have always
    
    
     6 i]  known "chat  water is at  a maximum  density at  39°» why was
       i
     7   it necessary to make studies in the  winter?  Was this  a fact
    
    
         that was just overlooked during your presentation  at the
     9
    10
    15
    17
    20
    21
    22
    23
    
    24
         earlier conference?
                   DR. PRITCHARD:  No.  The reason it was necessary
    
       i'!
    11 i  to make studies during the winter is that despite the fact
       ij
    12 i|  — and this is what I tried to emphasize in my testimony —
    
    13 i  that despite the fact that the temperature — that from
    
    14 !  the standpoint of the static stability — the plume should
         sink in about between 45° to 4o°>  it does not sink between
    16 |  45° and 46° if it had  excess momentum.      Even Waukegan,
         which is not designed with a high speed discharge, still has
          sufficient  excess momentum  so that  it actually  cools an
    
    19 |j   additional  7° to B° before  it sinks.  It actually passes
         through the region of maximum density before it sinks.  It
    
         has the same density as the surrounding water, 7° or 3° above
    
         the point that it sinks.
    
                   Now, while the physics of the fact that water in
    
         a condenser has its freezing point at 4° C. and, in fact,
    
         that water has the same density at 32° at a temperature of
    

    -------
         	366
    
    
    
    
    
                   Discussion - Commonwealth Edison Testimony
    
    
    
         46.5° approximately — while that was well known — I do not
    
    
    
         know of any physics at the present time,  any theory that
    
    
    
         allows us to predict at what excess momentum combined with
    
    
    
         the higher density the phenomena will occur*  And what is
    
    
    
         new here, and the reason we present it is that we now have
    
    
    
         some empirical data which allows us to make predictions
    
    
    
         about this.
    
    
    
     9             MR. McDONALD:  Well, let me see if I understand
    
    
    
    10   this now.
    
    
    
    11             This was the first time now that this data was
    
    
    
    12   presented by you publicly, today?
    
    
    
    13             DR. PRITCHARD:  The data, yes.   It is not the
    
    
    
         first time that we have talked about the winter plume.
    
    
    
    15             MR8 McDONALD:  Well, it is the first time you have
    
    
    
         talked about the sinking plume in this conference.
    
    
    
                   DR. PRITCHARD:  That is right.
    
    
    
                   MR. McDONALD:  Let me follow that point just a
       I
    
    
    19   little bit.
    
    
    
    20             What does the sinking plume mean to you in terms
       !
    
    
    21   of the method of discharge that might be employed by the Zion
    
    
    O o '
         plant in the event a  cooling tower is not installed?
    
    
    
                   DR. PRITCHARD:  As I have just said —
    
    
    
    2/f             MR. McDONALD:  At the location of the discharge;
    
    
    25
         the method  of discharge.
    

    -------
                                                                    667
     I
     2
                  Discussion - Commonwealth Edison Testimony
    
    
                  DR. PRITCHARD:   The present design of Zion will
        provide a discharge in which sinking of or bottoming out and
    
    
        spreading out of water along the bottom — a condition which
    
    
        would be unfavorable to rapid mixing — will not occur until
      11
    
    6 ||  the temperature in the worst case — and the worst case is
    
    
        when the lake is essentially 32° F. ambient condition — will
    
    
        not occur for temperatures higher than 34° to 35°.
    
    
                  I say that the possibility of the sinking plume at
    
    
        34° to 35° — I say this is —- on the basis of — both of
    10
    11
    12
    13
    15
    
    
    16
    17
    19
    20
    21
    22
    23
    
    
    24
        the observation of the fact that during winter there are
    
    
        natural periods in which bottom temperatures reach this
    
    
        situation? on the basis of the analysis of the incubation
    
    
        period as a function of temperature for whitefish eggs, that
    
    
        this has no biological significance whatsoever, and it does
    
    
        not exceed 3° above the ambient.
    
    
                  MR. MCDONALD:  It does not.
    
    
                  DR. PRITCHARD:  Does not.
    
    
                  MR. McDONALD:  At the thousand feet.
    
    
                  DR. PRITCHARD:  When you say "at the thousand
    
    
        feet," the Illinois standard is  "within an area equal to a
    
    
        circle having a radius of 1,000 feet."  And I might say
    
    
        this — I was rather surprised at the interpretation of the
    
    
        thousand foot limit because the worst kind of design is one
    
    
        that produces a circular dimension.
    

    -------
                                                                   868
     1
     2
    10
    11
    12
    13
    
    
    
    14
    
    
    
    15
    16
    17
    
    
    
    18
    19
    20
    21
              Discussion - Commonwealth Edison Testimony
              The way to design for minimum impact on the envir-
    
    
    
    onment produces an elongated plume with small area.  Now,  I
    
    
    
    can tell you that the area on the bottom at Zion, having
    
    
    
    temperatures exceeding 3° F. above ambient in the winter —
    
    
    
    I have computed, based upon the evidence we have from
    
    
    
    Waukegan, and I might say that during a summer of 70°, there
    
    
    
    will be no area having bottom temperatures 3° or greater
    
    
    
    above ambient, but during the wintertime when the temperature
    
    
    
    is on the order of 33° F,, the area of the lake for the double
    
    
    
    plume at Zion — that is twice the area of the single plume —
    
    
    
    having temperatures exceeding 3° will be 12,6 acres.
    
    
    
              MR. McDONALD:  12.6 acres.
    
    
    
              DR. PRITCHARD:  I am sorry for giving it that pre-
    
    
    
    cisely.  I admit I don't know it that precisely.  That is
    
    
    
    a computed value, but this will approximately be 12 acres*
    
    
    
              The surface plume would be approximately — well
    
    
    
    — several times that; but the bottom plume would be about
    
    
    
    12.6 acres.  But I'm almost certain that the bottom plume
    
    
    
    would be less than the 72 acres which is the acreage enclosed
    
    
    
    by a circle having a radius of 1,000 feet.  And I contend
     2   that from the standpoint of impact on the environment,
    
    
    
         while I question your conviction that there was a great deal
    
    
    
         of thought that went into that 1,000 feet, that there is
    
       i
    25 i!
       '  certainly no more and, in fact, because of the time-temperature
    

    -------
                                                                   869
    
    
    
                   Discussion - Commonwealth Edison Testimony
    
    
         relationship, considerably less potential for damage from
    
    
         an elongated plume, having larger dimensions in one direction
    
    
         than 1,000 feet but having no more area than the circle of
    
    
     5 11  1,000 feet area,
       i
    
     6             There has been much talk about the mixing zone and
    
    
     7   some implication that the mixing zone is a zone where damage
       |j
         will occur.  I resist that definition.
    
    
                   I might say that I have spent my whole life being
    
    
    10   concerned with protection of the environment.  That is my
    
    
    11   business.  And I contend that the mixing zone should not be
       i
    
    12   considered a zone at which damage will occur.  I define the
    
    
    13   mixing zone as the zone within which water quality criteria,
       i
    
    14 i!  based on long-time exposures, do not apply.  But water
    
    
         quality criteria  based upon time exposure history do apply,
    16
    17
    
    
    IB
    19
    20
    21
    22
    23
    
    
    24
    
    
    25
    and that there is no more damage within the mixing zone than
    
    
    there is outside, and in a properly designed plant that is
         zero.
    at Zion.
              MR. McDONALD:  Well, that is not going to happen
              DR. PRITCHARD:  I see — your legal experience
         gives you that
              MR. McDONALD:  Well, let me — no, your analysis
    gave me that.
              DR. PRITCHARD:  That what?  That there would be
    

    -------
        	870
    
    
     1             Discussion - Commonwealth Edison Testimony
    
     2   no damage?
    
     3             MR. MCDONALD:  Yes.
    
     4             DR. PRITCHARD:  That there would be damage?
    
     5             MR. McDONALD:  Was I wrong in that?
    
     6             DR. PRITCHARD:  You are.  I conclude that there
    
     7   will be no damage.  No damage.
    
     8             MR. McDONALD:  Okay.  Let me ask you another
    
     9   question, Dr. Pritchard.  And this concerns, again, this
    
    10   question of how much consideration, by way of field studies
    
    11   and data accumulation that you have engaged in beyond the
    
    12   immediate zone *>£ Zion, in coming up with your conclusion.
    
    13   How much beyond the area of Zion have you —
    
    14             DR. PRITCHARD:  Well, tne major part of ray work
    
    15   has been done elsewhere.
    
    16             MR. McDONALD:  I mean on Lake Michigan.
        i
    17  |           DR. PRITCHARD:  I personally have not conducted
    
    1&   research on Lake Michigan.  I have, however, studied the
        I
    19   results of the work at Waukegan and served on a consulting
       i'
    20   group that has come in and tried to direct that work so that
    
    21   it would be as solid scientifically as possible.
    
    22             I might say that that group has not been lenient;
    
    2^   it has been quite critical.  It has pushed that work to be
       ii
    2^   solid, scientific work.  I have studied the results from
    
    25
       i| the Waukegan  study.  I have also gone over most of the work
    

    -------
                      Commonwealth  Edison  Company
                      ONE FIRST NATIONAL  PLAZA  if  CHICAGO, ILLINOIS
                      Address Reply to
    
                      POST OFFICE BOX 767 * CHICAGO, ILLINOIS 60690
                                              October  3,  1972
    Mr. Francis T. Mayo, Chairman
    Lake Michigan Enforcement Conference
    U.S. Environmental Protection Agency
    Region V
    One North Wacker Drive
    Chicago, Illinois  60606
    
    Dear Mr. Mayo:
    
              On Thursday, September 21, 1972,  I  appeared before the
    Lake Michigan Enforcement Conference and presented testimony with
    respect to costs for alternate cooling systems  for Commonwealth
    Edison's Zion Generating Station.  Following  the  presentation of
    the above testimony, Mr. Carlos Fetterolf of  the  Michigan Water
    Resources Board asked a question of me requiring  that I  submit
    more detail with respect to the $34,105,000 figure appearing on
    Exhibit B Line II a.  This figure represents  the  cost of the
    loss of capability of the Zion plant when wet mechanical draft
    cooling towers are applied as the cooling means in place of
    once-through cooling which is proposed.  The  following explanation
    is submitted in answer to Mr. Fetterolf*s question:  If  wet
    mechanical draft cooling towers were applied  to the Zion Station
    the maximum continuous output of the station  would be reduced
    for the following three reasons:
    
         1.   The backpressure on the turbines would  be increased
              due to the higher temperature of the  water coming
              from the cooling towers to condense the steam. For
              the two Zion units this reduction in  net output
              capability is 127,596 kw.  Attachment 1 to this
              letter contains the turbine performance curves
              marked to illustrate the difference in  performance
              when using Lake Michigan water for  cooling vs.
              water returned from cooling towers  and  shows the
              method of development of the output loss.
    
         2.   Additional pumping power will be required to lift
              the circulating water to the cooling  towers.   This
              power requirement, in the plant, reduces the net
              plant output power by 21,901 kw.
    
         3.   Power will be required to operate the fans on  the
              cooling towers.  This will reduce the net plant
              output 9,616 kw.
    

    -------
    Mr. Francis T. Mayo              Page 2             October 3, 1972
              The above losses in net output add to 159,113 kw
    directly attributable to modifying the station to utilize
    mechanical draft cooling towers.  This loss of capacity must be
    replaced with nuclear generating capacity at some other location.
    We have been very conservative in valuing the replacement
    capacity at $207/kw, which is the presently estimated cost of the
    Zion capacity.  As I testified on September 21, to replace this
    capacity in a plant starting today would cost in the order of
    $400/kw.  Multiplication of the 159,113 kw times $207/kw amounts
    to $32,936,000.  The investment in additional generating capacity
    to replace that lost by the application of mechanical draft
    cooling towers will also incur property taxes.  The additional
    property taxes due to this investment are estimated to amount
    to $1,169,000.  The sum of the investment cost and property taxes
    amount to $34,105,000.
    
              I hope that the above explanation fully answers
    Mr. Fetterolf*s question.  If it does not, I will be pleased to
    hear from you.
    
                                             Very truly yours.
                                             O. D. Butler
                                             Assistant Vice President
    Attachments
    cc:  Mr. C. Fetterolf
          (Michigan Water Resources Com.)
         Mr. A. D. Feldman
          (Isham, Lincoln & Beale)
    

    -------
                                                    ATTACHMENT 1
                     CALCULATION OF CAPABILITY LOSS
    
    
    
    
    
    
    
    
    1.     From curve A using once through cooling the turbine back
    
    
    
           pressure at full load is established to be 2.7 inches of
    
    
    
           mercury absolute.
    
    
    
    
    
    2.     From curve B using cooling towers the turbine back pressure
    
    
    
           at full load is established to be 5.1 inches of mercury
    
    
    
           absolute.
    
    
    
    
    
    3. a.  From curve C the 2.7 inches of mercury absolute back
    
    
    
           pressure establishes a load correction of minus 1.8% of
    
    
    
           1,129,167 kw design for 1.5 inches of mercury absolute
    
    
    
           back pressure, or a load of 1,109,971.
    
    
    
    
    
    3. b.  From curve C the 5.1 inches of mercury absolute back
    
    
    
           pressure establishes a load correction of minus 7.35% of
    
    
    
           1,129,167 kw design for 1.5 inches of mercury absolute
    
    
    
           back pressure, or a load of 1,046,173.
    
    
    
    
    
    4.     The difference between 3a and 3b is 63,798 kw which is the
    
    
    
           loss in capability of one unit due to increased back
    
    
    
           pressure as a result of installing cooling towers.  Total
    
    
    
           loss in capability of two units is 127,596 kw.
    

    -------
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    -------
                                                                 871
    
                  Discussion - Commonwealth Edison Testimony
         that  has  been  done  by Argonne  in measurements of plume
         dimensions  and have even,  in fact, used their  data in con-
     4   firming thermal plume models that  are  —  I might say that
         this is not a  static field.  I consider the  thermal plume
         modeling  as a  living science and the models  as  living models
         which change as we add day-to-day more information, and  this
     8   is being  done.
     9             1 have spent a great deal of my time  in  taking
    10   data that is collected not only on Lake Michigan but  every-
    11   where else in the world, and feeding that into  the fund of
    12   knowledge that has gone into thermal modeling,  including
    13   work done at MIT and the plume work we do, work on other
    14   Great Lakes, the Ghinna plant — I did personally do some
    15   work on  Lake Ontario in the Ghinna plant, and I have looked
    16   at  the results of  that design as  far  as  the thermal plume
    17   goes.
    18              MR.  McDONALD:   No,  I wasn't trying to imply that
    19   you aren't interested and that you haven't  done work else-
    20   where.   The question that I really was interested in was  a
    21    question that I raised  with several other people, and that
    22    is the idea of getting  a blueprint that  would  link all  of
    23    the powerplants and all of  the discharges into some  common
    2/»-    overall  monitoring program  of the lakes  with participation
    25    beyond the parochial limits of Zion,  Point  Beach, where
    

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                                                                   372
    
    
    
     1             Discussion - Commonwealth Edison Testimony
    
    
     2   these very limited zones that, of necessity, you find your-
    
    
     3   self involved in*
    
    
     4             DR. PRITCHARD:  I wonder — have you ever read the
    
    
     5   testimony that I gave at the last conference?
    
    
     6             MR. McDONALD:  I have not read it in its entirety,
    
    
     7   no*
    
    
                   DR. PRITCHARD:  Well, I feel that quite contrary
    
    
     9   to some of the statements that were made — and I tried to
    
    
    10   keep my testimony short so I left it out this time — but
    
    
         I feel that it is a clear statement that the problem is not
    
    
    12   a  lakewide  problem, not even in the year 2020, not even
    
    
    13   when — not when but if you put 10 times the amount of heat
    
    
         into the lake  that you do now.
    
    
    15             MR. McDONALD:  Well, I am aware of that.  But the
    
    
    16   question I am asking is:  As a matter of insurance, whether
    
    
         you are convinced or not — some people feel that it may
    
    
         be a lake problem—and as a matter of insurance and as a
    
    
         matter of investment, would it make sense?
    
    
    20             DR. PRITHCARD:  Well, I think that it makes sense
    
    
         to have a monitoring program which is consistent in obtain-
    
    
    22   ing necessary data with respect to all plants and with
    
    
    2^ j  respect to the spaces in between them; and  it doesn't
    
    01 I
         necessarily have to be a centrally controlled program, but
    
    
         it should be one in which there is a collection of  data
    

    -------
     7
    
    
     8
    10
    11
    12
    13
    
    
    14
    
    
    15
    
    
    16
    17
    18
    20
    21
      	873
    
    
    
    
                Discussion - Commonwealth Edison Testimony
    
    
    
      and a review by some perhaps joint committee involving the
    
    
    
      various State agencies, the Federal agencies, and the univer-
    
    
    
      sity people who have an interest, and the companies.
    
    
    
                I might point out that this is exactly what is being
    
    
    
      done in another part of the country, in the Chesapeake Bay.
    
    
    
      It involves two States — not as many as you have; it in-
    
    
    
      volves a waterway of about the same size — perhaps not
    
    
    
      quite the volume, but of certainly more complexity than the
    
    
    
      lake — and there is in that region a group called the Clean
    
    
    
      Water Study Group.  It is comprised of all research institu-
    
    
    
      tions and universities engaged in work on powerplant siting
    
    
    
      and studies of the effects of thermal discharges in the
    
    
    
      Chesapeake Bay area; it comprises representatives from all
    
    
    
      Federal agencies concerned, including your own; it comprises
    
    
      representatives of industry; and all of the data is available
    
    
    
      to everyone else.  We have subcommittees that compare research
    
    
    i  and designs, that interchange techniques, and propose standard
    
    
      approaches to the studies.  There are coordinated studies
    
    
      involving company biologists, and State biologists, and
    
    
      university biologists with no lack of passage of information.
    22
                   I might say it wasn't always that way, and I got
    
    
    23
     J   into this business back when there were problems with very
    
    
    2.L \
         great lack of cooperation.
    
    
    25
                   But in Maryland I serve the State, and I serve on
    

    -------
         	S74
                   Discussion - Commonwealth Edison Testimony
         the various groups that are involved in this kind of research
         which in Maryland are supported by the  Federal  Government
         and the State, and I see a great deal of cooperation and
         study of the whole system with the intent of ultimately
         ending up with a — to be sure that we  stay ahead of
         the possibility of overloading the system,
     B             MR. MCDONALD:  Thank you.
     9             MR. FETTEROLF:  A while back — while Dr. Pritchard
    10   is still on the stand — I think I can clarify something for
    11   you, Jim.
    12             The Lake Michigan Technical Committee for the Study
    13   of Thermal Discharges pinpointed sinking plumes as a possible
    14   problem.  As a result of that, Argonne National Laboratory
       j
    15   established some stations off one of the plumes and did
    16   identify the fact that the plume did sink in the wintertime.
    17             The Bureau of Sport Fisheries conducted studies
         or what an increase in incubation temperature for the over-
         wintering eggs of whitefish would result in, in the way of
    20   changes to maturation and hatching time.
    21             They have shown that  shortening of this time or
         that increased temperatures would result in a shortening
         of this period.
                   The Palisades Impact  Statement included a consid-
         eration of  sinking  plumes.  And as a result of this activity,
    

    -------
     3
     4
        	375
                   Discussion - Commonwealth Edison Testimony
         Bio-Test then went out on these 2 days to investigate sinking
        plumes.
                  Now your question is:   why did Dr.  Pritchard bring
        this up?  And the reason that he did and that you were
        after, he didn't give you,  was that he was saying that by a
    7 i  jet discharge, there was enough horizontal momentum given
        to the plume that cooling in the surface waters occurred for
        an extended period and allowed the plume to cool down below
        the point of maximum density before it sank.
    10
    11
    12
    13
    14
    15
    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
                  In other words, if it had been a low velocity dis-
        charge, it would have sunk when it was at a temperature of
        about 43° or 44° F.,  but because Zion has a jet discharge,
        it didn't sink until it reached 36° or 37° F.  I think that
        is what his major point was.
                  DR. PRITCHARD:  I agree with the previous lady
        that said that they shouldn't hold this conference without
        you here.  Thank you very much, Carlos.
                  MR. McDONALD:  My concern was that it appeared to
        be contradictory to earlier  presentations by Commonwealth
        Edison, not by your Technical Committee.  You are not
        representing Commonwealth Edison.
                  DR. PRITCHARD:  Well, it is not contradictory to
        earlier testimony because the testimony given earlier dealt
        with the type of discharge which is at Zion, which we said
    

    -------
     1             Discussion - Commonwealth Edison Testimony
    
    
     2   there would not be 3° temperature water or any significant
    
    
     3   above ambient over any significant area involved during any
    
    
     4   season of the year*  We did not specifically discuss the
    
    
     5   sinking plume problem, but since it has arisen and there have
    
    
     6   been considerable questions about it, I then went into the
    
    
     7   analysis and asked that the Waukegan study be done following
    
    
         this question that was raised in the Technical Committee and
    
    
     9   also in the Illinois hearings, that we look and see if we
    
    
    10   could obtain an estimate of the excess momentum still present
    
    
    11   in the plume at the time that the plume sank.
    
    
    12             In other words, we went after this information —
    
    
    13             MR. McDONALD:  Okay.  I think that answers it.
    
    
    14             DR. PRITCHARD:  — to confirm what we had already
    
    
         said*
    
    
                   In a very similar way, we made use of the older
    
    
         model to confirm the things that we had already determined
    
    
    1°   theoretically.
    
    
    19             MR. MAYO:  I have just a brief inquiry, Dr.
    
    
    20   Pritchard.
    
    
                   On page 9 you make reference to the fact that on
    
    
         both of the occasions that Bio-Test did its work that there
    
    
         was a strongly developed sinking plume at the Waukegan
    
    01
         power station
    
    
    25             DR. PRITCHARD:  Yes.
    

    -------
         	$77
    
                   Discussion - Commonwealth Edison Testimony
                   MR. MAYO:  I gather that if you were looking for a
          situation that probably represented the worst kind of an
          opportunity or perhaps the best kind of an opportunity for a
          sinking plume to develop, it would be in the Waukegan config-
          uration for a discharge, where you have low velocities.
     7  |j           DR. PRITCHARD:  Well, Waukegan has a 3 f.p.s.
          discharge at these discharge volumes and up to 3.5 f*p.s« at
          other times, so that, by chance, because of the nature of the
    10    natural reaches of the processes of the fill that have taken
    11    place at the discharge ~ at the end of the discharge canal,
    12    actually Waukegan is a moderately high-speed discharge not
    13    a low speed.  There are much lower speed discharges in the
    14  |  area.
    15             MR. MAYO:  So that if we did indeed have concern
          for the sinking plume and its impact upon organisms, the
    17    shoreside  configuration for discharge with the Waukegan
          range of velocities or less would probably be very desirable
          to avoid them.
    20             DR. PRITCHARD:  Yes.  I might say that — I hope
          I am authorized to say this — but I know that the State of
    22  I
          Illinois is requiring that the Commonwealth Edison Company
    2*5
     J    provide plans to bring Waukegan into conformity with the
    2.L  \
     *    existing State standards, and the winter plume is under
    25
          consideration, and I have developed and given to the company
    

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     5
    
    
     6
    
    
    
     7
    
    
     6
    10
    11
    12
    13
    15
    
    
    16
    
    
    
    17
    
    
    18
    19
    20
    21
              Discussion - Commonwealth Edison Testimony
    
    
    
    the basis for a design of the change to discharge structure
    
    
    
    at Waukegan which I feel will eliminate at Waukegan also the
    
    
    
    winter plume, at temperatures higher than 3° above ambient.
    
    
    
              MR. MAYO:  Thank you.
    
    
    
              MR. FETTEROLF:  I had one more question.
    
    
    
              Dr. Pritchard, you alluded to the fact that a long,
    
    
    
    thin plume was more advantageous environmentally than a blob-
    
    
    
    type plume.  By this, are you inferring that if a regulatory
    
    
    
    group places restrictions of an arbitrary nature on a plume
    
    
    
    size that it might not always be the most environmentally
    
    
    
    benign type of thing that could be done?
    
    
    
              DR. PRITCHARD:  I am very much — I do that very
    
    
    
    much so, in terms of my great concern and my conviction,
    
    
    
    and also I think the biological evidence, that the pertinent
    
    
    
    biological consequences of the near field involved in the
    
    
    
    time-temperature exposure relationship is not specifically
    
    
    
    distance from the discharge.
    
    
    
              And when one designs a discharge to have a small
    
    
    
    time of exposure of an organism either entrained through
    
    
    
    the  condenser and  discharged out into the plume or entrained
    22    in the plume — that design will naturally produce an
    
    
    
          elongated plume.  That  is, you are  striving towards a high
    
       ;
    O}  I'
          Densimetric Froude  number and that  is an  elongated plume.
       i
    
    25 i
                    Now, if you strive for a  circular —  essentially
    

    -------
         	379
    
    
    
    
                   Discussion - Commonwealth Edison Testimony
    
    
    
         a blob, either through some widespread diffuser pattern, you
    
    
    
         are going to essentially have a very much longer exposure of
    
    
    
         the organisms entrained into the system, and to temperatures
    
    
    
         which may be detrimental.  And every organism that has been
    
    
    
         studied — and now there are literally hundreds of aquatic
    
    
    
         and marine organisms in which measurements have been made of
    
    
    
         the stress of a given temperature rise as a function of
    
    
    
         time, and it is clear that the temperature tolerance of an
    
    
    
    10   organism when exposed to 4# hours, 24 hours, or an hour, is
    
    
    
    11   quite different than to 15 minutes, 5 minutes, or 30 seconds,
    
    
    
    12   And these are order of magnitude differences, in effect*
    
    
    
    13   And I am not just talking about depth, I am talking about
    
    
    
    14   the large amount of measurements that have been made on some
    
    
    
    15   of the organisms that are pertinent here in the lake —
    
    
    
    16   the salmonid fishes, on fish fry — as far as escaping
    
    
    
    17   predation — a very  solid kind of test  in which you take
    
    
    
         a group of control, of salmon fry, or salmon fingerlings
    
    
    
    19   you have acclimated to some temperature; you take half of
    
    
    
    20   them, mark them  some way  so that you identify them from the
    
    
    
    21   control group, and raise  their temperature^ keep them at an
    
    
    
    22 j  elevated temperature until a certain time, and put both
    
    
    
    23   groups into a tank of hungry predators$ and after a standard
    
    
    
         length of time,  catch the predators, catch the remaining
    
    
    
    25   control and experimental  group and count the number of
    

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    10
    11
    12
    13
    14
    15
    16
    17
    19
    20
    21
    22
    23
    24
    25
    	sao
              Discussion - Commonwealth Edison Testimony
     survivors from  each group.  And this tells you whether or
     not  thermal  shock — which is not observable in any other
     way  —  has,  in  fact, increased the predation rate.
              Such  subtle events as this are clearly related to
     the  time-temperature exposure, and if you design a plume
     which is related to a high velocity discharge, you are going
     to cut  down  the time of  exposure of such organisms.   They
     can't stay in the plume; they have got to be carried  with
     it.
              MR. ZAR:  I have a brief question.
              Dr. Pritchard, do you believe that the 1,2  f.p.s,
     velocity is  well established at this point, or that perhaps
     some sort of Froude number formulas might be utilized?  How
     much more data  would you need  in order to handle that now?
              DR. PRITCHARD:  Well, I think that probably that
     I took  a somewhat higher number — on one of those examples
     it was  less  than 1  f.p.s. — and if I used a Densimetric
     Froude  number at that point I  would come out with the same
     number  because  we are talking  about essentially only  slight
     differences  in  the  density  difference between  the 37° and
     the  35° water.   So  the   Densimetric Froude number would be
     very much the same  in  the  two  cases.
               So I  am just  using  the  velocity  essentially as a
     measurement.  I took 1.2,  and in  one  case  it was  0.7.  We
    

    -------
                                                                   aai
                   Discussion - Commonwealth Edison Testimony
         didn't observe temperatures above 37° on the bottom.
                   In the other case, I took 39,  which raised the
         velocity to 1.17.  On the other hand, there was only one
         measurement out of 140 bottom measurements which was 39°
     5   outside the immediate area of the discharge.  So that I
     7   really used a rather — I was conservative in just taking
     >
         a high number.  So I think that is reasonably well estab-
         lished.
    10             MR. ZAR:  The calculation you drew for the 2.6° F.
    11   temperature in the Zion
    12             DR. PRITCHARDi  Yes.
                   MR. ZAR:  — plume — was that based on the plume
    14   analysis that we  saw back in October of 1970, or has there
    15   been  some more recent plume analysis been done on the lower
    16   temperatures, and so on?
    17             DR. PRITCHARD:  I have —  since that time, I  say
    18   I have what I consider to be a living model and the model
    19   has improved, I  feel.  I have literally 10 times as much data
    20 l  as I  had then on the plumes to confirm the model.     The
    21   model now includes the Densimetrlc Froude number, includes
    22   the prediction of depth thickness, vertical thickness,  etc.,
    23   and this has been applied to  Zion,   And I guess —  and  I
    24   might say from  some  standpoint somewhat gratuitously — the
    25   choice of a two-dimensional model, which was used in the
    

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                                                                   S82
     1             Discussion - Commonwealth Edison Testimony
     2   early work, was done because of the lack of complete data
     3   on the vertical growth.  But it also was conservative in
     4   that it eliminated any vertical entrainment.  There is
     5   evidence that vertical entrainment will take place restricted
     6   by the increased  density   gradient there but that some ver-
     7   tical entrainment does take place.
                   MR. ZAR:  Has that work been written up in a form
     9   that would be useful to the conferees?
    10             DR. PRITCHARDs  I am in the process of writing it.
    11   I owe it to AEG and to a number of other agencies to get the
    12   new thermal model out.  But essentially it  contains as much
    13   of elements of some of the other sophisticated models such as
    14   the MIT model, which I think is more consistent with data
    15   — even their own — than that model.
    16             And i would  just  say that the results are essen-
         tially similar as far  as the Zion  3° isotherm.
                   MR. ZAR:  In relation to the thermal bio	 I'm
         in trouble  already.  I did  have several questions,  but I
         will  only  ask one.
    21              There were a few  references noted in the  Argonne
    22   report, which I presume you have  read,  some of which  seem
         to  suggest that the thermal bar is indeed inhibiting.
                    i presume you  looked at those references and I
         wonder if you could comment just  briefly on those.
    

    -------
     T              Discussion - Commonwealth Edison Testimony
     2             DR. PRITCHARD:  Well,  I have looked at,  I think,
     3   most of the references on the thermal bar, and I don*t
     4   remember precisely the details of those that suggested
     5   that it was inhibiting*  The ones that I feel are the best
     6   ones on these studies have indicated that the thermal bar is
     7   a region of vertical convection.  It clearly has to be a
     8   region of vertical convection*  It is not like a thermo-
     9   cline if it is a region of maximum density difference or
    10   density stability, but it is a region of minimum stability.
    11   And you cannot have essentially the creation of water of
    12   maximum density without it sinking and causing convective
    13   overturn.  It is just a physical impossibility.
    14             So that — I don't remember the details of the
    15   specific statement that suggested this, except the  "white
    16   paper,11 which I think just misunderstood the physics com-
    17   pletely.  They have referred to  it as a region of stability.
    IS   which  it is  not.
    19             MR. ZAR:  I have some  other questions, but I will
    20   get you  some other time.
    21             MR. MAYO:  Any  questions,  gentlemen?  Any questions
    22   of any of the other  Commonwealth Edison representatives?
    23             MR. FETTEROLF:  I am  going to be  very brief.
    24             Mr. Butler,  on  page 6 you said  your loss of
          capacity —  generating capacity — the  loss is  $34 million.
    

    -------
                   	884
                   Discussion - Commonwealth Edison Testimony
     2   Per what, sir?
     3             MR. BUTLER:  That is $34 million for the entire
     4   plant,
     5             MR. FETTEROLF:  Per what?  For the year?  For the
     6   life  of the plant per year, or what?
     7             MR. BUTLER:  That is a difficult question,
                   MR. FETTEROLF:  Well, if it is a difficult ques-
     9   tion, maybe you could answer it in writing, in the interest
    10   of time*
    11             (Mr, Butler's reply to this question, submitted
    12   following the conference, follows in its entirety.)
    13
    14
    15
    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
    

    -------
         	335
    
     1             Discussion - Commonwealth Edison Testimony
     2             MR. FETTEROLF:  For Dr. McNaught, on page 2,  isn't
         your finding on the mortality of zooplankton in the raising
     4   of those temperatures from different acclimation temperatures
     5   something new in the zoological literature?
     6             DR. McNAUGHT:  As I said, I think we are about a
     7   magnitude below some of this weakly supported evidence that
         we have heard.
     9             MR. FETTEROLF:  This does not not conform with
    10   Fisheries information on increased temperatures and mortalities
    11   of fish over certain time periods.
    12             DR. McNAUGHT:  But look at the size of organism
    13   we are dealing with.  I think that this is going to be a
         clue.
    15             MR. FETTEROLF:  This is a new concept, isn't it?
    16             And, Dr. Raney — I know you are not bashful,
         sir,  (Laughter) — very frankly, aren't you considered the
         country's leading expert on intake design  as far as preclud-
    19   ing  fish?
    20             DR. RANEY:  Well, I can  only say that I  have been
    21   interested  in it and  I  think I know all of the methods, and
         over the last 5 years I have spent a good  many thousands of
         dollars trying to improve the kinds of intake structures
    24
         that we now have.
    25
                    MR.  FETTEROLF:   This is your reputation as  the
    

    -------
     1             Discussion - Commonwealth Edison Testimony
    
    
     2   country's leading  expert; you are a consultant for Common-
    
    
     3   wealth.   Have  you  been consulted as far as intake design and
    
    
     4   problems by other  utilities  on Lake Michigan?
    
    
     5             DR.  RANEY:  Yes, sir.
    
    
     6             MR.  FETTEROLF:  And are they following your advice?
    
    
     7             DR.  RANEY:  I  think in  some cases.
    
    
     g             You can't be  sure  until the structures are  built.
    
    
     9   (Laughter)
    
    
    10             MR.  FETTEROLF:  Well, we will  look into  that.
    
    
    11             MR.  MAYO:  I  think you  were extremely complimentary
    
    
    12   to Commonwealth Edison,  Dr.  Raney, when you commented on the
    
    
    13   fact that at the intake facility  for Zion,  when they put up
    
    
    14   nets with   3.-inch mesh and that  you felt very confident
       I
    
    15   that for any of the organisms,  fishes that would pass that
    
    
    16   1-inch mesh, that Zion was going  to  find a  way that  they
    
    
    17   could gather them up some way and find a way to keep them
    
    
    13   from going  into the intake.  When you consider, I think,
    
    
    19   that the intake is 2,500 feet from shore, I think that is
    
    
    20   a challenge indeed.
    
    
    21              DR. RANEY:  Yes,  it is a challenge.  And we  back
    
    
    22   up this challenge by actually doing  experimental work  in a
    
    
    23   situation that  is much, much worse,  and  that  is off  southern
    
    
    2/*   California where  we have  similar intakes, and where  millions
    
    
    25 I  of fish actually  are brought in.  And after about a  year's
    

    -------
                                                                   as?
    
    
    
                   Discussion - Commonwealth Edison Testimony
    
    
    
     2   hard work with experimental plumes, we have reached the point
    
    
    
     3   where we can make recommendations, and we are confident that
    
    
    
     4   we are going to be able to cut those mortalities by 99.9
    
    
    
     5   percent.
    
    
    
     6             MR. FRANCOS:  Could I ask a question?
    
    
    
     7             Is there any way that you can generalize, on the
    
    
    
         basis of the reports that we have had of these large kills
    
    
    
     9   at intake structures, the primary cause?
    
    
    
    10             DR. RANEY:  Yes.  There are — basically, due to
    
    
    
    11   originally poor design, where you have vertical trapping
    
    
    
    12   screens located in the far end of an intake canal, what
    
    
    
    13   happens:  Fish get in there and they turn and face the cur-
    
    
    
    14   rent; they swim sometimes for weeks until they get tired,
    
    
    
    15   and they come up on the screen and go into the bins.
    
    
    
    16             Now we worked out a system that we can put into
    
    
    
    17   these situations.  It is what we  call a Murphey basket lift,
    
    
    
         and what this basket does is sweeps up in advance of the
    
    
    
         stream, dips gently — just like  pouring water out of a
    
    
    
    20   pitcher — into a sluice.  This sluice then goes back into
    
    
    
    21   the lake or the sea.  So that there are lifts available or
    
    
    
         sluices where the original design was bad.
    
    
    
                   MR. FRANCOS:  Thank you.
    
    
    2L
                   MR. ZAR:  May I ask a question of Dr. McNaught?
    
    25
                   As to your Figure 1 which includes some 1972
    

    -------
        	aaa
    
    
    
     1             Discussion - Commonwealth Edison .Testimony
    
    
     2   zooplankton data, as I understand Dr. McNaught's answer to a
    
    
     3   question we asked earlier about the data availability, much
    
    
     4   of this data has not yet been made available, and a number
    
    
     5   of our scientists have indicated an interest in getting it.
    
