ned)
24, 2S, 1971
, Illinois
ILLINOIS
CONFERENCE
In the Matter of Pollution off Lake
Michigan and its Tributary Basin
ENVIRONMENTAL PROTECTION AGENCY • WATER QUALITY OFFICE
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RECONVENING OF THE THIRD SESSION OF THE
CONFERENCE IN THE MATTER OF POLLUTION OF
LAKE MICHIGAN AND ITS TRIBUTARY BASIN IN
THE STATES OF WISCONSIN, ILLINOIS,
INDIANA, AND MICHIGAN - VOLUME III
Randolph Room
Sherman House
Chicago, Illinois
March 25, 1971
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CONTENTS
I
Opening Statement - Murray Stein
James B. Henry
Evan James
J. A. Pelletier (Read by Charles Kern)
Robert J. Baker
Executive Session (Previously numbered pp. 1-137) After
James C. Vaughan
City of Racine, Wisconsin
Donald I. Mount
Glenn Pratt
Discussion on Phosphorus
Discussion on Chlorides
Discussion on Phosphorus
Mrs. Wendell Alexander
— ~ — •
Statements received after the close of the Conference:
David P. Currie
Sister Francis Wagner, Secretary, Milwaukee
Audubon Society
Will C. LaVeille
Wisconsin Ecological Society
Mason County Anti~«Pollution Action Council
Jack R. Munsee
'age
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Ill
Reconvening of the Third Session of the Conference
in the Matter of Pollution of Lake Michigan and Its Tributary
Basin, in the States of Wisconsin, Illinois, Indiana, and
Michigan, held in the Randolf Room of the Sherman House,
Chicago, Illinois, on Thursday, March 25, 1971» at 9:00 a.m.
6
7 PRESIDING:
Murray Stein, Assistant Commissioner for
9 Enforcement and Standards Compliance, Water
10 Quality Office, U.S. Environmental Protection
11 Agency, Washington, B.C.
12
13 CONFEREES:
RALPH W. PURDY, Executive Secretary, Michigan
15 Water Resources Commission, Lansing, Michigan.
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PERRY E. MILLER, Assistant Director, Stream
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Pollution Control Board, Indiana State Board
of Health, Indianapolis, Indiana.
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FRANCIS T. MAYO, Regional Director, Water
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Quality Office, U.S. Environmental Protection
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Agency, Region V, Chicago, Illinois.
23 DAVID P. CURRIE, Chairman, Illinois Pollution
24 Control Board, Chicago, Illinois.
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IV
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CONFEREES, Continued
THOMAS G. FRANCOS, Administrator, Division of
Environmental Protection, Wisconsin Department
of Natural Resources, Madison, Wisconsin.
6 ALTERNATE CONFEREES:
CARLOS FETTEROLF, Water Quality Standard
Appraisal, Michigan Water Resources Commission,
Q
7 Lansing, Michigan.
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ORAL H. HERT, Director, Division of Water Pollution
11
Control, Indianapolis, Indiana.
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DALE S. BRYSON, Deputy Director, Office of
... Regulatory Programs, Water Quality Office, U.S.
- Environmental Protection Agency, Region V, Chicago,
_, Illinois.
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17 JACOB D. DUMELLE, Member, Illinois Pollution
Control Board, Chicago, Illinois.
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7 DONALD Jo MACKIE, Assistant Secretary, Division
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of Environmental Protection, Wisconsin Department
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j of Natural Resources, Madison, Wisconsin.
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CARL T. BLOMGREN, Environmental Control Engineer,
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Illinois Environmental Protection Agency,
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Springfield, Illinois.
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PARTICIPANTS:
James B. Henry, Vice-President and General Counsel
of American Electric Power Service Corporation, New York City,
New York.
Evan James, Vice-president, Power Generation and
Engineering, Wisconsin Public Service Corporation, Green
Bay, Wisconsin
J. A. Pelletier, Vice-president, Engineering and
Electric Operations, Northern Indiana Public Service Company,
Hammond, Indiana.
11 Robert J. Baker, Technical Director, Wallace and
Tiernan Division, Pennwalt Corporation, Belleville, New
Jersey.
James C. Vaughn, Engineer of Water Purification,
Department of Water and Sewers, Chicago, Illinois
Donald I. Mount, Ph.D., Chairman, Lake Michigan
Interstate Pesticide Committee, National Water Quality Labora--
1° tory, Environmental Protection Agency, Duluth, Minnesota.