    
     6             DR. McNAUGHTj  To be truthful, I stole that figure
    
    
     7   from a Bio-Test report, so I think it is on the way.
    
    
     8             MR. ZAR:  The second thing, on page 4 you referred
    
    
     9   to upper lethal temperatures, but you don't indicate what
    
    
    10   they are or what you found them to be for those organisms
    
    
    11   or whether you have actually done that.
    
    
    12             DR. McNAUGHT:  Yes, that was by personal communica-
    
    
    13   tion with some of the Bio-Test people.  They told me  that
    
    
    14   they were much higher than some of the work that had  been
        I
    
    15   done in the Mihurski group, and I have not seen the data
    
    
    16   report yet.   I only have it by personal communication.
    
    
    17             MR. ZAR:  So you donft know if the numbers  are —
    
    
                   DR. McNAUGHTs  I don't think it would be  fair to
    
    
         put the numbers  in the record at this time until I  have a
    
    
    20    chance to personally  examine the data report.
    
    
    21             MR.  zAR:  Then there are  two  other questions that
    
    
    22    I have been asked to  put to you.  One is:   Can you place  an
    
    
          importance  on the killing  of  a million  pounds of zooplankton,
    
    
          or 500,000  pounds or  2 million pounds,  or whatever?
    
    
    25              DJJ. McNAUGHT:   That  is a difficult question.  I
    

    -------
     1             Discussion - Commonwealth Edison Testimony
     2   think that, as Mr. McDonald has repeatedly stated tonight,
     3   we should place this in a total ecosystem context,
     4             Now, we are talking about 7 percent of the stand-
     5   ing crop passing through the condensers.  This is not, of
     6   course, the total lake standing crop; this is the portion
     7   of the standing crop that passes through the condenser,
     8   And it is my feeling, from my own personal studies on the
     9   Great Lakes, that these subpopulations, as you will have it,
    10   that suffer this mortality, will very rapidly come back to
    11   carrying capacity once they are back in the open lake again,
    12   Detailed studies in the future in the plume areas will tell
    13   us where this return in carrying capacity indeed will
    14   occur,
    15             MR, ZAR:  Have you looked at the Bio-Test data
    16   with respect to zooplankton or does your work on Lake
    17   Ontario give you a feel for this?
    IS             DR. McNAUGHT:  I was referring passively to my
    19   work on Lake Ontario.  I think when the animals first come
    20   back into the plume that they probably overshoot to a slight
    21   degree the  carrying capacity that they once held.  The plume
    22   is going to make up for this condenser mortality*
                   MR. ZARs  I have one last  question.  Comparison
         was drawn between Waukegan and Zion.  What was done was
         that Waukegan condensers that were used were unusually high
    

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                                                                   390
    1
    2
     3
     4
     5
     6
     7
     9
    10
    11
    12
    13
    15
    20
    21
    22
    23
    2/f
    25
                   Discussion - Commonwealth Edison Testimony
             T's?
                  DR.  McNAUGHT:   Right.
                  MR.  ZAR:   Because of the longer intake and the
        different plumbing that is in the Zion system,  would there
        be any differences expected as to mechanical damage that woulc
        occur?  I am thinking in part of the Grosse lie in the EPA
        report which seemed to indicate  some additional effects at the
        Big Rock plant.
                  DR.  McNAUGHT:  I can't remember the data to bear
        out the mechanical damage.  I can say that I think that the
        Waukegan experiment was unusually conservative and severe
        because the organisms were exposed to something like 5
        minutes instead of 3 minutes as they were exposed to at
        Zion.  Timing is so extremely important in the shortshot,
        I think the Waukegan data  for heat are conservative.  As far
        as the types of banging around that we get in the two plants
        I can't say at this time.
                  MR. FETTEROLF:   As a last thing, I have got to
        even  the  score up  just a  little.
                  This morning I  chided  the U.S.  Bureau of  Sport
        Fisheries a little bit for not  including all of Marcy's
        information on the significance  of those fish  kills.
                  Dr. Raney,  when you discussed  Dr.  Coutant's work
        on the Columbia River,  you said  that  the  heated effluent
    

    -------
                   Discussion - Commonwealth Edison Testimony
         produced no direct or latent mortalities,  but the real signi-
         ficance of his work was that he showed that these fish were
         in thermal shock and they were much more subject to predation,
     5   and that there were losses due to predation by squaw fish in
     6   that river.  Isn't that correct?
     7             DR. RANEY:  les.  And these losses were, in my
         opinion, insignificant,
     9             MR. FETTEROLF:  Now we are even.  Thank you.
    10             MR. MAYO:   Is there any more to the Illinois
    11   presentation?
    12             MR. CURRIE:  Let me ask the audience.
    13             Are there other persons from Illinois who would
    14   like to be heard at this time?  I see two hands.  Mr.
    15   Muchmore first, and then the gentleman in the back, Dr.
    16   Gustafson.
    17             MR. MAYO:  These two gentlemen should receive
         medals.
                   MR. FELDMAN:  I might thank you and your conferees,
    20   Mr. Mayo, for having sat through this rather long thing.  We
         are not apologizing for having done it, but we do appreciate
    22   your willingness to hear it.
                   MR. MAYO:  Well, there is no need for you to
     ^   apologize, the invitation was there.
    25
    

    -------
                                                                  391
                                 C. Muchmore
     2
     3              STATEMENT OF CHARLES MUCHMORE, P.E.,
     4              MEMBER OF THE DEPARTMENT OF THERMAL
     5                 AND ENVIRONMENTAL  ENGINEERING,
     6                 SOUTHERN  ILLINOIS  UNIVERSITY,
     7                     CARBONDALE, ILLINOIS
     3
     9             MR. MUCHMORE:  Chairman Mayo, conferees, ladies
    10   and gentlemen.  I will make this very brief*  I know the
    11   hour is late.
    12             I am Charles B. Muchmore, a member of the Depart-
    13   ment of Thermal and Environmental Engineering at Southern
    14   Illinois University, Carbondale, and currently I am Chairman
    15   of the Environmental Quality Committee of the Illinois
         Society of Professional Engineers, who I am representing
    17   here today.
                   I am here to reemphasize the position of the
         Illinois Society with respect to the threat of thermal
    20   pollution to  Lake Michigan
    21             In  April of 1970, the Society proclaimed its
    22   position on this  issue*  Reexamination of subsequent data
         and  events has not altered the  Society's basic position on
         this very important environmental matter.
                   i would like to quote, therefore, from  an ISPE
    

    -------
         	392
    
    
    
    
    
     1                           C, Muchmore
    
    
    
     2   statement issued 2 and a half years ago that we feel ade-
    
    
    
     3   quately expresses our concern and recommendations concerning
    
    
    
     4   the current and future development of Lake Michigan as a
    
    
    
     5   valuable and irreplaceable natural resource for recreational
    
    
    
     6   as well as power supply needs,
    
    
    
     7             "The Great Lakes are an important natural resource
    
    
    
         that provide great benefits to the people of this region,
    
    
    
     9   These benefits are both industrial and recreational.  One of
    
    
    
    10   the important industrial uses of the water in the lakes is
    
    
    
    11   to provide the cooling required in the generation  of elec-
    
    
    
    12   trie power.  Electric power is extremely important to all of
    
    
    
    13   us and our need for power is increasing at a tremendous rate,
    
    
    
    14             "The Illinois Society of Professional Engineers
    
    
    
    15   shares in the public concern for the well-being of the lake,
    
    
    
    16   However, we believe that the current standards set up and
    
    
    
    17   administered by the Illinois Pollution Control Board provide
    
    
    
         adequate protection.  These are responsible standards that
    
    
    
         provide for the greatest benefits to all without impairing
    
    
    
    20   the long-term recreational use of the lake.  Actually we
    
    
    
    21   know a great deal about the assimilation and dissipation of
    
    
    
    22   heat in the lake.  We, as  engineers, can and will  design
    
    
    
         the facilities that will make it possible  to use Lake
    
    
    
         Michigan without damaging  it.  Our health,  safety, and
    
    
    
         welfare require that we continue with construction of
    

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            .	393
    
    
    
    
     1                           C, Muchmore
    
    
    
     2   powerplants.  Some of these have to be on Lake Michigan.  We
    
    
    
     3   should proceed cautiously but we should and must proceed
    
    
    
     4   now.M
    
    
    
     5             As I say, this statement is essentially the stand
    
    
    
     6   made 2 and a half years ago.
    
    
    
     7             Of major concern to the Illinois Society of
    
    
    
         Professional Engineers, which represents over 5»000 regis-
    
    
    
     9   tered engineers from varied areas of employment — private
    
    
    
    10   practice, industry, government, and education — is that
    
    
    
    11   actions taken to cope with potential environmental dangers
    
    
    
    12   be kept in perspective.  First, let us review some basic
    
    
    
    13   facts.
    
    
    
    14             It has been pointed out in previous hearings that
    
    
    
    15   the thermal pollution danger to Lake Michigan is not one of
    
    
    
    16   significantly increasing the average temperature of the
    
    
    
    17   lake.  Straightforward calculations assuming complete mixing
    
    
    
         and adiabatic conditions indicate that heat loads projected
    
    
    
    19   to 19#0 would result, over a year's operation, in a temper-
    
    
    
    20   ature increase of less than 0.1° F.  The potential danger
    
    
    
         due to thermal pollution is, therefore, definitely local
    
    
    
    22   in character.  I think this has been well documented.
    
    
    
                   The extent and nature of thermal effects on aquatic
    
    
    
     ^   biota is  not fully understood.  As additional knowledge is
    
    
    
         gained, changes in recommended methods of discharge and
    

    -------
       	S94
     1                           C, Muchmore
     2   areas of mixing zones may well be justified.  Consideration
     3   must always be given, of course, to the trade-off between
     4   increased heat dissipation to a lower temperature atmosphere
     5   by maintaining a smaller, higher temperature mixing zone,
     6   compared to environmental effects in a lower temperature,
     7   larger one,
     g             Comparison of the anticipated or unknown results
     9   of the following two alternatives to continued and expanded
    10   use of Lake Michigan as a cooling source results in the fol-
    11   lowing conclusions:
    12             Alternative 1:  Prohibit powerplant construction
    13   at the lake.  The obvious needs for greater power production
    14   to match future needs does not make this an attractive
    15   alternative,
    16             Alternative 2:  Require cooling tower construction
    17   to satisfy heat dissipation needs.  The uncertain environ-
    13   mental impact of cooling towers does not at this time justify
    19   the expense of their substitution for the lake as a heat
    20   sink,
    21             Thus, we do not feel that the above alternatives to
    22   use Of Lake Michigan as a cooling source are acceptable
    23   solutions to the problem.  We advocate continued use of the
    2^   lake for this purpose, and encourage more extensive studies
    25   ^0 determine significant effects on the aquatic biota,  Shoulc
    

    -------
                                                             895
    
    
    
                            C.  Muchmore
    
    
    
    current and future studies  clearly demonstrate undesirable
    
    
    
    thermal effects to a significant  extent,  backfitting of
    
    
    
    cooling towers to existing  power  generating stations would
    
    
    
    be possible.
    
    
    
              It  is likely that aquatic environmental effects due
    
    
    
    to slight temperature changes would be relatively reversible
    
    
    
    in nature, compared to those resulting from chemical contam-
    
    
    
    ination.  Overemphasizing potential harmful effects  of thermal
    
    
    
    pollution may tend to diminish our efforts on preventing de-
    
    
    
    terioration of the lake quality as a result of other pollu-
    
    
    
    tional sources, an inherently more irreversible danger to
    
    
    
    future generations' enjoyment of  Lake Michigan waters.
    
    
    
              And to point out  specifically here, I think we
    
    
    
    could draw upon yesterday's comments concerning phosphate.
    
    
    
    I believe the economic picture came into view very clearly
    
    
    
    there, and I  think that we  all recognized that whether we
    
    
    
    paid for our  environmental  improvements through local taxes,
    
    
    
    the water bill, higher utility rates — one way or another —
    
    
    
    there is, of  course, an upper limit to what our economy can
    
    
    
    stand.
    
    
    
              I believe yesterday the conferees arrived at a
    
    
    
    ballpark figure of about a  tenth of a cent per capita per
    
    
    
    day as the incremental cost to enable us to attain that
    
    
    
    1 mg/1 phosphorus standard  compared to the 2 mg/1.  I
    
    
    
    believe this  figure is about in the ballpark of the
    

    -------
       		396
    
    
    
    
    
     ±                           C. Muchmore
    
    
    
    
     2   additional incremental costs that we are talking on a per
    
    
    
     j   capita basis if we talk putting in cooling towers rather
    
    
    
     4   than using straight-through cooling of the lake on the cur-
    
    
    
    
     5   rent installations.  And perhaps someone from the industry
    
    
    
     6   could clarify this.  I think they are in the same ballpark.
    
    
    
     7             In other words, I think we have to look carefully
    
    
    
    
     #   here at what has to be done and where the money can be spent
    
    
    
     9   that will have the greatest impact on the lake.  And from
    
    
    
    10   our point of view, the case for phosphorus is a lot more
    
    
    
    11   clearly interpreted, better documented, than is the thermal
    
    
    
    
    12   question at this point.
    
    
    
    13             I thank you.
    
    
    
    14             MR. McDONALD:  Mr. Muchmore.
    
    
    
    15             MR. MUCHMORE:  Yes.
    
    
    
    16             MR. McDONALD:  On that tenth of a cent added
    
    
    
    
    17   cost for cooling towers, I wouldn't expect you to develop
    
    
    
         this now, but I would be very  interested in having you
    
    
    
         submit this, on how you arrived at your calculation.
    
    
    
    20             MR. MUCHMORE:  Well, we  could rough it out here.
    
    
    
    
    21   Could we take a 3  percent  —
    
    
    
    22             MR. FETTEROLF:   How  about submitting it in writing?
    
    
    
                   MR. McDONALD:   I'd rather not.  But that tenth of
    
    
    
    
     *   a cent is a very interesting —
    
    
    
                   MR. MUCHMORE:  My off-the-top-of-the-head guess  is
    

    -------
                                 C. Muchmore
     2   that is probably low.  But I think it is in the same ballpark
     3   as the number you were talking about with regard to phosphorus
     4   yesterday,  I think they are comparable costs,
     5             MR. McDONALD:  See if you can refine it a little
     6   and maybe you can send it in to us,
     7             MR, MUCHMORE:  Surely.
     8             MR. McDONALD:  Thank you,
     9             (Mr, Muchmore 's submission following the confer-
    10   ence follows in its entirety,)
    11
    12
    13
    14
    15
    16
    17
    19
    20
    21
    22
    23
    24
    25
    

    -------
     ENVIRONMENTAL PROTECTION AGENCY • STATE OF ILLINOIS
    
               William L. Blaser, Director  •  Richard B. Ogilvie, Governor
                                                               Please  reply  to:
                                                               2121 West Taylor  Street
                                                               Chicago, Illinois 60612
                                                               Phone 312   793-3730
    
           Four State Lake Michigan Enforcement Conference
    
                                                October  2,  1972
    
    
           Francis T. Mayo,
           Regional Administrator
           USEPA
           1 North Wacker Drive
           Chicago, Illinois 60606
    
           Dear Mr. Mayo:
    
                During  the recent session  of  the  Four State Lake  Michigan Enforcement
           Conference,  Charles B. Muchmore representing  the Illinois  Society  of
           Professional  Engineers made  some statements concerning the thermal standards
           for Lake Michigan.  In his statement he  related  to  per capita  costs  asso-
           ciated with  the requirement  of  backfitting of cooling  towers for existing
           power plants  on Lake Michigan.   He has submitted a  letter  dated  September
           28, 1972 including some data to substantiate  his comments.  I  am including
           six copies of his documents  and request  that  it  be  included in the record
           of these proceedings and if  you deem necessary,  forward it on  to the other
           conferees.
    
                Thank you for your consideration  of this  matter.
    
                                                Very truly  yours,
    
                                                ILLINOIS  ENVIRONMENTAL PROTECTION  AGENCY
                                                 Carl T. Blomgren,  Mana
                                                 Standards Section,  DWPC
           CTB:dk
           Enclosure
    2200 Churchill Road       •        Springfield, Illinois 62706        •        Telephone: 217-525-3397
    

    -------
                                         Southern Illinois
    
                                         University
    
                                         CARBONDALE, ILLINOIS  62QOI
     School of Engineering and Technology
     DEPARTMENT OF THERMAL AND ENVIRONMENTAL ENGINEERING
     September 28,  1972
     Conferees,  Lake Michigan Enforcement Conference
       September 19-21,  1972
    
     Gentlemen:
    
     Enclosed find the information requested by Mr.  James 0. McDonald concerning
     the estimated economic impact, on a per capita  basis, associated with the
     requirement that backfitting of cooling towers  be required for existing
     power plants on Lake Michigan.
    
     I did obtain a more accurate figure on current  per capita electric service
     expenditures (I used my  own electric bill for an approximation at the tine
     of my statement at  the Conference)  by contacting Mr. Joseph McCluskey,
     Director of Environmental Affairs for Commonwealth Edison.  The calculated
     result is not significantly different from the  order of magnitude estimate
     that I stated at the Conference,
    
     I hope this clarifies the intent and basis for  my statement at the Conference.
    At the time of my testimony, the hour was late  and detailed discussion at
     that time seemed inappropriate.
    
     Yours truly,
    
     Charles B,  Muchmore,  PJE.
    
     CEM/dk
     cc:   Mr. J. McCluskey,  Director of Environmental Affairs
               Commonwealth Edison
          Mr, W. Dart, Executive Director, Illinois Society of Professional Engineers
    

    -------
                  Supplemental Testimony at Lake Michigan
    
               Enforcement Conference, September 19-21, 1972
    
                       by Charles B. Muchmore, P.E.,
              Chairman of the Environmental Quality Committee
             of the Illinois Society of Professional Engineers
    
    
         My comments following presentation of my written statement were
    
    intended to emphasize our concern that in setting regulations governing
    
    the use of Lake Michigan water, full recognition be given to the relative
    
    costs involved and potential benefits to be gained.
    
         At the Conference the previous day, the question of additional cost
    
    associated with attaining a 1 mg/1 phosphate effluent standard, rather
    
    than the previously suggested figure of 2 mg/1, was discussed.  An approx-
    
    imate figure of 0.1<£/capita-day was mentioned.  Computed on a similar
    
    basis, the cost associated with backfitting cooling towers to existing
    
    power plants on Lake Michigan gives a figure of 0.34
    -------
                                    -2-
    
    
    
    
    
    or new technology dictate that the removal of phosphorus by precipitation
    
    
    
    techniques is no longer justified, there would be no problem in changing
    
    
    
    the requirement.  Not so with cooling towers.  The financial committment
    
    
    
    resulting from a requirement to back-fit cooling towers is a long term one.
    

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                                    -3-
                               CALCULATION:
    Basis:
    
    Average annual residential billing,
     Commonwealth Edison, 1971
     (Source: Telephone conversation 9/22/72
      with Mr. J. McCluskey, Director of
      Environmental Affairs, Commonwealth
      Edison)
    
    Cost of backfitting with an evaporative
     tower system:
     (Source:  Mr. Tichenor's testimony
      given at the three state hearings, as
      reported in Summary of Recent Technical
      Information Concerning Thermal Discharges
      Into Lake Michigan, Argonne National
      Laboratory, U.sT EPA Contract Report 72-1,
      p. 105)
           $159.00
    Nominally a 33 residential
     rate increase
    Assuming an average family size of 4 (perhaps a bit optimistic for the
    future, but current reports are encouraging) , the average per capita
    daily billing is
    Applying the 3% increase that would result from backf itting cooling
    towers gives a daily per capita increase of
    

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                                                                   $93
                                 C. Muchmore
     2             MR. MAYO:  Mr. Currie.
     3             MR. CURRIE:  Dr. Gustafson.
     4             While he is coming up, I have written statements
     5   I have been asked to have entered into the record as if
     6   read.  They are from Paul R. Harrison, from Ann Ghellman,
     7   from Mrs. Catherine T. Quigg, from Dr. James E. Carson, and
         from Arthur Pancoe.
     9             (The documents above referred to follow in their
    10   entirety.)
    11
    12
    13
    14
    15
    16
    17
    19
    20
    21
    22
    23
    24
    25
    

    -------
           Statement Before the Atomic Energy Commission Hearing on
                 Effects of Thermal Discharge on Lake Michigan
    
                              September 19, 1972
    Gentlemen:
    
              The purpose of the Chicago Technical Society Council Ecological
    
    and Environmental Committee at this hearing is' to attempt to provide
    
    objective criticism of the past, present and future assessments of the
    
    effect of thermal discharges on Lake Michigan and surrounding environs.
    
              It is obviously difficult to predict with certainty the effect
    
    of these new, large energy inputs into the local biosphere when they
    
    have not occurred under like conditions at any other location.  However,
    
    it is not difficult to say that there wijlj^ be ecological effects for
    
    certain-no matter how or where this massive amount of energy is released
    
    in such small physical scales.  The basic concept of entropy states that
    
    there is a minimum amount of energy that can be recovered in any energy
    
    conversion process.  It must be, at the very least, the primary resolve
    
    of any controlling agency to minimize any excess above this basic physical
    
    principle.   Conversion of nuclear energy into steam energy, and finally
    
    into electrical energy, and the transportation of that electrical energy
    
    to inefficient electrical devices does not in any way maximize energy use.
    
    This is especially true when one sees that the majority of the steam energy
    
    is wasted by cooling by large amounts of water and then this excess energy
    
    dumped into a small area creating sure changes in the local ecology.  There
    
    have been many arguments brought forth concerning the use of atomic power
    
    plants, dumping of waste energy (which we do not consider useless), and
    
    subsequently using that electricity in extremely inefficient ways.  We feel
    

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                                                                                    2.
    
    
    
    that this Committee cannot ignore this inefficiency because the subject of
    
    
    
    today's discussion is a prime example of that inefficiency and lack of
    
    
    
    creative ability and resolve to use this thermal energy in a productive way.
    
    
    
    We are reminded of the Ruler in Adu Duabi in the Middle East who spent
    
    
    
    millions of dollars, indeed billions of dollars, in securing atomic power
    
    
    
    plants, not for the sake of creating electricity, but to use the heat and
    
    
    
    the steam process in an atomic power plant to create pure water and to
    
    
    
    create heated water for irrigation in large areas of greenhouses in order
    
    
    
    to produce fruit year-around.  In other words, a creative use of what is
    
    
    
    considered in our country as waste heat.  It is apparent that the primary
    
                                                                   £>,.'*. >''
    concern of the power company and AEC has been the production of power
                                                                  A
    
    
    rather than the efficient use of energy.  Likewise, it requires creativity
    
    
    
    and larger assessments of the total problem, which seemingly, bewilders
    
    
    
    both the Atomic Energy Commission and the American Power Company con-
    
    
    
    sortiums.  The remaining possible reason for this lack of concern could be
    
    
    
    that they truly do not care about the environment.  But, as a modern day
    
    
    
    Will Rogers, I only know what I see on television.  These advertisements
    
    
    
    tell me that the electric companies do, indeed, care about our "total en-
    
    
    
    vironment".
    
    
    
              Assuming we are stuck with this "waste" energy, why is it then
    
    
    
    that the controversy still reigns as to the environmental impact of these
    
    
    
    monsterous energy generators?
    
    
    
              In our opinion, the causes can be summed up in that there is  a
    
    
    
    lack of basic foundation to make proper decisions.  As is the case in most
    
    
    
    ecological problems currently in vogue, there are many computer massagers
    
    
    
    and modelers who take very questionable data, take data out of context, and
    
    
    
    mis-apply basic concepts so  that the final result after much computation
    

    -------
                                                                                     3.
    
    and brilliance in mathematics come out with  a very nice  conclusion  which
    
    "remains to be shown".  The record shows  that this is  the  past  case and  also
    
    the present case.
    
              Gentlemen, it is very difficult to make decisions using models
    
    based upon scant and inadequate, and in some cases,  incompetent data.
    
    To be creative, we would like to highly recommend that a thorough oceanographic
    
    study be undertaken and properly reviewed before a license is given for  the
    
    building, let alone the operation of these power producers.  This study
    
    should be intra-disciplinary in nature and consider  the  following:
    
              1.   Models should fit field data  - not the  data - the model
    
         wborovor	^hJrB-Hbg-tte^eissaiy ami/in UegrrabJbe..
    
              2.a)  Can a model be fitted to  all important variables?
    
                b)  What are the important variables?
    
                c)  To what extent do variables  interact to  produce auto-
    
         matically what may be best described as a complex polynomial?
    
                d)  How valid are simplistic models compared to the higher
    
         order reactions which may actually occur?
    
                e)  If any one site data must be modeled specifically for
    
         that site - is it best to construct  a limited model or obtain
    
         definitive data for each site?  We think each site  is unique.
    
              Some variables that need to be  adequately  monitored concerning
    
    thermal plume are:
    
              1.  Geology
    
                  a)  Bed rock
    
                  b)  Sedimentation
    
                  c)  Geologic processes  (Chem.  & phys.)  e.g., Analytical reaction
                                           with heat, acids, etc.   Current rate  and
                                           carrying capacity.
    
                  d)  Ground water inflow (hydrology)
    

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                                                                                    4.
    
    
    
    
                  Bathymetry
    
    
    
    
                  a)  Geomorphology
    
    
    
    
              2.   Geochemistry
    
    
    
    
                  e.g. Carbonate balance; reaction rates
    
    
    
    
              3.   Climatology
    
    
    
    
                  a)  Heat and vapor affects on the local environment
    
    
    
    
                  b)  Winds and currents
    
    
    
    
                  c)  Pressure systems
    
    
    
    
              4.   Biology ( per se and in response to water quality)
    
    
    
    
                  a)  Phyto and zooplankton within and beyond the thermal plume
    
    
    
    
                  b)  Speciation of fish (birds)
    
    
    
    
                  c)  Effects on N. S. & C. cycles - as heat input may in-
    
    
    
    
         fluence microflora present
    
    
    
    
                  d)  Biochemistry of water relative to biota present
    
    
    
    
              5.   Engineering
    
    
    
    
                  a)  Design of site in accord with the above
    
    
    
    
                  b)  Physical, thermal and pressure shock characteristics on biota
    
    
    
    
              6.   Monitoring of plant effluents on the environment
    
    
    
    
              Some of the above parameters are already considered but are not
    
    
    
    
    measured adequately or given proper weight in decision making.
    
    
    
    
              It is obvious that the local current measurements are entirely
    
    
    
    
    inadequate.  In fact, many of the assumptions as to current directions are
    
    
    
    
    completely wrong.  I point to the Michigan City breakwater and the Traverse
    
    
    
    
    City situations as primary examples on Lake Michigan.  These current studies
    
    
    
    
    must be conducted over six months at the minimum and a year or more, as
    
    
    
    
    desirable.
    

    -------
                                                                                     5.
    
    
    
    
              We cannot understand, or  at  all  agree, with  the  statement  that
    
    
    
    
    geological measurements are not necessary.   I  point  to outfall erosion
    
    
    
    
    problems and other geo-chemical considerations carving away  at other
    
    
    
    
    locations on Lake Michigan, both nuclear and fossil  fuel plants.
    
    
    
    
              Much of the lake shore has not been  properly mapped in  order  to
    
    
    
    
    show before and after situations due to the  discharge  of water, let  alone
    
    
    
    
    its temperature considerations.  It has been shown by  Miss Edith  McKee
    
    
    
    
    that a detailed one-foot interval map  of the lake bottom within a few miles
    
    
    
    
    of an outfall can adequately describe  much of  the currents.  Laminar and
    
    
    
    
    turbulent flows are easily discerned in these  mappings.
    
    
    
    
              A study should be made of the chemistry of the water and the
    
    
    
    
    effect of the reactor on the chemical  equlibrium which has been established.
    
    
    
    
              We must determine the interaction  between  the various parameters
    
    
    
    
    measured.
    
    
    
    
              The above parameters are  the ones which seem of  current concern.
    
    
    
    
    However, as in the case of all dynamic problems, the parameters being
    
    
    
    
    assessed must be continuously reviewed and may change  with time.
    
    
    
    
              It is required that two years of climatological data be made
    
    
    
    
    before a license is granted to atomic  power  plants.  We ask  simply,  - why
    
    
    
    
    not an equal amount of time for oceanographic  studies  (or oceanographic
    
    
    
    
    climatology, if you will) to be conducted  for  two years prior to  issuance
    
    
    
    
    of a license?  To our knowledge, these types of studies have been only in
    
    
    
    
    a peripheral and cursory manner.  I am sure none of  the persons in this room
    
    
    
    
    would like to live next to a reactor in  which the safety research was done
    
    
    
    
    in a similar inadequate manner.
    

    -------
                                                                                     6.
    
    
    
    
              All of the above considerations and suggestions are not at all
    
    
    
    
    prohibitively expensive, especially considering the back fitting and
    
    
    
    
    possible future damages and reparations that may be necessary due to the
    
    
    
    
    fact that these studies were not made.
    
    
    
    
              It is our recommendation that adequate studies be made as soon
    
    
    
    
    as possible of the above parameters, as well as those currently under study.
    
    
    
    
              It is recommended that no new facilities be built until new
    
    
    
    
    guidelines and adequate basic, physical s'tudies are made in order to obtain
    
    
    
    
    adequate input data to these sophisticated models.  Without this basic data
    
    
    
    
    they are full of brilliant sound and fury and signify nothing, or at the
    
    
    
    
    best, signify the wrong decisions, which are not only dangerous to the
    
    
    
    
    health and well being of Lake Michigan, but our own enjoyment and
    
    
    
    
    guarantee of adequate fresh water supplies for other activities, both
    
    
    
    
    recreational and industrial.
    
    
    
    
              If Lake Michigan, or any other lake, be it large or small, turns
    
    
    
    
    into a eutrophlcated cess pool other industries and users of this large
    
    
    
    
    heat sink will be severely restricted and will pay a dear price, as well
    
    
    
    
    as the civilian sector.
    
    
    
    
              Gentlemen, in summation, it is our opinion that the following
    
    
    
    
    basic criticisms can be made:
    
    
    
    
              (1)  Proper use of energy is not and will not be a reality until
    
    
    
    
    a re-assessment of the basic thinking of the Atomic Energy Commission comes
    
    
    
    
    about so that they may assess the entire enrgy cycle of nuclear reactors
    
    
    
    
    and the energy produced from them.
    
    
    
    
              (2)  There is much too much reliance upon computer modeling
    
    
    
    
    without obtaining basic physical measurements.
    

    -------
                                                                                     7.
    
              We would humbly  recommend  that  those  who earn their living or
    
    supplement as  the case may be,  by  consulting with both your agency and/or
    
    the utilities, should obtain more  detailed  and  more pertinent physical
    
    measurements in  the  field  and  get  their "tail feathers wet" in order to
    
    make these models and mathematical gyrations more meaningful.   We  would
    
    suggest that they spend  as much time  in the  field as they  do on the models
    
    and the amount of time on  the  models  as they would usually spend in the
    
    field.  I think  that all of us would  be much more capable  of making good
    
    decisions and designs by the proper use of  this "waste energy" dumped in
    
    our increasingly fragile environment.
    
              Thank you  for your attention.
                                                 Paul  R. Harrison,  Ph.D.
                                                 Chairman
                                                 Ecology and Environmental Comm.
                                                 Chicago Technical Society Council
    PRH:hsl
    9/20/72
    

    -------
    Lake Michigan is the single major natural resource in the Chicago area.
    One of the basic attributes of the lake is its large volumn of relatively
    cold water and its attendant populations of cold water flora and fauna.
    
    Ecologists consider temperature the primary control of life on earth and
    fish, which are unable to regulate their body temperature, are particularly
    sensitive to changes in the thermal environment.
    
    Elevated water temperatures present a real threat to the aquatic ecosystem
    of the lake.  Temperature levels that fall short of lethal, but may be
    considered unfavorable, can aversely affect the animals1 metabolism, feed-
    ing, growth^and reproduction.  Even though a single game-fish species may
    be able to adapt to the temperature variations, the food chain envolving
    smaller fish, invertebrates, plants and dissolved nutrients is more sen-
    sitive.  Any environmental change that seriously affects the proliferation
    of any link in the chain can affect the harvest of game fish.
    
    Thermal discharges add stress to the lake already polluted by chemical
    wastes of shoreline industries.  The capacity of water to carry dissolved
    oxygen necessary to support useful forms of aquatic life diminishes as
    temperature rises.  Higher temperatures cause reduced solubility of
    oxygen and, if this is combined with an organic load, the temperature
    increase will unbalance a mixed algae population to blue green algae,
    the species found in organic or chemical pollution.
    
    Because of the rate of increase projected for future electric power pro-
    duction, we cannot continue to add waste to the environment in the form
    of heat.  We must cure the disease rather than treat the symptoms, by re-
    ducing heat pollution at it's source.
                                                       Ann Chellman
                                                       136 S. Hickory St.
                                                       Palatine, Illinois 6006?
    

    -------
                 &
      NViRGNMENTAL
    LAKE MICHIGAN ENFORCEMENT CONFERENCE
    SEPTEMBER 20, 1972
    St«t«m«nt
    49 SOi,T.-i GR.atY SIKEIT
    
        ^£, iUtNOIS 60067
       CAj?NO,V MD
    
    
       s • to . . -f M - one
           !0 , noit Allot ley
          ,ronrr,en>al Quality
                                           Mrs. Catherine T. Qj.ig£
                                           Vic* Prssidaat
                                                     & Environmental  Problems
    H»w many of you  nro  awaro  that C«mrnonw«altk Edi
    
    is "c«nc«rnod  for your total «nvlronm«nt"?  Haw
    
    much do you think it coats Common wo a 1th Edison «vcry
    
    yoar to got th» t mossago  across to tko public...
    
    on toloviaion. . .in nowsp«]»*rs. . .mar*zin«
    
    ov«n on cardboard lifhtbulb holdors.  It must
    
    »o millions.1
    
    
    Wo tklnk that Commonwoalth Edison would apond
    
    that mtn«y on ooollng  t«w«ra at tfcio Zien
    
    if thoy woro roally  eonsornod for our total
    
    onvironm«nt.
                                »lso but an onormeusly woadthy company-"-aid«d
    
                            anr.  ^oatcod by th« Atomio Energy Cammission--
    
                            would K»vo tho gall to uao our valualsla Lako
    
                            Michigan as a daily wasto dump far ©illions ©f
    
                            gallons  of hoatod water ...and then t«ll us it's
    
                            protoctiȣ our onvironment?
                                ¥lso  but a combiMio liko this coulci supply
    
                            this and  ovory othor oavironmflntal oonf«r«r.c
    
                            with sciontists, lawyors and PR mon ox tolling
    
                            its  / -two*.
    
                ENVIRONMENTAL  RESTORATION  THROUGH  EDUCATION
    

    -------
                            -2-
    It 's net easy for scientists or citizens to fight the
    
    
    
    political-utility nuclear power claque.  Wo don't have
    
    
    
    their power — or money.  It could make a big difference
    
    
    
    in getting; the message to tko public -- that tkolr lake
    
    
    
    will die from tho kiad of ooncor» it's jotting from
    
    
    
    CommonwoAltk Edison,
    
    
    
    
    
    How will wo know wkoa our l«ko is dying from tkermal
    
    
    
    pollution?  Wo will know.
    
    
    
    
    
    Its fish will dio from t«mporaturo lethality...not iranodiatoly
    
    
    
    but eventually.  Because wo see fisk in keatod discharges
    
    
    
    does net mean tkese effluents are «iesira»lo for tkat
    
    
    
    species.  Many organisms, including man, ara at times
    
    
    
    and under certain oondititns attracted to environments
    
    
    
    that are clearly not optimal,  A critical look at the fisk
    
    
    
    found near effluents frequently skews tkat these dense
    
    
    
    populations are not of desirable game species lout are less
    
    
    
    desirable, rough fisk species.
    
    
    
    
    
    Wo will know our lake is dying of thermal pollution when
    
    
    
    wo go fishing and eatck a string of algae instead of fish.
    
    
    
    We'll know when we see windrows of rotting; algaes on our
    
    
    
    shorelines and >j«ach«s.
    
    
    
    
    
    By the green in our drinking water--we will know.  Wo '11
    
    
    
    add BIO re  chlorine to our water to control the bacteria and
    

    -------
                            -3-
    slime.  And then we'll knew by the unpleasantness of drinking
    highly chlorinated watar,
    
    We will find fish mysteriously dead on our shores.  And seme
    will know that thoy have died from toxicity.  Bocauso they know
    that tho toxicity of most mateii «ls -- whether pesticides, solvents,
    h«avy metals, er others -- increases at higher temperatures,
    Watar quality criteria can be determined for materials toxie
    to aquatic life under desirable temperatures, but when
    temperatures are elevated above optimum, toxicity is increased
    and these criteria may no longer protect aquatic life.
    
    Yes, by these and other signs, we will know when our lako
    is dying.
    
    I say -- kill our lake if you nrast -- because you can afford
    to convince most of us that you "mean well."  But please don't
    add insult to injury tey making us listen to the constant
    rendition of "Commonwealth. Bdison -- concern for your total
    environment,"
    

    -------
                                                   Reprint from Annual report ot the
                                                   Radiological Phy»ic» Division for 1971,
    M O U
                                                   AHL-7860   Part III» August  1972
    
    
          THE ATMOSPHERIC CONSEQUENCES OF THERMAL DISCHARGES
          FROM POWER GENERATING STATIONS
    
                 James E. Carson
    
                 Concern for the biological and ecological effects of heated water
          has resulted in legal actions that will prevent power companies from dumping
          the waste heat from the majority of their new generating units into rivers
          and lakes. Many nuclear- and fossil-fueled plants now under construction,
          and even some now on-line, are being required to change from once-through
          cooling systems to other methods, such as wet cooling towers, cooling
          ponds and spray canals, despite higher costs and lower themal efficiencies.
          Yet, these alternate cooling procedures are not without their own environ-
          mental problems.
                 The primary weather change  due to once-through cooling on a large
          water body is a local increase in fogginess at the plant outfall. But the
          relative probability of significant local meteorological effects is much higher
          with alternate cooling procedures, since these reduce the  area  of heat and
          moisture  transfer.  It is, therefore,  concluded that, from a meteorological
          point of view, the least undesirable way to dispose of waste  heat is by
          using once-through cooling on large water bodies.
    
    
          Introduction
                 The peak demand for electrical power in the United States is increasing
          at a rate  of 7% per year.     This increase is due both to increasing popula-
          tion and to increasing per capita consumption.  According  to the Federal
          Power Commission, the installed capacity in 1970 was about  340,000 MW,
          while the estimated requirement for  1990 will be 1,260,000 MW.    Almost
          all of the new capacity will consist of thermal (steam) units,  both nuclear-
    
          and fossil-fueled,  with marked trends toward larger capacity  units and more
          units on a given site. Despite their lower thermal efficiencies, an increas-
          ing fraction of the new plants will be nuclear, this choice being made in
          part to reduce emissions of atmospheric pollutants such as fly ash and
    
          sulfur dioxide.
                 Large quantities of reject heat are  not unique to nuclear electrical
          generating stations since all heat engines release heat to  the environment.
          In other words, what is frequently called "waste heat" is really a necessary
          part of the energy conversion process.
    

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                                                                               251
            Almost all of the energy produced by electrical power stations, both
     the waste heat and the useful power generated, is eventually dissipated to
     the atmosphere.  In this paper the potential meteorological effects of the
     waste heat are explored. While studies of the effect of thermal discharges
     on the atmosphere are relevant to all types of power  generation, they are
     particularly significant to water-cooled nuclear power plants which produce
     40 to 50% more waste  heat per unit of electricity than modern fossil-fueled
     plants.  Part of the difference in cooling requirements is caused by the  loss
     of heat up the chimney in conventional power plants  (10 to 12% of the total)«,
     It should be noted that most fossil-fueled plants now on-line operate at
     efficiencies comparable to those of the new nuclear plants.
            Utilities use large amounts of water to cool the condensers in the
     plants; the cooler this water is,  the more efficient the process will be.
     Until recently, most plants  used once-through cooling,  drawing water from
     lakes, rivers,  or the ocean, heating it   10° to 25° F as it passes through
     the plant, and  returning it to the source.   Because of concern for both the
     effects of increased temperatures on the biota of the  receiving water body
     and shortages of cooling water,  many power generating stations now under
     construction will use cooling towers or cooling ponds to dissipate much of
     the heat to the atmosphere before recycling the cooling water or returning it
     to the source.  Lower costs of operation and installation dictate the use of
     "wet" or evaporative supplemental cooling  systems except in areas of very
     limited water supplies.
           The state of the art is such that meteorologists are not able to pre-
     dict quantitatively how the atmosphere will react to the large amounts of
     heat energy and water  vapor that it will be forced to absorb as the result of
     the disposal of waste heat from  power plants.  Conceivably,  critical heat
    release rates may exist for particularly sensitive sites which, when exceeded,
    may lead to significant meteorological effects, such  as the generation of
    thunderstorms in convectively unstable,  subtropical conditions.
           To date only a  limited number of research and field studies  on the
    atmospheric aspects of thermal pollution have been conducted and reported
    

    -------
    252
          in the literature.  Published papers include those of Aynsley,   Stockham,
          Overcamp and Hoult,    Decker,   Colbaugh et al. ,    Huff et al. ,
          Hosier/   Hanna and Swisher,    EG & G,     Altomare,   2' and Carson/13^
          Most reports dealing with thermal discharges into rivers, ponds, lakes, or
          from cooling towers , indicate that changes in weather near the outfall might
          occur, but few contain data to support or quantify this conclusion.
                As a result of the National Environmental Protection Act, utilities are
          now required to file statements anticipating the environmental impact of their
          new plants, including the atmospheric effects of their proposed cooling
          systems. Most of these statements have been prepared by meteorological
          consultants, and many include forecasts of the frequency of  plant-induced
          fogs and icing.  Unfortunately,  the majority of these analyses  have  not been
          made part of the public record and, therefore, are not available for quotation.
          One of several reports that have' k§en ma'de public is a  study of possible cool-
          ing tower plume effects at the Zion (Illinois) Nuclear Generating Station by
          McVehil.(14)
                 In September,  1971, the National Science Foundation sponsored a
          workshop to prepare a list of the areas of ignorance in the field of environ-
          mental aspects of thermal discharges from large sources and to suggest
          research projects  to improve our knowledge.     This conference covered
          many topics in addition to the atmospheric aspects of wast heat discharges,
          One-through Cooling on a Large Lake
                 An important problem in mid-western U.S. concerns the possible
          atmospheric effects of waste heat discharged from nuclear power plants
          around  Lake Michigan. Two fossil-fueled plants (capacity 616 MWe) and
          five nuclear units (6,732 MWe) are now being installed along the shores  of
          Lake Michigan.     These units  are scheduled to be operational in 1974;
          the total power plant load will then be 15,625 MWe. Originally, each of
          these units was designed for once-through cooling; but recent actions of
          regulating agencies will force most, if not all, of the new plants to use
          other cooling techniques, such as cooling towers.
    

    -------
                                                                              253
            Except for a small amount advected through the Straits oi A/Iackinac
    into Lake Huron, all of the power plant waste heat discharged into the lake
    will eventually enter the atmosphere through radiation,  evaporation, and
    conduction from the lake surface.  Except for an increase in fogginess near
    the individual thermal  outfalls,  it is expected that atmospheric modifications
    attributable to once-through cooling installations will be insignificant, as
    the energy will enter the atmosphere slowly over a large area.  The reactor
    heat will warm the lake a small  fraction of one degree.
            While the  total quantity  of heat put into the lake by these power
    plants is very small compared to that exchanged by natural  processes (solar
    radiation, evaporation, conduction,  and long-wave radiation), it does not
    immediately follow that the meteorological consequences will also be small,
    It is possible that the  frequency and severity of the lake snows,  fog, and
    freezing fog around the south and east shorelines of the lake could be
    increased somewhat as a result  of a small increase in lake  surface temper-
    ature.  In any event, such meteorological and climatological changes would
    be very difficult to isolate in the noise of natural variability of weather
    elements.
            Thermal plumes introduced into large bodies of water are dissipated
    by two processes:  through direct surface losses to the  atmosphere by
    evaporation, radiation, and conduction, and through dilution by mixing
    with the cooler main body of water.  Unfortunately, the relative magnitudes
    cf these two temperature-lowering processes are not known for various
    weather and lake conditions.  Meteorologists are not able to measure directly
    the locally-increased vertical fluxes of radiation,  heat,  and water vapor
    over a thermal plume with the accuracy required because of the small size
    and meander of the thermal plume itself. Direct measurements of plume
    temperature reduction by mixing  with ambient lake water presents  experi-
                                (17)
    mental difficulties.  Csanady     has concluded from a theoretical analysis
    that only a small part (on the order of 5%) of the plume's heat is lost to the
    atmosphere before mixing lowers the plume's surface temperature excess to
                                       (18)
    1°F.  More recently, Csanady et al.     measured the heat balance of a
    

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    254
          thermal plume from a nuclear power plant on Lake Huron and found that "the
          direct heat flux to the atmosphere from the detectable plume was 1/3 of the
                               (19)
          total heat flux."  Ayers    concludes that there is a "significant loss of
          excess heat to air, and an insignificant loss of heat to the underlying cold
          water."  Clearly,  more field measurements are needed to determine rates of
          heat loss from thermal plumes over a range of weather conditions. The rela-
          tive importance of the two temperature-lowering processes will vary as lake
          arid atmospheric conditions change.  When the lake is rough, mixing will
          be rapid. When it is  smooth, the warm water will tend to float with little
          mixing and present a larger area of greater temperature excess, and hence
          increased heat transfer to the atmosphere.
                 Except for  that advected into Lake Huron, the heat energy mixed
          into the main body of Lake Michigan will eventually be returned to the
          atmosphere.  This transfer takes place over such  a large area that it is
          reasonable to conclude that once-through  cooling will have a much smaller
          impact on the atmosphere than alternate cooling methods such as  towers or
          ponds.
                 Lake Michigan has a natural temperature resetting mechanism due to
          the cooling of the  entire  body of the lake every winter below 4° C, the
          temperature of maximum density of fresh water.  Twice each year  the lake
          is observed to be vertically isothermal at  the temperature of maximum density
          due to thermal instability and mechanical  mixing resulting from storms. Thus,
          except for an improbable condition in which a temperature as low  as 4°C is
          not obtained, lakes such as Lake Michigan cannot accumulate heat energy
          year after year. It has been observed     that the average temperature of Lake
          Michigan has actually decreased 1° to 2°F during the past two  or three decades,
          despite its use for cooling by industry  and fossil-fueled plants, and despite
          warmer inflow stream  temperatures due to  tree removal.
                 Two scales of weather changes can be expected  from thermal dis-
          charges into the lake:  local changes due  to increased heat and moisture
          fluxes over the thermal plume, and large scale modificiations due to the
    

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                                                                              255
     accumulation of heat energy in the main water body.
            Heat and water vapor are added to the atmosphere as air moves from
     the land over the lake surface.  Owing to the local temperature excess, more
     heat will enter the atmosphere from the thermal plume than from the main lake
     surface.  Thus, air with a trajectory over a thermal plume will be somewhat
     warmer, more humid, and less stable as  a consequence of thermal discharges.
     Observations confirm that an increase in the  frequency and density of steam
     fog over the  immediate plume area is  the primary observable effect of thermal
     discharges into large water bodies.
            Thermal discharges from power plants also might conceivably modify
     the large-scale climate of an area.  Much of the heat will be mixed into
     the main body of the lake, raising its temperature a small fraction of one
            (13,21  22)
     degree.    '   '    Some of the  energy added in summer will be stored  until
     the fall cooling period is reached; increased  evaporation and conduction
     could then increase the intensity and frequency of lake snows  in late fall.
     It. does  not necessarily follow that the increase in lake snows  would be
     directly proportional to the extra heat discharge; even a small  increase in
     water temperature could be just  sufficient to  release an atmospheric
     instability.  The amount of heat discharged by power plants is much too small
     to cause measurable air temperature changes  on the lake shore (see below).
            A review of the literature indicates that, except for fog, changes in
     weather and climate  due to once-through cooling on lakes, rivers, and cool-
     ing ponds are too small to be observed.  Numerous cases of thin fog and/or
                                                                            I r\ f\  *) » \
     light freezing fog near thermal outfalls or cooling ponds have been reported.
     These steam  fogs are "wispy" thin and dissipate quickly.  In no case did
     a statement that these plume-related fogs pose a problem to visibility and
     traffic on nearby land appear. If the air temperature is below freezing,  these
     steam fogs may drift over structures and through vegetation and cause rime
     icing.  The author has observed  dense steam  fog 3 to 10 m deep over a
     cooling  pond  when the air was more than  55° C (100° F) cooler than the water.
    Ambient air temperature was about -7°C,  with low humidity. The fog drifted
    inland a maximum of 15 m and deposited a 2- to 3-cm layer of flaky, low-
    

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         density rime ice on vegetation within ifrin'df the canal edge. This ice was so
         light as to be no hazard to the plants.  No ice had formed on either a bridge
         crossing the canal or on trees further inland.
                Perhaps the most serious difficulty in  conducting field studies at
         existing  cooling ponds, rivers,  and lakes is that the undisturbed water
         body itself affects weather conditions. For example, lake-effect snows
         and  steam fogs frequently occur near Lake Michigan far from any thermal
         discharge.  But it is very hard to say how the intensity, duration, and
         frequency of fogs and freezing fogs in Waukegan, for example   (which has a
         1,100  MWe coal plant using once-through cooling)  has been altered by this
         local influx of additional heat.
                Isolating possible long-term changes in weather and climate around
         the lake  will be an even more difficult problem.   Calculations show that the
         total reject heat from power plants now being  built is very small compared
         to the  meteorological input, and is also very small compared to natural
         variations of atmospheric processes.
                Nowhere in the literature has the author found a single report of
         observed precipitation or significant temperature  changes due to once-through
         cooling on a large water body.
                In midwinter, ice-free areas will be formed at or near the point of
         discharge.  Plant personnel (including a professional meteorologist) at a
         large fossil-fueled plant on Lake Ontario report that the plume area is too
         small to  affect weather conditions on the shore.  Steam fogs are often present
         over the  plume,  but these are rapidly dissipated by mixing with dryer air as
         they move inland.
    
         Estimated Weather Effects from Once-through  Cooling on Lake Michigan
                Some appreciation of the relative improbability of a  significant
         weather modification by waste heat from nuclear power stations  on Lake
         Michigan can be obtained by comparing the  amounts of heat involved in
         power  generation with those quantities involved with natural meteorological
                    (13,21,22)
         processes.
    

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                                                                              257
           A nominal plant-year, defined as a 1,000 MWe nuclear power plant
    operated at full capacity for the entire period, generates 1.5 x 10   cal of
    waste heat.  Assuming that all of this  energy stays in the lake (that is, no
    heat is lost to the atmosphere) and that the heat is uniformly mixed through-
    out the lake, the temperature rise will be only 0.0032° C per year.  If all
    nuclear plants  scheduled for operation by 1974 are on line  (total capacity
    about 7,000 MWe) for an entire year, the maximum possible temperature rise
                           (13)
    would be only 0.022°C.      This temperature increase is two orders of
    magnitude  smaller than the observed year-to-year temperature variations
    observed in Lake Michigan.
           These calculations represent an upper limit of the ability of power
    plants to warm the lake, since zero heat losses  to the atmosphere were
                       (21)
    assumed.  Longtin,     using a more complex model which allows for heat
    losses to the atmosphere, has  concluded that the thermal input from all power
                                                                         (22)
    facilities on the lake is ". . .crudely estimated to be 0.028°C."  Asbury,
    using a  similar but more refined model, reports that the average annual
    temperature of the lake will increase only 0.0055°C because of the reject
    heat from nuclear plants totaling 7,000 MWe.
           A more realistic assumption for the energy distribution within the lake
    is that the  waste heat is confined to the epilimnion.  If it is assumed that
    all of the reactor heat generated during the 6-month summer season is  con-
    fined to a layer 20 m  deep and  is further restricted to the southern basin
    (about 1/3  of the area) of the lake, the temperature rise from nuclear plants
                                                (13)
    with a capacity of 7,000 MWe  will be  0.14°C.     Again, the value is much
    smaller than the observed natural variability.  These calculations show that
    the warming of Lake Michigan by power plants, while undirectional, is too
    small to  change measurably the average air temperature along its shore.
                  (13)
           Carson    has shown that, if all of the reactor waste heat were dis-
    sipated to the atmosphere by evaporation only, the additional evaporative
    flux would  be 0.308 cm/yr.  The natural evaporation rate is not known exactly,
    but a value of 76 cm/yr is reasonable. Thus,  the  maximum additional
    evaporation due to reactor heat is less than 0.4% of natural.  Whether such
    

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         a small increase in humidity is sufficient to be observable is another question.
         The extra moisture should also tend to increase  precipitation around the lake,
         but predicting how much the increase would be,  or in what form, is beyond
                            /o r o C \
         the state of the  art.    '     If all of this water were to fall as snow with a
                            3
         density of 0.1 g/cm   over an  area 500 km by 50 km, the snow depth would
         be 9 cnu(13)
                Ihe  heat transfer rate  by natural  evaporation corresponds to the heat
         loss from nuclear plants  totaling  1,730,000 MWe, showing that man's heat
         burden on the lake is trivial.
         Natural-Draft Cooling Towers
                Weather changes due to cooling towers are more severe than those
         related to once-through cooling; at least they are  more easily and frequently
         observed.  Towers dissipate large amounts of heat and water vapor from small
         areas at  the same rate as power is generated.
                Meteorological problems associated with both natural- and forced-
         draft types of cooling towers can be separated into three zones; within the
         tower, the water droplet plume,and the vapor plume after the droplets
         evaporate.  Within the tower, the meteorological question is the nucleating
         properties, if any, of the drift or carryover o  The visible plume presents the
         primary and most easily studied problem; predicting the position  (plume rise
         and height of base), dimensions (length, width, and depth), and liquid
         water content of the  visible plume from weather conditions (wind speed, wet
         and dry bulb temperatures, stability) and plant parameters (inlet  water tem-
         perature, approach,  plant load, size and type of tower, and number of units
         on line)*  Data on the frequency and areal extent of ground level fog, icing,
         and drizzle (mist) are also needed.  In the final zone, information on the
         effect of the water vapor plumes on cloud formation, precipitation, and
         ground-level humidity is  needed.
                Ground-Level Fog and Icing
                Practically every article on cooling towers includes a  statement that
         natural-draft units "have the potential to cause or to  increase the frequency
    

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                                                                                259
     of ground-level fog and icing."  On the other hand, available observations
     near natural-draft towers indicate that the plumes rarely, if ever, reach the
     ground.  For example, Mr. W.  C. Colbaugh of TVA  (personal communication)
     reports that there have been no cases of visible plumes reaching the ground
     during two years of operation of the Paradise, Kentucky steam plant.  Accord-
     ing to Mr. F. A. Schiermeier of the Office of Air Programs (personal com-
     munication) , no surface fogs or icing have been observed in four years of
     operation of the Keystone,  Pennsylvania Power Plant (1800 MWe). The same
                                         (27)
     results have been reported in England    and elsewhere in the United
            /c 23 28)
     States.   '  '    These observers report that the visible plumes enter the
     atmosphere at heights of 100 m or more and evaporate completely before
                                  (8)
     reaching ground level.  Hosier   does report one occasion on which the
     visible plume from a natural-draft cooling tower did reach the ground; this
     is the only reported case in the literature.  Nevertheless, contrary to actual
     observations taken at tower sites, most theoretical analyses predict frequent
                                   (10,14,29)
     tower-induced ground-level fog.
            Theoretical analyses designed to predict plume dimensions and
     ground-level fog from cooling towers usually contain three sections.  First,
     a model is used to predict  plume rise.  This model may be one of the standard
     plume rise formulas    or  a cumulus cloud model.      Second, a calculation
     of the rate of dilution of water vapor from the tower is made using one of the
     standard dispersion formulas.  Finally, the wind direction and moisture-
    deficit climatology of the site are used to determine plume lengths and when
     and where the plume will reach the surface.
            Photographs taken at cooling tower installations often show the plume
     leaving the towers and rising, completely separated from the surface fog of
     evidently independent origin, since aerodynamic downwash is not observed
     (for example, see Ref. 2).  Of course, large orographic eddies could bring
     the plume down in areas of sufficiently rough terrain.   Then,  in any terrain,
     mist falling from the plume could  cause or add to ground-level fog and icing.
     Natural ground fog is  fairly frequent in the vicinity of cooling towers, since
     these  installations are usually located near rivers and  other water sources.
    

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                 Dimensions of the Visible Plume
                 Under certain weather conditions (low temperature, high humidity,
         moderate wind speed, and a stable atmosphere), the visible plume from a
         cooling tower may extend several miles.  Colbaugh et al.   have measured
         plumes extending 16 km in Tennessee.  Even longer plumes have been observed
         but not reported in the literature.  A literature search shows a lack of good
         data on cooling tower plumes collected on a systematic basis. The TVA is
         now engaged in a major field program to obtain such data, but their analysis
                                /c\
         has not been completed.    This program is also measuring the dispersion
         of the water vapor plume after the visible portion evaporates.
                              (32)
                 Bierman et al.    have published the only climatology of plume
         lengths available.  They measured the length of the plume from a cooling
         tower complex in Pennsylvania for six months in 1969 (January 31st through
         July).  These pictures were taken in early morning, normally the time of day
         with the longest visible plumes.  It was  found that the plumes evaporated
         completely on 81.5%  of all days during the period of study.  Of these, 87 .3%
         disappeared within 5  stack heights or 1625 ft of the tower; only 2.6% extend
         more than 15 stack heights or 4875 ft. The plume merged with an existing
         overcast on 16.5% of all days.  On the remaining days (2.0%), the plumes
         were classified as "special cases," such as cloud building.
                 Cloud and Precipitation Formation
                        (2)
                Aynsley    has observed that cooling tower plumes can, if meteoro-
         logical conditions are proper, create cumulus clouds.  He concludes that
         this is a "rare occurrence," and that these man-made clouds only precede
         natural cloud formation.  He discussed the possibility that a cooling tower
         plume could somehow trigger  an existing atmospheric instability and create
         extra cumulus congestus clouds and precipitation miles  downwind of the
         release point.  As the number and size of cooling towers on a  given site
         increase,  the probability of significant  alteration of cloudiness  and pre-
         cipitation patterns will increase.   '     The state  of the art in cloud physics
         is such that we cannot say with any degree of certainty that there will be any
                                                               (7)
         increase in rainfall amounts due to cooling tower plumes.
    

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                                                                               261
            There are at least three reported occurrences of snow showers or ice
                                                         (33)        (34)
    crystals being generated by cooling towers [Culkowski,    FWQA,    and
    Colbaugh  ] .  In all cases, the amounts of snow were very small.
            In an unpublished report, the  Central Electricity Generating Board of
                (27)
    Great Britain     reported its findings on the environmental effects of cooling
    towers.  No measurable change  in surface relative humidity was detected
    downwind.  The visible plume sometimes  persisted for a number of miles down-
    wind, altering sunshine in the area.  No drizzle was observed from the towers.
    Cumulus clouds were sometimes formed, but no cases  of showers  or pre-
    cipitation being generated by the plume have been observed.
            A small part of the cooling water (estimated to  be less than 0.1 %), is
    carried  into the plume without being evaporated.  These droplets,  called
    drift or  carryover, contain whatever impurities  are present in the makeup
    water and release these materials into the atmosphere  when they evaporate.
    River water, containing soil erosion products,  and sea water, are  frequently
    used in cooling towers.  Since certain clay materials are known to be good
    cloud seeding agents, these drift particles could be effective cloud nucleat-
    ing agents and conceivably might modify clouds and precipitation  over a
    large area.  These drift particles evaporate as  they fall to the ground and
    may cause surface fog and/or icing near the tower.
    
    Mechanical-Draft Cooling Towers
            The fog potential from these smaller forced-ventilation towers is much
    greater  than for natural-draft units for the following reasons:
            1.  mechanical units release their water vapor  at a much lower
    elevation (50 to 80 ft compared to 350 to 500 ft) where winds are weaker, the
    saturation deficit is less, and the surface nocturnal inversion frequently
    prevails;
            2.  the plumes are frequently  trapped in building eddies; and
            3.  much higher entrainment rates  are generated owing to smaller
    exit diameters, high (100  fps) exit speed, and  additional turbulence created
    by the fan.
    

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    262
                Argonne National Laboratory has several wet cooling towers.  On very
         cold, calm days, a visible plume may extend upwards 200 ft or so before
         disappearing.  On cold,  windy days,  plumes often extend 200 to 500 ft
         horizontally.  In January 1970 during  a near-record period (70 hr) of subzero
         temperatures, the author was not able to find icing on any of the trees 200 ft
         downwind of the cooling  tower, even  though they had been in the visible plumes
         for over 24 hr. The author has examined these trees on numerous occasions
         during the past three years; no ice has ever been detected.
                The most thorough review of the effects of natural- and forced-draft
         cooling towers on local fogginess and cloud precipitation formation can be
         found in a recent paper by Huff et al.
    
         Dry Cooling Towers
                In areas where water is expensive or scarce, dry cooling towers
                      (35)
         may be used.      It is possible that the large quantities of heat releas*
         from such cooling towers could generate sufficient convection to create
                                         (14)
         cumulus  clouds and precipitation,    but this seems unlikely in the sei
         desert climates where such units are used.
         Cooling Ponds
                In areas where land is relatively inexpensive, cooling ponds or lakes
         are being constructed.  Commonwealth Edison will use this method of heat
         dissipation at its Dresden (1,618 MWe) and LaSalle County,  Illinois (2,156
         MWe) plants.  There is a "rule" that 1 acre of water surface  is needed to
         cool one MWe-fossil, while 1.5 acres are needed for each MWe-nuclear.
                Water losses from cooling lakes can be separated into two components:
         natural evaporation from an unheated lake and extra water losses due to the
         reactor heat.  This extra evaporation is less than would be used by cooling
         towers of similar capacity, but the total water loss from  the cooling pond
         is usually greater than that from a cooling tower of similar heat capacity.
         In most western states, the total water loss from artificial ponds may be
                                             /
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                                                                               263
            The frequency, intensity, and inland penetration of pond-induced
     fogs are items of concern in pond site selection.  Observations made at
     existing cooling ponds indicate that the fog, except for cases of  large-scale
     fog formation, is thin, wispy and usually does not penetrate inland more than
     100 to 500 ft.  It would appear that because the water vapor is released over
     large areas, ponds are not a major source of fog, despite the release of the
     water at ground level.  The pond should be located so that the induced  fogs
     (and freezing fogs) do not affect roads and bridges.
            Steam fog is created whenever the air is sufficiently colder and  less
                                           (37)
     humid than the underlying water.  Church    has indicated that steam fog
     will form if the vapor-pressure differences between the  air and water is 5
     millibars or more and the air temperature is at or below  freezing.   The air
     layer next to the water surface is heated and has moisture added; mixing of
     this air with the unmodified air just above can lead to supersaturation and
     condensation. Further vertical mixing tends  to evaporate the steam fog.
            It should be remembered that natural steam fog is fairly common in
     much of the nation due to the frequent passage of cold air masses over  open
     water.  Because of higher water temperatures, steam fog may form over  the
     heated water in cooling ponds when conditions do  not favor natural steam fog.
     Some of the water droplets will be removed by vegetation and other surfaces
     as they move across the nearby land areas, causing a local increase  in
     humidity and dew.  During periods of subfreezing temperatures, some of the
     droplets will freeze and create a layer of low-density rime ice on nearby
     vegetation and structures. Observations at existing ponds indicate that
     this rarely,  if ever, causes problems with plants,  power lines, etc.
           Air crossing the pond will be slightly warmer and more humid than it
     would otherwise be.  How large these changes  will be at the shoreline is not
     known; it is reasonable to assume that the differences will be insignificant
     and too small to measure a short distance inland.
           On a very cold winter day, January 5, 1972 (air  temperature -2_50F,
    relative humidity about 80%), heavy steam fog was present over the cooling
    pond of a nuclear power plant in northern Illinois.  Light rime ice up to
    

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    264
          1/4-in thick was observed on fences and vegetation up to 100 ft from the
          lake.  The horizontal visibility on a highway bridge over the pond was more
          than 100 ft; no ice was observed on the roadbed.  Ice crystals were observed
          floating in the atmosphere over another road about 100 ft downwind of the pond,
                On January 14 and 15,  1972, the visibility on a bridge over the pond
          itself averaged less  than 100 ft as the fog moved in patches from the pond.
          The air temperature during this period remained near zero, with W to NW
          winds 10 to 15 knots.  Dense portions of this fog momentarily reduced visi-
          bility to  5 to 10 ft; a few seconds later, the fog thinned and occasionally
          the visibility improved to  200 ft.  The bridge was quite slippery, owing
          mostly to 2  in of snow on January 13; the combination of poor visibility and
          slick roads  caused two automobile accidents.  Visibility on another road
          200 ft from the pond  never went below 200 ft.
                The  maximum observed inland penetration of ground-level fog from
          this cooling pond (period of record, November  1971 through February 18, 1972)
          was only 1/4 mile (400 m).  The steam fogs  either evaporate completely or
          move aloft and form a cloud deck.
                A study has been made of the inland  extent of  steam fogs generated
                               /og\
          by other  cooling ponds.     In four steam fogs over a cooling pond in
          central Illinois, the  downwind fog extended  40 to 150 m.  Five observations
          were made at the Four Corners power plant in New Mexico in December 1970
          and January 1971. The reported inland extent of the fog on two days was 20
          to 40 m;  on another,  50 to 150 m.  On January  7, 1971, when the air temper-
          ature was -12° F and the water was +51° F, the fog moved inland 3000 to
          3400 m.  The next day was 2°F colder, and the inland movement was 14,000
          to 18,000 m.  The report made no mention of the density of the fog.
                       (24)                (23)
                Decker    and Zeller et al.    have published papers on the effects
          of cooling ponds on atmospheric conditions;  they report no serious fogging
          problems at several cooling ponds in Europe and the USA.
    
          Spray Canals and Ponds
                In a spray cooling system, pumps are used to send the heated water
    

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                                                                              265
    into the atmosphere to increase the area of contact between water and air,
    thus increasing the rate of cooling by conduction and evaporation.  Typical
    units now in service send the water 20 ft upwards over a 40-ft diameter
    circle.  The primary advantage of a spray system over a cooling pond is the
    much smaller area needed to cool a given plant load.
           Since spray canals concentrate in both space and time (when compared
    to once-through cooling or cooling ponds) the heat transfer to atmosphere,
    the atmospheric changes due to the extra heat and water vapor will  be en-
    hanced o  The visible plume created by the spray canal contains drift water
    droplets in addition to drops ot condensed vapor.  These drift droplets  will
    tend to be larger than those produced by condensation and add considerably
    to the wetting and icing potential of the visible atmospheric plume.
           In contrast with cooling towers and ponds, there has been little oper-
    ating experience with large spray cooling systems, especially in winter, the
    season of greatest interest.  A small spray system, designed primarily as a
    scale or test model of a full system, has been operated for one winter in
    New Hampshire; no serious meteorological problems  were experienced
    (Mr. James Parks, Public Service of New Hampshire, personal communication).
    This system is  located in a valley which keeps wind speeds over the spray
    modules low; most of the drift droplets fell back into the canal and  were not
    carried inland„   Typically, the fog created by the spray units rose to a height
    cf 200 ft before evaporating and/or moving inland.  Her.ce, icing has not
    been a serious  problem near the canal.  On two occasions, very thin fog has
    been observed as far as 2 miles from the canal.  Canal-produced fogs, in
    contrast to natural fogs in this part of New England,  are thin and do not
    reduce visibilities over nearby highways to less than 100 ft. Since no
    significant environmental problems were  observed  during the  past winter, the
    utility is now expanding the spray canal  to dissipate the entire heat load
    from the power  plant.
           The Dresden, Illinois/Station of the Commonwealth Edison Company
    started operation of a  spray canal system in August 1971.  Experience during
    the summer months gave no indication of serious environmental problems due
    

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    266
         to log from the spray canal.  Commonwealth Edison is now sponsoring a full-
         scale investigation of the fogging and icing potential of the Dresden cooling
         system which contains a 1275-acre lake in addition to the spray canal.
         Although this observation program has just started, experience to date at
         Dresden can be used to predict atmospheric effects at other spray canals.
                On January 5,  1972, the overnight temperature was well below zero.
         At 0800 C.S.T., when the first visual observation of fog and icing was made,
         the air temperature was -2.5T and the relative humidity 100%. Over the
         spray canal, a dense plume rose to a height of 100 to  150 ft; this visible
         plume extended inland about 1000 ft before evaporating (R. W. McLain,
         Murray and Trettel,  Consulting Meteorologists, personal communication).
         About 1-1/2 to 2-1/2 in of hard,  dense rime ice was deposited on vegetation
         and fences next to the canal; this dense ice, with decreasing thickness, was
         found to extend inland 100 to 150 ft.  Light rime ice formed further downwind,
         up to 1/2 in thick 500 to 700 ft downwind,  and 1/4 in at 1000 ft.  It was
         observed that ice formed only on vertical surfaces, such as fences,  posts,
         and vegetation.  No ice was observed on a road 600 ft downwind of the
         spray units.
                From the limited experience to date, it is reasonable to expect that
         spray cooling systems will create more severe icing conditions during winter
          than mechanical draft cooling towers and cooling ponds,  with^drift being
          a serious problem.
                Quantitative estimates of fog and icing potential from spray canals
         are not possible, in part because the properties of the air downwind of spray
         units (temperature, liquid water content, drop size distribution, etc,,) are
         unknown functions of ambient weather conditions (wind speed, air temperature,
         humidity, stability), water temperature, and characteristics of the spray-
         heads (drop size distribution, number of sprays and their location with respect
         to the wind direction, etc.). For most wind conditions, the air will be in
         contact with the water from the spray for a shorter period than it would be  in
         a cooling tower.  Thus, the heat and moisture transfer to the air will be
         slower, and more air  will be modified to cool a given plant load.
    

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                                                                              267
           Based on experience at the two locations mentioned above, the
    primary atmospheric effect will be dense fog and hard rime ice on vertical
    surfaces near the spray units on cold days  (< + 10°F) in winter, with thin fog
    and light rime ice extending some distance inland.
    
    Summary and Conclusions
           The amount  of heat energy contained in the cooling water from the
    large nuclear power stations is quite small compared to the natural heat
    processes.  Since the heat energy from these plants with once-through cool-
    ing systems will enter the atmosphere over a  large area,  changes in weather
    will be small and probably impossible to isolate in the natural variability
    of weather elements.  An exception will be an increase of steam  fog in fall
    and winter at the point of discharge.
           Alternate cooling systems, such as cooling towers,  cooling ponds,
    and spray canals, release the energy to the atmosphere rapidly over a small
    area;  hence,  the potential for local weather changes is greatly enhanced.
    Much care should be given to cooling site location so that the fog and icing
    do not seriously restrict road traffic, etc.
           From a meteorologist's point of view,  once-through cooling on a large
    water body is to be  preferred over either cooling towers or cooling ponds.
    
    References
     1. Federal Power  Commission, Chicago Office, Electric Load and Supply
           Pattern in the Contiguous United States,  September 1971.
     2. Aynsley, E.  Cooling-tower effects: Studies abound.  Electrical World,
           42-43 (May  11,  1970).
     3. Stockham, J.   Cooling Tower Study. Final report for Contract No. CPA
           22-69-122,  IITRI Report No. C6187-3, EPA Air Poll. Cont. Office,
           Durham, North Carolina (1971).
     4. Overcamp, T.  J. and D.  P. Hoult.  Precipitation from Cooling Towers in
           Cold Climates.  Publ. No.  70-7, Dept. Mech. Eng.,  MIT
           Cambridge,  Mass. (1970).
     5. Decker,  F. W.  Report on Cooling Towers and Weather.  FWPCA,
           Corvallis, Ore.  (1969).
     6. Colbaugh,  W.  C.,  J. P. Blackwell, and  J..M.  Leavitt.   Interim  report
           on investigation  of cooling tower plume behavior,  TVA Muscle Shoals.
    