Glenn Pratt, Sanitary Engineer, Office of Regulatory
Programs, Water Quality Office, Environmental Protection
Agency, Region V, Chicago, Illinois.
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Mrs. Wendell Alexander, Citizen, Racine, Wisconsin.
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J0 B. Henry
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5 MRo STEIN: Let's reconvene.
6 When we terminated yesterday, Mr. Henry was asked
y to speak and unfortunately we recessed before he could come
up. We would like to call on Mr. Henry now.
9 MR. HENRY: Mr. Chairman, yesterday after I had
10 terminated my remarks and while Mr. Petersen was at the
11 podium, I understood you to characterize my comments as a
12 personal attack on Mr. Mayo without a scintilla of evidence
in support of those remarks.
Now, obviously I think you were joking, but jokes
15 don't often come across on the record and, therefore, I
think I have to make a statement in this regard.
As you will recall, the only reason that I named
lg Mr. Mayo was that you pointed out that I was incorrect in
19 referring to the Federal conferees in the plural, and I
20 apolqgize for that mistake. I admit to confusion because
2i of the fact that there are four Federal people — or were
22 at the first day — on the podium, and there were four
23 Federal people on the Technical Committee. But I apologize
24 for my error in referring to the Federal conferees in the
25 plural to the extent that I made the remark that the
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1 J, B. Henry
2 Federal conferees had indicated that if they did not get
3 the cooperation of the State conferees, they would use
4 whatever methods were available to them to ensure that the
5 Federal point of view prevailed. I think I recall that both
6 Mr. Mayo and you made a remark along those lines, and, there-
7 fore, I will amend my statement in that regard by saying
$ that the Federal conferee and the Chairman made such remarks,
9 and I am sure if I am in error on that point you will correct
10 me»
11 With regard to —
12 MR. STEINt May I do that now? The Chairman never
13 made a statement on that at all, and I think the record
14 will show thato
15 MR. HENRY: All right. The record will show
16 whatever it shows, and if I am wrong in that I apologize,
17 With regard to a personal attack on Mr. Mayo,
lg obviously I made no such attack. I did make an attack upon
19 the administrative procedures that are being followed here,
20 and I have no way of knowing at all that Mr. Mayo is
21 responsible for those procedures. Even if he is, obviously
22 by attacking those procedures, I am not making a personal
23 attack on Mr. Mayo; and with regard to your comment about
24 a scintilla of evidence, at the risk of getting myself into
25 further difficulty by using a Latinism — another Latinism —
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J, B. Henry
2 I will say that the arbitrary nature of the proceeding we
~ have been following here is a case of res ipsa loquitur,
, And may I also suggest that if you have any comment on my
c statement yesterday or upon my statement this morning, that
x you make it now while I am at the microphone and not subse-
7 quently when I have to go through this kind of procedure to
reply to it.
MR. STEIN: Mr. Mayo, do you —
,Q MR. MAYO: Well, obviously, I was for myself
,, quite disturbed at what I interpreted as a rather personal
•i 2 attack on my professional integrity and my integrity as an
TO administrator representing the Environmental Protection
Agency.
-, c I am pleased to hear your comment this morning,
, x which I would interpret as something of a clarification
on your part on that point„
MR. HENRY: Let me just say that I apologize if
anything I said came across as a personal attack, because
2Q I didn't mean it that way.
21 MR. STEIN: Right. Maybe we can clearly clarify
22 that.
23 As I recall — I think the record will show —
I am not sure how many Latinisms we used, but the first
remark appearing in the record on scintilla of evidence
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J, B. Henry
2 was contained in your presentation. But what I was address-
o ing myself was not to the procedure here but if I am incor-
• rect, let me see if this is at the point,
c You said that a position — factual position on
the proposal that Mr, Mayo presented to this Conference, as
the Federal conferee, was apparently concocted overnight.
That has nothing to do with the procedure, I asked Mr, Mayo
about that and he, as I recall his statement for the record,
said that was patently incorrect or false,
-,, Now, I think that was the issue. My remarks
were not directed to any judgment that someone may have
in on the procedure|which is prescribed by statute, but that
TI was the point.
,c Also, if the point was made that Mr, Mayo
apparently concocted something overnight for presentation
here, I did not see for the record any supporting evidence
for that statement.
Now, maybe I am incorrect on that, and perhaps
20 you and Mr, Mayo can work this out. But that is the way
21 the record seems to me* I wouldn't characterize this as
22 a personal attack or anything of that sort.