    -------
    268
                Paper presented at the A, I. Ch. E. Cooling Tower Symp., Houston,
                Texas, March 3, 1971.
          7.  Huff, F. A., R. C. Beebe, D. M. A, Jones, G. M.  Morgan, and R. G.
                Semonin.-  Effect of Cooling Tower Effluents on Atmospheric Conditions
                in Northeastern Illinois.  Ill, State Water Survey, Urbana,  Circ. 100
                (1971).
          8.  Hosier, C. L.  Wet cooling tower plume behavior.   Paper presented at
                the A. I. Cho E. Cooling Tower Symp0, Houston, Texas, March 2,
                1971.
          9.  Hanna, S.  R. and S, D. Swisher.  Meteorological effects of the heat
                and moisture produced by man.  Nucl. Safety _1_2_, 114-122 (1970).
         10.  EG & G, Inc.  Potential Environmental Modifications Produced by Large
                Evaporative  Goolirtg Towers.  EPA WQCX Water Pollution Control
                Research Series Report No. 16130 DNH 01/71 (1971).
         11.  Kolflat, T. D.  Thermal discharges—an overview.  Proc. of the American
                Power Congress, Vol.  3, pp.  412-426, Chicago,  April 20-22,  1971.
         12.  Altomare, P.M.  The application of meteorology in  determining the
                environmental effects of evaporative heat dissipation systems.
                Paper presented at 64th Ann. Mtg. Air Pollut.  Control Assoc.,
                Atlantic City, June 27-July  1, 1971.
         13.  Carson, J. E.  Some comments on the atmospheric consequences of
                thermal enrichment from power generating stations on a large lake.
                Paper presented at the 64th Ann. Mtg. of Air Pollut.  Control Assoc.,
                Atlantic City, N. J.,  June 29,  1971.
         14.  McVehil, G. E. Evaluation of Cooling Tower Effects at Zion Nuclear
                Generating Station,  Final Report, Sierra Res. Corp. for Commonwealth
                Edison Co.,  Chicago (1970).
         15.  Ackermann, W. C.  Research Needs on Waste Heat  Transfer from Large
                Sources  into the Environment.  Illinois State Water Survey Report
                (December 1971).
         16.  Great Lakes Fishery Laboratory.  Physical and Ecological Effects on
                Waste Heat on Lake Michigan.  Bur.  Commercial Fisheries, Ann
                Arbor , Mich. (1970).
         17.  Csanady, G. T.  Waste heat disposal in the Great Lakes.  Proc. 13th
                Ann. Conf. Great Lakes Res,,  388-397 (1970).
         18.  Csanady, G. T., W. R. Crawford, and B. Pade. Thermal Plume Study at
                Douglas Point, Lake Huron.  University of Waterloo (1970).
         19.  Ayers, J. C. Remarks on  Thermal Pollution in the Great Lakes.
                Unpublished report (1970).
         20.  Ayers, J. C. The Climatology of Lake Michigan. Great Lakes Research
                Division,  University of Michigan, Publication No,,  .- (1965).
         21.  Longtin, J.  P.  Temperature Increase in Lake Michigan due to Thermal
                Discharges from Electrical Power Facilities. Unpublished FWPCA
                Report (February 1969).
         22.  Asbury,  J.  P.  Effects of Thermal Discharges on the Mass/Energy Balance
                of Lake Michigan,  ANL/ES-1, July 1970,
    

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                                                                              269
     23.  Zeller, R. W., H.  E. Simison, E. J. Weathersbee, H. Patterson,
            G. Hansen, and P. Hildebrandt.  Report on Trip to Seven Thermal
            Power Plants.  Prepared for Pollution Control Council, Pacific North-
            west Area (1969).
     24.  Decker, F. W.  Background Study for Pond Cooling for Industry. Oregon
            State University, Corvallis (March 1970).
     25.- Lowry, E. P.  Environmental effects of nuclear cooling facilities.  Bull.
            Am. Meteor. Soc.  51,  23-24  (1970).
     26.  Hewson, E. W.  Moisture pollution of the atmosphere by cooling towers
            and cooling ponds.  Bull. Am. Meteor. Soc. 51, 21-22 (1970).
     27.  Great Britain Central Electricity Generating Board.  Pollution of the
            Atmosphere by Humidity from  Cooling Towers.  Report 23/63  (1968).
     28.  Broehl, D.  J. Field Investigation of Environmental Effects of Cooling
            Towers for Large Steam Electric Plants.  Portland General Electric
            Company (1968).
     29.  Travelers Research Corp.  Climatic Effects of a Natural Draft Cooling
            Tower.  Davis-Besse Nuclear Plant (1969).
     30.  Briggs, G.  A.  Plume Rise. AEC Critical Review Series, Report
            TID-25075  (1969).
     31.  Weinstein, A.  I. and L. G. Davis.  A Parameterized  Numerical Model
            of Cumulus Convection.  NSF Report No. 11, NSF GA-777, Department
            of Meteorology,  Penn. State Univ., University Park (1968).
     32.  Bierman,  G. F.,  G-. Ai  Kunder, J. F. 'Sebald,  and R.  F. Vi'sbisky.
            Characteristics, classification and incident plumes from large natural
            draft cooling towers. Proc. Am. Power Conf. 33, 535-545 (1971).
     33.  Culkowski, W. M.  An anomalous snow at Oak Ridge, Tennessee.
            Monthly  Weather Rev. 90., 194-196  (1962).
     34.  Federal Water Quality Administration.  Feasibility of Alterative Means
            of Cooling for  Thermal Power Plants near Lake Michigan. Prepared
            by National Thermal  Pollution Research Program, Pacific Northwest
            Water Laboratory and Great Lakes Regional Office, U.S. Department
            of Interior (1970).
     35.  Rossie, J. P., E. A. Cecil, P. R. Cunningham, and C. J. Steiert.
            Electric power generation with dry-type cooling systems.  Proc. Am.
            Power Conf. 3.3,  524-534 (1971).
     36.  Hauser, L.  G. and  K. A. Oleson.  Comparison of evaporative losses in
           various condenser cooling water systems,  Proc. Am. Power Conf.  32,
            519-527  (1970).
    37.  Church, P.  E.  Steam-fog over Lake Michigan in winter. Trans. Am.
           Geophys. Union  26.,  353-357  (1945).
    38.  Bechtel Company.  The  Environmental Effects of the Midland Plant  Cool-
           ing Pond-Interim Report.  Part of the Environmental Impact Report
           submitted by Consumers Power Co ., Michigan (June 1971).
    

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                          The  Atmospheric Effects  of Thermal
                          Discharges  into a Large  Lake
                          James E. Carson
                          Argonne National Laboratory
    Concern for the biological and ecological effects of heated water has resulted in
    legal actions that will prevent  power companies from dumping the waste heat
    from  the majority of their new generating units into  rivers and lakes.   Many
    nuclear- and fossil-fueled plants now under construction, and even some now on-
    line, are being required to change from  once-through  cooling systems to other
    methods, such as wet cooling towers, cooling  ponds, and spray canals, despite
    higher costs and lower thermal efficiencies.   Yet, these alternate  cooling pro-
    cedures are not without their own environmental problems.
      The primary weather change due to once-through  cooling on  a  large  water
    body is a small local  increase in fogginess at the plant outfall.   But the relative
    probability of significant local meteorological effects is much higher with alternate
    cooling procedures, since these reduce the area of heat and moisture transfer.
    It is therefore concluded that, from a meteorological point of view,  the least un-
    desirable way to dispose of waste heat is by using once-through cooling on large
    water bodies.
    The peak demand for electrical power
    in the United States is increasing at a
    rate of 7% per year.1 This increase is
    due both to increasing population and
    to increasing per capita  consumption.
    Almost  all of the  new  capacity will
    consist of thermal (steam) units, both
    nuclear- and fossil-fueled, with marked
    trends  toward  larger  capacity  units
    and  more units on a given site.  De-
    spite their lower thermal efficiencies,
    an increasing fraction of the new plants
    will be nuclear,  this choice being made
    in part to reduce emissions of atmo-
    spheric  pollutants such  as flyash and
    sulfur dioxide.
      Two fossil fuel (with a capacity of 616
    MWe)  and  five nuclear  plants  (6732
    MWe) are now being installed along the
    shores of Lake Michigan2 and are ex-
    pected to be on-line with the 25 opera-
    tional plants by  1974.   These plants
    will have  a total capacity  of 15,626
    MWe.  All were originally designed for
    once-through cooling.   Recent actions
    of the Environmental Protection Agency
    may force most, if not all, of the new
    plants to  use alternate  cooling tech-
    niques, such as cooling towers or cooling
    ponds.
      Utilities use large amounts of water
    to cool  the condensers in the plant;
    the cooler this water is, the  more effi-
    cient  the  process  will  be.  Until re-
    cently,  most plants have used once-
    through cooling,  drawing water from
    lakes, rivers, or the ocean,  heating  it
    10°-25°  F  as  it  passes  through the
    plant, and returning it to the source.
    Because of concern for both the effects
    of increased temperatures on the biota
    of the receiving water body  and short-
    ages of  cooling  water,  many power
    generating  stations  now under  con-
    struction  will use  cooling  towers  or
    cooling ponds to dissipate much of the
    heat to the atmosphere before recycling
    the cooling water or returning it to the
    source.  Lower costs of operation and
    installation  dictate the use  of "wet"
    or  evaporative  supplemental  cooling
    systems except in areas of very limited
    water supplies.
      The  state  of  the  art is  such  that
    meteorologists are not able  to predict
    quantitatively how the atmosphere will
    react to the large amounts  of  heat
    energy and water vapor that it will be
    forced  to  absorb as  the result of the
    disposal  of waste  heat  from power
         Dr.  Carson is associate meteor-
       ologist in the Atmospheric Physics
       Section, Radiological Physics Divi-
       sion, Argonne National Laboratory,
       Argonne,  111. 60439.  The  work
       upon which  this paper was  based
       was performed under the auspices of
       the U. S. Atomic Energy Commis-
       sion.  The paper was presented at
       the 64th Annual Meeting of APCA
       at Atlantic City, N. J., in June 1971
       as Paper No. 71-58.
    July 1972   Volume 22, No. 7
                              Reprinted from APCA JOURNAL, Vol. 22, No. 7, July, 1972
                                                                                                                    523
    

    -------
    plants.  Conceivably,  critical  heat re-
    lease  rates may  exist for particularly
    sensitive sites  which,  when exceeded,
    may lead to significant meteorological
    effects, such as the generation of thun-
    derstorms  in  convectively  unstable,
    subtropical conditions.
      Large  quantities of reject heat are
    not unique to nuclear electrical gener-
    ating  stations  since all  heat  engines
    release heat  to the environment. In
    other words, what is frequently  called
    "waste heat" is really a necessary part
    of the energy conversion process.
      Almost all  of  the  energy produced
    by  electrical power stations, both the
    waste heat and the useful power gener-
    ated,  is  eventually  dissipated to the
    atmosphere.  In  this paper the poten-
    tial meteorological effects of the waste
    heat  are explored.  While studies of
    the effect of thermal  discharges on the
    atmosphere are relevant to all types of
    power generation, they are particularly
    significant   to  water-cooled  nuclear
    power plants which produce 40 to 50%
    more  waste heat  per unit of electricity
    than modern fossil-fueled plants.  Part
    of the difference in cooling requirements
    is caused by  the loss of heat up the
    chimney in conventional power plants
    (10 to 12% of the total).   It should be
    noted that all but the most modern of
    the  fossil-fueled   plants  now  on-line
    operate  at efficiencies comparable to
    the new nuclear plants.
      Statements   made  by   the  utilities
    serving the Lake Michigan area indicate
    that  alternate cooling methods,  such
    as cooling  towers and  ponds,  may be
    used  for plants  now being designed.
    These alternate  cooling  methods are
    not without their own  environmental
    problems, and the meteorological con-
    sequences  of  these  procedures  are
    briefly  discussed.  It  is  found  that
    once-through  cooling  is  the  preferred
    method,  meteorologically speaking.
      To date only  a limited number of
    research and field studies on the atmo-
    spheric  aspects  of  thermal  pollution
    have  been conducted  and reported in
    the  literature.  Published  papers in-
    clude  those  of Aynsley,2  Stockham,4
    Overcamp  and Hoult,5  Decker,6 Col-
    baugh,  et  al.,7 Huff,  et  al.,8  Hosier,9
    Hanna  and  Swisher,10 EG&G,11  Kol-
    flat,12 and Altomare.13
      In  September   1971,  the  National
    Science Foundation sponsored  a work-
    shop  to  prepare  a list of the areas of
    ignorance in the  field of environmental
    aspects of thermal discharges from large
    sources  and  to suggest research  proj-
    ects  to   improve  our   knowledge.14
    This  conference  covered many  topics
    in addition to the atmospheric aspects
    of waste heat discharges.
      This paper deals primarily  with the
    atmospheric  effects  of   once-through
    cooling on a large  lake,  such as Lake
    Michigan.  It was found that  the total
    energy released by these  nuclear power
    plants is a very  small fraction of the
    natural heat transfer processes on the
    Lake;  it is concluded that the meteoro-
    logical and climatological consequences
    will  be  small.   Except   for  a  small
    amount advected into Lake Huron, all
    of the  power  plant reject  heat will
    eventually enter the atmosphere through
    radiation, evaporation, and conduction
    from the lake surface.
      While  the total quantity of heat put
    into  the  lake by  these power  plants is
    very small compared to that exchanged
    by natural  processes (solar radiation,
    evaporation, conduction,  and long-wave
    radiation),  it  does  not  immediately
    follow that  the  meteorological  con-
    sequences  will  also be  small.  It is
    possible that the frequency and severity
    of the lake snows, fog, and freezing fog
    around the south  and  east shorelines
    of the lake could  be increased  some-
    what as  a result  of a small increase in
    lake   surface   temperature.   In  any
    event, such meteorological  and  cli-
    matological changes would  be  very
    difficult to isolate in the noise of natural
    variability of weather elements.
    
    Observed Weather Changes Caused by
    Thermal Enrichment
      Thermal  plumes  introduced  into
    large bodies of  water are dissipated by
    two  processes:  through  direct surface
    losses to the atmosphere by evaporation,
    radiation, and conduction, and through
    dilution  by  mixing  with the  cooler,
    main body of  water.  Unfortunately,
    the  relative  magnitudes  of these two
    temperature-lowering processes are not
    known for  various weather  and lake
    conditions.   Meteorologists   are   not
    able  to  measure  directly the locally-
    increased vertical  fluxes of radiation,
    heat, and water  vapor over a thermal
    plume with the accuracy required due
    to the small size and meander of the
    thermal  plume  itself.  Direct  measure-
    ment of plume temperature  reduction
    by mixing  with ambient  lake  water
    presents  experimental difficulties.  Csa-
    nady15 has concluded from a theoretical
    analysis  that only a small part (on the
    order of 5%)  of the plume's heat is
    lost  to the. atmosphere  before  mixing
    lowers the plume's surface temperature-
    excess to 1 °F.   More recently,  Csanady,
    et al.16 measured the heat balance of
    a thermal plume from a nuclear power
    plant on Lake Huron and found that
    "the direct heat flux to the atmosphere
    from  the detectable plume  was  %  of
    the total heat flux."   Ayers17 concludes
    that there is a "significant loss of excess
    heat to air, and an insignificant loss of
    heat  to  the underlying  cold  water."
    Clearly,  more  field  measurements are
    needed to determine rates of heat loss
    from  thermal plumes  over a  range of
    weather  conditions.   The relative im-
    portance  of  the  two   temperature-
    lowering processes will vary as lake and
    atmospheric conditions change.   When
    the lake is rough, mixing will be  rapid.
    When it is smooth, the warm water will
    tend to float with little mixing and pre-
    sent a larger area of greater temperature
    excess, and hence increased heat transfer
    to the atmosphere.
      Except for that advected into Lake
    Huron, the  heat energy  mixed into
    the main body of Lake  Michigan will
    eventually  be  returned  to  the  atmo-
    sphere.   This transfer takes place over
    such a large area that it is reasonable to
    conclude that once-through cooling will
    have  a much  smaller impact on the
    atmosphere   than   alternate   cooling
    methods such as towers or ponds.
      Lake Michigan has a  natural tem-
    perature resetting mechanism due  to
    the cooling  of  the  entire body of the
    lake every winter below  4°C,  the tem-
    perature of  maximum density  of fresh
    water.  Twice  each  year  the lake is
    observed to be vertically  isothermal at
    the temperature of  maximum density
    due  to thermal instability  and me-
    chanical mixing due to storms.  Thus, up
    to an improbable condition  in  which a
    temperature  as low  as 4°C is not ob-
    tained,  lakes  such as Lake Michigan
    cannot  accumulate  heat energy year
    after  year.  It  has  been  observed18
    that  the average temperature  of  Lake
    Michigan has  actually decreased  1°-
    2°F during  the past two or three dec-
    ades  despite  its use  for cooling by  in-
    dustry  and  fossil-fueled plants, and
    despite  warmer  inflow-stream   tem-
    peratures due to tree removal.
      Two  scales of weather changes can
    be  expected  from  thermal discharges
    into the lake:  local changes due to  in-
    creased heat and moisture  fluxes over
    the  thermal  plume,  and  large-scale
    modifications due to the  accumulation
    of heat energy in the main water body.
      Heat and water vapor are added to
    the atmosphere as air moves  from the
    land over the lake surface. Due  to the
    local  temperature  excess,  more heat
    will  enter the  atmosphere  from the
    thermal plume  than from the main lake
     524
                                                                                 Journal of the Air Pollution Control Association
    

    -------
    surface.  Thus,  air  with a  trajectory
    over a thermal plume will bi  somewhat
    warmer,  more humid, and  less stable
    as a consequence of thermal discharges.
    Observations confirm that an increase
    in the frequency and density of steam
    fog over the immediate  plume area is
    *he primary observable effect of thermal
    discharges into large water bodies.
      Thermal  discharges  from   power
    plants also might conceivably modify
    the  large-scale  climate   of  an  area.
    Much of the heat will be  mixed into the
    main body of the lake, raising its tem-
    perature a small  fraction of one  de-
    grr,, 19,20  gome  Of the energy added in
     _.,   ,er  will be stored  until the  fall
    cooling period  is  reached;  increased
    evaporation and conduction could then
    increase  the  intensity and  frequency
    of lake snows in late fall.  It does  not
    necessarily follow  that the increase in
    lake snows would be directly  propor-
    tional to  the   extra  heat   discharge;
    even  a small  increase in  water tem-
    perature could  be  just sufficient  to
    release an atmospheric instability.  The
    amount of heat discharged  by power
    plants is much too small to cause mea-
    surable  air temperature changes   on
    the lake shore (see below).
      A review of  the literature indicates
    that, except for fog, changes in weather
    and climate due  to once-through cooling
    on lakes, rivers, and  cooling  ponds are
    too small to be observed.  Numerous
    cases  of thin  fog  and/or light freez-
    ing   fog   near  thermal  outfalls   or
    cooling ponds have  been reported.21'22
    These steam fogs are "wispy", thin  and
    dissipate quickly.   In no case did  a
    statement that these plume-related fogs
    pose a problem  to visibility and traffic
    on  nearby  land  appear.  If  the  air
    temperature  is  below freezing,  these
    steam fogs  may drift over  structures
    and through vegetation and cause rime
    icing.  The author has observed dense
    steam fog 3 to  10  meters deep over a
    cooling pond when  the  air  was  more
    than 55°C (100°F)  cooler  than  the
    water.  Ambient air temperature  was
    about —7°C, with low humidity.   The
    fog drifted inland  a maximum of 15 m
    and deposited a  2 to 3 cm layer of flaky,
    low-density rime   ice   on  vegetation
    within 4 m of the canal edge.  This ice
    was so light as  to be no hazard to the
    plants.  No ice had formed on either
    a bridge crossing the canal or on trees
    further inland.
       Perhaps the  most serious  difficulty
    in  conducting field  studies  at existing
    cooling ponds, rivers, and lakes is that
    the undisturbed water body itself affects
    weather conditions.   For example, lake-
    effect snows and steam fogs frequently
    occur near Lake Michigan far from any
    thermal discharge.  But it is very hard
    to say how the intensity, duration, and
    frequency of fogs  and freezing fogs in
    Waukegan,  for example  (which has a
    1100  MWe  coal  plant  using  once-
    through cooling),  has  been  altered by
    this local influx of additional heat.
      Isolating possible long-term  changes
    in weather and climate around the lake
    will be an even more  difficult problem.
    Calculations show that the total reject
    heat from power plants now  being built
    is  very small  compared  to the  me-
    teorological input, and is also very small
    compared   to  natural variations  of
    atmospheric processes.
      Nowhere  in  the literature  has  the
    author found a single report i if observed
    precipitation or significant temperature
    change due to once-through  cooling on
    a large water body.
      In  midwinter, ice-free areas  will be
    formed at or near the point of discharge.
    Plant personnel (including  a professional
    meteorologist) at  a large fossil-fueled
    plant on Lake Ontario report  that the
    plume area is too small to affect weather
    conditions on the shore.  Steam  fogs
    are often present over the plume, but
    these are rapidly  dissipated  by mixing
    with drier air as they move  inland.
      The power plant heat in Lake Mich-
    igan will act to reduce the ice cover by
    delaying its  formation in fall  and  to
    advance its  melting in spring.  Thus,
    the  shipping  season  will be  slightly
    increased; how many  minutes  or hours
    per year is  a  valid  but unanswered
    question.
    Estimated Weather Effects from Once-
    Through Cooling on Lake Michigan
      Some appreciation  of  the   relative
    improbability of  a significant  weather
    modification by waste heat from nuclear
    power stations on Lake Michigan  can
    be obtained  by comparing the  amounts
    of heat involved  in power  generation
    with  those   quantities involved   with
    natural meteorological processes.
      The following assumptions,   all  con-
    servative (that is, yielding a maximum
    value for  the meteorological  change
    being considered),  were  made in  the
    following calculations:
    a. Each reactor   is  operated  at  full
       capacity for the entire year.
    b. The  thermal efficiency of the  plant
       is 33%,  and all of the  waste  heat
       enters  the lake (in nuclear power
       plants, about  5% of the energy is
       lost  to the atmosphere  inside the
       plant).
    c. No heat is lost from coolitig water to
       the atmosphere before it enters the
       lake.
    d. Only one heat dissipation process is
       operating at any one time.
    e. Nuclear plants with  a  capacity of
       7000 MWe will be on line.
    
    Data on the volume,  surface area, and
    other features  of  Lake  Michigan  are
    listed in the Appendix.
    Annual Temperature Rise
      A quantitative estimate of the amount
    of temperature  rise  possible  in Lake
    Michigan because of nuclear waste heat
    can  be obtained  from  the  following
    simple calculation.   A  nominal plant-
    year, defined as a 1000 MWe nuclear
    operated at  full capacity for the entire
    period,  generates  1.5  X 1016  calories
    of waste heat.   If we assume that all of
    this  energy  stays in the lake (that is,
    there are  no losses to the atmosphere
    by evaporation, radiation, or  conduc-
    tion), the temperature rise is given by
                  AT =
    H_
    ms
    where H is the heat added, m is the mass
    of water warmed, and s the specific heat
    of water ( = 1 cal/g/°C).  If  this heat
    were uniformly  mixed throughout the
    lake (horizontally and vertically), then
    for a 1000-MWe plant,
      AT7 =
                   1.5 X  1016 cal
            4.65 X 1018 g X 1 cal/g/deg
      AT = 0.0032°C/yr
    For 7000 MWe,
              AT7 = 0.022°C/yr
      Both are two orders of magnitude
    smaller than the observed year-to-year
    temperature variations in Lake Mich-
    igan.18  It should also be remembered
    that Ayers has found that the Lake has
    cooled about 2°F in the past 40 years
    despite its use  as  a thermal sink  for
    existing  power  plants and  industry,
    and  warmer stream temperatures  due
    to forest removal.
      These calculations represent an upper
    limit of the ability of power  plants to
    warm  the lake, since  zero heat losses
    to   the  atmosphere   were  assumed.
    Longtin,19 using a more complex model
    which allows for heat  losses to  the at-
    mosphere,   has   concluded  that  the
    thermal input from all power facilities
    on the Lake is ".. .crudely estimated to
    be 0.028°C."  Asbury,20 using a similar
    but more refined model reports that the
    average annual temperature of the Lake
    will  increase only 0.0055° C due to the
    reject heat from nuclear plants totaling
    7000 MWe.
     July 1972    Volume 22, No. 7
                                                                                                                        525
    

    -------
      Summer Surface Temperature Changes
      A more realistic assumption for the
    heat distribution within the lake is that
    the energy is confined to the epilimnion.
    If it is assumed that all of the reactor
    heat generated during the 6-mo summer
    season is confined to a layer 20 m deep
    and is further restricted to the southern
    basin (about J^ of the area) of the lake,
    the temperature rise is
    
           AT = H/ms = H/pAds
    
    where p is water density, A is the area,
    and  d  the  depth  of the mixed  zone.
    For a 1000-MWe nuclear plant,
             AT =
                                        7.5 X 1016 cal
                   1 g/cm3 X 1.93 X 1014 cm2 X 2 X  103 cm  X 1 cal/g/°C
                   7'5 X
                               = 0.0194°C
                   3.86 X 10"
    
    For 7000 MWe,
    
                AT = 0.14°C
    
    This value is again much smaller than
    the observed natural variability.
      These  calculations  show  that  the
    warming  of  Lake   Michigan,  while
    unidirectional,  is much  too small  to
    change  measurably   the  average air
    temperature along its shore.
    
        Warming Inside the Thermal  Bar
      In spring, the waters of the lake near
    the shore warm faster than the deeper
    waters, and a "thermal bar" is created.23
    This "bar" acts to reduce lateral mixing,
    and  confines  heated  effluents  to  the
    shore-line.
      Two of the nuclear installations now
    under  construction will  have  a  total
    capacity  of 2200 MWe.  The maximum
    heat discharge rate into  the lake will
    be 2.1 X 109  cal/sec.  It is assumed
    that the  thermal bar is only 2 km from
    the  shore  (a  conservative  estimate),
    that the water  at this point is  10 m
    deep, and the  coastal  current is 0.5
    in/sec  (about  1  mph).  The  water
    transported  past the discharge  point
    will be 5 X  109 cmYsec.  If the water
    inside  the thermal bar  is  completely
    mixed, the temperature rise will be
                                =  0.42°C
    AT =  --  =
           m/t X s
           2.1  X 109 cal/sec
       5X109g/secXlcal/g/°C
    This temperature rise is small compared
    to  measured  hour-to-hour  changes in
    lake  temperature  observed near  the
    shore.
    
                  Evaporation
      In  the above  calculations, it was as-
    sumed that  no  heat  was lost  to  the
    atmosphere by evaporation, conduction,
    or radiation.
                                               If we now assume that all  of  the
                                             nuclear waste heat is  used to evaporate
                                             water  (again, a  conservative assump-
                                             tion), the amount of additional evapora-
                                             tion is given by
    
                                                       // = mL — LpAd
    
                                             where p, A, and d are density, area and
                                             depth as before,  and L is  latent heat.
                                             For a 1000-MWe plant,
                                                        1J5JX 1016 cal/yr
                                                       ""
                                             Ig/cm3
    For 7000 MWe,
    
        d =  0.308 cm/yr or 0.12 in./yr
    
      The natural  evaporation rate is not
    known exactly, but a depth of 76 cm/yr
    (30 in. /year) is reasonable.  Thus, the
    additional evaporation  due to reactor
    heat is less than 0.4% of natural.   This
    extra moisture should  act to increase
    slightly humidity in the area; whether
    the increase is sufficient to be observable
    is  another question.  The  extra vapor
    should also act to increase precipitation
    around  the  lake,  but  predicting  how
    much the increase would  be, and in
    what form, is beyond the state of the
    art.24.25
      The heat transfer rate of the natural
    evaporation   (76  cm/yr)  corresponds
    to the heat  loss from  nuclear  plants
    totaling 1,730,000 MWe, showing again
    that man's heat burden on the lake is
    trivial compared to nature's.
                 Water Budget
      It is estimated that the flow of water
    from Lake Michigan into Lake  Huron
    lies  somewhere between 40,000   and
    55,000 cfs (1133 to 1560 rn3/sec).   An
                                             additional  3200  cfs  (91  m3/sec)  is
                                             diverted  into  the  Mississippi  River
                                             Basin.  The water lost by evaporation
                                             per unit time, V/t, is given by
    
                                                        V/t = H/t/Lp
    
                                             For a 1000-MWe plant,
    
                                             V/t = H/t/Lp
                                                 ~ 590 cal/g X 1 g/cm3
    
                                                 = 8.1 X 105 cmVsec or 28.6 cfs
    
                                             For 7000 MWe,
    
                                                       vol/sec = 210 cfs
    
                                               This number  represents the  upper
                                             limit of water loss  by evaporation by
                                             any cooling technique used.   Because
                                             of heat losses by radiation and conduc-
                                             tion, once-through cooling would evapo-
                                             rate less water  than a  cooling  pond,
                                             and both  would use  less than cooling
                                             towers.
    
                                                          Net Radiation
                                               Long-wave radiation From the water
                                             surface  is  another  heat  dissipation
                                             process.  The Brunt26 formula for  net
                                             heat loss for clear conditions at night is
    where  
    -------
      Church27 reports that the heat lost
    to the atmosphere during these turnover
    periods averages about 300 cal/cm2/day.
    Over the  entire area of the lake, this
    amounts to 1.74 X 10" cal/day.  Nu-
    clear plants with  7000-MWe capacity
    generate  1.05  X  1017 cal/year.  It
    would appear that the change  in the
    time of  overturning will be  of the order
    of one day, or  much less than the ob-
    served   variability,  about  one month.
    Church  measured daily heat losses to the
    atmosphere as large as 600 cal/cm2/day,
    or 3.5  X  10"  cal/day  over the entire
    lake.
      Church27 reports that the annual heat
    budget  of the  south  basin  of  Lake
    Michigan  is 52,000 cal/cm2.  That  is,
    this amount of energy is absorbed during
    the summer and returned to the atmo-
    sphere  the following winter.  If all  of
    the reactor heat were used in a similar
    manner, the extra annual heat exchange
    would be  (from 7000  MWe)  181 cal/
    cm2.  For comparison  on  an average
    daily basis,  the observed solar  energy
    received at the  Argonne site is 348 cal/
    cm2/day.  In  December,  the  month
    with the  least  insolation,  the average
    over 15  years is  135 units.
            Reactor Heat rs Sunshine
      Solar radiation  reaching the ground
    at noon  on  a  clear day  at Argonne
    averages  about  1.5  cal/cmVmin  in
    June, 0.7  units in December.  A 1000-
    MWe  reactor  generates  28.6  X  109
    cal/min  of  reject  heat.  This  cor-
    responds  to  noon  sunshine on  a 477-
    acre area in June, 1000 acres  in De-
    cember.  The  observed  plume  from
    1100-MWe coal plant on Lake Michigan
    covers  an area somewhat  less than a
    square  mile.  Thus, the heat generated
    by the  plant is  about equal to the solar
    load on the plume at noon in summer,
    doubling the thermal input to that body
    of water.
      A 1000-MWe reactor puts 28.6 X  109
    cal/min into the cooling  water,  7000
    MWe places 2  X 10n units.   The solar
    constant  is  2.00  cal/cm2/min.   Over
    an area equal to that of Lake Michigan,
    this amounts to 1.16 X  1015 cal/min.
    That is,  the reactor heat  load  on the
    lake is  only 0.02% of the solar constant
    on the same area.
      The  Argonne sunshine data show a
    value of  about 800 cal/cm2 on  a clear
    day in  June. 300 units on a clear day
    in  December.   Very  cloudy days   in
    June can receive as  little  as 80 units,
    and only 1  in December.  These  are
    record  single days in  a  15-yr  period.
    If all of the heat energy from 7000 MWe
    reactors operating  at capacity for a full
    year were  stored in  the water  and
    released during one day, the heat flux
     would be 181 cal/cm2/day.  This value
     is equivalent to a few extra hours of
     clear skies in summer, and is less than
     one additional clear day in winter, and
    is also small  compared to year-to-year
    variations in cloudiness in the area.
    
                  Snowfall
      It is assumed that all of the heat from
    a 1000-MWe reactor is used to evaporate
    water.  In one  day,  this amounts  to
    7.0  X 1010 grams.  If all of this water
    were  to fall  as  snow (density  =  0.1)
    over  a  10- X  30-km area,  the  snow
    depth from this water would be
    h =  -
             mass
        area X density
                       7.0 X 1010 g
                0.1 g/cm3 X 3 X 1012 cm2
    
    = 0.233 cm or 0.1 in.
    
      If all the reactor heat for a full year
    were converted  into snow  over a belt
    500 X 40 km, the snow depth would be
    and  cause the  plume  to  descend  to
    ground level; this has not been observed
    in England but may  occur in hilly
    terrain,   The  extra  heat  and water
    vapor does under proper meteorological
    conditions create cumulus clouds.  The
    possibility that the cooling tower plume
    somehow  triggers   an  existing  atmo-
    spheric  instability  and creates  extra
    cumulus congestus clouds and precipita-
    tion  miles  downwind  of  the  release
    point must be considered.  There are at
    least three reported occurrences of snow
    showers or ice crystals being generated
    by cooling towers.7'29'30
      Aynsley3 has  observed that cooling
    tower  plumes   can,  if  meteorological
    conditions  are proper,  create cumulus
    clouds.  He concludes  that  this  is  a
                  /, =  (7.0 X 1010g/GWe/day) (7 GWe)  (365 days/yr)
                                 (0.1 g/cm3) (2 X  1014cm2)
                    = 8.94 cm or 3.5 in.
    