MR. HENRY: Well, thank you, Mr. Chairman, I
24 don't wish to prolong this, I meant no personalities; I
25 was addressing myself to procedure only.
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J. B. Henry
2 MR. STEIN: Right,
MR. HENRY: Thank youa
, MR. STEIN: May we go on with the companies.
c MR. MILLER: Wisconsin is first.
MR. STEIN: Wisconsin.
7 MR. FRANGOS: Mr» Chairman, I have a statement of
H the Wisconsin Public Service Corporation that I would like
q to submit for the record at this time.
MR0 STEIN: Without objection, that will be
n-, entered into the record as if read.
(The statement of Evan James, Vice President,
Power Generation and Engineering, Wisconsin Public Service
Corporation, follows in its entirety.)
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STATEMENT OF WISCONSIN PUBLIC SERVICE CORPORATION
PREPARED FOR THE THIRD SESSION OF THE LAKE MICHIGAN
ENFORCEMENT CONFERENCE CONCERNING THERMAL DISCHARGES
TO LAKE MICHIGAN SCHEDULED FOR MARCH 23 AND 24, 1971
I am Evan James, Vice President - Power Generation and
Engineering, of the Wisconsin Public Service Corporation. This Corporation
is an electric and natural gas utility serving northeastern Wisconsin. A
statement on behalf of this company was presented at the previous session
of this conference held during the week of September 28, 1970. I will not
repeat the description of its environmental studies and continuing program
relating to the construction and proposed operation of the Kewaunee Nuclear
Generating Plant now being built on the shore of Lake Michigan near Kewaunee,
Wisconsin. The unit is to be jointly owned by Wisconsin Power & Light Company,
Madison Gas & Electric Company and Wisconsin Public Service Corporation,
with the latter being the operating partner.
Up until yesterday, based on the notice given us of this meeting,
it was my understanding that the purpose of this reconvened session of the
Lake Michigan Enforcement Conference was for the purpose of considering the
Recommendations of the Lake Michigan Enforcement Conference Technical Committee
on Thermal Discharge to the Lake. Since early yesterday, the Conference appears
to be addressing itself to some other recommendations.
Be that as it may, I believe it is still appropriate that the
Technical Committee Report not be ignored, and also, as it is the only
written report I have been given the opportunity to review and evalute, I
shall direct my comments to that report and its conclusions. By so doing,
I in no way am indicating that my company feels it should not be afforded a
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full opportxinity to address itself to the new proposals presented here
for the first time. It should be granted a reasonable time to study and
evaluate the recommendations. The imposition of the enormous cost which
would result if these recommendations were made enforcible on particular
utilities and their rate payers should not occur without conclusions being
reached which are based upon sound factual findings.
I'll now proceed to comment on the Technical Committee's Report.
A most, if not the most, significant aspect of the document is
its inability to describe present or anticipated ecological damage to the
Lake based upon any scientific data. The document variously states: "It
is obvious that further field studies are warranted and necessary to
determine ecological impact on Lake Michigan" (p.3) and: "... there has
been no demonstrated significant damage at existing Lake Michigan thermal
plume sites from artificial heat inputs: (p.4). Of further significance
in this area is the Committee's statement that "The amount of waste heat in
a body of water is always in equilibrium with the atmosphere and cessation
in inputs will result in an almost immediate return to the natural temperature
regime" (p.5). Two conclusions are apparent from these Committee observations:
(1) At least as of this time there is no demonstrated thermal
damage to the Lake, and
(2) Thermal effects which might occur after experience are not
irreversible, but, on the contrary, the Lake's equilibrium can be re-established.
These two findings of the Committee would seem to lead to a simple
and obvious conclusion: Until there is more experience with thermal discharges
and close observation and study of the effects of such discharges, there is
no justification for shutting off Lake Michigan as a source of cooling water
for electric generating plants. To do so would be to place an unnecessary
burden on the utility customer - a burden for which there is no demonstrated
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need. This does not make economic sense, and if no further heat is discharged
into the Lake, it can never be demonstrated that the ecology had been protected
from anything.
The conclusion that it is premature to place restrictions on Lake
use is, of course, tremendously reinforced by the recently published report
of the Argonne National Laboratory's Center for Environmental Studies and
Radiological Physics Division to the effect that thermal discharges into
Lake Michigan are "negligible and will continue to be so for the rest of this
century". The Argonne report also significantly points out that the ecological
effects of cooling towers are not known - this fact also should make us proceed
carefully and with firm knowledge of all consequences.
And may I say at this point that it could well be that I and the
Technical Committee are not in basic disagreement. The heart of the Committee's
recommendations would seem to be its paragraph 4 on page 8. There the
Committee recommends that all generating facilities be required to have
closed cycle cooling systems or some other technique "under construction
by a date considered reasonable and appropriate by the Conferees". The
recommendation is then qualified by eliminating the need for such construction
by such date "unless it has been conclusively demonstrated . . . that
ecological damage does not or will not occur from once-through cooling". It
is probably true that the difference, and I think it is important, between
my viewpoint aad this recommendation is one of emphasis only. The Committee
seems to say the utilities should spend their millions of dollars if by a
certain date a complete absence of ecological damage has not been conclusively
demonstrated. I would respectively suggest that the emphasis should be some-
what tempered. By all means scientific study should be, as it is planned to
be, continued until conclusions can be drawn one way or the other. Once
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firm conclusions are available, then the manner and extent of corrective
measures, if any are needed, can be determined. Leaving the final conclusion
open for making decisions after the facts are in would seem to be the way
to avoid needless expense and avoid guesswork as to when and what if anything
should be done. Since the Technical Committee has not in fact recommended a
specific date on which the decision should be made—a very slight modification
of its paragraph 4 would appear to meet the utilities' and the public's needs.
Rather than to suggest some date be designated for the construction of cooling
systems, both the type of system and the time should await the results of
post-operative surveys. My company will cooperate to the full both with
personnel and the necessary expenditures to conduct the studies necessary
to establish the fact of thermal effect on the Lake.
With reference to the suggested backfitting of operating plants,
which was mentioned yesterday and implied to be an easy task to which I might
take some exception—I refer to such plants as Pulliam, Edgewater, Port
Washington—it appears that the Conference would be reaching far—to require
substantial alteration of these plants—some with units 30 to 40 years old.
Where there is no conclusive proof that these plants, operating over the many
years, have damaged the waters of Lake Michigan.
In conclusion, may I introduce one other consideration which appears
to get overlooked as we concentrate our attention on Lake Michigan. I believe
we must look at the overall question of the conservation of our resources
beyond those existing within the Lake. I refer to the conservation of our
sources of energy, specifically uranium and coal. I believe I can best
illustrate my point by an example.
If it were found advisable to install cooling towers on, say, a
500 MW plant such as Kewaunee, the effect of this cooling device on the
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efficiency of that plant would be such that in the 30 year life of that plant
an additional 100 tons of uranium would be consumed to generate the same
number of kilowatt hours. I repeat—an additional 100 tons would be used.
To express this in coal (another source of our energy and about
which most of us have a better concept) the decrease in efficiency at
Kewaunee would necessitate the use of an equivalent of 2,000,000 tons of coal
in 30 years.
This is the tapping of our energy resources which should not be
overlooked as we view the Lake Michigan environmental question.
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J, A. Pelletier
2 MR. STEIN: While that is being distributed, I
o would like the conferees to consider this. I have had
• several requests individually from conferees that we finish
c the thermal matter with the industries, then the Conference
will go into Executive Session, and that Executive Session
will be held right here in public, as I understaand it,
and then we will try to come to a conclusion, if we can,
n on thermal matters, then go back into public session and
•J_Q take up the other matters which are on the agenda.
Do you have any others, Mr. Frangos?
MR. FRANGOS: No further from indsutry.
MR. STEIN: Indiana.
MR. MILLER: Mr. Chairman, I have Mr. Kern for
the Northern Indiana Public Service Company.
I might say this was handed to the conferees. It
is Mr. Pelletierfs statement.
STATEMENT 0? J. A. PELLETIER, VICE PRESIDENT,
20 ENGINEERING AND ELECTRIC OPERATIONS,
2i NORTHERN INDIANA PUBLIC SERVICE COMPANY,
22 HAMMOND, INDIANA (READ BY CHARLES KERN)
23
24 MR. KERN: Mr. Chairman, conferees, my name is
25 Charles Kern. I am making this statement today on behalf
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1 J. A. Pelletier
2 of Mr. J. A. Pelletier, Vice President, Engineering and
3 Electric Operations, Northern Indiana Public Service Company,
L Hammond, Indiana,
e The stated purpose of this Conference is for con-
5 sideration of the Technical Committee's Report to the
7 conferees of the Lake Michigan Enforcement Conference,, I
_.g intend to address my remarks to this purpose.