      Average depths  in  the  snow belt of
    the State of  Michigan run from  40 to
    100 in./yr, with the  lower value near
    the site of the power plant now  under
    construction.28
      It should be remembered that lake-
    effect snows are the result of convection
    created by intense surface heating by
    the  relatively  warm  water.   It  is
    entirely possible that increases  in snow
    amounts could be considerably greater
    than  suggested by the above  calcula-
    tions  due to a greater release  of con-
    vective instability.
    Meteorological Effects of Cooling Towers
      Weather  changes  due to  cooling
    towers are more severe than those re-
    lated to  once-through cooling;  at least
    they  are more easily and frequently
    observed.   Towers   dissipate  large
    amounts of heat and  water vapor from
    small areas,  and  at the  same  rate as
    power is generated.
      In once-through cooling systems, the
    heat  releases to  the atmosphere may
    occur  over large  areas days or  weeks
    after  being generated and long after
    the thermal plume has disappeared.
      Most  reports dealing  with  the  me-
    teorological  consequences of  natural
    draft cooling towers state that they have
    the  "potential" to cause ground-level
    fog: observations  at towers indicated
    that they rarely if  ever do.2'3-6~9'21  The
    warm, moist plume  enters the  atmo-
    sphere at heights of 100 m or more, and
    evaporate, before reaching ground level.
       Cooling tower  vapor  releases could
    reach the ground  in hilly terrain areas.
    An inversion aloft plus  radiative  and
    evaporative cooling from  the top of the
     plume could create a negative buoyancy
    "rare occurrence," and that these man-
    made  clouds  only  precede  natural
    cloud  formation.  He  also  speculates
    that extra heat and water vapor could
    increase downwind rainfall.
      Photographs taken at cooling  tower
    sites frequently  show ground level fog
    completely  separate  from  the  rising
    plume from  the towers.3  The surface
    fog is caused by natural processes, such
    as nocturnal radiation; the rivers  and
    reservoirs used to supply makeup water
    to the towers aid in the formation of fog.
      In an unpublished report (date   June
    1968),  the   Central  Electricity   Gen-
    erating Board of Great Britain reported
    its  findings  on  the environmental ef-
    fects of cooling towers.  No measurable
    change in  relative humidity was de-
    tected downwind.  The visible plume
    sometimes  persisted  for  a  number of
    miles  downwind,  altering sunshine in
    the  area.   No  drizzle  was  observed
    from the towers.   They  reported  that
    cumulus clouds were  sometimes formed
    but that no cases of showers or precipita-
    tion being generated by the plumes have
    been observed.
      A small  part  of the cooling  water
    (estimated to be less  than 0.1% of the
    cooling water) is carried into the plume
    without  being   evaporated.   These
    droplets, called  drift,  will  contain
    whatever impurities are in the makeup
    water, and  release these  materials into
    the atmosphere when  they  evaporate.
    River water,  containing soil  erosion
    products, and sea water  are  common
    sources  of  this   water.  Some   clay
    materials are known to be good seeding
     agents.  The resulting particles  may
     July 1972   Volume 22, No. 7
                                                                                                                        527
    

    -------
    be effective nucleating agents, and thus
    could modify clouds and  precipitation
    over a large area.
      Many nuclear  plants  will  use me-
    chanical draft cooling towers.  These
    towers,  with their low level of release
    (20-30 m) and more rapid  entrainment,
    do cause ground-level fog.   The plumes
    mix  rapidly with  ambient air (due  to
    their small diameters, higher exit speeds,
    and greater internal turbulence) and are
    often caught in  the  building  wake.
    Also, the saturation deficit is  lower  at
    this height than for natural draft towers.
      Therefore, more attention must  be
    paid to site  selection to minimize fog
    over  highways if forced  draft towers
    are used.31
      The  Argonne  National  Laboratory
    has  several small wet cooling towers.
    On very cold, calm days, a  visible plume
    may extend upwards 100 m or so before '
    disappearing.  On cold,  windy  days,
    they  often  extend a similar  distance
    horizontally.  Last  winter, during  a
    near-record period (70 hr) of  sub-zero
    temperatures, the author was  not able
    to find  icing  on  any of the trees just
    downwind  of the Zero  Gradient Syn-
    chrotron cooling  tower, even though
    they had been in  the visible plume for
    over 24 hr.
      The most thorough review of the effects
    of cooling  towers on  local fogginess,
    and  cloud  and precipitation formation
    can  be found in  the recent paper  by
    Huff, et al.8  There are several  refer-
    ences  in the  literature  on   observed
    weather changes  due  to   wet cooling
                 APPENDIX
    
      The following data tor Lake Michigan
    were used :
    Area
                                  6.25 X
    Summary and Conclusions
    
       The amount of heat energy contained
    in  the cooling water  from  the large
    nuclear power stations is  quite small
    compared to the natural heat processes.
    Since the heat energy from  these plants
    with once-through cooling systems will
    enter the atmosphere over a large area,
    changes  in  weather  will be small and
    probably  impossible to isolate  in  the
    natural variability of weather elements.
    An exception  will  be  an  increase  of
    steam fog in fall and winter at the point
    of discharge.
       Alternate  cooling  systems, such  as
    cooling  towers,   cooling  ponds,  and
    spray  canals,  release  their energy  to
    the  atmosphere  rapidly over  a small
    area;  hence,  the  potential  for local
    weather changes  is  greatly  enhanced.
    Much care  should be  given to  cooling
    site location so that the fog and icing
    do not seriously restrict road traffic, etc.
       From a meteorologist's point  of view,
    once-through cooling on a large water
    body  is  to be  preferred  over either
    cooling towers or  cooling  ponds.   Be-
    cause  of the large  heat capacity of the
    lake, this heat rejection procedure  will
    not cause  any significant changes  in
    the weather and climate of the area.
                22,400 sq  mi
                  1012 sq ft
             =  5.80  X  104 km2 =  5.80
                  X  10" cm2
    Volume  =  1.64  X 1014 ft3 = 1.23 X
                  ]015gal = 1116 mi3
             =  4,652 km3 =  4.652  X
                  10lb cm3
                1.02  X  !016 Ib
      Mass    =
      Average
      depth
      Outflow
             =  4.65 X 1018 g
    
                276ft =  81.4m
                40 to 55  X 103 cfs (1133
                  to 1560 ms/sec) into
                  Lake Huron
                3.2 X  103 cfs into the
                  Mississippi  River
                  Basin (91 m3/sec)
    References
     1. Federal Power Commission, Chicago
       Office.  "Electric  Load  and Supply
       Pattern  in  the  Contiguous United
       States," September 1971.
     2. Great  Lakes  Fishery  Laboratory.
       "Physical and Ecological Effects  of
       Waste Heat on Lake Michigan," Bur.
       of Commercial Fisheries, Ann Arbor,
       1970.  101 pp.
     3. E.  Aynsley, "Cooling-Tower Effects:
       Studies Abound," Electrical World, 42-
       43  (May 11, 1970).
     4. J. Stockham, "Cooling Tower Study,"
       Final Report  for Contract No. CPA
       22-69-122, IITRI Report No. C6187-3,
       EPA Air Poll. Cont  Office,  Durham,
       North Carolina, 1971.  116pp.
     5. T.  J.  Overcamp  and 1). P.  Hoult,
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       Cold  Climates,"  Publ.  No.  70-7,
       Dept.  Mech.  Eng.,  M. I. T.,  Cam-
       bridge, Mass., 1970.   30 pp.
     6. F.  W. Decker,  "Report  on Cooling
       Towers  and  Weather,"   FWPCA,
       Corvallis, Oregon, 1969.  26 pp.
     7. W. C. Colbaugh, J. P. Blackwell, and
       J.  M.  Leavitt.  "Interim Report on
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       Behavior,"  T.V.A.   Muscle Shoals,
       Paper presented at  the  Amer. Inst.
       Chem. Engrs. Cooling Tower Sym-
       posium,  Houston, Texas (March  3,
       1971).
     8. F.  A.  Huff,  U.  C. Beebe, D. M.  A.
       Jones, G.  M.  Morgan,  and  R. G.
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       Effluents on Atmospheric Conditions
       in   Northeastern  Illinois/'   Illinois
       Stale  Water  Survey, Urbana, Giro.
       100, 1971.   37 pp.
     9. C. L. Hosier, "Wet Cooling Tower
       Plume Behavior," Paper presented at
       the Amer.  Inst. Chem.  Engineers
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       Texas (March 2, 1971).
    10. S.  R. Hanna  and   S.  D.  Swisher,
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        DNH 01/71, 1970.  76 pp.
    12. T. D. Kolfjat,''Thermal Discharges—
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        April 20-22, 1971.
     13. P. M. Altomore, "The Application of
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        Heat  Dissipation  Systems,"  Paper
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     14. W. C.  Ackermann, "Research Needs
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     15. G. T.  Csanady, "Waste  Heat Dis-
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     17. Ayers,  J.  C., "Remarks on Thermal
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     19. J. P. Longtin, "Temperature Increase
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        Discharges  from  Electrical   Power
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     22. F. W. Decker, "Background Study for
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     23. G. K.  Rodgers, "The Thermal Bar in
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        the  atmosphere  by  cooling   towers
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        Meteor. Soc., 51: 21 (1970).
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     27. P.  E,  Church,  "Convection  in the
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        role  in  Michigan,"   Bull.   Amer.
        Meteorol. Soc., 51: 403 (1970).
     29. W. M. Culkowski,  "An  anomalous
        snow  at   Oak  Ridge,  Tennessee,"
        Monthly  Weather  Review, 90:  194
        (1962).
     30. Federal Water  Quality  Administra-
        tion.    "Feasibility  of   Alternative
        Means of  Cooling for Thermal Power
        Plants  near Lake  Michigan."  Pre-
        pared by National Thermal Pollution
        Research Program, Pacific Northwest
        Water Laboratory and Great Lakes
        Regional Office, U. S. Department of
        Interior, 1970.  114pp.
    ' 31. W. A.  Hall, "Elimination of  cooling
        tower  fog from a highway,"  J. Air
        Foil. Contr. Assoc.,  12: 379 (1962)
     32. A. Blum,  "Drizzle precipitation from
        water  cooling towers," EnyiW'i'f, 186,
         128 (1948).
     528
                                         Journal of the Air Pollution Control Association
    

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     SHOULD THERMAL DISCHARGE INTO LAKE MICHIGAN
    
    
    
    
                    BE ALLOWED?
                        BY
    
    
    
    
                  ARTHUR PANCOE
    
    
    
              SCIENTIFIC DIRECTOR OP:
    
    
    
     SOCIETY AGAINST VIOLENCE TO THE ENVIRONMENT
    FOR PRESENTATION BEFORE THE RECONVENING OF THE
    
    
    
    
    LAKE MICHIGAN ENFORCEMENT CONFERENCE ON SEPTEMBER
    
    
    
    
    19TH, 1972 IN CHICAGO, ILLINOIS.
    

    -------
         I am appearing before this Board to tell you why I  believe it
    
    
    
    
    is inadvisable to allow thermal infusion into Lake Michigan from
    
    
    
    
    electric generating plants.  At this time I  will bring before this
    
    
    
    
    Board five major dangers, amongst others, that have not  at any time
    
    
    
    
    in previous testimony been accounted for satisfactorily.
    
    
    
    
         One:  The first peril I wish to emphasize is the inability of
    
    
    
    
    plankton to withstand the rapid temperature  rise across  the condenser.
    
    
    
    
    In Dr. Donald W. Pritchard's paper of September, 1970 before the Lake
    
    
    
    
    Michigan Enforcement Conference, supporting  the use of Lake Michigan
    
    
    
    
    for cooling water used in generation of power, he discusses in detail
    
    
    
    
    various aspects of the problem, with the ultimate conclusion that
    
    
    
    
    presently proposed plants will have no measurable effect on the overall
    
    
    
    
    Lake temperature.  In this I concur.  But the subject Dr.  Pritchard
    
    
    
    
    deals with in most detail is how to discharge the cooling water in a
    
    
    
    
    way which will allow the most rapid dilution of the thermal plume.  Why
    
    
    
    
    is this the major concern of his presentation?  I suggest the answer may
    
    
    
    
    be found on the bottom of Page 20 of Dr. Pritchard's report.
    
    
    
    
         "For example, in the case of the Zion Power Station,  the time of
    
    
    
    
    transit of the condenser cooling water from  the condensers to the point
    
    
    
    
    of discharge will be approximately two minutes.  In order to minimize
    
    
    
    
    any possible biological effects of using the surface waters of Lake
    

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                                     - 2 -
    Michigan for cooling, the condenser cooling water flow system should
    
    
    
    
    be designed to minimize the time of transit of the heated  effluent
    
    
    
    
    from the condensers to the point of discharge."  Note:   Dr.  Pritchard
    
    
    
    
    even though a proponent of using the Lake for  once through cooling
    
    
    
    
    purpose, and a Commonwealth Edison witness at  the last Conference,
    
    
    
    
    uses the words "minimize any possible biological  effects."  This
    
    
    
    
    means there is a problem here,  and at the very basic  level of the
    
    
    
    
    food chain.  Since only 10% of  the energy radiated to the  Lake is
    
    
    
    
    available to man and is manifest at this microscopic  level of the
    
    
    
    
    food chain, as we move up the food chain, each level  is at most 10%
    
    
    
    
    efficient.  We can readily see  that we are taking a risk at  the most
    
    
    
    
    basic level of life, and the dangers, if we are wrong, are not in-
    
    
    
    
    significant.
    
    
    
    
         On March 21, 1971, during  the reconvening of The Lake Michigan
    
    
    
    
    Enforcement Conference, I received a call from Dr. Thomas  Roos, the
    
    
    
    
    Biologist of Dartmouth College, who expressed  deep concern over the use
    
    
    
    
    of Lake Michigan water for once through cooling.   He  said  that the sud-
    
    
    
    
    den rise of 20° F. across the condenser, in his opinion, will kill most,
    
    
    
    
    if not all, the Phyto and zoo plankton.  He stated that the  two minutes
    
    
    
    
    of anticipated time that this plankton is exposed to  the extremely warm
    
    
    
    
    water may not seem much in the  life of an individual, but  must be cor-
    
    
    
    
    related to the one and a half or two day life  span of the  form of life
    

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                                      - 3 -
    in question.
    
    
    
    
         He reiterated the danger to the entire Lake's life if harm comes
    
    
    
    
    to this primary level of the Lake's food chain.  For further amplification
    
    
    
    
    of this and other concerns of Dr. Ross see letter attached (3)
    
    
    
    
         I might point out that Professor Roos formerly lived on the North
    
    
    
    
    Shore and has an overall familiarity with the Lake.
    
    
    
    
         In their detailed article on waste heat in "Technology Review"
    
    
    
    
    December, 1971, Professor Donald Harleman and Professor Ralph Parsons
    
    
    
    
    of M. I. T. Laboratory for Water Resources dealt with this problem with
    
    
    
    
    the following statement: "Smaller organisms such as zooplanton pass
    
    
    
    
    through the intake - condenser - discharge system.  The effect of their
    
    
    
    
    passage depend upon both temperature rise and the time of exposure.  Water
    
    
    
    
    temperature increases which approach the sub-lethal range of impaired bio-
    
    
    
    
    logical activity should be avoided.  Most states therefor limit both maxi-
    
    
    
    
    mum temperatures and allowable temperature rises, from l^g to 5°F."
    
    
    
    
         It should be noted here that it is estimated that all inshore water
    
    
    
    
    will flow through, on the average, one of those plants three times per
    
    
    
    
    year.  To the extent that the Palisades and Bailly Station Plants are
    
    
    
    
    intending to use cooling towers, the magnitude of this problem may be
    
    
    
    
    reduced.  It is recognized that the inshore water is biologically the
    
    
    
    
    most productive portion of the Lake, and the biota being drawn through
    
    
    
    
    these plants is the base upon which all fishes, and to some extent fowl,
    

    -------
    depend upon for life.
    
    
         Two:  According to Dr. P.  F.  Gustafson of Argonne  National
    
    
    Laboratory in a paper also presented before The Lake  Michigan Enforce-
    
    
    ment Conference, little, if any,environmental  changes can  be  detected
    
    
    about the discharge areas from- existing fossil plants operating about
              (2)
    the Lake.      But he goes on to  say "but  secondary,  more  subtle,  ef-
    
    
    fects at some distance from the point of input may take place." But
    
    
    can it be denied that there is  an ideal optimum temperature for the
    
    
    growth of blue-green algae, and such an ideal  environment  will be
    
    
    created artificially and rather permanently in a boundary  area about
    
    
    the mixing zone?
    
    
         This algae has some species  which multiply most  profusely at  95°F.
                                                                    (2)
    
    and other species that prefer temperature  in the range  of  86° F.
    
    
    This algae is already found in abundance at the Southern end  of Lake
    
    
    Michigan.  It is very adaptable and will even  grow well within the
    
    
    plants'  cooling systems where the water is at  its highest  temperature.
    
    
         Three:   Mr. George E. McVehil on behalf of Commonwealth  Edison
    
    
    Company testified before the Illinois Pollution Control Board on Novem-
    
    
    ber 7, 1970 that if cooling towers were installed at  Zion, fog condi-
    
    
    tions would exist in the Zion area, as the result, various number  of
    
    
    days per year, depending upon the type of  towers installed.
    
    
         I concur in this  prediction,  but I believe he failed  to  mention
    

    -------
                                       - 5 -
    that similar fogging conditions may very well occur over the Lake in
    
    the area of discharge.  That is, a large amount of the heat loss from
    
    the area of thermal plume will be due to increased surface evaporation,
    
    as a result of increased heat.  You will note in Dr. Pritchard's testi-
                           (1)
    mony mentioned earlier     he specifies that approximately 15% of the
    
    heat lost from the Lake is due to evaporation.  While he was discussing
    
    this figure in a different context, its application to my point is
    
    obvious.  Also, Dr. Gustafson mentions this problem in a very peripheral
                       (2)
    way in his report.
    
         Heat is dissipated from water surface by evaporation, radiation
    
    and conduction, and the percentage of the total heat dissipation by
    
    evaporation increases as the temperature of the water surface increases
    
    above its natural state.  For a water surface at 5° F. above equilibrium,
    
    the heat lost by evaporation is about one-third of total.  Naturally,
    
    in winter the percent of heat lost by evaporation will be radically
    
    higher than this figure.
    
         Should the fogging over the Lake be less intense than above towers,
    
    but cover more area, the total effect on the environment of say, Zion,
    
    might be more extreme than in the case of towers.
    
         Four:  In lakes and ponds (lentic environments) the biota is
    
    synchronized in its life cycles by changes in water temperatures.  If
    
    man in a major way distorts this very finally turned gradual and seq-
    

    -------
                                       - 6 -
    uential mechanism of the inshore waters  in the  spring  of the year,  the
    
    consequence may be far more dramatic than we can even  envision.   For
    
    a detailed description of this possible  danger, I refer  you to a  pre-
    
    vious paper I presented before The Lake  Michigan Enforcement Conference,
    
    September, 1970, with special reference  to a paper attached to that
    
    report, by J. J. Resia of the Department of Biological Sciences,
                             CO
    Northwestern University,
    
         Five:  The last point I wish to bring up is what  I  believe to  be
    
    an erroneous idea that now, or in the future, will it  be possible to
    
    isolate, for example, heat alone, as a specific contributor to the
    
    death of Lake Michigan.
    
         Synergism:  The detrimental effects of heat, chemical fertilizers,
    
    chemical pollutants, sewage, bacteria, and solid wastes  being discharged
    
    into the Lake may very well in combination be far more disastrous to the
    
    Lake than the study of any one of the perils alone might suggest.
    
         If damage does occur from the heat, it will be subtle at first and
    
    may not make itself manifest for years or even  decades into the future.
    
    Damage will be accumulative, as Lake Michigan does not have a rapid
    
    changeover of water. I also suggest that at no  time will it be provable
    
    that heat alone is responsible for the damage.
    
         In a statement to me on March 21, 1971 Professor  Arthur D. Hasler,
    
    of the University of Wisconsin, one of the world's outstanding  lim-
    

    -------
                                       - 7 -
    nologisis, expressed deep concern over the direction we are going
    
    with regard to disposing large amounts of heat into the Lake.   He
    
    stated to me that he would much prefer to see this heat disposed of
    
    into the atmosphere at this time.
    
         I would like to conclude by requesting that this  Board adapt a
    
    standard allowing no thermal discharge into Lake Michigan from new
    
    electric generating plants, either under construction  now, or  planned
    
    for the future, since alternative means of distribution of the heat
    
    are available.
                                               Arthur Pancoe
                                               Scientific Director
    Reference (1)  Title:  Statement on Temperature Standards  for Lake
    Michigan by Dr. Donald W. Prirchard, September, 1970 before The Lake
    Michigan Enforcement Conference.
    
    Reference (2)  Title:  Thermal Discharges and Lake Michigan by
    Dr. P. F. Gustafson, September, 1970, also before The Lake Michigan
    Enforcement Conference.
    

    -------
                 Dartmouth College HANOVER. • NEW HAMPSHIP^  01755
    
                 Department of Biological Sciences • tat. (603) 646-3378
    
                                                 22 March 1971
    Reconvened Third Session of Lake Michigan Enforcement Conference
    c/o Mr,  Arthur Pancoe
    1030 South Waboph Avanuw
    Chicago,  Illinois 60605
    
    Gentlemen:
    
    The proposed  use of  Lake Michigan on-shore  surface  water  as  a coolant for
    power-generating nuclear reactors poses  a potential threat  to the lake
    for at least  two reasons:  damage to  surface plankton and long-term thermal
    disturbance.
    
    Constant cycling1 -of  virtually  all on-shore  surface  waters through the
    reactors will expose sensitive planktonic organisms, both plant and animal,
    to a profound thermal  shock.   Although their duration at  elc-.  .  •! temper-
    atures will be short in terms  of a  human life,  even two to  fi\ u minutes is
    long in the life of  a  single-cell organism.  The  process  of cell division,
    necessary for cell continuity  requires only five  to thirty  minutes, depen*.
    ding on the species.  Planktonic organisms  have evolved in  a relatively
    stable environment,  in which temperature changes  arc slow or absent.
    Indeed,  many  minute  plants and animals use  small  (less  than two degree)
    fluctuations  in temperature as signals for  developmental  change.   Bri^f
    exposure to elevated temperatures is  sufficiently likely  to produce change
    in organism physiology and maturation to warrant  a detailed study of the^
    effects of temperature on all  of the  organisms  involved in  the specific
    waters to be  affected. I know of no  such detailed study  on Lake Michigan
    plankton, but one whould be done before  risking major,  permanent damage.
    It should be  emphasized that the surface algae  are the  sole base of the
    food chain on which  all lake animal life depends:  a reduction in available
    fixed carbon  (i. e.  starch and cellulose)  will propagate proportionally
    through the entire ecological  pyramid.
    
    Thermal pollution itself poses a special problem  for the  Lake Michigan
    basin.  The V-shaped profile of the lake favors a high  thermocline, with
    a shallow layer of warm water  overlying  a deep  mass of  cold water:  mixing
    between these two water masses is  slow.   Complete turnover requires 10,000
    years in Lake Michigan.  Calculations of heat dissipation must take into ac-
    count only this  limited mass of available diluent water,  and not the entire
    water volume.  It is even possible  that  adding  to the heat of the surface
    layer will slow doen water  turnover,  intensify  thermal  stratification, and
    spedd the process of deoxygenation of the lake  bottom.
    
    I hope that this  letter  expresses  the tiasis of  my concern as a biologist
    for the planned use  of Lake Michigan.  The potential damage is great and
    irreversible.  I doubt that adequate information is available to prove that
    the changes will be  benign:   such  changes ought not be  made until their
    safety is ascertained.
                                        Thomas D. RODS, Associate
    

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      ..f  r.
            SOCIETY
    
    C.M:.'5T VIOLENCE
                                   6* t.-
              DOX 81
    
    CO:, ILUM6I5 6QP33
    
         iM-riiiC Comm:' •
    
     f- ;.,;.•; V.'ILK CI .'< .
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       .'.'!; HOWARD SWCIG
              831-1177
       A'.'; i:f KNARD VERIN
              132-6680
         "One thing which definitely is nat n&Pripd in DIP feyr^pnt debates
    over effects of waste  heat from nuclear power plants on Lake
    Michigan is another biologist who takes the position of an advocate.
    I therefore  must preface my following remarks with a brief bit-
    of philosophy.
         With few significant exceptions,  predictions of resultant harm
    to the Lake's biota are honestly debatable.  When  specialists in
    pertinent fields disagree, the issues become quite clouded and
    confusing to the public.   The clouds part a bit,  though,  if the
    layman keeps two things in mind.
         First,  the empirical, inductive method to which modern
    science is wedded never "proves" or disproves" anything.  No
    matter how dogmatically some scientific "truths"  often are taught,
    it must be remembered that  at the philosophical foundation of
    scientific method is a rule which says that the most an investigator
    can  hope to accomplish  by his experimental results and interpre-
    tations is to cause on'e hypothesis or another to seem more or less
    likely to be true.  Hence, competent scientists, honestly attempting
    Lto be objective, can and often do disagree.
         This brings us to the second point.   The current environmental
    quality crusades in general and the nuclear power plant controver-
    sies in particular have seen  too many scientists showing too little
    regard for objectivity.  Abuses of this nature seem to come from
    both sides of almost every confrontation.  It can be maddening
    for a scientist to try to  refute a less idealistic  oponent's "absolute
    certainties" with wishy-washy "it appears thats" and "the  data
    suggest thats. " Nevertheless, scientists and engineers who my-
    opically  pander either to their employers' vested interests on the
    one  hand or to crowd  response on the other do service to no one
    and, I fear,  are going to learn that in the long run,  their credibility
    and  that  of their profession is as fragile as it is valuable.
         Granted the above,  I  would like to describe a  problem  which I
    feel has  not yet been given any real attention by those about to decid
    what can and can not be done with waste heat in Lake Michigan.
         In the temperate  latitudes in which  we live, organisms are
    forced to adjust their life cycles to the rigors of changing  seasons.
    Mother Nature has been very fussy about  compliance, and those
    species which  failed to synchronize became evolutionary drop-outs.
    One  well-known environmental cue that  is widely used by plants
    and animals as & season-indicator is photoperiod, the changing
    length of the day.  Thus, many birds,~Tor~exampTe, are "told"
    when their gonads should ripen,  when they should  mate, and when t!
    should fallen up and migrate by the lengthening or shortening day-
    light hours,
         For terrestrial organisms,  as well as for  those which are
    found in rivers and streams  (lotic environments),  photoperiod
    

    -------
          SOCIETY
    
    ,v.;:~r VIOLENCE
         I»K*1  O'.y.
      C,\Vi;10N.V.ENT
    
            COX 84
    
    C;. ILLINOIS C007.2
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            -133-3638
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            E31-1177
      vs. niRNARD VERIN
            132-6680
                                                        PAGE 2
    
    is a cue far more trustworthy than temperature.  For the biota  of
    lakes and ponds (lentic environments), however, seasonal temper-
    ature changes usually are pretty consistent (especially in large
    lakes),  and it is well-known that for many lentic species (notably,
    fishes), water temperature plays the principal role in seasonal
    synchronization.
         Since the effects of thermal discharges, present and  proposed,
    on the overall  temperatures of Lake Michigan can be considered
    insignificant (which,  possibly, is why Commonwealth Edison
    spokesmen have mentioned them so often),  and since the plumes
    of heated water will be small in relation to total Lake area,  it is
    not immediately evident that a significant proportion of any popu-
    lation in the Lake could be affected adversely.
         There is more to the story, however.  In the first place, the
    littoral  (nearshore) areas of any large body of water are by'far
    "the most biologically important.  In these littoral areas,  Nature
    provides light and nutrients in relative abundance, and productivity
    is high.  Since populations always produce more offspring than
    the environment can support, and  since the principal limiting
    factor in the survival of offspring  of most aquatic animals is
    food availability,  natural selection Has "taught" the great majority
    of species to reproduce in littoral waters.  Thus, these near-
    shore areas, into which the nuclear plant effluents are to be
    directed,  see a lot more biological traffic than comparable off-
    shore areas.  Included in this relatively congested situation  are
    those fishes which are spawning, those which have been spawned,
    and those predators desirous of eating spawner or spawnee.
         We understand, then, that biomass is relatively large in the
    general vicinity of the proposed heated effluents^But the story
    goes  further.   Most animals have  preferred temperatures.   This
    means that their activity is less at one temperature than at any
    other.  In fishes,  for example, an individual's preferred  tempera-
    ture depends on such factors as species,  previous thermal history,
    a6e»  physiological state, time of day and year, and many other things
    known and unknown, but it may be generalized that, if a group of
    similar fish are placed in a thermal gradient,  they will tend to
    congregate at their preferred temperature in a sore of "gapers'
    block" effeqt.
         I have heard the advocates of  "thermal enrichment" speak
    enthusiastically of fishing "hot spots" produced by power  plant
    discharges.  Such phenomena are  produced when ambient water
    temperatures are below the preferred temperature of fish in the
    general vicinity of a heated plume.  When the fish congregate at
    their preferred temperature in the gradient caused by the plume,
    a fisherman's bonanza results.
         But there may be a catch to this.  I have already discussed
    why fishes tend to be in the general vicinity of the  thermal plumes,
    and how they can  tend to move to positions  in the plumes  where
    temperatures are above ambient.  Such situations already exist
    

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           SOCIETY
    
    ;/.::;cr VIOLENCE
    
            TO THE
             COX 84
    
    
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                                                      PAGE_3
    
    on small scale in Lake Michigan.   But if to these considerations
    we add the proposals for a growing number of large  discharges
    from nuclear plants, we must conclude that greater  percentages
    of the Lake's fish populations would be spending greater amounts
    of time at temperatures above ambient.
         Besides having other, more well-known,  physiological effects,
    water temperature (as mentioned previously) is the  principal
    seasonal timer for many species of fish.  In effect,  prr ._* . .isive
    changes in the ambient temperature of the Lake "tell" a lish
    when to begin and complete gonadal development, when to feed,when
    to migrate, and when to spawn.  Thus, each species of fish is
    influenced to perform some or all of these activities at a time of
    the year most advantageous for- survival  of the population.  It
    must be noted that the physical characteristics of the season ai-e
    not the only reasons why timing is  important.   Spawning, for ex-
    ample, must be performed simultaneously by  the greatest possible
    proportion of the population, for maximum efficiency, and the lar-
    vae must latch in synchrony with the often ephemeral availability
    of important food species (which also are influenced by tempera-
    ture).
         Add to all o'f these considerations the complex,  seasonally-
    variable food-web interactions in the Lake,  and one  begins to
    understand the validity of questions raised about fishes spending
    time  in the proposed "hot spots" rather than in waters of ambient
    temperatures.  The temperature a fish "likes" bears no necessary
    resemblance to the  temperature that is good for survival of its
    population.
         I have heard attempts by some to defend calefaction on the
    grounds that elevated temperatures have no adverse effects on
    certain aquatic animals from arctic or tropical latitudes.  I have
    also heard it mentioned that in certain fish culture practices,
    people spend money to heat ponds to increase yield. In answer
    to the latter,  it should be noted  that such people also have to feed
    the fish in those  cultures.  Cultures  are  not ecosystems.  Arid in
    answer to both, we need only keep  in mind that we are concerned
    with temperate latitude fishes trying to stay alive and obtain food
    in a  temperate latitude lake.
         Finally, I wish that discussions  of ecological effects of waste
    heat could rise above naive considerations of what is lethal to
    adult fishes.  There's more than one way to skin a population,
    and knocking out reproduction sounds to me as though it might be
    fairly effective. "
                                                         J. J. Resia
                                                         Department of Biological Sciences
                                                         Northwestern University
    

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                                                                  399
    
     1                          P. Gustafson
     2             MR. CURRIE:  Dr. Gustafson.
     3
     4              STATEMENT OF DR. PHILIP F. GUSTAFSON,
     5          ASSOCIATE DIRECTOR, DIVISION OF RADIOLOGICAL
     6                   AND ENVIRONMENTAL  RESEARCH,
     7                  ARGONNE NATIONAL LABORATORY,
                             ARGONNE, ILLINOIS
     9
    10             DR. GUSTAFSON:  Mr. Chairman, conferees, and
    11   remaining participants.  I am Philip F. Gustafson, Argonne
    12   National Laboratory, Associate Director of the Division of
    13   Radiological and Environmental Research at the Laboratory,
         and coordinator of our Great Lakes Research Program,
                   As I think most everything that I have to say has
         been said already, but what I am going to say is fairly
         brief anyway, and having stuck it out this long, I am going
    lg   to go ahead.  (Laughter)
                   As you all know, in its past several sessions, the
    20   Lake Michigan Enforcement Conference has dealt with the
    2i   problem of setting thermal effluent standards which will
    22   maintain the ecology of Lake Michigan in its present or,
    23   hopefully, even in an improved state, and yet allow the lake
    24   to be used for a multiplicity of purposes which are of
         benefit to mankind*
    

    -------
       	900
    
    
    
    
     ,                            P. Gustafson
    
    
    
     2             The principal obstacle to reaching agreement on
    
    
    
     o   thermal standards has been the question of what biological
    
    
    
     •    effects will occur as a result of large electrical generat-
    
    
    
     5   ing stations, particularly nuclear stations, using once-
    
    
    
     5   through cooling on the lake.  There is some feeling that
    
    
    
     7   until this question can be answered completely, no further
    
    
    
     #   discharges should be permitted.  Paradoxically, the answer
    
    
    
     9   can only be obtained by field studies in the lake, not by
    
    
    
    10   laboratory studies or computer simulations.
    
    
    
    11             For the past 3 years, Argonne National Laboratory
    
    
    
    12   has been conducting physical and biological research on
    
    
    
    13   thermal discharges into Lake Michigan under its Great Lakes
    
    
    
    14   Research Program,  These thermal studies have  centered about
    
    
    
    15   some of the large fossil~fueled stations, and  have included
    
    
    
    16   the three nuclear plants now in operation on the lake.  We
    
    
    
    17   have also examined the results of other researchers on Lake
    
    
    
    18   Michigan and the other Great Lakes as part of  our total
    
    
    
    19   program.  The conclusion that we have come to, on the basis
    
    
    
    20 I  of our own work and that of others, is that there is no
    
    
    
    21   evidence of unacceptable  ecological effects due to present
    
    
    
    22   thermal discharges, even on a local scale.
    
    
    
    23             This does not mean that there are not biological
    
    
    
         responses directly attributable to the warm water —
    
    
    
         attraction of fish to the  thermal plume, for example.   It
    

    -------
                                                                  901
     •j_                           P. Gustafson
     2   does not mean that fish acclimated to the higher than
    
    
    
     •3   ambient temperatures in the thermal plume may not be injured
    
    
    
     4   or killed by a sudden shutdown of the plant,  particularly
    
    
    
     5   in cold weather*  It also does not mean that  a substantial
    
    
    
     6   amount of entrained biota passing through the cooling system
    
    
    
     7   will not be damaged or killed; however, increased productivity
    
    
    
     8   due to increased temperature partially replaces this loss.
    
    
    
     9             What our conclusion does mean is that the total
    
    
    
    10   impact of these various factors will not produce changes
    
    
    
    11   which are irreversible or irreparable in the physical and
    
    
    
    12   biological state of those portions of Lake Michigan now
    
    
    
    13   subject to thermal discharges.  Since the local impact is
    
    
    
    14   tolerable, the lakewide or system impact is also acceptable.
    
    
    
    15   Furthermore, on the basis of present knowledge we believe
    
    
    
    16   that the operation of powerplants now under construction on
    
    
    
    17   the shores of Lake Michigan will also have an acceptable
    
    
    
    1#   impact on the local or system ecology if operated with
    
    
    
    19   once-through cooling.
    
    
    
    20             i think that there is, by and large, general
    
    
    
    21   agreement on the part of the participants in  the Enforcement
    
    
    
    22   Conference that the real concern is not the present thermal
    
    
    
         additions to Lake Michigan, or  even the incremental addition
    
    
    
         of the generating facilities now under construction; rather
    
    
    
         it is the prospect of addition  upon addition  which the
    

    -------
                                                        	902
    
    
                                 P. Gustafson
    
    
         future may bring with our present rate of regional growth
    
    
         and power needs.  In order to answer this concern before it
    
    
         becomes a reality, we must determine the present state of the
    
    
         lake in general and understandable terms, determine the
    
    
         long-term, long-range effect of present and soon-to-operate
    
    
         thermal discharges, and to then determine at what point the
    
    
         long-range effects have an unacceptable influence on the
    
    
     9   entire lake or a significant portion thereof.
    
    
    10             Considerable research is under way on Lake Michigan
    
    
    11   to provide data which can answer these questions.  Some of
    
    
    12   it is supported by Federal agencies such as AEC and EPA,
    
    
    13   some by State agencies, and an increasing amount by utility
    
    
    14   companies.
    
    
    15             Certainly the greatest return on the money being
    
    
    16   spent on research will be attained if these efforts are
    
    
    17   coordinated— coordinated in the sense that standardized
    
    
    18   techniques in sampling and data acquisition are employed,
       I
    
    19   and standard analytical methods used so that results from
    
    
    20   one group to another or one site to another will be com-
    
    
    21   patible.
       ;
    
    22             Such coordination could be done through an Envir-
    
    
    23   onmental Assessment Committee — call it what you will ~
    
    
    24   such as was proposed by the Technical Committee at a pre-
       I
    
    25 !  vious session of the Enforcement Conference*  I would like
    

    -------
                                                                  903
    
    
    
    
                                 P. Gustafson
    
    
    
         to propose that the Enforcement Conference consider sponsor-
    
    
    
         ing such a committee.  The logical members of such a group
    
    
    
         are already active participants in the conference.  The
    
    
    
     5   committee should include representatives from involved
    
    
    
     6   Federal and State agencies, the academic community, industry
    
    
    
     7   — particularly the electric utilities — environmental
    
    
    
         groups, and I would hope that Argonne might also be a par-
    
    
    
     9   ticipant.
    
    
    
    10             In addition to the coordinating role,  the committee
    
    
    
    11   could review and interpret results, suggest new avenues of
    
    
    
    12   investigation, and even engage in the development and test-
    
    
    
    13   ing of a systems model of the entire lake.  Perhaps a start-
    
    
    
    14   ing point for the latter would be the preparation of a
    
    
    
    15   Regional Environmental Impact Statement, which would be
    
    
    
    16   essentially the type of impact statements that are being
    
    
    
    17   prepared under the National Environmental Policy Act for
    
    
    
         nuclear powerplants.  Such a NEPA-type statement for the
    
    
    
    19   entire lake would involve the combined effects of man's
    
    
    
    20   activities upon the lake.  This would be a most useful
    
    
    
    21   document with which to assess future courses of action not
    
    
    
    22   only in thermal but in terms of chemical pollutants as
    
    
    
    23   well.  Working cooperatively, I think we can accomplish much
    
    
    
         more than we can ever hope to do independently.
    
    
    
    25             Lake Michigan is a valuable multiple use resource
    

    -------
                                                                  904
    
    
    
    
                                 P. Gustafson
    
    
    
     2   which with wise management can provide perhaps even more
    
    
    
     3   benefit to future generations.  If we use our talents
    
    
    
         properly, we can develop and conduct a regional study which
    
    
    
     5   will serve as a demonstration to other areas of our Nation,
    
    
    
     6             MR. BRISON:  I have to ask one question,
    
    
    
     7             DR. GUSTAFSON:  Yes*
    
    
    
                   MR. BRYSON:  Some time ago, didn't Argonne under-
    
    
    
     9   take to form such a group in cooperation with the various
    
    
    
    10   studies going on around the lake involving the various
    
    
    
    11   utility companies?  Whatever happened to that effort?
    
    
    
    12             DR. GUSTAFSON:  Well, we still work cooperatively
    
    
    
    13   with a number of utilities and with EPA and with the univer-
    
    
    
    14   sity people.  But it is — well, I would say this:  that
    
    
    
    15   cooperation, coordination — particularly coordination —
    
    
    
    16   is a  fulltime job.  And I find that more and more as our own
    
    
    
    17   work goes on we tend to lose track on a day-to-day basis,
    
    
    
         which is really, I think, very essential — we lose this as
    
    
    
    19   we get further into our own work.  And what we sort of need
    
    
    
    20   is an overseeing body that will do the coordinating more
    
    
    
    21   tightly than we can,
    
    
    
    22             MR. BRYSON:  Good point,
    
    
    
                   DR. GUSTAFSONi  But I think we have — and I am
    
    
    
         very pleased to see the use made of — data which Argonne
    
    
    
         has acquired, and the degree to which we have, I think, in
    

    -------
          	905
    
    
    
    
     -j_                           P. Gustafson
    
    
    
    
     2   a relatively short time, become reasonably proficient in
    
    
    
     3   some of these things.     I would hope that we could continue
    
    
    
     4   to do this and we have tried to — with our still fairly
    
    
    
     5   limited resources, when we know that somebody is going to
    
    
    
     6   do an experiment somewhere — throw our resources in, too,
    
    
    
     7   with the feeling, and I think the correct feeling, that we
    
    
    
     $   get a lot more out of it the more parameters, the more people
    
    
    
     9   that are looking at something,
    
    
    
    10             But I would hope that this could grow and perhaps
    
    
    
    11   this conference is a means of promoting such growth.  I know
    
    
    
    12   we all have this feeling that t  what is the future going to
    
    
    
    13   bring?  And how are we going to assess — well, I have used
    
    
    
    14   the term — "acceptable" damage or "unacceptable" damage,
    
    
    
    15   because I have gotten so tired of trying to defend what is
    
    
    
    16   "significant" and what is "insignificant,"
    
    
    
    17             So this is sort of pushing it on a stage further,
    
    
    
    l£   i realize, but that is something we have got to determine,
    
    
    
    19   Is it a powerplant or is it one fish or what is it?  And I
    
    
    
    20   think that this is — as has been said before — partly a
    
    
    
    21   social problem; it's partly a technical problem.  And it is
    
    
    
    22   something that I think can be ironed out, but we have got
    
    
    
    23   to do it some way.  It is sort of late for philosophy, I
    
    
    
    2A-   guess,  (Laughter)
    
    
    
    2 5             MR. FRANCOS:  Dr. Gustafson.
    