Q The Technical Committee Report of the Lake Michi-
10 gan Enforcement Conference, dated January 1971, states on
11 page 4: "The Committee recognizes the value of receiving
12 water temperature standards but, since there has been no
13 demonstrated significant damage at existing Lake Michigan
1^ thermal plume sites from artificial heat inputs, the
15 assignment of nuperical effluent values or other engineering
16 design requirements at this time would be arbitrary and
17 not defensible,"
lg The report further states on page 5: "Unlike many
19 other waste problems, there is limited concern about
20 persistence or buildup ia the water environment or other
21 biological magnification (such as with toxic substances)
22 or about a direct effect upon the health or safety of man,
23 The amount of waste heat in a body of water is always in
24 equilibrium with the atmosphere and cessation in input will
25 result in an almost immediate return to the natural
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c committee believes that the above characteristics of the
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o In view of the above statements from the committee
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J. A. Pelletier
temperature regime. The behavior of waste heat in Lake
Michigan is also significantly different than it is within
the predictable confinement of a flowing stream. The
waste heat problem in Lake Michigan are such that they do
allow a period of time for the establishment of sensible
controls."
report, we believe adoption of the committee recommendation
No. 5 on page 8 would provide the most sensible approach
to controls and assure that all of the other recommendations
of the committee are thoroughly studied before being acted
upon without adequate investigation. Any action prior to
a thorough study could provide economic waste, and in fact
could have an adverse effect on the environment.
Recommendation No. 5 states: "The committee
further recommends that in-depth field and laboratory
studies to determine the effects on the ecology be con-
ducted under the guidance of a technically competent
steering committee appointed by the Lake Michigan Enforcement
Conference. The studies should determine the physical and
biological effects on Lake Michigan of heated discharges
from thermal electric power generating facilities and the
effects on organisms in the cooling water passing through
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1 Jo A, Pelletier
2 these facilities0"
3 NIPSCO would be willing and would appreciate the
opportunity to work with a technically competent steering
5 committee to obtain substantive information which would
5 determine criteria and standards for Lake Michigan. NIPSCO
7 is presently engaging in comprehensive site studies and
has joined with other utilities serving areas adjoining
9 Lake Michigan in sponsoring a buaad inventory of Lake
10 conditions.
That is the end of this statement and I would
12 like to add just a comment of my own that the inventory
which the electric utilities has gone into a second stage
and is continuing on.
15 Thank you
15 MR. STEIN: Thank you. Are there any comments
17 or questions?
If not, thank you very much, sir
19 May I call on Michigan? Mr. Purdy.
20 ME. PURBT: I am wondering if Mr. Baker, Techni-
21 cal Director of Wallace and Tiernan is here.
22 Mr. Baker.
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1 R, J. Baker
2
3 STATEMENT OF ROBERT J. BAKER, TECHNICAL DIRECTOR,
4 WALLACE AND TIERNAN DIVISION, PENHWALT CORPORATION,
5 BELLEYILLE, NEW JERSEY
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7 MR. BAKER: I am Robert Baker, Technical Director,
g Wallace and Tiernan Division of Pennwalt Corporation,
9 Mr. Chairman, I have a prepared statement here
10 concerning Recommendation No. & of the Technical Committee.
H The statement is essentially against the substitution of
12 mechanical cleaning for chlorination in condensers, and I
13 would like to make a few remarks about the proposed Federal
14 regulation which is essentially the same thing, I believe.
15 For the last 2 days I have been trying to get a
1$ hold of a copy of the proposed regulations and I have been
17 unable to. As I recall, it says in different words, about
lg the same thing about the substitution of mechanical cleaning,
19 but it goes about it on the basis oft There shall be no
20 chemicals — I am quoting from memory here — no chemicals
21 used — do you have one?
22 MS« FETTEROLF: Yeah.
23 MR. BAKER: It is No. M4. Fouling problems shall
24 be solved by use of inert chemical devices. In exceptions
25 where antifouling chemicals must be used to supplement
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1 R, J. Baker
2 mechanical devices or as an interim measure, the concentra-
3 tions at the point of discharge shall not exceed the 96-hour
4 Tifci concentration for fishes and important fish food
5 organisms."
6 I don't know exactly what that means. However,
7 on the basis of a statement by Dr. Mount, which inciden-
g tally this whole subject is covered in a 7-line paragraph,
9 I would assume on the basis of the tests where they were
10 using Daphnia and demonstrated effects on a part per
11 billion level, that this would essentially eliminate chlor-
12 ination for any use at all.
13 Now, there was no workshop hearings on this point.
14 It cropped up rather unexpectedly in the Technical Committee
15 recommendations. We were exposed to this for the first
16 time, I guess, on Monday in the Federal — recommended
17 Federal standards. And to me this statement of this —
lg of the recommendation as well as -- incidentally the para-
19 graph I am speaking of in Dr. Mount's report is on page 12
20 — the third paragraph on page 12.
21 Now, this seems to me to reflect a complete mis-
22 understanding of both the mechanics and the chemistry of
23 the chlorination of condensers. Yesterday afternoon, Mr.
24 Miskimen mentioned briefly how — what the practice was.
25 I would like to review those parts which are important from
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Ro J, Baker
2 this aspect,
•3 First, we do not chlorinate water —- that is, the
purpose is not to chlorinate cooling water. The cooling
5 water is used only as a means of carrying residual chlorine
6 to the deposits in the condenser tube,
7 Now, in case you are not aware of it, water has
what is known as chlorine demand. Let me give you an example
9 In order to maintain a residual level of available chlorine
10 of, Sa7> 1 milligram per liter or part per million, the
dosage required, the amount applied, may be in the order
12 of k or 5 parts per million« The difference between the
amount applied and the residual is called chlorine demand.
Now, condensers are chlorinated on a program
basis, i,e,, while the plant is operating, a condenser or
one-half — possibly even half a condenser will be chlor-
iy inated at a time. The total elapsed time from the time the
chlorine is applied to the cooling water until the water
19 is through the condenser is in the order of 20 or 30
20 seconds. At this time, it mixes with the other cooling
21 water from the other condenser or the other half of a
22 condenser, and the chlorine demand in that water imme-
23 diately reduces the available chlorine. So the total time
24 of contact of any organism passing through that condenser
25 with residual chlorine is a matter of only a few seconds.
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R. J. Baker
We think of this in terms generally of 20 to 30 seconds.
Now, in this proposed regulation of a 96-hour
TLm, there isn't any conceivable way that an organism
around a powerplant discharge would be exposed to any
chlorine for 96 hours. It is impossible. It couldn't even
be done for 96 minutes, and it is more likely that a 96
seconds would have about a 3-to-l factor in it, so the use
of such a standard borders on the ridiculous, in ray opinion.
Now, in these studies and the TLm — it is a time
concentration relationship — if the time is reduced, the
concentration which will not cause damage is increased
tremendously. This is not a linear relationship.
I am not a biologist incidentally but I would
expect without any question that if this 96-hour limitation
— that is the concentration involved were 96 hours — if
the 96 hours were reduced to 96 seconds, there will be a
change in concentration of at least a thousandfold and
this puts us back up in the area of present practice of
residual concentration levels in the order of a half to
one part per million,' and at these levels, and at these
very short contact times, there has been no demonstrated
effect on the biological system of the water passing through
a condenser, not that I am aware of at all.
My firm has done more research in the area of
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Ro J. Baker
2 water chlorination than any in the world, and we have been
3 involved in the chlorination of heat exchangers for over 45
r years. I am sure if there had been any major damage it
c certainly would have come to our attention.
Now, I would like to recommend one of two things:
Either you drastically change the 96 hours — and I
realize this might not be possible, because this may be
a a standard test, I don't know why that should bother the
10 Federal people, however, because in the studies showing
11 that less than a part per billion of chloramines — there
12 is no standard test which can measure a part per billion
13 or less, as the words are here, in the water anyway. So
they have used a nonstandard analytical method — I don't
know why they wouldn't be prepared to use another non-
15 standard method as long as they are setting Federal
17 standards anyway. But I have even a better idea. Why
don't you discard the thing completely? This has absolutely
nothing to do with thermal pollution of cooling water.
20 Thank you
MR. STEIN: Are there any comments or questions?
22 MR. FETTEROLF: Yes, Mr. Chairman. I would like
23 to ask Mr. Baker if he is at all familiar with the Am^rtap
24 system
25 MR. BAKER: Yes, I am.
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R. J. Baker
MR. FETTEROLF: The Amortap System involves the
introduction of small balls into condenser tubes. Is this
done as a batch type treatment? Do you introduce the balls
all at once or are these balls continually circulating
throughout the condensers?