    -------
                                              	906
    
     -^                           P» Gustafson
     2             DR. GUSTAFSON:  Yes.
     •2             MR. FRANCOS:  It is late for a couple of questions.
     •    But is  it correct that it was your group that prepared the
     5   report  that appeared in the EPA document that was distributed
     5   prior to the convening of this session?
     7             DR. GUSTAFSON:  Yes, it was some of the people
     #   from Argonne, right.
     9             MR. FRANCOS:  Were you associated with that, or
    10   was it  done under your direction?
    11             DR. GUSTAFSON:  It was actually done under Bart
    12   Hogan's direction, and I looked over the document as it was
    13   being prepared but did not have a truly active role in its
    14   preparation.
    15             MR. FRANCOS:  Is this statement that you are making
    16   here this evening in any way an official position of the
    17   Argonne National Laboratory?
    13             DR. GUSTAFSON:  Essentially it is the position of
    19   the people at the Laboratory engaged in Great Lakes research.
    20             MR. FRANGOS:  Thank you.
    21             MR. MAYO:  Is that the conclusion of the Illinois
    2? !
    f-f-   presentation, Mr. Currie?
                   MR. CURRIE:  Yes.
                   MR. MAYO:  Mr. Frangos.
    25            MR. FRANGOS:   Thank you, Mr. Chairman,  conferees,
    

    -------
                                                                  907
                                 E. James
         and holdoutSo   (Laughter)
                   Unaccustomed as I am to making presentations at
         11:15 p.m. in the evening, I do want to make a standing
         request, Mr. Mayo, for the record, that in any future con-
     5   ferences, symposia, meetings, colloquia, or hearings that
     y   may be conducted or sponsored by your Agency, that the order
         of appearance of States be determined by lottery conveyance,
     9   (Laughter and applause)
    10             Having said that, I will defer attempting to sum-
    11   inarize the State of Wisconsin's statement but rather proceed
    12   with those who have indicated that they wish to make a
    13   statement, and then I will get back to the Wisconsin state-
    14   raent,
    15             With that, I would like to call upon a representa-
    16   tive of the Wisconsin Public Service Corporation.
    17
               STATEMENT OF EVANS W. JAMES, SENIOR VICE PRESIDENT,
    19               WISCONSIN PUBLIC SERVICE CORPORATION,
    20                        GREEN BAY,  WISCONSIN
    21                   (AS READ BY CHARLES J. MARNELL)
    22
    23 .            MR. MARNELLs  Mr. Chairman, conferees, and those
    24   who have endured.  My name is Charles Marnell.  I am employed
    25   by Pioneer Service and Engineering, and I am here to represerr
    

    -------
                                                   	90S
    
    
    
    
    
                                 E. James
    
    
    
     2   Mr, Evans James of Wisconsin Public Service,   I am here to
    
    
    
     3   read the statement prepared by Mr, Evans James,
    
    
    
     4             Wisconsin Public Service Corporation is a Wiscon-
    
    
    
     5   sin public utility engaged in the production,  transmission
    
    
    
     6   and distribution of electricity and the purchase and dis-
    
    
    
     7   tribution of natural gas*  Its service area  is located in
    
    
    
         northeastern Wisconsin and Menominee County, Michigan,  Its
    
    
    
     9   principal office is located in Green Bay, Wisconsin,
    
    
    
    10             This utility has an interest in three electric
    
    
    
    11   generating plants which are affected by rules  governing
    
    
    
    12   thermal discharges into Lake Michigan,  It wholly owns and
    
    
    
    13   operates the Pulliam fossil-fired steam plant  at Green Bay
    
    
    
    14   located at the confluence of the Fox River and Green Bay,
    
    
    
    15   It has a minority interest with Wisconsin Power & Light
    
    
    
         Company in the Edgewater fossil-fired steam  plant at Sheboygar
    
    
    
    17   on the shores of Lake Michigan,  The Edgewater plant is
    
    
    
         operated by Wisconsin Power & Light Company,   This utility
    
    
    
         together with Wisconsin Power & Light Company  and Madison
    
    
    
    20   Gas & Electric Company shares ownership in the Kewaunee
    
    
    
         nuclear generating plant now under construction on the
    
    
    22
         west shore of Lake Michigan,  It is in charge  of the con-
    
    
    
         struction of the Kewaunee plant and will operate it when it
    
    
    2L
     *   is expected to go on line in the fall of 1973,
    
    
    25
                   This brief statement will be directed to the
    

    -------
        	909
    
    
    
    
     I                          E.  James
    
    
    
     2   Pulliam and Kewaunee plants only since these are or will
    
    
    
    
     3   be operated by this company.
    
    
    
     4             As this conference knows,  the Wisconsin Department
    
    
    
    
     5   of Natural Resources on December 6,  1971,  established thermal
    
    
    
     6   standards for Lake Michigan, such standards to become effec-
    
    
    
     7   tive on February 1, 1972.   Subsequently, on March 29, 1972,
    
    
    
     8   the Department issued guidelines for environmental studies
    
    
    
     9   to be undertaken at Lake Michigan thermal discharge sites.
    
    
    
    10   These standards and guidelines affect both the Pulliam and
    
    
    
    
    11   Kewaunee plants.
    
    
    
    12             It should first be noted that with respect to
    
    
    
    13   Kewaunee, Wisconsin Public Service Corporation had under-
    
    
    
    14   taken comprehensive studies of the environment surrounding
    
    
    
    15   the Kewaunee site well in advance of the establishment of
    
    
    
    16   standards by the Wisconsin Department of Natural Resources.
    
    
    
    17   As a matter of  fact, these  comprehensive studies have been
    
    
    
    13   under way the past  3 years and have encompassed extensive
    
    
    
    19   examination of  air, water,  and food sources.
    
    
    
    20             Following the issuance of the standards  and the
    
    
    
    21   guidelines, this utility  has prepared and  presented to  the
    
    
    
    22   Wisconsin Department of Natural Resources  study plans for
    
    
    
         both Pulliam  and Kewaunee and  these plans  have  been approved
    
    
    
    2Zf    subject to  continuing  review by the Department.  While  the
    
    
    
          Kewaunee studies were  begun in advance of  the creation  of
    

    -------
    10
    11
    12
    13
    14
    15
    16
    17
    19
    21
    23
    25
                                         	910
                             E. James
    the Department's guidelines, the future program at Kewaunee
    will be modified to the degree necessary to meet the guide-
    lines.  The studies at Pulliam are beginning this fall based
    on the approved study program.
              Since the Wisconsin Department of Natural Resources
    has laid down specific measures for studying the effect of
    thermal discharges into Lake Michigan, and since this utility
    has invested and will continue to invest substantial sums of
    money in the required studies, it now urgently requests this
    conference to hold in abeyance any rules which would inter-
    fere with the operation of any plant now operating or under
    construction on Lake Michigan until the data being accumula-
    ted has been secured and studied.  Only in that way can
    judgment based on fact rather than theory reasonably be
    made.  To follow any other procedure would be grossly wasteful
    of time and money and would interfere with a well conceived
    and efficiently managed program which will produce a sound
    basis for establishing any environmental controls which may
    20   be found necessary,
              I will briefly describe the programs under way at
    22 |  Kewaunee and Pulliam for your information.
              At Kewaunee, a preoperational radiological moni-
    toring program was begun in September 1969 by Industrial
    Bio-Test Laboratories, Inc. of Northbrook, Illinois for the
    

    -------
                                                                   911
    
    
    
    
     1                            E» James
    
    
    
     2   primary purpose of establishing baseline data for airborne
    
    
    
         radioisotopes which naturally occur from atomic testing,
    
    
    
         A meteorological program was started in August 196$ under
    
    
    
     5   the management of NUS of Washington, B.C. for the purpose of
    
    
    
     6   securing 2 years of meteorological data to satisfy the
    
    
    
     7   Atomic Energy Commission's licensing requirements.  The
    
    
    
         company continued to gather meteorological data following
    
    
    
     9   the expiration of the 2-year period until in June 1972, a
    
    
    
    10   meteorological program was developed with Bio-Test for it
    
    
    
    11   to assess the best available data concerning radioactive
    
    
    
    12   airborne releases,  A series of studies was begun in 1969
    
    
    
    13   by the University of Michigan and its environmental research
    
    
    
    14   group to assess the normal background of radioisotopes
    
    
    
    15   which occur throughout Lake Michigan in plant (phytoplankton)
    
    
    
    16   and animal (zooplankton and fish) sediments.  This study is
    
    
    
    17   continuing to determine the food change relationship between
    
    
    
         fish and man.  Another program was begun in 1971 known as
    
    
    
    19   the Helgeson Nuclear Lake Bottom Study, which consisted of
    
    
    
    20   mapping the lake bottom at the Kewaunee site for natural
    
    
    
    21   occurring radionuclides in order to get appropriate baseline
    
    
    
    22   data.  This mapping study was carried out twice in 1971,
    
    
    
    23   in addition to the above, Bio-Test and University of Wis-
    
    
    
         consin-Milwaukee are each performing studies to determine
    
    
    
    25   Kewaunee's interaction with Lake Michigan.  I have available
    

    -------
                                                                 912
    
                                 E. James
         an outline of these  studies which identifies the nature and
         frequency of them and will be glad to produce them for the
         conference's information if desired.  I will place them in
         the record as A  and  B.
     6             MR.  MAYO:   Fine.
     7             MR.  MARNELL:  Thank you.
                   (The documents above referred to follow in their
     9   entirety.)
    10
    11
    12
    13
    14
    15
    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
    

    -------
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                                                      Wisconsin  Public Service Corp,
                                                      Exhibit B
                                TABLE I
    
                   FREQUENCY OF FIELD SAMPLING
                              BY CATEGORY
    Sampling Period - 1972'
    
    1.
    2.
    3.
    4.
    5.
    6.
    7.
    8.
    9.
    Category
    Water Column Profile
    Lake Currents-
    Water Quality
    Bacteriology
    Phytoplankton
    Zooplankton
    Periphyton
    Benthos
    Fish
    Mav
    xxi'
    X
    XX
    XX
    XX
    XX
    X
    X
    XX
    July
    XX
    X
    XX
    XX
    XX
    XX
    X
    X
    XX
    Sept.
    XX
    X
    XX
    XX
    XX
    XX
    X
    X
    XX
    Nov.
    XX
    X
    XX
    XX
    XX
    XX
    X
    X
    XX
    —   XX = Two independent samplings during the quarter.
    —   Certain aspects will be monitored  on a continuous basis.
    

    -------
     1
     2
    10
    11
    12
    13
    14
    15
    16
    17
    19
    20
    21
    22
    23
    24
                                                                   913
                             E. James
              MR. MARNELL:  These University of Wisconsin-Mil-
    waukee studies began in 1969 and the Bio-Test studies began
    in 1971.
              At the Pulliam plant, the environmental quality
    water studies will follow closely the Department of Natural
    Resources' guidelines.  Temperature measurements and infra-
    red photos of the thermal plume will be taken in order to
    evaluate the plume dimensions.  Fish will be collected to
    determine the numbers, species, length, weight, and age.
    The benthic organisms, phytoplankton and zooplankton samples
    will be collected in replicate from permanent sample loca-
    tions.  Continuous monitoring of the intake and discharge
    water temperatures will be undertaken as well as continuous
    monitoring of the discharge for pH and dissolved oxygen.
    Dissolved oxygen and Biochemical Oxygen Demand (BOD) profile
    will be determined in conjunction with the temperature
    profile study.  The intake and discharge will be analyzed
    to determine their various chemical constituents including
    copper, calcium, zinc, specific conductance, sodium,
    potassium, fluoride, sulfate, silicon, color turbidity,
    ammonia, total phosphorus, soluble phosphorus, chlorides,
    magnesium, pH, hardness, alkalinity, mercury, boron, arsenic,
    iron, chromium, nickel, lead, and manganese.  The residual
     ^   chlorine in the discharge water will be determined by using
    

    -------
                                                                  914
    
    
    
    
    
     1                            E. James
    
    
    
     2   the amperometric procedure.  A permanent record will be kept
    
    
    
         of a  summarization of the total amounts, frequency, and volumo
    
    
    
         of chemicals discharged to the water
    
    
    
     5             I believe this description of our programs empha-
    
    
    
     6   sizes the depth and great extent of the environmental studies
    
    
    
     7   being undertaken.  I again urge that the value of these
    
    
    
         studies not be destroyed by any change in procedures.  The
    
    
    
     9   standards and guidelines issued by the Wisconsin Department
    
    
    
    10   of Natural Resources should be pursued and their results used
    
    
    
    11   in making a final determination.
    
    
    
    12             That concludes the statement.
    
    
    
    13             MR. MAYO:  Any questions, gentlemen?
    
    
    
    14             MR. MARNELL:  Mr. Chairman, I have to defer from
    
    
    
    15   any questions as I am not prepared to answer them for Mr.
    
    
    
    16   Evans James.
    
    
    
    17             MR. MAYO:  Thank you.
    
    
    
                   MR. MARNELL:  But I would refer any questions
    
    
    
    19   that  you have to him.
    
    
    
    20             MR. MAYO:  Thank you for the statement.
    
    
    
    21             MR. FRANCOS:  Miss Sarah Jenkins of the Sierra
    
    
    
    22   club.
    
    
    
    23
    
    
    
    24
    
    
    
    25
    

    -------
                                                                  91$
                                      ,	,	
                                S. Jenkins
     2
     3              STATEMENT OF SARAH JENKINS, MEMBER,
                  EXECUTIVE COMMITTEE, JOHN MUIR CHAPTER,
     5                SIERRA CLUB, MADISON, WISCONSIN
     6
     7             MISS JENKINS:  Mr. Chairman, conferees, and
         holdouts.
     9             My name is Sarah Jenkins, and I am from Madison,
    10   Wisconsin.  I am speaking for the Sierra Club national
    11   organization.
    12             My background is that I have got a Bachelor's
    13   Degree  in Physics and a Master's in Biophysics, and I have
    14   been  studying energy for work on a second Master's since
    15   June  of 1970.  I have been on the John Muir Chapter Execu-
    16   tive  Board since January of this year.
    17             Sierra Club is interested in problems involving
         nuclear powerplants on Lake Michigan because along with
    19   Businessmen for the Public Interest we have intervened on
    20   several of the plants.  We have actually intervened on
    21   Palisades and on Point Beach 1, and along with Businessmen
    22   for the Public Interest we have filed to intervene on Point
         Beach 1, Zion 1 and 2, Donald C. Cook 1 and 2.
                   Sierra Club is concerned about the effect of
         powerplants on Lake Michigan because we feel that the evidence
    

    -------
                                                                  916
    
    
    
    
    
                                S. Jenkins
    
    
    
     2   from the studies being conducted on the lake is not in yet,
    
    
    
     •3   and we don't believe that the data gathered from laboratory
    
    
    
         studies is particularly promising.  It does show that there
    
    
    
     5   are biological effects.  We do not like using the lake as
    
    
    
     6   a laboratory.  We are unwilling to gamble with the integrity
    
    
    
     7   of the Lake Michigan ecosystem.
    
    
    
                   We feel that the decisions that this conference
    
    
    
     9   is going to make will create an important precedent and we
    
    
    
    10   are worried about the type of decision that will be made
    
    
    
    11   here.
    
    
    
    12             It is extremely easy — as Mr, McDonald was point-
    
    
    
    13   ing out earlier today — to say that you can go on line now,
    
    
    
    14   and when we see signs of damage you will have to come off
    
    
    
    15   line.  But the problem comes:  What are the signs of damage
    
    
    
    16   when you decide that you are going to have to put in closed—
    
    
    
    17   cycle cooling?
    
    
    
                   It is particularly difficult if the plant has been
    
    
    
    19   operating for, say, half its expected lifetime to insist that
    
    
    
    20   somebody spend a great deal of money to put in closed-~cycle
    
    
    
         cooling because it is difficult to amortize the cost.
    
    
    
    22             We are worried, as Dr. Gustafson commented, about
    
    
    
         the problem of the projected growth of powerplant use of Lake
    
    
    
         Michigan for cooling water.  The base that is being doubled
    
    
    
         is getting increasingly large -- the base of electric power
    

    -------
         	917
    
    
    
    
    
                                 S. Jenkins
    
    
    
     2   generation — and so the effects are becoming more and more
    
    
    
     3   serious.
    
    
    
     4             We have some disagreement with the projections for
    
    
    
     5   growth in demand, based on data presented at a Sierra Club
    
    
    
     6   conference in Vermont last January — data indicating that
    
    
    
     7   we may not need as much power in the future for installing
    
    
    
         mass transit and sewage treatment as some people very glibly
    
    
    
     9   said we might.
    
    
    
    10             We believe that whatever standards are set should
    
    
    
    11   apply to all large powerplants, should apply to all power-
    
    
    
    12   plants built since January 1, 1971; that these standards
    
    
    
    13   should require high quality monitoring; that if closed-
    
    
    
    14   cycle cooling systems are to be required that the micro-
    
    
    
    1$   meteorology surrounding where the cooling towers are being
    
    
    
         put up must be accurately surveyed.  At this point, the exact
    
    
    
    17   effects of such cooling towers of the size projected is not
    
    
    
         known and until the studies are made it will be difficult to
    
    
    
         evaluate the actual environmental trade-offs between cooling
    
    
    
         towers and once-through cooling.
    
    
    
                   We also feel that this issue is part of broader
    
    
    29
         questions that are really societal questions and not bio-
    
    
    
         technical decisions.
    
    O l
    
                   Three questions are basically:
    
    
    25
                   1.  How much power does our society and this Lake
    

    -------
                             	913
    
     1                           S. Jenkins
     2   Michigan region really need?
     3             2.  When do the environmental and societal costs
     4   of continued growth of energy use exceed the benefits?
     5             3.  Who is and who should be deciding these
     6   questions?
     7             Members of the Sierra Club believe that these
     8   matters should be the subject of inform   public debate and
     9   that the informed debate should be informed because the facts
    10   have been made public,
    11             Thank you.
    12             MR. MAYO:  Thank you, Miss Jenkins.
    13             MR. McDONALD:  I think your point about backfitting
    14   on a plant that has been used half its life is a very good
    15   point.  We run into this, and I am sure we are going to run
    16   into it more as we go after the industrial plants — the
    17   steel mills, the oil companies — they are all old.  Hardly
    1&   a plant that has been in business doesn't age very rapidly
    19   as far as treatment systems are concerned.
    20             (The documents submitted by Ms. Jenkins  following
    21   the conference follow in their entirety.)
    22
    23
    24
    25
    

    -------
                             SIERRA CLUB
    by Ansel Adams in This Is tht American Earth
    Mills Tower, San Francisco 94104
    Midwest  Office
    444 West Main Street
    Madison, WI  53703
        (608) 257-4994
    
    Sept.  26,  1972
        Mr. Francis T. Mayo
        Regional Administrator
        Region V
        Environmental Protection Agency
        One North Wacker Drive
        Chicago, IL 60606
    
        Dear Mr. Mayo:
    
             The enclosed is a written version of my comments last
        Thursday night at the Lake Michigan Enforcement Conference.
        It may clarify some of the points I made then.
    
             Could these written comments be included in the written
        record of the conference?
    
             Thank you for your attention.
        SJ:mh
                                                     Sincerely,
                                                     Sarah Jenkins
                                                     Member, Executive Committe
                                                     John Muir Chapter of the
                                                        Sierra Club
    

    -------
                                                     Mills Tower, San Francisco 94104
    by Ansel Adams in This Is tht American Earth
                             SIERRA CLUB  STATEMENT
    
                                    MADE  TO
    
                   THE LAKE MICHIGAN ENFORCEMENT CONFERENCE
                              September 21,  1972
        Statement made by Sarah Jenkins
    
        Mr. Chairman, Conferees, and Holdouts.
    
    
        My qualifications are a bachelor's degree  in  physics,  a master's
        in biophysics, and  I have been studying energy  problems for the
        past two years in connection with writing  a second  master's thesis
        I have been on the  John Muir Chapter (Sierra Club) executive board
        since January 1972.
    
        Sierra Club has been involved in the problems associated with sit-
        ing electric power  plants on Lake Michigan since  the first inter-
        vention at Palisades.  Sierra Club has been one of  the intervenors
        in the Palisades and Point Beach II cases, and  along with Business
        men for the Public  Interest has filed for  intervention in Point
        Beach I, Zion I and II, and Donald C. Cook I  and  II.
             The Sierra Club is concerned about  the  effects  of discharge of
        vast quantities of heated water  into Lake Michigan.   We are aware
        that the results of field studies of the lake  are  not in yet,  but
        the evidence from laboratory  studies of  the  effects  of heat upon
        organisms is not very promising.  It could be  a  long time before we
        notice the effects of the discharge of the heated  water.  Whenever
        there are long time delays between cause and effect, it is possible
        for the effects to be serious before their existence is noticed.
    
             We do not want Lake Michigan to be  treated  as a laboratory.
        We are unwilling to gamble with  the integrity  of the Lake Michigan
        ecosystem.
    

    -------
                                  •2-
         We would prefer that in this case, any errors in standards
    be made on the side of caution.
    
         Whatever decision is reached by the conferees will set an
    important precedent affecting the future uses of Lake Michigan.
    Because of this, we would be very worried about a decision that
    says that heat may be discharged  . co the lake until such time
    as signs of damage appear, at Wi) .ch time devices to control the
    discharge of heat must be backf i..tt_d.  I would like to emphasize
    a point made earlier by Mr. McDonald   it is too easy to question
    what constitutes evidence of damage.  Will it be the first ten-
    tative signs of ecosystem change or a major change?  Further, it
      . always possible to say that whatever changes are being seen are
    re '  ;y due to another cause such as fertilizers being applied to
         land and washed into the lake.
         The other problem with a decision requiring backfitting arises
    if a plant has been operating for 10-20 years and will only be in
    operation Cor a further 10 years.  Then it can be argued that the
    cost of backfitting will be too great when amortized over the re-
    maining life  )i; the plant.  The argument becomes - we will install
    contro] equipiti'-' it in new plants but it is too costly to backf it
    existing planes,
    
         Case-by-case decisions then become completely arbitrary, not
    based on scientific evidence.  It is arbitrary to say that equip-
    ment must be built into new plants but does not have to be back-
    fitted to existing plants.
    
         We are concerned about this decision as a precedent because of
    the enormous rate of growth of the electric power industry.  As the
    base amount of energy which is doubled by exponential growth in-
    creases, the consequences of short doubling times become more serious.
    We do not entirely agree with projections of demand for electricity
    into the future.  At the Vermont Power Conference (sponsored by Sierra
    Club in Johnson, Vermont, January 14-15, 1972) a paper was presented
    which questions two of the reasons given for needing vast amounts of
    more power in the future - mass transit and sewage treatment.  In
    both cases,  the increased demand was two per cent once in 30 years
    compared with the present growth rate of seven per cent per year
    (which equals 800 per cent in 30 years) .  Residential and commercial
    demand for electricity will be very sensitive to changes in codes
    for lighting and insulation, and to the extent of further growth of
    electrical heating.
    
         Whatever standards are set by this conference should include
    the following points:  they should apply to all large power plants,
    and to all plants built since January 1, 1971.  Further the stand-
    ards should require high quality monitoring of the ecosystem ad-
    jacent to the power plant.  If closed cycle cooling systems are re-
    quired then the micrometeorological effects of such systems must be
    studied.  Prediction and evaluation of the trade-offs between the
    

    -------
                                 -3-
    effects of once-through cooling and closed cycle cooling will not
    be possible without better data on their actual effects.
    
         The Sierra Club believes that the issue of discharge of heat
    to Lake Michigan is part of three broader questions:
    
         1. How much power does our society and this Lake Michigan region
            really need?
    
         2. When do the environmental and societal costs  of continued
            growth of energy use exceed the benefits?
    
         3. Who is and who should decide these questions?  We in the
            Sierra Club believe that these matters should be the subject
            of informed public debate.  Informed debate because the
            facts have been made public.
    
    Thank you.
    

    -------
                                             	      919
                                  S* Burstein
                   MR. FRANCOS:  Mr* Sol Burstein.
    
              STATEMENT OF SOL BURSTEIN, SENIOR VICE PRESIDENT,
     5               WISCONSIN ELECTRIC  POWER COMPANY,
     6                     MILWAUKEE, WISCONSIN
    
                   MR. BURSTEIN:  Mr. Chairman, conferees, ladies
     9   and gentlemen
    10             I would like to add a good bit of weight to this
    11   conference.  I am sorry that this is not the forum, I be-
    12   lieve, nor the hour, to refute some of the things that have
    13   been said concerning the Point Beach nuclear Plant, the
    14   AEG licensing proceedings, and certain matters that go with
    15   that.
    16             But if Mr. Mayo will permit me, I would like to
    17   introduce as an exhibit the eleven volumes of the transcript
    18   of the record of that proceeding which speaks for itself.
    19             MR. MAYO:  Fine.
    20             MR. BURSTEIN:  I would also like to introduce
    21   for your record as an exhibit the Environmental Impact
    22   Statements that were alluded to before and in which people
    23   like Dr. Coutant were quoted completely out of context.  The
    24   conclusions of those Impact statements, I think, are irapor-
         tant in the analyses of the thermal effects of powerplants
    

    -------
         	   920
    
    
    
    
                                  S, Burstein
    
    
    
         on Lake Michigan.
    
    
    
    
     3             MR. MAYO:  Do you have that material with you?
    
    
    
     4             MR. BURSTEIN:  Yes, sir.
    
    
    
     5             MR. MAYO:  Fine.
    
    
    
    
     6             MR. BURSTEIN:  Forgive me, Mr. Chairman,
    
    
    
     7             Let me suggest that it is a very complete and
    
    
    
         competent record that was made of Point Beach.  It deals
    
    
    
         with many of the questions concerning diving plumes, con-
    
    
    
    10   cerns with condenser transport.  It is concerned with almost
    
    
    
    11 j  every other question that was raised here, in a public
    
    
    
    12 !  hearing in which sworn testimony was given, in which there
    
    
    
    
    13   were adversary opportunities for cross examination of wit-
    
    
    
    14   nesses,  and I think as such deserves an opportunity for
    
    
    
    1$   those who haven't to review a very important history.  As
    
    
    
    16   my text indicates, this AEC proceeding was the first full
    
    
    
    17   power, full NEPA hearing on environmental issues in an
    
    
    
         operating license case, to my knowledge.
    
    
    
    19             (The documents above referred to are on file at
    
    
    
    
         U.S. EPA Headquarters, Washington, D.C. and Region V Office,
    
    
    
    21   Chicago, Illinois.)
    
    
    
    22             MR. BURSTEIN:  I will attempt to paraphrase some
    
    
    
         of my remarks in order to conserve what litle time we may
    
    
    
         have left.  But let me say first that Point Beach Unit 1
    
    
    
         has been operating rather successfully for almost 23 months,
    

    -------
         	921
    
    
    
    
    
                                  S. Burstein
    
    
    
         during which time we have had an opportunity to actually
    
    
    
         monitor one of the more recent and significant nuclear plants
    
    
    
         on the lake.  Unit 2, as you have heard,  has had its hearing
    
    
    
         concluded, but the decision is still awaited, and is operat-
    
    
    
         ing at 20 percent power license after many appeals and court
    
    
    
         reviews which, as you heard,   are still being reviewed.
    
    
    
                   As I mentioned before to this conference, we had
    
    
    
         time between a period when it was agreed essentially that
    
    
    
    10   no damage to Lake Michigan exists and when it was feared
    
    
    
    11   by some that future additional sources of heat input might
    
    
    
    12   cause irreversible adverse effects.  I am pleased that the
    
    
    
    13   Enforcement Division of this Region of EPA undertook to have
       i
       I
    
    14   Argonne provide the summary embodied under Contract Report
    
    
    
    15   72-1.  My copy of this valuable and exhaustive review is
    
    
    
    16   covered in black, which I assume is to mourn the passing
    
    
    
    17   of the "white paper."  I believe an examination of this new
    
    
    
    1&   Argonne report will indicate that even in the short inter-
    
    
    
    19   val between the 1971 conference and today, substantial scien*-
    
    
    
    20   tific effort has been and is being expended to develop a
    
    
    
    21   responsible, objective body of technical knowledge concern-
    
    
    
    22   ing thermal discharges.  Not all the data are in, of course,
    
    
    
    23   but to my knowledge none represents any confirmation of the
       I
    
    
    24   fears expressed earlier concerning adverse effects of these
    
    
    
         thermal effects.
    

    -------
                                             	922
    
     1                            S
     2             As you know, ay own State of Wisconsin passed new
     3   water quality criteria last December which were made effec-
     4   tive in February, and following the details of rules at the
     5   end of March concerning substantial monitoring effects, all
    
     6   of the utilities with plants on Lake Michign undertook their
     7   implementation, including my own companies*
    
                   In the next 1$ months, we will be spending in
     9   excess of $1»2 million for these studies at four of our
    10   plants, including Point Beach,  1 believe this work to be
    11   one of the most detailed and comprehensive programs for the
    12   monitoring of thermal discharges and the analysis of their
    13   effects.  They are designed to be of the highest profes-
    14 I  sional quality, and we are confident that these new studies
    15   will confirm what we have been talking about before, and I
         would be happy to share •chem with the Environmental Protec-
    17   tion Agency and all of the conferees.
                   Additionally, of course, we are continuing on
         with the numerous other programs that we have enumerated
    
         to you before, some of which I have mentioned in detail in
    O"l
       I  the text of my comments.
    22
                   In my remarks to the workshop sessions of Septem-
         ber-October of 1970, I stated that I believed no new Federal
    O I
       I  thermal standards were required for Lake Michigan, but that
    05
         the adequacy of State criteria could be confirmed by actual
    

    -------
                                                                   923
    
    
     •i                             S* Burstein
    
     2   observations at the operating steam electric generating
    
     o   plants,  I stated that any effects of thermal discharges on
    
     K   sensitive localized areas could be accommodated on a case-by-*-
    
     5   case analysis*  It is, of course, heartening to read care-
    
     6   fully Mr. John Quarles1 May 12, 1972, policy statement on
    
     7   thermal discharges and the report of the Environmental Pro-
    
     g   tection Agency to this conference which I understand to
    
     9   specify a case-by-case analysis of all relevant facts apply-
    
    10   ing to a particular site,
    
    11             As I indicated before, the full record of the
    
    12   Point Beach nuclear plant proceeding is an excellent example
    
    13   of that case-by-case treatment,
    
    14             At the same time that I am encouraged by the EPA
       |
    15   policy statements, I am dismayed by two apparently contra-
    
    16   dictory matters.  The first concerns Regional Administrator
    
    17   Mayo's letter to the Chairman of the Licensing Board in the
    
         Point Beach proceeding as recently as August 10, 1972, which
    
    19   states that EPA "... continues to support the recommendations
    
    20   of the Lake Michigan Enforcement Conference approved by the
    
    21   Administrator of the EPA on May 14, 1971, and continues to
    
    22   urge that the Point Beach Unit No. 2 have a closed-cycle
    
         cooling system in accordance with the recommendations of
    
         the Enforcement Conference.1*
    
                   Evidently Mr. Mayo finds himself constrained by
    

    -------
         	 _	924
    
    
    
    
                                  S. Burstein
    
    
    
         the recommendations of the 1971 Enforcement Conference which
    
    
    
         are in conflict with present EPA case-by-case analysis policy.
    
    
    
                   The second matter concerns an item appearing in the
    
    
    
         September l£, 1972, issue of Electrical Week*  The report
    
    
    
         references EPA sources as continuing to maintain their stand
    
    
    
     7   on requiring closed-cycle cooling for Lake Michigan power-
    
    
    
         plants rather than the case-by-case consideration, with a
    
    
    
         quote:  "We [EPA] are simply viewing Lake Michigan as a
    
    
    
    10   single case."
    
    
    
    11             Perhaps I should be even more concerned by similar
    
    
    
    12   statements, Mr, Chairman, that have been made on the thermal
    
    
    
    13   question today.
    
    
    
    14 I            I believe that we have now gone past the point of
    
    
    
    15   further nonsense.  I do not honestly see how we can say that
    
    
    
    16   there is consistency between a case*-by-case policy statement
    
    
    
    17   and Lake Michigan as a whole,
    
    
    
    IS             We have been around this barn innumerable times,
    
    
    
    19   and there is nothing further to be gained by more evasion.
    
    
    
    20   The record in these conferences clearly demonstrates that
    
    
    
    21   insofar as thermal matters are concerned there is no tech—
    
    
    
    22   nical basis for considering Lake Michigan as a single case.
    
    
    
    23             There are many, many items which I have deliber-
    
    
    
         ately summarized in a single paragraph concerning the
    
    
    
         reasons why it is imperative that I think this conference
    

    -------
        	92$
                                  S.  Burstein
         take clear and unmistakable  action to  rescind the  1971  thermal
         recommendations*   This will  give the EPA Regional  Administra
         tor confirmation of the actions of the respective  States  and
         will avoid any present or potential conflict between Federal
         and State agencies, the Congress, and  the courts.
                   I suggest perhaps, Mr* Chairman and conferees,
     &   that it is time for this conference, including EPA,  to
         endorse for the Region what  the conferees have accomplished
    10   individually*
    11             MR. MAYO:  Are there any questions, gentlemen?
    12             Thank you, Mr, Burstein.
    13             (Mr. Burstein's presentation follows in its
    14   entirety,)
    15
    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
    

    -------
                    STATEMENT OF SOL BURSTEIN
                      SENIOR VICE PRESIDENT
                 WISCONSIN ELECTRIC POWER COMPANY
               LAKE MICHIGAN ENFORCEMENT CONFERENCE
                        CHICAGO, ILLINOIS
                      SEPTEMBER 19-22, 1972
           My name is jol Burstein.  I am Senior Vice President
    
    of Wisconsin Electric Power Company.  You will recall that at
    
    previous sessions of the Conference I presented details in
    
    regard to the Wisconsin Electric Power system that I repre-
    
    sent, the territory and number of customers we serve, and the
    
    power plants we operate in the State of Wisconsin along the
    
    western shore of Lake Michigan.  Among these power plants,
    
    which utilize once-through-cooling, are the Oak Creek Plant,
    
    which is presently the largest operating thermal plant on Lake
    
    Michigan, and the Point Beach Nuclear Plant, one unit of which
    
    has been operating at essentially full power for almost twenty-
    
    three months.  In regard to the second unit, we have recently
    
    concluded one of the longest and most detailed public hearings
    
    on environmental effects of its operation and it is now in
    
    service at an interim 20% level.
    
           In my remarks to this Conference on March 24, 1971,
    
    I emphasized certain observations from the proceedings and
    
    from the conclusions of the January, 1971, report of the
    
    Technical Committee on Thermal Discharges.  I expressed my
    
    concurrence with the Committee recommendation and the then
    

    -------
                                - 2 -
    Assistant Secretary of the Interior, Carl Klein, that there
    
    
    
    is a period of time between the present when no damage to
    
    
    
    Lake Michigan from thermal discharges exists - and some un-
    
    
    
    defined future time when some feared additional sources of
    
    
    
    heat might cause irreversible adverse effects.  I stated this
    
    
    
    period affords and, indeed, demands that we use this time to
    
    
    
    determine what we should intelligently do before we do it.
    
    
    
           I am pleased that the Region V Enforcement Division
    
    
    
    of the Environmental Protection Agency undertook to have
    
    
    
    Argonne National Laboratory provide the summary embodied
    
    
    
    under Contract Report 72-1.  My copy of this valuable and
    
    
    
    exhaustive review is covered in black which I assume is to
    
    
    
    mourn the passing of the White Papers,  I believe an examina-
    
    
    
    tion of this new Argonne report will indicate that even in
    
    
    
    the short interval between the 1971 Conferences and today,
    
    
    
    substantial scientific effort has been and is being expended
    
    
    
    to develop a responsible, objective body of technical know-
    
    
    
    ledge concerning thermal discharges.  Not all the data are in,
    
    
    
    of course, but to my knowledge, none represents any confirmation
    
    
    
    of the fears expressed earlier concerning adverse effects of
    
    
    
    these thermal effluents.
    
    
    
           In my own state of Wisconsin, new thermal criteria
    
    
    
    adopted in December,  1971,  and effective February 1,  1972,
    

    -------
                                - 3 -
    call for extensive monitoring of existing power plant dis-
    
    
    
    charges and their effects on the aquatic environment.  Data
    
    
    
    and analyses are to be provided to the Wisconsin Department
    
    
    
    of Natural Resources in interim progress reports and in a
    
    
    
    final report due February 1, 1974.  An advisory board of
    
    
    
    eminently qualified scientists developed a set of require-
    
    
    
    ments to implement these Wisconsin criteria in March, 1972,
    
    
    
    immediately after which the utilities in my state undertook
    
    
    
    to perform the studies.
    
    
    
           In the next eighteen months we will be spending in
    
    
    
    excess of $1,200,000 for these studies at the Oak Creek, Lake-
    
    
    
    side, Port Washington and Point Beach plants.  I believe this
    
    
    
    work to be one of the most detailed and comprehensive programs
    
    
    
    for the monitoring of thermal discharges and the analysis of
    
    
    
    their effects.  They are designed to be of the highest pro-
    
    
    
    fessional quality.  We are confident that these new studies,
    
    
    
    together with the data observed in the past at our facilities
    
    
    
    and at other similar installations, will provide further hard
    
    
    
    scientific corroboratior. of our past positions before this
    
    
    
    Conference.  We would be pleased to share the results of our
    
    
    
    studies with EPA and the conferees.
    
    
    
           Additionally, the Center for Great Lakes Studies at
    
    
    
    the University of Wisconsin in Milwaukee has undertaken studies
    
    
    
    at our Oak Creek Power Plant under AEC funding with instrumen-
    

    -------
                                - 4 -
    tation and other services supplied by us.  You will recall
    
    
    
    my having suggested such an undertaking in 1970.  The other
    
    
    
    programs being conducted by the Sea Grant Program at the
    
    
    
    University of Wisconsin, Argonne National Laboratory, Uni-
    
    
    
    versity of Wisconsin-Milwaukee and those being sponsored by
    
    
    
    the Lake Michigan Utility Study Group continue to receive
    
    
    
    our financial and technical support and continue to supply
    
    
    
    further information on thermal effects.  More and more we
    
    
    
    are beginning to give Administrator Ruckelshaus as well as
    
    
    
    the states and the conferees that "considerable and growing
    
    
    
    body of evidence" that we did not have earlier.  To date/ none
    
    
    
    of these data provide any basis for any arbitrary or hasty de-
    
    
    
    cisions absolutely precluding thermal releases to Lake Michi-
    
    
    
    gan.
    
    
    
           In my remarks to the workshop sessions of last Septem-
    
    
    
    ber-October, I stated that I believed no new federal thermal
    
    
    
    standards were required for Lake Michigan but that the ade-
    
    
    
    quacy of state criteria could be confirmed by actual obser-
    
    
    
    vations at operating st-aam-electric generating plants.  I
    
    
    
    stated that any effects of thermal discharges on sensitive
    
    
    
    localized areas could be accommodated on a case-by-case analy-
    
    
    
    sis.  It is, of course, heartening to read carefully Mr. John
    
    
    
    Quarles May 12, 1972, policy statement on thermal discharges
    
    
    
    and the report of the Environmental Protection Agency to this
    

    -------
                                - 5 -
    Conference which I understand to specify a case-by-case
    
    
    
    analysis of all relevant facts applying to a particular site.
    
    
    
           We have just had what I believe is the first full
    
    
    
    public hearing on environmental issues attending an AEC con-
    
    
    
    tested operating license proceeding in connection with our
    
    
    
    Point Beach Nuclear Plant, Unit 2.   During t-.nis hearing, a
    
    
    
    major emphasis was on the effects of plant operation on the
    
    
    
    aquatic environment.  I believe an objective review of the
    
    
    
    transcript of that hearing will indicate that a valid, scien-
    
    
    
    tifically based analysis on a case-by-case basis is the only
    
    
    
    realistic approach to an understanding and evaluation of
    
    
    
    power plant thermal effects.  I would be glad to provide this
    
    
    
    Conference with a copy of that transcript.
    
    
    
           At the same time that I am encouraged by the EPA policy
    
    
    
    statements, I am dismayed by two apparently contradictory mat-
    
    
    
    ters.  The first concerns Regional Administrator Mayo's let-
    
    
    
    ter to the Chairman of the Licensing Board in the Point Beach
    
    
    
    proceeding as recently as August 10, 1972, which states ex-
    
    
    
    plicitly that EPA "continues to support the Recommendations
    
    
    
    of the Lake Michigan Enforcement Conference approved by the
    
    
    
    Administrator of the EPA on May 14, 1971, and continues to
    
    
    
    urge that the Point Beach Unit #2 have a closed cycle cooling
    
    
    
    system in accordance with the recommendations of the Enforce-
    
    
    
    ment Conference".  Evidently, Mr. Mayo finds himself constrained
    

    -------
                                - 6 -
    by the recommendations of the 1971 Enforcement Conference
    
    
    
    which are in conflict with present EPA case-by-case analysis
    
    
    
    policy.
    
    
    
           The second matter concerns an item appearing in the
    
    
    
    September 18, 1972, issue of Electrical Week, a McGraw-Hill
    
    
    
    utility industry newsletter.  This report references EPA
    
    
    
    sources as continuing to maintain their stand on requiring
    
    
    
    closed cycle cooling for Lake Michigan power plants rather
    
    
    
    than the case-by-case consideration with the quote, "We
    
    
    
    [EPA] are simply viewing Lake Michigan as a single case".
    
    
    
           I believe, Mr. Chairman and Conferees, that we have
    
    
    
    gone past the point of further nonsense.  We have been around
    
    
    
    this barn innumerable times and there is nothing further to
    
    
    
    be gained by more evasion.  The record in these Conferences
    
    
    
    clearly demonstrates that insofar as thermal matters are con-
    
    
    
    cerned, there is no technical basis for considering Lake
    
    
    
    Michigan as a single case.
    
    
    
           I need notrepeat here in detail what you all know and
    
    
    
    have heard — the separate actions of the respective states,
    
    
    
    the present events in the Congress on the new water quality
    
    
    
    legislation, the analysis and the conclusions by all the
    
    
    
    national laboratories in the environmental impact statements
    
    
    
    for all the current nuclear plants on Lake Michigan which are
    
    
    
    against closed cycle cooling, the absence of a NEPA statement
    

    -------
                                - 7 -
    on the 1971 recommendations, present litigation which records
    
    
    
    the fact that these 1971 recommendations have no legal effect,
    
    
    
    the forthcoming publication of the revised Green Book, the
    
    
    
    actual results of currently operating power plants on Lake
    
    
    
    Michigan and the extensive and high caliber additional studies
    
    
    
    currently under way to provide further information.  All these
    
    
    
    matters, together with the apparent conflict between EPA
    
    
    
    present policy on thermal discharges and the 1971 recommenda-
    
    
    
    tions of the Enforcement Conference require that this Con-
    
    
    
    ference take clear and unmistakable action to rescind the
    
    
    
    1971 thermal recommendations.  This action will give the EPA
    
    
    
    Regional Administrator confirmation of the actions of the res-
    
    
    
    pective states and will avoid any present or potential conflict
    
    
    
    between federal and state agencies, the Congress and the courts,
    
    
    
           I believe we in Wisconsin have demonstrated that the
    
    
    
    utility industry and state agencies charged with environmental
    
    
    
    protection and enhancement can work together on a realistic
    
    
    
    timetable to determine and evaluate environmental impacts and
    
    
    
    to effect remedial actions where necessary.  I believe othrfr
    
    
    
    utilities and other state agencies around Lake Michigan have
    
    
    
    provided similar demonstrations of their capacity and intent.
    
    
    
    I suggest it is now time for this Conference, including EPA,
    
    
    
    to endorse for the region what the conferees have accomplished
    
    
    
    individually.
    

    -------
                                                                   926
    
     •,                            P. Keshishian
     2             MR. FRANCOS:  Mr. Paul Keshishian.
    
     3
     4             STATEMENT OF PAUL KESHISHIAN, DIRECTOR,
     5              POWER PRODUCTION,  WISCONSIN  POWER AND
     6                LIGHT COMPANY, MADISON, WISCONSIN
    
     7
                   MR. KESHISHIAN:  My name is Paul Keshishian,  I
     9   am the Director  of Power Production of the Wisconsin Power
    
    10   and Light Company
    11             Before I read my prepared statement, I would like
    12   to make  reference to  what Mr. Barber said earlier — I
    13   think it was — this  evening.   (Laughter)
    14              I  take strong exception with Mr.  Barber's list
    15   of  fish  kills as proof of the need  for cooling towers on Lake
    16   Michigan.  As a point of  fact,  one  incident he referred to
    17   occurred in  December  1952 at the Glenwood Landing Station
         of  Long  Island  Lighting Company, and involved their 100  MW
    19   No.  4 unit.  It was a serious problem.   Brown herrings were
    20   being found  in  their  intake  screens and  their unit condensers
          so  that  periodic shutdowns occurred.
    22              £  noted ichthyologist was hired to  determine the
          cause of the problem.  After careful  study  of the incident
          and field investigation,  he recommended  that  they shut off
    25    their dock lights at  night as the  lights were an attraction
    

    -------
                                                                  927
     1
     2
     3
    
    
     4
    
    
     5
    
    
     6
    
    
     7
    
    
     &
     9
    10
    11
    12
    13
    14
    17
    19
    20
    21
    22
     '
                                P. Keshishian
    
    
         to  the  fish  that resulted in their being sucked into the
    
    
         intake  structures.  Once the lights were shut off, they had
    
    
         no  further problems with herrings in their intakes.  For the
    
    
         past 20 years,  they have not had any problems.  And this is
    
    
         not a fish story.   (Laughter)
    
    
                   I  also take exception to his  conclusions regarding
    
    
         the Indian Point  station of the Consolidated Edison Company
    
    
         of New York.  While this  station apparently  has a problem,
    
    
         there are many other  stations  on the  Hudson  River that do
    
    
         not have a problem.   Specifically,  on the  Consolidated
    
    
         Edison system, there  are  11  other  stations he  did not  refer
    
    
         to.  I was general superintendent  of 5  of  those  stations
    
    
         between 19 5^ to 1969, and I  never  witnessed or had  knowledge
    
    
         of any fish kill.   Specifically,  I was general superintendent
    
    
         of the 59th Street station,  the 74th Street station,  the
    
    
         Kent Avenue station,  the Astoria generating station,  and the
    
    
         Raymond  generating station.
    
    
                   j aiso point out that both the latter two stations
    
    
         are  5  times the size of the Indian Point station.  I think
    
    
         it  is  absolutely incorrect to  reach a  conclusion that
    
    
         because  a small percentage of  stations may  have had a
    
    
         problem that,  ergo,  a thousand other stations will also
    
    *}}
         have the same problem.
                    I won't read my complete  statement.   You have
    

    -------
                                                        	92$
                                         •—•—•	
    
    
                                 P.  Keshishian
    
    
     2   that*
    
    
     3             The Wisconsin Power and  Light  Company is  basically
    
    
     4   in partnership with the Wisconsin  Public Service  Corporation
    
    
     5   and Madison Gas and Electric Company, who are building the
    
    
     6   500 MW  nuclear power station at Kewaunee.  We are  also
    
    
     7   building the Columbia generating station near Portage,
    
    
     8   Columbia County, and we own 40 percent of both stations*
    
    
     9             I am pleased to have the opportunity to comment on
    
    
    10   a proposed policy for the responsible use of our water
    
    
    11   resources*  We have an interest in the development of such
    
    
    12   a policy as an electric public utility charged with the
    
    
    13   responsibility under Wisconsin law of providing electric
    
    
    14   service to its customers and also  reasonably adequate
    
    
    15   facilities to provide that service.  Wisconsin Power and
    
    
         Light Company believes that its record to date in all ways
    
    
         establishes itself as a responsible citizen in these areas.
    
    
                   j ^11 confine my remarks to the Edgewater gener-
    
    
         ating station in regard to the Lake Michigan proposed
    
    
         standards.
    
    
    21             At the outset, it may be helpful to discuss this
    
    
    22   question in the perspective of the cost implications involved
    
    
         particularly in view of the fact that there is no proven
    
    
         damage to Lake Michigan from the operation of the electric
    
    05
     '   generating plants.
    

    -------
                                                                   929
    
    
    
    
                                P, Keshishian
    
    
    
     2              Since  the last Lake Michigan conference study in
    
    
    
     3    Chicago, we have had an engineering report prepared for
    
    
    
     4    alternative cooling systems  for our Edgewater generating
    
    
    
     5    station.   The  capital  cost of installing a mechanical draft
    
    
    
     6    cooling tower  at our Edgewater station is now estimated to
    
    
    
     7    be $7,S35>000,   In addition, as a result of the decrease in
    
    
    
     8    turbine capability and requirements for auxiliary power to
    
    
    
     9    operate the towers, an additional equivalent investment of
    
    
    
    10    $6 million would be required to replace this capability and
    
    
    
    11    compensate for the additional fuel requirements.  Thus, the
    
    
    
    12    total required equivalent capital investment for the instal-
    
    
    
    13    lation and operation of these towers would be $13,^35,000,
    
    
    
    14    In addition, $200,000  per year will be required for the
    
    
    
    15    maintenance of these towers  and their auxiliary equipment
    
    
    
    16              We should also point out that to operate these
    
    
    
    17    towers it  is necessary to burn an additional 117 million
    
    
    
          pounds of  coal per year with the resulting discharge to
    
    
    
    19    the atmosphere of over 7 million pounds of sulfur dioxide
    
    
    
    20    and large  amounts of nitrogen dioxide and particulate
    
    
    
    21    matter. In the  absence of evidence that there is signifi-
    
    
    
    22    cant damage to the lake, what justification is there for
    
    
    
    23    this magnitude of expenditures and this increase in atmos-
    
    
    
          pheric pollution?
    
    
    
    25              The  Wisconsin Department of Natural Resources
    

    -------
                                 	930
     -.                           P. Keshishian
     2   determined that it would study the effects of the operations
     3   of each powerplant on Lake Michigan on a case-by-case basis.
     4   As a  result, we are currently negotiating a contract for a
     5   year-long environmental study at the Edgewater generating
     6   station to determine if any damage is occurring to the lake
     7   at this site as a result of our powerplant operations.  This
         study will obtain all the necessary information requested
     9   by the Department of Natural Resources of Wisconsin in its
    10   proposed Guidelines for Environmental Studies at Lake
    11   Michigan Thermal Discharge Sites as required under Wisconsin
    12   Administrative Code N.R. 102.04.
    13             The  question  of appropriate temperature limitations
    14   for waters discharged into Lake Michigan involves the bal-
    15   ancing of all  public rights in the use of Lake Michigan
    16   including the  industrial use of those waters provided the
    17   industrial use does not result in significant damage.
         Wisconsin Power and Light Company is  strongly opposed to
         any program  such as the imposition of an effluent require—
    20   ment  that is not based  upon actual experience that would
    21   result in substantially higher costs to Wisconsin electric
         rate  payers  without any corresponding decrease  in damage
         to Lake Michigan.
                   Thank you, Mr, Chairman and conferees.
                   MR.  MAYO:  Thank you.
                   (Mr. Keshishian1s statement follows in its
    

    -------
             STATEMENT OF WISCONSIN POWER AND LIGHT COMPANY
    
    
    
    
    
    
              My name is Paul Keshishian.  I am the Director of
    
    
    
    Power Production of the Wisconsin Power and Light Company.
    
    
    
    
              Wisconsin Power and Light Company is an investor owned,
    
    
    
    
    electric, gas and water utility.  It provides the retail electric
    
    
    
    service to 232,000 customers in over 400 communities.   It provides
    
    
    
    
    wholesale electric service to 33 communities and 5 cooperatives.
    
    
    
    Its service area occupies 15,000 square miles in central and
    
    
    
    
    southern Wisconsin with a population of almost 700,000.
    
    
    
    
              Wisconsin Power and Light Company owns and operates
    
    
    
    four fossil-fueled electric generating plants with a total
    
    
    
    
    generating capacity of 780,000 kilowatts.  One of the generating
    
    
    
    
    plants, Edgewater, with a capacity of 458,000 kilowatts, is
    
    
    
    located on Lake Michigan at Sheboygan.  Two of our plants are
    
    
    
    located in Rock County, and one is located in Grant County.
    
    
    
    
    It also owns hydroelectric facilities with a generating capacity
    
    
    
    of 51,200 kilowatts and gas turbine generating facilities with
    
    
    
    a capacity of 86,000 kilowatts.
    
    
    
              Wisconsin Power and Light Company, in partnership with
    
    
    
    Wisconsin Public Service Corporation and Madison Gas and Electric
    
    
    
    Company, is in the process of constructing a 527,000 kilowatt
    
    
    
    nuclear generating plant on Lake Michigan near Kewaunee, in
    
    
    
    
    Kewaunee County.  Operation of the Kewaunee plant is scheduled
    
    
    
    for 1973.  The same three oompanies are also constructing a
    
    
    
    
    527,000 kilowatt fossil-fueled generating plant, known as tne
    

    -------
    Columbia Generating Station, near Portage, Columbia County.
    
    
    
    Commercial operation for the Columbia Plant is scheduled for
    
    
    
    March 1, 1975.
    
    
    
              I am pleased to have the opportunity to comment on a
    
    
    
    proposed policy for the responsible use of our water resources.
    
    
    
    We have an interest in the development of such a policy as an
    
    
    
    electric public utility charged with the responsibility under
    
    
    
    Wisconsin law of providing electric service to its customers
    
    
    
    and also reasonably adequate facilities to provide that service.
    
    
    
    Wisconsin Power arid Light Company believes that its record to
    
    
    
    date in all ways establishes itself as a responsible citizen
    
    
    
    in these areas.
    
    
    
              I will confine my remarks to the Edgewater Generating
    
    
    
    Station in regard to the Lake Michigan proposed standards.
    
    
    
              At the outset, it may be helpful to discuss this
    
    
    
    question.in the perspective of the cost implications involved
    
    
    
    particularly in view of the fact that there is no proven damage
    
    
    
    to Lake Michigan from the operation of the electric generating
    
    
    
    plants.
    
    
    
              Since the last Lake Michigan conference study in
    
    
    
    Chicago, we have had an engineering report prepared for alternate
    
    
    
    cooling systems for our Edgewater Generating Station.  The capital
    
    
    
    cost of installing a mechanical draft cooling tower at our
    
    
    
    Edgewater Station is now estimated to be $7,835,000.  In addition,
    
    
    
    as a result of the decrease in turbine capability and requirements
                                   -2-
    

    -------
    for auxiliary power to operate the towers, an additional
    
    
    
    equivalent investment of $6,000,000 would be required to replace
    
    
    
    this capability and compensate for the additional fuel require-
    
    
    
    
    ments.  Thus, the total required equivalent capital investment
    
    
    
    
    for the installation and operation of these towers would be
    
    
    
    $13,835,000.  In addition, $200,000 per year will be required
    
    
    
    
    for the maintenance of these towers and their auxiliary equipment.
    
    
    
    
              We should also point out that to operate these towers
    
    
    
    it is necessary to burn an additional 117,600,000 pounds of coal
    
    
    
    
    per year with the resulting discharge to the atmosphere of over
    
    
    
    7,000,000 pounds of sulfur dioxide and large amounts of nitrogen
    
    
    
    dioxide and particulate matter.  In the absence of evidence that
                                                             i
    
    
    
    there is significant damage to the Lake, wnat just.iricata.on is
    
    
    
    
    there for this magnitude of expenditures and this increase in
    
    
    
    atmospheric pollution?
    
    
    
              The Wisconsin Department of Natural Resources determined
    
    
    
    
    that it would study the effects of the operations of each power
    
    
    
    plant on Lake Michigan on a case by case basis.  As a result,
    
    
    
    we are currently negotiating a contract for a year-long environmental
    
    
    
    study at the Edgewater Generating Station to determine if any
    
    
    
    damage is occurring to the Lake at this site as a result of our
    
    
    
    power plant operations.  This study will obtain all the necessary
    
    
    
    information requested by the Department of Natural Resources of
    
    
    
    
    Wisconsin in its proposed Guidelines for Environmental Studies at
    
    
    
    
    Lake Michigan Thermal Discharges Sites as required under Wisconsin
    
    
    
    
    Administrative Code N.R. 102.04.
    

    -------
              The question of appropriate temperature limitations for
    
    
    
    
    waters discharged into Lake Michigan involves the balancing of
    
    
    
    
    all public rights in the use of Lake. Michigan including the
    
    
    
    industrial use of those waters provided the industrial use does
    
    
    
    
    not result in significant damage.  Wisconsin Power and Light
    
    
    
    Company is strongly opposed to any program such as the imposition
    
    
    
    
    of an effluent requirement that is not based upon actual
    
    
    
    experience that would result in substantially higher costs to
    
    
    
    Wisconsin electric rate payers without any corresponding decrease
    
    
    
    
    in damage to Lake Michigan.
    

    -------
       	931
     1                           J. Rogers
     2             Any questions, gentlemen?
     3             MR. FRANGOS:  Mr. Keshishian, I have recently
     4   learned that Mr. Mayo is an old Brooklyn boy.  Maybe you
     5   fellows can get together a little bit later and talk about
     6   the  Dodgers and old timesj
     7             MR. KESHISHIAN:  I would really like to.
     8             MR. McDONALD:  Maybe Mr. Mayo ought to talk about
     9   the  East River because  it is ray understanding — I am from
    10   upstate New York originally — but I always thought that the
    11   East River was something like the Chicago River and Sanitary
    12   Ship Canal now as  far as containing fish.  Isn't it just abou
    13   devoid of fish, Mr. Mayo, so it is hard to have a fish  kill?
    14             (Laughter.)
    15             MR. FRANGOS:  Mr* Chairman,  I have a statement by
    16   Mr.  James A. Rogers,  Assistant Attorney General of Wisconsin.
    17   He asked that I  read  this  into the record,  so if you will
    IS    indulge  me,  I will read it.
    19
    20                  STATEMENT OF JAMES  A.  ROGERS,
    21                   ASSISTANT ATTORNEY GENERAL,
    22                  WISCONSIN JUSTICE  DEPARTMENT,
    23                      MADISON, WISCONSIN
    24                  (AS READ BY THOMAS G.  FRANGOS)
    25
    

    -------
                                                                   932
    
     I                            J.  Rogers
     2             MR. FRANCOS:   My name is James A,  Rogers and I  am
     3   an Assistant Attorney General of Wisconsin.   I work in a
     4   division of the State Justice Department that specializes
     5   in environmental matters, and in that capacity I have par-
     6   ticipated in a lengthy Atomic Energy Commission Safety and
     7   Licensing Board hearing on Wisconsin Electric Power Company's
     S   application to operate Unit 2 of the Point Beach nuclear
     9   powerplant.  This plant is located near Manitowoc, Wiscon-
    10   sin.  I am speaking today only in behalf of the Justice
    11   Department.
    12             One of the major issues in those proceedings,
    13   defined most broadly, was whether the water discharged from
    14   the  plant at a  substantially higer temperature than
    15   ambient,  would  cause "pollution," and,  if so, what should
    16   be done about it,
    17             It would be  improper at this  time to attempt to
    1&   publicly  generalize as to what the  evidence showed;  it is
    !9   proper and  important,  however, to ask what  evidence  exists
    20   that was  not presented.  Specifically,  I feel that if the
    21   United States  Environmental Protection  Agency possesses
    22    information which is relevant to the environmental issues
    23    posed by  the operation of a specific nuclear powerplant
    2/f    sited on Lake Michigan or by the operation of such plants
    25    as a group, it is desirable to have that Agency present
    

    -------
        	933
     I                            J, Rogers
     2   this information, either as an advocate for intervenors or
     3   applicants, or as a friend of the court, so that the decision
     4   of the Atomic Energy Commission hearing panel may be more
     5   intelligently made.  Even testimony to the effect that the
     6   findings are contradictory or that specialists within the
     7   Agency disagree would be valuable*
     8             There was great frustration experienced by our
     9   office in the Point Beach hearings, and to some extent it
    10   was  caused  by the Environmental Protection Agency's
    11   tantalizing criticisms  of the scientific approach being
    12   taken by Applicant power company, by warnings of dangers,
    13   and  by the  suggestion that the Agency would indeed become
    14   involved in the  hearing.
    15             In the Environmental Protection Agency's comments
    1^   to Environmental Impact Statement for Point Beach, dated
    17   March  22, 1972,  the Agency reiterated the position that
    1^   Point  Beach would  not be in  compliance with the recommenda-
    19   tions  of the  Lake  Michigan Enforcement  Conference, and in
    20    detailed  comments  suggested  several  possible  ways  in which
    21    the  thermal effluent would damage Lake Michigan's  ecology.
    22    For example,  the comments  said thats
    23              "Research performed at the Environmental Protectior
    2/l"    Agency's National Water Quality Laboratory in Duluth,
    2^    Minnesota,  indicates that  reproductive ability may be
    

    -------
                                                                   934
     1                            J.  Rogers
     2   impaired in fish exposed to  elevated water temperatures.
     3   ... [T]he effluent from the  Point Beach plant  could signi-
     4   ficantly reduce the reproductive success of yellow perch
     5   attracted to the plume."
     5             It was hoped by our office that such evidence
     7   would be offered by the EPA and subjected to adversary
     8   scrutiny, a hope that had been encouraged by the Agency's
     9   filing of a notice of limited appearance.  But the only EPA
    10   witness who appeared at the hearing was under subpoena by
    11   the private intervenors.  The confusion was heightened
    12   somewhat when, on August 10 of this year, Mr. Mayo sent a
    13   letter to the  Chairman of the Atomic Energy Commission
    14   hearing panel  stating:
    15             "This Agency  ...  continues to urge that Point
    16   Beach Unit  No. 2 have a  closed-cycle cooling system in
    17   accordance  with the recommendations of the  [Lake Michigan]
    1#   Enforcement Conference."
    19              It also  stated that EPA would forego  appearance
    20 |  at the  Point Beach hearings until after this  session  of
    21   the Enforcement Conference.
    22              The  point of all  this is  that,  especially in the
         wake of recent court decisions   broadening Atomic Energy
          Commission obligations in the environmental field,  the
          licensing proceedings before the Atomic Energy Commission
    

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         	935
                                 J. Rogers
     2   are the fora in which environmental challenges can be
     3   directly responded to with enforceable orders of the Atomic
         Energy Commission, either conditioning the granting of
     5   licenses or, in theory, denying the license application
     6   altogether.  It is at these Atomic Energy Commission hearings
     7   that data in the possession of the Environmental Protection
     g   Agency will have its most telling impact.
     9             While my remarks may be taken as severe criticism
    10   of EPA's role in the Lake Michigan thermal question, I would
    11   rather characterize it as a request to that broadly-based
    12   and well-funded Agency to assist those struggling State
    13   agencies to get an initial grasp of this problem.  The
    14   Environmental Protection Agency has repeatedly shown an
    15   ability to make a sophisticated scientific analysis of
    16   important  environmental questions and I have merely assumed
    17   that  studies of this  caliber  have been made of the thermal
    13   question.
    19              End  of  statement.
    20              Mr.  Chairman, I would also  like to  submit  for
    21    the record a  statement by Mrs. Miriam Dahl  on thermal  dis-
    22    charges  into Lake Michigan.
    23              ^The document above referred to  follows in its
    2L
     *    entirety.)
    

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                                               SbPX.U
    14 «* S **                                                Q3K fQft
    wf «T;i«»l>
    Mr. Chairman ;Confei-©ea;  Ladies and G*ntl«aen:
    1 aa Mir las O.Uahl.   I represent today the .^iaconsln &tat« ^Ivlaion of
    the Isaek  «a  Ifeon  i-eague of America which has 22 Chapters representing a
    grass roots opinion  fro® the State.
    
    The Wisconsin -Division baa in previous statements takes a positio»
    promoting  economic health and progress.  ^e hallev© the only
    course of  survival of such eeonosiio health 1* «? much s*lser apprQaeh to
    our past and  present flagrant use of irreplaceable resources and to atop
    the continuing abase of our
     In line with this  thinking,  a© have previously proposed studies using
    »@w approaehee and theories  as well as the usual ajethode to find new and
     i&te ways  to use the resources we have.  Cotieensit^ wee of the atomic
    «««rgi©8 fsethods of pro<3uQliig electric possrep, testing has not been ade-
     quate to reassure, even partially, ttoe proper sMithods of use, let alone
     the safeguards to  protect fron possible accidental holocaust*  ftee nort
        b©en to  4^ ahead and s@e what fesppfsus.  If wfeat happ0B« i» i
          IB destruction and/or  sau tat Ions, that Is too bewl.  Juat go
    0i©po@al  of  radioactive  wsstes have eot been solved satisfactorily.  So
    ishrt?  w® are  toM  that  people ^aut p©ak <3eaiatt4s «et no saatter at what
    cost.  This  oould barai^ b® l«t«rpret«a as httaltlyr eooooalos la any sense.
    The discharge  of  heated  -?ater Into the waterways, in tills ease into
    Lake -ilohlgan  ha a been contested in the courts.  The aoxtey spent to gain
     .•e-rsaldsion  to  go  ahead with the discharge as stated at the original 20*
    u0aid have  beext uaed  to  research methods of reducing the temperature
    to a lower  level,  but the old aetho^a of operation still persist IB the
    eoocoay even though OB a sore sophisticated level.
    ID our position state a«nt the yiBConsin Di vision of Izaak «alton League
    stated; that we believe  a  1*  difference in temperature oan be achieved
    ar*d should b© a goal vfithin  tbe near future IF the research project is
    pursued with the same deter-alnation as the action to preserve the 20*
    figure. ;* preeeut 4* allowance Mould be adequate- for present use and
    would cot hurt the ecology accord lag to present findings.  *e have bees
    told that a 5* teaper®tuure couia be achieved 2 years ago. We deplore the
    allowase© of the 20*.   ffeie  mums th -t progress in the last 3 years has
    bemi nil. in this area.  It is certainly not what ite expected,  'the ex-
    penditures have been for  a holding aofion,  Hot for the forwana thrust.
    We have lost the preeioue aosnuxlities of ti»©,aoney and researeh iafoi?-
    aatlon.
    The threatened laolt of  electrical energy last euHMier did uot occur.  The
    ^iscorjain £leotrio Power Goaipaay t  aooordlng to news releases purchased
    th« extra power needed  from another ooapany.  Ko eurtailtsest o» lose of
              experienced.
    Policy changes in sdvortising of  Power Companlea has been useful in show-
    Ing the public how it can best use electric  power.  This is a step in the
    right direction,  mother great step would be to charge the sliding scale
    rates to industrial users so that it would not r*iy less for using sore
    power. **ior» eff iciest use of industrial  power would effect great savings
    This should fee reviewed in every  industrial  plant.  Waste of aore than
        in sosae eases oan be eliminated.
    

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    Lighting up downtown areas to sunlight  intensity during the night
    can be better controlled.  Me do HOT tueed to atop lighting, even display
    light Ing, but It IB sew overdone and can be vodlfled.  Streets must too
    illuminated, 80ao more than they are.  Public buildings have overllghtlng
    of auoh brilliance that It Is tiring, if not Injurious to the eyes.  The
    heat generated must be dissipated by sore cooling energy.  Recently to
    a convention halll asked that only 1/2 of the GlifssCBS&ytX lights be
    extinguished.  It was done.  Everyone had good via Ion and conducted busi-
    ness as usual,  flany people later reaarked that they felt less sleepy
    and more comfortable.  Sueh changes oan be made immediately and would
    result in providing "extra power resources*  when needed.
    
    Innovative seasures are needed.  To continue pragmatically refusing to
    try so®e of tint suggest ions is to refuse healthy economic progress is
    proper use of our resources.  Laws emu, of course help, b ut laws are sot
    needed by pr&9%loal business sea with aosae inagi native sis ion who want
    to achieve the same ecological world for which we work. We believe the
    power company off iciala are such aen.
    
    f)ie large hurdle Is the change of approach to our problems.  OBoe over
    thatt we oaa devote our energies and funds to finding the answers to
    safe uses of nuelea r sources and to reducing the hear discharges,
       eharge this Conference with the responsibility to protect the waters
    from the condesmatiotj of such high heat additions.  At the same tiae,
    we charge our State of Wisconsin with the responsibility of re-evalua-
    ting its position on this same problem.
                                           Respectfully submitted,
                                           Chr. Water Pollution Committee
                                           Wisoonein State Division of the
                                           Izaak Walton League of America.
      September 19,1972.
    

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                                  	936
    
    
    
    
     1                            T, Frangos
    
    
    
     2
    
    
     3                 STATEMENT OF THOMAS G.  FRANGOS,
    
    
    
     4      ADMINISTRATOR, DIVISION OF ENVIRONMENTAL PROTECTION,
    
    
    
     5           WISCONSIN DEPARTMENT OF  NATURAL RESOURCES,
    
    
    
     6                      MADISON, WISCONSIN
    
    
    
     7
    
    
     #             MR. FRANGOS:  At this time, I would like to read a
    
    
    
     9   2-page statement by the Department of Natural Resources, and
    
    
    
    10   i think at this point in time it is easier for me to read
    
    
    
    11   it rather than try to paraphrase it.
    
    
    12             in the summer of 1971, the Wisconsin Department of
    
    
    
    13   Natural Resources held a public hearing to consider revising
    
    
    
    14   thermal standards for Lake Michigan to conform with the
    
    
    15   recommendations of the Lake Michigan Enforcement Conference.
    
    
    16   Following the hearing, oral agreements were presented to a
    
    
    17   quorum of the Natural Resources Board by representatives of
    
    
    1^   the utilities, environmental groups, and the U.S. Environ-
    
    
    •^   mental Protection Agency.  The Environmental Quality Committe
    
    
    
    20   of the Board reviewed the  transcript of the public hearing,
    
    
    
    21   took  cognizance of the oral presentation, and discussed the
    
    
    
    22   proposed standards with  staff members of the Department.
    
    
    23
         The committee's conclusions reached  in the fall of 1971 are
    
    
    24
         as follows:
    
    25
                   "The problem of  heat discharges is complex
    

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        	937
     j_                            T. Frangos
     2   involving not only the scientific data required to establish
     3   criteria, but also the social and economic considerations
     4   that must be evaluated in establishing standards and provid-
     5   ing preventive and corrective measures.  Based on our review
     6   of the information presented, we are of the opinion that much
     7   is unknown about the effects of thermal discharges and about
     #   the environmental impact of corrective works or methods that
     9   may be employed to reduce the quantity of heat discharged,
    10   However, because of the increased possibility of damage to
    11   Lake Michigan from proliferation of powerplants, the
    12   committee believes that it is sound public policy to prohibit
    13   thermal  discharge from plants not now operating, operable,
    14   or under construction until questions we and others have
    15   raised have  been answered.  The  committee holds that the
    16    financial burden to  establish the impact of heated dis-
    17    charges  rests on the  industry.
    18             "A 2-year  study  conducted at the various power-
    19   plant  sites  on  Lake Michigan together with data now being
    20    obtained from several  other  studies,  should provide data
    21    on which rational  decisions  as  to proper  corrective measures
    22    to be taken can be based.  These studies will  be  conducted
    23    by the industry and will be  designed and  supervised by the
          Department.
    25              «in the meantime,  the Department  will be
    

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              	933
     ,                             T.  Frangos
     2   conducting its own investigations,  including further evalua-
     3   tion of the environmental problems associated with cooling
     4   towers or cooling ponds.
     5             "Further, we would reserve to the Board and the
     6   Department the right to take immediate remedial action should
     7   it be determined at any time during the 2-year study period
     &   that environmental damage appears imminent or existent.
     9             "This provision, coupled with a moratorium on the
    10   siting of additional plants on Lake Michigan, satisfies the
    11   committee that the quality of the lake can and will be main-
    12   tained to best serve the public interest."
    13             The Natural Resources Board approved the revised
    14   thermal  standards  on December B, 1971*  They were published
    15   in the January 1972 Register and became effective on February
    16   1,  1972.  As part  of the Wisconsin Administrative Code, the
    17   standards have the force and effect  of law.
                   fhe new  thermal standards  establish monthly maximum
         temperature criteria and a  limit of  3° F.  over the  existing
    20   temperature of the receiving water at the  edge of an  estab-
    21   lished mixing  zone.  Milwaukee  Harbor, Port Washington Har-
    22   bor and  the mouth  of the Fox Fiver are exempted  from  the
         monthly  maximums because of the naturally  occurring higher
         temperatures.
                    j-or existing or  soon-to-be completed facilities
    

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     5
     6
     7
     a
    10
    11
    12
    13
    14
    15
    16
    17
    19
    20
    21
    22
    23
    24
    25
    	939
    
                             T. Frangos
     that exceed a discharge  of  500 million B.t.u. per hour, it
     is required that  the  owners submit monthly reports of temper-
     ature and flow data,  a detailed  chemical analysis of blow-
     down waters,  a preliminary  engineering report for the instal-
     lation of alternative cool:n^ systems, and the  findings of
     a 2-year study of the environmental  and ecological impact
     of the discharges.  The  environmental study  must be conducted
     in a manner approved by  the Department and it will aid in
     the establishment of a mixing zone.
               Any new facility  must  be designed  so  as to  avoid
     significant thermal discharge to Lake Michigan, and  should
     existing discharges appear  to threaten or  cause environ-
     mental damage, the Department may order  the  reduction of
     thermal input regardless of interim measures undertaken  by
     the source owners.
               The Department of Natural Resources immediately
     notified the affected utilities of the reporting requirements
     of  the new thermal standards.  In addition,  a committee was
     formed to develop guidelines for Environmental Studies at
     Lake Michigan Thermal Discharge Sites. Included in the com-
     mittee were  two  representatives from UW-Madison, two
     representatives  from UW-Milwaukee and one representative
      from UW-Green Bay.   Copies of the guidelines, which are
      attached, were distributed to Wisconsin utilities and
    

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     1
     2
     3
     4
     5
     6
     7
     9
    10
    11
    12
    13
    14
    15
    16
    17
    18
    19
    20
    21
    22
    23
    24
    25
    	940
                             T. Frangos
     subsequent meetings were held by DNR to determine the
     adequacy of the utilities' proposed environmental studies.
              At the present time, all of the reporting and
     environmental  study requirements of the Wisconsin thermal
     standards are  being complied with.  An attached status
     report lists the involved powerplants and the dates various
     reports were received and preliminary study plans approved.
              I would like to make the attachments also a part
     of  the record.
              MR. MAYOi  Do you have copies of the attachments
    with you?
              MR. FRANGOS:  Yes.  I thought those were dis-
    tributed, Mr. Mayo.  I have additional ones though if you
    would like.
              MR. MAYO:  I just wanted to make sure they were
    available  for the record.
              MR. FRANGOS:  I believe that concludes the
    Wisconsin presentation.
               (The documents above referred to follow in their
    entirety.)
    