MR. BAKER: They are continually circulating
throughout the condensers.
MR. STEIN: Any other comments?
MR0 FETTEROLF: Thank you.
MR. BAKER: I might add one other thing. As far
as another comment here, there is an assumption — this 7-
line paragraph carries a lot, and another apparently is
the assumption that mechanical devices are as effective as
chlorination and, gentlemen, this is not true. You heard
this statement yesterday,, They are not in common use and
they are not as effective as chlorination.
MR. STEIN: Are there any other comments or
questions?
MR. MAYO: Dr. Mount has indicated the willingness
to respond to a portion of the comments.
MR. STEIN: All right.
Dr. Mount.
Why don't you wait up here, you may want a
rejoinder?
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1 R. J. Baker
2 DR0 MOUNT: I don't think that there is a problem
3 at all as has been described and I presume that is because,
4 as you said, you don't understand the 96-hour Tl^ nor its
5 application,
£ To begin with, if the residual chlorine drops,
7 as you have described it does, after the other part of the
g condenser water is mixed with that part which is chlorinated
9 and drops essentially to zero, as you have said, then there
10 is no problem, because the recommendation says "... at the
11 point of discharge ..." which would be after it is mixed,
12 and if there is no condensation, there would be no toxicity
13 and there would be no problem.
IJL I suspect, however, there is a residual there,
15 and in the standard way in which these tests are applied,
16 one would take the discharge water — a quantity of it —
17 and put the animals in it and determine whether or not they
13 died. And if a part per billion were there, it would have
19 to be there for quite a long period of time during the 96-
20 hour test in order to show toxicity.
2i So this recommendation does not say that there
22 could not be a part per billion in the discharge at all,
23 It says that if there is enough there to kill the animal
24 during the period of the test that would be too much.
25 You also commented that you could see no way in
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630
R. J. Baker
which these animals could be exposed for 96 hours. It is
entirely possible that it wouldn't be a full 96 hours, but
I think that your comments that it would be 96 seconds are
equally ridiculous.
The point is that we are talking about animals
such as plankton, and fish fry which cannot swim but which
will be floating with the discharge water in the plume, and
they will be there for a substantial period of time if that
plume is traveling down along the shore, for example, or in
any direction, in a reasonably defined fashion, so that the
water mass discharge is standing entire, the entrained
animals floating in that water will be exposed to the dis-
charge water for that period of time. And so it will be
quite a bit longer than the 96 seconds that you have pro-
posed. Now, this would not be true, of course, of a
swimming fish, for example, which has the ability to propel
itself around. But the point is that it is much, much
longer than 96 seconds simply because the animals are
floating in the discharge water and being carried by it.
I would repeat again though that if your
assumption is true that the residual drops to essentially
zero, then there would be no toxicity and there would be
no probleme
MR. STEIN: Do you want to respond?
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1 R. J. Baker
2 MR. BAKER: Well, we have done — I will grant
3 you —• no exhaustive tests because we weren't aware that
4 was going to come up here. But we have been unable at all
5 to find any residual chlorine of any kind in the discharge;
6 of powerplants with this type of procedure, which I am
7 sure — I think almost all plants at least on Lake
8 Michigan operate on this circulation basis.
9 Therefore, if — and I am still confused as to
10 exactly what this recommendation means, if you are going
11 to pull a sample of water from a condenser which is being
12 chlorinated and take it to the laboratory — and, by the
13 way, I have seen this done — this does not duplicate the
14 test at all unless you dechlorinate the sample before it
15 is taken.
16 Now, if we can go back to my contention, and you
17 remark, that if there is dechlorination after the 20 or 30
lg seconds, how, then, do we apply this particular proposed
19 regulation, this is what I don't understand.
20 MR. MAYO: The regulation that was proposed
21 would be applied at point of discharge.
22 MR. BAKER: How do you define the point of
23 discharge?
24 MR. MAYO: Well, as a general rule, in the issu-
25 ance of waste discharge permits under the State processes,
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_ 632
R. J. Baker
the discharge is identified, and a point of discharge can
be identified. It might be the end of a jet type diffuser
facility, or it might be the outlet of whatever works are
installed to dissipate the discharge, and that would be the
point of discharge.
MR. BAKER: Well, let me again clarify my ques-
tion. If a sample is taken at this point and does not
demonstrate any toxic effect to aquatic organisms, does
this in effect, then, permit the use of chlorine for
condenser chlorination under this proposed regulation?