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    Unit
    
    Edgewater
    
    Kewaunee
    
    Pulliam
    
    Point Beach
    
    Oak Creek
    
    Lakeside
    
    Port Washington
    
    Valley
                          STATUS OF WISCONSIN POWER PLANTS
    
                      IN MEETING LAKE MICHIGAN THERMAL STANDARDS
    
                                  SEPTEMBER 5, 1972
                                                            Monthly
             Preliminary  Chcmicr.l Analysis  DNR Approval  Operating
    Utility  Eng. Report   BlowcHvm Waters    Env.  Study    Reports
    WPL
    WPS
    WPS
    WEP
    WEP
    WEP
    WEP
    WEP
    8/31/72
    8/2/72
    8/2/72
    8/1/72
    8/1/72
    8/1/72
    N/A
    N/A
                               3/9/72
    
                             Nuc.lear Plant
    
                               8/2/72
    
                             Nuclear Plant
    
                               7/31/72
    
                               7/31/72
    
                               7/31/72
    
                               7/31/72
    7/19/72 .       Yes
    
    6/14/72   Not in Operation
    6/13/72
    9/5/72
    9/5/72
    9/5/72
    N/A
    N/A
    Yes
    Yes
    Yes
    Yes
    Yes
    Yes
              N/A - Not applicable since not  required  in administrative  code.
    
              WPL - Wisconsin Pov:er and Light Company
    
              WPS - Wisconsin Public Service  Corporation
    
              WEP - Wisconsin Electric  Power  Company
    JRM:mn
    

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        WISCONSIN  ADMINISTRATIVE  CODE
    
                  NATURAL  RESOURCES
       102.04 Lake Michigan  thermal  standards.  For  Lake
    Michigan the following  thermal  standards are established
    so  as  to minimize effects on  the  aquatic  biota in the
    receiving waters.
       (I)  (a) Thermal discharges shall not raise  the receiving
    water  temperature more than 3 degrees F. at the bound-
    ary of mixing zones established by the department.
       (b)  In addition to the limitation set forth  in subsection
    (1) (a); but excepting the Milwaukee  Harbor, Port Wash-
    ington Harbor  and the mouth of the  Fox River, thermal
    discharges shall not raise the  temperature of the icceiving
    waters at the boundary of the  established mixing zones
    above  the following limits:
       January   	  45 degrees F.
       February  	  45 degrees F.
       March 	  45 degrees F.
       April  	  55 degrees F.
       May  	  60 degrees F.
       June  	  70 degrees F.
       July  	  80 degrees F.
       August  	  80 degrees F.
       September   	  80 degrees F.
       October   	  65 degrees F.
       November 	  60 degrees F.
       December  	  50 degrees F.
       (2)'All owners utilizing, maintaining  or presently con-
    structing sources  of  thermal discharges exceeding a  daily
    average of 500  million BTU per hour shall:
       (a) Submit monthly  reports  of temperature and  flow
    data on forms  prescribed by the department commencing
    60 days after the  effective date of this rule.
       (b)  Within 24 months of the effective date of this rule,
    complete an  investigation and study of the environmental
    and  ecological  impact  of such  discharge  in  a  manner
    approved  by  the department.  After a  review  of the
    ecological and  environmental  impact  of the discharge,
    mixing zones shall be established  by  the department.
       (c) Submit to the department within 6 months of the
    effective  date of this rule a preliminary engineering report
    for the installation of alternative  cooling systems.
       (d)  Submit within 6  months  of  the  effective  date of
    this rule  a  detailed chemical analysis of blowdown waters
    discharged to Lake Michigan and  its tributaries.
       (3)  Any plant  or facility, the  construction of which is
    commenced after the effective date of this rule,  shall be
    so designed as  to avoid significant  thermal  discharge to
    Lake Michigan.
       (4)  The  department  may order the reduction  of  ther-
    mal  discharges  to Lake Michigan regardless of interim
    measures undertaken by the source owners in compliance
    with this rule if environmental damage appears imminent
    or existent.
       (5) The  provisions of this rule are not applicable to
    municipal waste and water treatment plants and vessels.
    

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                    Wisconsin ).X:partr.ent of Natural Rcnources
                      Division of'Environmental Protection
                  LAKE MICHIGAN - TilERMAL I1TACT INVESTIGATIONS
    
                                GENERAL CO'-raiJTS
    An investigation or study of the environmental and ecological ir.pact of
    thernal discharges that exceed one half billion BTU's per hour to Lake
    Michigan is required by the new thermal standards.  Pover plants vhich
    are to conduct the studies are:
    
          Point Beach Nuclear Plant, Wisconsin Electric Pover Conroany
          Kevaunec Nuclear Plant, Wisconsin Puolic Service Corporation
          Oak Creek Plant, Wisconsin Electric Power Company
          Lakeside Plant, Wisconsin Electric Pover Company
          Edgcvater Plant, Wisconsin Pover and_Light Company
          Pullian Plant, Wisconsin Public Service Corporation
    
    The studies are to be prepared in a manner approved by the Department, and
    the report covering the results nust be submitted vithin 2k months of the
    effective date of the thermal standards (January 31, 197*0.  All studies
    are to be conducted in a manner such that the data obtained provides an
    accurate and quantitative description of the phenomena under investigation.
    These investigations shall include studies specifically designed tc3 evaluate
    the variability of the data obtained and, therefore, the expected Tjrecision
    vith vhich a predicted or measured effect is estimated or determined.
    The analytical and other methods used for measurements shall be in accord
    vith methods that are known to give a high degree of reliability under the
    conditions used in this study.
    
    The studies should be conducted in a manner so that a quarterly review of
    the data collected is made by the investigator,  Any particular problems
    indicated by this quarterly reviev should be brought to the Department of
    liatural Resources for possible advice and assistance.  It is imperative
    that an active data reviev be conducted during the course of the study
    and adjustments of the study planned in accord vith the findings of the
    previous period.
    
    Attached are specific guidelines for these thermal impact investigations.
    JRMtjm
    3-29-72
    Attachment
    

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                         Guidelines  for  Environmental  Studies
                       at Lake  Michigan  Thermal  Discharge  Sites
    I.        Predictive  Model  and Measurement  of  Existing Temperature and
              Velocity  Structure  of  the  Thermal Plume Under  Prescribed Boundary
              Conditions.
    
                 At  those  installations  where  thermal discharges are in effect
    today,-field measurements  of the  thermal plume  should be made.  At new
    or  soon  to operate facilities,  mathematical models of the expected thermal
    discharge plume  should  be  developed.
    
           These studies should:
    
              a.  .Present expected temperature  iso'j ines for  the thermal plume
    from  the  point of  discharge  in  the  lake to the  2° FJlT  isoline  (i.e.
    above  the au.bient) ,  The  isolines should be computed for at least 2° F
    intervals.  These  computations  should  be made for the expected  temperature
    distribution at  least eight  times throughout  a  year, twice during each
    season,  and should include the  sinking plume  conditions that may develop
    each winter.  Consideration  should  be  given to  the potential effects of
    lake  currents and  stratification  on the shape and extent of the thermal
    discharge plume.
    
              b.  Present velocity contours in  the thr.rr.al disrhrrgc plvtr.e
    along with estimates or measurements of the tine-temperature relationship
    that would exist in  the discharge plume.   Data  should also be provided
    on  the tir.ic from the point where  the water enters the condenser until
    it  is discharged to  the lake.
    
              c.  Estimates  should be made  of the  amount of entrainment of lake
    water by  the discharge  plume,   i.e.  estimate  the dilution of the heated
    effluent  that will occur.
    
              d.  Estimate the  amount of  recycle of  water that will occur during
    winter operating conditions  when a  portion of the discharge water is
    returned  to the intake  in  order to  prevent freezing.
    
              e.  Measure ambient water  temperature  conditions in the region
    of  the discharge in order  to establish the temperature and rate of change
    of  temperature under the normal and  extreme meteorological conditions
    that may  exist in that area.
    
                 The definition  of existing plumes  should include consideration
    of  the use of drogues and  aerial photography  temperature imagery in order
    to  define plume conditions.  All air-borne temperature studies should be
    made with ground truth observations  in order  to  check the reliabil : ':y
    of  them.   During all thermal plume studies, an  accurate record sho/ d be
    kept of the intake and discharge temperatures as  well as at least hourly
    readings  of plant load and discharge.  This data  should be collected for
    

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                                        - 2 ~
    
    
    at least the period (> hours prior to the initiation  of  the special  purpose
    study.  Also the meteorological condition:", should bo  read at at -least
    hourly  intervals during the special purpose  studies  on  the plumes.   It
    will be important to try to define  rno plume characteristics as  a  function
    of plant operating condition.'; and meteorological conditions.  All  plant,
    lake and meteorological factors that are likely to influence the shape
    and extent of the plu:::e should be monitored  prior to  and during  any study
    on the  characteristics of the plume.
    
    II.      Environmental Considerations
    
             A.  Sampling station locations should be established using a
    grid system, and each station should be marked with  a permanent  buoy.
    In lieu of this requirement, shipboard or land based  navigation  may be
    used provided that it accurately locates the sampling stations used in
    the study.  The sampling grid should provide a sufficient number of samples
    to accurately describe aquatic organisms and water quality characteristics
    within  and in the area adjacent to  the thermal discharge plume.  Where
    possible, sampling stations within  the plume shall be established at the
    2° F'f isolir.es.
             B.  The parameters and frequency of sampling used in these  studies
    shall be chosen to give a known degree of precision for each potentially
    significant effect of the thermal discharge on water quality in  the  region
    of discharge and Lake Michigan as a whole.  The degree of precision  shall
    be such that it is normally attainable with the best technology  available
    f"OflflV   rrMi'> 1° m7p c t -i c*n t-riT- chf''!''' l-oo-^ aKT-^^cf r\ f r\o-\-ra 1 or>-tia n t- c =r>r! TIC.TT
        •>   -"' ~~   --•->'    .........   r         -- -- ---- r --------     ----- %
    technology In this area and incorporate them into the study where  it  is
    found that the now technology may significantly improve the ability  to
    detect the effects of thermal discharges on water quality.  If a change
    is made in the analytical procedure during the course of this study,  a
    limited scope study should be conducted in order to establish within a
    reasonable degree of certainty the relationship between the measurements
    made with the old and new analytical procedure.
    
                 The frequency and location of sampling shall be done  in a
    manner so as to detect any potentially significant effect of the thermal
    discharge on water quality.  The investigator should establish a tower
    in the lake for noniteriuq- meteorological and ambient lake conditions
    in the region of the discharge plume.  This meteorological station should
    be equipped with instruments for measurements, at a minimum, of, wind
    speed and direction, air temperature, dew point, solar radiation,  net
    radiation, water temperature and currents at various depths, wave  heights
    and frequencies and lake levels.
    

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                                        - 3 -
                 1.  Fish
    
                     (i)    Sample at least eight times per year; twice during
                            each season as a minimum.
    
                     (ii)   Fishery personnel to determine most appropriate
                            techniques for collection.
    
                     (iii)  Record number of species, length, weight, and
                            collect scale sample for aging.
    
                     (iv)   Spawning areas and activities:  Numbers and types
                            of juvenile fish found in the area.
    
                 The objective of the fish studies shall be to determine the
    numbers, types, characteristics and activities of the fish populations
    of existing or proposed thermal discharge plumes.  Particular attention
    shall be given to the affect of the plume on the distributions of fish
    populations for each season of the year.   Information on the numbers
    and types of fish found in the discharge  plume at various times of the
    year is essential.   Particular note should be made of the potential effects
    of the thermal discharge plume on fish migration.  Doef  the plume inhibit
    fish migration?  Are fish prevented from  returning to selected areas for
    spawning in the region of the plume?   Finally,  the effects of the intake
    on fish populations shall be determined.
    
                 2.  Benthic Macro Invertebrates
    
                     (i)     Bimonthly collections at permanent stations.
                            Sufficient numbers of samples  shall be taken at
                            any one location  to  detect potentially significant
                            changes in the numbers  and types of macro
                            invertebrates  between sampling locations and sampling
                            dates.
    
                     (ii)    Sampling  equipment will  be determined by bottom
                            type,  and  shall provide  representative samples of
                            the bottom fauna.  All  benthic fauna retained in
                            a  No.  30  mesh  sieve  shall be enumerated and
                            identified to  genera where possible.
    
                 3.  Plankton
    
                     (i)     Collections to be  made  over at least a one week
                            period  of  intensive  study in spring,  summer and
                            fall  and where possible  in the winter, at permanent
                            stations.
    
                     (ii)    Utilize standard collection techniques which record
                            volume  of  water sampled.
    
                     (iii)   Record  percent composition and chlorophyll content.
    

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                 Zooplankton may be collected by towing metering zooplankton
    nets, using conditions which nrc known to give reliable estimates of
    zooplankton population in the area being sampled.  The phytoplankton shall
    be collected by discrete water sampling, i.e., do not use nets.  The depth
    of sampling for the plankton shall be chosen to give an accurate estimate
    of the plankton populations in the region being sampled.  The plankton
    shall be enumerated and identified to At least genera (identify major species)
    where possible with emphasis on food chain relationships.
    
                 A.  Attached Algae, Macrophytes and Periphyton
    
                    'The amount and types of attached algae, macrophytes and
    periphyton within the discharge plume and adjacent areas shall be determined
    during the late spring, mid-suir.rr.er and early fall.  This type of sampling
    is often best done by divers and manual collection.  Record the amounts
    of benthic algc. : found in terms of mass per square meter of bottom.
    Sufficient numbers of.samples should be taken at any one location to provide
    a reliable estimate with a known degree of precision in the sampling area
    in order to detect the high degree of reliability differences in the benthic
    algae biomass between sampling locations at: any one sampling time and
    between sampling times.  Consideration should be given to the use of artificial
    substrates whic'; should be placed in the thermal plume discharge area and
    in adjacent areas in order to ascertain whether there might be a change in
    the periphyton as a result of the discharge.
    
                 5.  Bacteriological
    
                     To be collected every month in season if appropriate.
    Fecal coli.form, fecal streptococci and total plate count should be made.
    
                 6.  Water Temperature and Currents
    
                     (i)    Continuous monitoring, of intake and effluent.
    
                     (ii)   Profiles at one foot depth intervals at permanent
                            stations every two weeks with due allowance for
                            adverse weather conditions.  Note that surface and
                            subsurface drogues, coupled with aerial photography,
                            could provide a synoptic picture of the current
                            patterns.
    
                 7.  Water Chemistry
    
                     (i)    Dissolved oxygen profiles to be made every two
                            veeks at permanent 'stations.   Define extent of
                            dissolved oxygen supersaturation in the thermal
                            discharge plume.   Determine area of thermal
                            discharge plume with 110 percent or greater dissolved
                            oxygen-dissolved nitrogen supersaturation.   Estimate
                            dissolved nitrogen supersaturation.  Detc'...ine
                            area for each season.   The fish sampling should
                            take special note of the areas with 110 percent or
    

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                            -  5  -
               greater  dissolved  oxygen-dissolved nitrogen
               superraturation.   The  numbers  and types of fish
               within this  area should  be  determined  if at all
               possible, especially during the winter period.
    
        (ii)   Residual chlorine  if used for  algae control in the
               system.  Measure total and  free available chlorine
               in the thermal discharge  plume using aniperometric
               procedure.   Determine  areas where total chlorine
               exceeds  5/tcp,/l in  the  discharge plume at various
               seasons  of the year.
    
        (iii)  Dissolved copper,  cadmium and  zinc if present in
               the discharge to be measured at monthly intervals.
               Four times a year  detsrmine mercury, boron, arsenic,
               iron, chromium, nickel,  lead and manganese in the
               thermal  discharge  of the power plant.
    
        (iv)   A complete list of all chemicals used at the plant
               which could  potentially be  in  the discharge should
               be provided.  At quarterly  intervals, the amounts
               of these chemicals present  in  the discharge should
               be determined.
    
        (v)    Nutrient series and other chemical parameters
               (total inorganic nitrogen,  total organic carbon,
               specific conductance,  sodium, potassium, fluoride.
               sulfate,  silicon, color, turbidity,  BOD, ammonia,
               nitrate,  nitrite, total phosphorus,  soluble
               phosphorus,  pH, hardness and alkalinity) to be
               collected at designated permanent stations once
               a month.   Samples should be collected one foot
               below the surface,  mid-depth, and one foot above
               the bottom where appropriate.
    
    8.  Bottom and Sediments
    
        (i)    The lake  bottom topography  should be mapped in
               the vicinity of the outfall at least four times
               per year  (once per season).
    
        (ii)   Sediment  movements  and the  type and  characteristics
               of the sediments should be determined in the  outfall
               vicinity.
    

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                                         -  6  -
    III.     Special Studies
    
             a.  Effect on  fish  fry,  fish  eggs and plankton by passage through
                 condenser.
    
                 All special  purpose  studies  designed  to simulate the passage of
    materials  through the condensers  shouid use a time- temperature relationship
    which is typical for  that  found in  the discharge waters from the point of
    the condenser to the  discernnble  edge  of  the thermal plur;e.  Actual sampling
    of the condenser discharge water  should be done in a manner such that it
    is representative of  the water mass.   The organisms should be held for
    a sufficiently  'tone period of time  to  detect any substantial changes that
    might occur as  a result of damage in passing through the condenser.
    
             b.  Effects  of intake structures on aquatic life.
    
             c.  Estimate cost and potential beneficial uses of waste heated
                 water.
    
             d.  Estimate cost and potential detrimental effects of alternate
                 methods  of c'ooling on  environmental quality.
    
    IV. .     Other  Factors to Consider
    
             Consider,  and where possible, evaluate any other discharges in
    the region of the plant which might influence water quality in the thermal
    pi '.imp rlicrrh.^rg? =re?..  An accursts rccor- shall be kept
    of chemicals to Lake Michigan  in the region of thp discharge plume area.
    This should incJude vsters which have been in contact with ash pits for
    fossil fuel plants, boiler and other blowdown waters, cooling tower
    Slowdown  if they are used, discharge of sanitary waste, etc.  The concentrations,
    total amounts, frequency of discharge, and volumes should be recorded in
    order to assess the total load and possible significance of the various
    chemicals added to the lake on water quality in the region of the plant.
    JKM:jmm
    3-22-72
    

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                               	941
                               P.  Oppenheimer
                  MR.  CURRIE:  Mr. Chairman,  there  is  one  additional
     3   witness who wished to  make a statement  from Illinois.   I  was
     4
     5
     6
     7
     9
    10
    11
    12
    13
    14
    15
    16
    17
    1*
    19
    20
    21
    22
    23
    24
    25
    not aware of him when I called for additional witnesses.
    Four minutes, I am told.
    
                  STATEMENT OF PAUL OPPENHEIMER,
              HYDE PARK-KENWOOD COMMUNITY CONFERENCE,
                        CHICAGO,  ILLINOIS
              MR. OPPENHEIMERs  Mr. Chairman, members of the
    conference.  I am Paul Oppenheimer and I am making this
    statement for the Hyde Park-Kenwood Community Conference.
    We have over 2,000 member families.
              I swim in Lake Michigan almost every day from late
    spring to fall for the last 30 years.  In the forties and
    early fifties the water was as clear as a mountain stream,
    and  you could see right down to the bottom along the shore.
    Today when I swim under water I can hardly see my own hands.
              Thanks to the fact that United States Steel and
    the  other industrial  law violators use Lake Michigan as  a
    dump for their waste  materials, we have  slimy and slippery
    algae growing all over the  rocks at the  shore and on the
    lake bottom, announcing the high degree  to which Lake
    Michigan has gone down the  drain already.  It is not unusual
    

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        	942
     I                          P. Oppenheimer
     2   for United States Steel to spend large suras of money for
     3   advertising, money they should spend to  remove their waste
     4   materials.  A number of municipalities throw their untreated
     5   or half-treated wastes into the lake, too.  The poor, starv-
     6   ing millionaires of Highland Park, for instance, could not
     7   afford to build a satisfactory treatment plant.  They prefer
         to watch from their $200,000 mansions high up on the shore
     9   when their own excrements flow undisturbed into the lake.
    10   (Laughter)
    11             Now, to top it all, half a dozen utilities want
    12   to build nuclear powerplants which are designed to use
    13   tremendous quantities of lake water and want to dump it
    14   back into the lake, heated up some 20°.  There can be no
    15   doubt that, added to the already  existing and continuing
    16   abuse of Lake Michigan, this will, in the long run, make
    17   Lake Michigan unfit to  support life, destroy recreational
         activities along its shores, and  endanger our drinking
    19   water.
    20             Besides, these atomic reactors  are not  even  safe.
    21   Many prominent  scientists,  including A.EC  staff members
    22   have testified  to  their belief that  the  emergency core  cool-
         ing system  as it  exists today will not  cool the  core in
         time to prevent melting down, and consequent  release of
    2 5   fatally high concentrations of radioactive  gases.
    

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                                               	943
    
    
    
    
      •i                           P.  Oppenheimer
    
    
    
      2              If constructed at  all,  nuclear  powerplants  should
    
    
    
          be on sites away from the  lake.   They should never be allowed
    
    
    
          to damage the lake  by returning heated water into it.   The
    
    
    
          Council on Environmental Quality  states in  its  latest report
    
    
    
          that $267 billion will be needed over  the  next 10 years  to
    
    
    
          keep pollution under control,  with a  cost of $100 to  every
    
    
    
      g  j  individual taxpayer.   May  I  ask:   What sense does it  make
    
    
    
      9    to give the utilities license  to  misuse and damage the  lake,
    
    
    
    10    make millions of dollars in  profits in the  process, and then
    
    
    
    11    have the taxpayers  spend dollars  in the billions to repair
    
    
    
    12    the damage do^-o by  the issue of licenses  which  should not
    
    
    
    13    have been issued in the first  place?   All I can say is  that
    
    
    
    14    these utilities don't seem to  hesitate to make  our country    j
    
        i
    
    15    thu greatest welfare state on  earth,  and  themselves the
    
    
    
    16    recipients of this  welfare.
    
    
    
    17              It is the duty of  the Federal and State authori-
    
    
    
          ties to protect the lake.  That does  include the Atomic
    
    
    
    19    Energy Commission.   Lake Michigan is  the  property of  all
    
    
    
    20    the people,  and no  private interests  have any right to  use
    
    
    
    21    it for financial gains at  the  expense of  the quality  of
    
    
    
          its waters.
    
    
    
     3              Thank you,  gentlemen.
    
    
    
                    MR.  MAYO:   Thank you, sir.   (Applause)
    
    
    25
     '              Are there any other  presentations?
    

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                                  	944
    
    
    
    
                            Closing  Remarks - F.  Mayo
    
    
    
                   The general practice of the conference at the
     £f
    
    
     3   reconvened sessions is that following the presentation of
    
    
    
         material by the interested parties, the conferees will then
    
    
    
     5   go into Executive Session at some appropriate time for the
    
    
    
     5 j  purpose of discussing that record and developing conclu-
    
    
    
     7   sions and recommendations.
    
    
    
     3             There has been an opportunity to discuss an
    
    
    
     Q   appropriate date for an Executive Session with the conferees,
    
    
    
    10   They are in general agreement that November 9 and 10 would
    
    
    
    11   be an appropriate time.  There has been no decision so far
    
    
    
    12   as time and place are concerned.
    
    
    
    13             i want to thank those who have endured.  It has
    
    
    
    14   indeed been a very trying day for all of the parties
    
    
    
    15   involved.    I want to express the appreciation of the con-
    
    
    
    16   ferees to those who have come and  stayed with us  in an effort
    
    
    17   to ensure that all those interested in  getting statements
    
    
    
    13   into the record were able to do  so.
    
    
    
    19
    
    
    20             Are there  any  comments as far as the  conferees
    
    
    
    21   are  concerned?  With that,  gentlemen,  the Fourth  Session of
    
    
    
    22   the  Lake Michigan Enforcement  Conference is  adjourned.
    
    
    
    23              (The  Conference  adjourned at 11:59 p.m.)
    
    
    
    24                           	
    
    
    
    25              (Documents received following the  conference
    
    
          are included at the end of this volume.)
    

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    NAmE OF AGENCY
     EPA, REGION  V
     CHICAGO,  ILLINOIS  60606
    ACCOUNTING CLASSIFICATION
                                                    PRECEDENCE
                             ACTION
    
                             INFO	
    
                             TYPE OF MESSAGE
    
                              [Xj SINGLE        fj BOOK
    
                              ~ MULTI-ADDRESS
    THIS BLOCK FOR USE OF COMMUNICATIONS UNIT
    U
    R
    I
    T
    Y CLASSIFICATION
     STANDARD FORM 14  REV MARCH 15, 1957
     GSA REGULATION 2 IX-203 04
     14-303
    
      TELEGRAPHIC MESSAGE
    
            OFFICIAL BUSINESS
           U. S. GOVERNMENT
    MESSAGE TO BE TRANSMITTED (Use double spacing and all capital letters)
     HONORABLE ADLAI E. STEVENSON  III
     UNITED STATES  SENATE
     WASHINGTON,  D.C.   20510
     IN REGARD TO YOUR WIRE TO  ME  AS CHAIRMAN OF  THE LAKE MICHIGAN ENFORCE-
    
     MENT CONFERENCE, YOUR EXPRESSION OF CONCERN  OF THE DAMAGES  OF THERMAL
    
     POLLUTION IN LAKE MICHIGAN IS VERY MUCH APPRECIATED.
    
    
     THE FOURTH  SESSION OF THE  CONFERENCE ADJOURNED ON SEPTEMBER 21, 1972
    
     AFTER THREE DAYS OF EXTENSIVE TESTIMONY ON A NUMBER OF ISSUES IN-
    
     CLUDING THE THERMAL ISSUE.   I SHARE YOUR CONCERN ON THE QUESTION OF
    
     THERMAL POLLUTION.  TOWARD THAT END, THE CONFERENCE RECORD  WILL BE
    
     STUDIED BY  THE CONFERREES  PRIOR TO RECONVENING IN EXECUTIVE SESSION
    
     ON NOVEMBER 9 AND 10, 1972 AT THE PICK CONGRESS HOTEL IN CHICAGO TO
    
     MAKE FURTHER RECOMMENDATIONS  ON PROTECTING THE LAKE FROM ADVERSE
    
     HEAT DISCHARGES.  THE CONFERENCE WILL ALSO BE RECONVENED IN EXECUTIVE
    
     SESSION ON  OCTOBER 25 AND  26, 1972 AT THE SHERATOiJ-CHICAGO  HOTEL TO
    
     CONSIDER ADDITIONAL RECOMMENDATIONS ON NON-THERMAL ASPECTS  OF THE
    
     CONFERENCE.   YOU ARE MOST  CORDIALLY WELCOME  TO ATTEND BOTH  SESSIONS.
     FRANCIS T.  MAYO
     REGIONAL ADMINISTRATOR
     REGION V
                                                                                THIS COL. FOR AGENCY USE
                                                                cc:
                                                                LMEC File
                                                                               PAGE NO
                                                                                 1
                                                                                        NO OF PAGES
                                                                            1
    NAME AND TITLE OF ORIGINA
                                                  ORIGINATOR'S TEL NO.
     JAMES 0.
     ENFORCEMENT DIVISION
    I certify that this message is official bus
                                         (Signature)
                                                    DATE AND TIME PREPARED
    
                                                    SEPTEMBER 25,  1972  11:00 A.M.
                                                    SECURITY CLASSIFICATION
                                                                    UNCLASSIFIED
    

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       western union
    Telegram
        LLB3U6 (25).(19>CTA137 WD156
        W NFA080 EG INTER FR US GOVT PDB OTC  NF  WASHINGTON DC 191 09-21
        526PEDT
        MR FRANCIS MAYO, CHAIRMAN
         LAKE MICHIGAN ENFORCEMENT CONFERENCE  i  NORTH WACKER DR /CHICAGO
        ILL
        DELIVER DO NOT PHONE
        I WULD L!KE T0 EXPRESS TO THF L/KFMICHIGAN  ENFORCEMENT CONFERENCE
        ONCE AGAIN MY DEEP CONCERN OVER THE DANGERS  OF THERMAL POLLUTION
        IN LAKE MICHIGAN, THE NEED FOR
       INCREASED RESERVES OF ELECTRICAL POWER IN  THE MIDWEST MUST BE
        BALANCED AGAINST PRESERVATION OF THE  ECOLOGY OF  THE LAKE.
        UNTIL SUFFICIENT DATA, PROVING BEYOND ALL DOUBT  THAT HEATED
        DISCHARGES ARE NOT THE CAUSE OF SIGNIFICANT  ECOLOGICAL HARM,
        CAN BE GATHERED FROM THOSE FEW PLANTS PRESENTLY  UNDER CONSTRUCTION,
        FURTHER CONSTRUCTION OF THE MANY FACILITIES  CURRENTLY IN THE
    SF-1201 (R6-69)
       FLANKING
            STAGE SHOULD NOT BE PERMITTED,
       I REITERATE MY POSITION AS  PRESENTED TO THE CHAIRMAN OF THE
       1971 LAKE MICHIGAN ENFORCEMENT CONFERENCE THAT FUTURE CONSTRUCTION
       OF NUCLEAR PLANTS WITHOUT A TESTED LAKEWIDE  STANDARD DERIVED
       FROM AND APPLIED TO THOSE PLANTS  PRESENTLY UNDER CONSTRUCTION
       WOULD BE A GRAVE MISTAKE ENDANGERING THE FUTURE  OF THE LAKE
       AND THE LIVES OF THOSE MILLIONS WHO DEPEND UPON IT FOR THEIR
       WELL- BEING
       I STAND READY
       READY TO WORK WITH THE CONFERENCE IN IMPLEMENTING THESE
       RECOMMENDATIONS IN SUCH A WAY THAT THE INTERESTS OF THE CITIZENS
       OF THE MIDWEST ARE BEST SERVED IN TERMS OF ADEQUATE POWER RESOURCES
       AND PROTECTION FOR LAKE MICHIGAN
    SM201 (R5At)LAI E, STEVENSON III UNITED STATES SENATE,
    

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                  f / I/  \~/l/ffftS/ INC.
                                                              7000 N. Westnedge Avenue
    
        ENVIRONMENTAL EDUCATION                    Kalamazoo, Michigan 49007
                                                              Telephone (616) 381-1574
         September 21, 1972
         Lake Michigan Enforcement Conference
         Francis T. Mayo
         1 North Wacker Drive
         Chicago, Illinois  60606
    
         Dear Sir:
    
         The Board of Trustees  of the Kalamazoo Nature  Center of
         Kalamazoo, Michigan, were shocked and concerned about
         the condition of the waters of Lake Michigan as reported
         by the Enforcement Conference.
    
         We urge that the Enforcement Conference adopt  stringent
         standards to insure protection of water quality of the
         lake.
    
         Please include this in the record of the Enforcement
         Conference proceedings .
    
         Very truly yours,
         Daniel R.
         President, Board  of Trustees
         DRS/vg
    RESEARCH       EDUCATION       CONSERVATION
    
                      (7 This is recycled paper — please use it again
    

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              THE ROE£ Of ZAtiD USE MANAGEMENT AMD ACCELERATED
                      EUTROPHICATION OF LAKE MICHIGAN
    
         The biosphere consists of many interacting ecosystems.  There
    is a multitude of interacting biological and physical factors within
    «ach of these ecosystems.  Mankind has greatly altered most of these
            systtaae, and we &re now having to try and correct some of the
            of ttis*? manipulations.  We ere just beginning to become
              of some of the ramification? of the changes that we have
    brought about In these ecosystems.  One of these has been the increase
    in rate of eutrophication of Lake Michigan.  Many of the changes in
    thase system involve alteration of land use patterns.
         The general nature of the natural systems in the Lake Michigan
    watershed have been briefly examined in an attempt to determine causes
    for the denudation of water quality in the lake.  A major input into
    the lake ol" t»;,e element phosphorous has been demonstrated to come
    fs?om sedimentation in the basin.  This relationship between land use
    ar«d management and accelerated eutrophieation of the lake is the topic
    of this ^Testimony.
         Forested communities which dominated the region surrounding the
    lake are very effective in trapping and cycling plant nutrients.  The
    boll of the trees contain considerable quantities of nitrogen, phos-
    phorous, and other necessary plant nutrients.  Soil erosion and sedi-
    mentation from these kinds of plant communities were insignificant.
    The result of these processes was a very low attrition of nutrient/
    sediments into the lake.
         Phosphorous is an element which is a plant nutrient frequently
    involved in accelerated eutrophieation of waters.  Ground water sources
    do not contain large concentrations of phosphorous because the soils
    

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    *  ''QO*.
    %*. ^**
     *«v,  «v  ***
         >
    

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    ill the wsttrihtd effectively filter out moat of the phosphorous
    from tht percolating waters.  Hit form la which this is held Is
    dependent upon tht pM or reaction of tht soil system.  One* •roslon
    of tits soil matrix tskss pises, then large Quantities of the phos-
    phorous may enter the lake.
         Two land usas will be examined in sons detail to emphasise
    the necessity of placement of high level priorities on land use
    ginning and implementation.  Tht firat is agricultural fend ust.
    Major technological changes have taken place in this industry during
    tht last twenty years.  There has been an abrupt change to much
    larger and more efficient farming equipment, increased uses of pesti-
    cides and fertiliser* and alteration of many associated agronomic or
    cultural practices,  The small diversified farm has suddenly become a
                fee»ed corporation.  These alterations have resulted in
          chains in tht input act of agriculture on the environment.
         The monoculture system of much of modern agriculture has increased
    the need for peat control and fertiliser use but perhaps the moat Impor-
    tant change has bean in soil erosion control.  Small fields of pasture
    land, small grains and row crops can be arranged in s landscape so
    that minimal amounts of sedlmtnt art lost from an agricultural area.
    This is not the case with many modem farms which art dependent upon
    Urge fields of a single crop.  A tragic loss in soil erosion control
    practices such as contour atrip cropping, grata waterways, and terraces
    has also resulted from these changes in land management.
         The Soil Conservation Service remains the primary agency respon-
    sible for soil erosion control in this country.  This federal agency
    does considerable conservation planning on amll watersheds through
    

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    the P.L. 566 projects.  These projects potentially remain the best
    alternative to the "cement, steel, end large dam" philosophy of the
    U.S  Corps of Army Engineers.  The email watershed projecta do Include
    corner vat ion planning in the basin but unfortunately many of these
    plans are never implemented.  Agreements between Soil Conservation
    District Cooperators and the Soil Conservation Service are not binding*
    The Soil Conservation Service has drifted off into the cement and
    Steel philosophy of the Corps of Army Engineers many times instead of
    dealing with the real problem of getting each acre of land used within
    its capability.  Channelization and dam construction are not viable
    substitutes for good land management.  They tend to treat only the
    symptoms of man's mismanagement rather than the causes.
         fhe seec* d lasid use problem that directly deals with the sediment/
    eutrophication process going on in Lake Michigan is the disturbance
    resulting from construction projects,  this disturbance of soil and
    vegetation results in massive losses of sediment when adequate controls
    have not been installed.  Disturbance of the vegetation and subsequent
    exposure of the mineral soil results in erosion.  Again, this sediment
    becomes a major water pollutant.  The technology to control these
    inputs of phosphorous into the lake clearly exists and the socio-
    economic costs are quite low.
         The importance of land-use planning in the restoration or main-
    tenance of a quality environment cannot be overstated.  The soil and
    other associated resources are the basis upon which man survives on
    this planet.  The capabilities of these resources should therefore
    be very carefully evaluated when dealing with any environmental problem.
    The basic planning procedures suggested here have already been developed
    

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    and utilized.  Ian M&lavg'B wodk in the Minneapolis and St.  Paul and
    
    Baltimore areas has developed practical methods of using this kind of
    
    information.
    
         The following are some recommendations for dealing with this
    
    problem and its solution:
    
         1.  To emphasize the in^ortance of broad-scale land-use
             planning in all attempt* to preserve or restore the
             quality of the water in Lake Michigan.
    
         2«  To work for some alteration in procedures and practices
             to place greater enphasis on land-use  planning by the
             Soil Conservation Service.  For exanple,  binding agree-
             ments concerning land use could be made a part of the P.L.
             566 program.
    
         3.  To reeonroend the establishment of regional erosion  or
             sediment control laws—i.e.* similar to the one recently
             passed in the State of Iowa*
    
         H.  To reec^iime and stress in all planning and control
             activi";-fee the interrelationships between natural resources.
                                              aU.S.Government Printing Office: 1974— 751-197
    

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