MR* MAYO: I would think so. If it meets the
suggested requirement there.
MR. STEIN: Are we all set?
MR. BAKER: Unfortunately I don't have the require-
raent to look at, but I guess so.
MR. STEIN: Thank you.
MR. BAKER: Thank you.
(Mr. Baker's prepared statement follows in its
entirety. )
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WALT t° "/>, lferch 19' 1971
13 */!-* i/ / y/-*, ^ v/,
These comments are directed particularly to Section 8 of the conclu-
sions and recommendations of the January 1971 Conference Report on ther-
mal discharges to Lake Michigan.
The premise on page 6 of this Report that "ecological damage must be
assumed until it is shown otherwise" is the equivalent of "guilty until
proven innocent". The practice of chlorination to control heat exchanger
fouling has been practiced for over 45 years throughout the world without
any observed detrimental effects on the cooling water discharged when
chlorination is properly controlled. This, no doubt, accounts for the
scarcity of information to protect it against a charge of ecological
damage.
The beneficial effects of chlorination of water are known, however,
and some aspects of this relating directly to condenser operation will be
considered briefly.
There is a general impression that the purpose of chlorination is to
treat cooling water. This is not so. The water is used merely as a
carrier for chlorine to cause the disengagement of organic and inorganic
deposits on the tube surface to maintain heat exchanger capacity.
Chlorination is not applied for the purpose °f preventing fouling of the
condenser tubes by treating the water but to remove deposits after they
are formed. This is done by intermittent application, carefully con-
trolled and programmed. It is a corrective, not a preventative measure.
It is not chemical cleaning in the generally accepted definition of that
term.
The fact that the residual chlorine level approximates that used in
the treatment of municipal water and wastewater is testimony in itself.
-1-
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However, even this comparison can be misleading for two reasons. First.,
the effect of chlorine on biological life is influenced, armng cth;r
factors, by the level of residual chlorine and the tiir.3 of contact. For
levels approximating 1 nig/1, the times required for the destruction of
bacterial cells range from several minutes to over an hour, depending on
species and other factors. The total contact tiir.e of chlorine with a
specific volume of cooling water is a matter of seconds (usually less
than 30) instead of minutes. This occurs in the condenser. Upon dis-
charge, the water is immediately mixed with unchlorinated water.
This brings us to the second factor to be considered. Any residual
remaining in the cooling water is lost to the unchlorinated water. This
is due to chlorine demand. Chlorine demand is the difference between
chlorine applied and residual chlorine. Again, time is a factor. Where
it is desired to carry a residual for a long period, more chlorine must
be applied. Municipal water supplies are chlorinated to provide a
residual for hours, this being necessary to ensure disinfection. For the
very short time of contact in once-through cooling water systems, the
chlorine demand and, consequently, the amount of chlorine applied is
less. This is why chlorine is applied as close as possible to the con-
denser inlet, which in turn is why the contact time is so short.
The time of contact must not be confused with the duration of a
chlorination cycle. Contact time refers only to the time it takes for
water to pass through a condenser.
Completely ignored in this matter is the beneficial effect of satis-
faction of the chlorine demand. Chlorine, being an oxidant, reacts with
reducing substances, both organic and inorganic, in the water. The net
result is a reduction in the oxygen demand, and the enhancement of the
-2-
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635
quality of the water. The extent of the chlorine demand is directly
related to water quality. Thus, the greater the demand, the greater the
beneficial results from a chlorination program. No such results
occur with mechanical cleaning.
It is our opinion that the beneficial effects from condenser chlori-
nation more than compensate for any effect on biological life that may
occur in the very short time exposure available.
RJB:GMH
-3-
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1 Murray Stein
2 MR, STEIN: May we call on Illinois, please?
3 MR. CURRIE: So far as I know, Mr. Chairman, we
4 have no other witnesses on the thermal question.
5 MR. STEIN: Wisconsin?
6 ! MR. FRANCOS: We have no further witnesses.
7 MR. STEIN: Indiana?
3 MR. MILLER: Mr. Chairman, as far as I know, we
9 have no further witnesses.
10 MR. STEIN: And Michigan?
11 MR. PURDY: No further witnesses that I know
12 of, Mr. Chairman.
13 MR. STEIN: Are there any further witnesses on
14 the thermal question?
15 If not, I am going to ask the conferees whether
16 they want to take up the thermal matter at the present
17 time* If they do, the conferees will be in Executive
lg Session until we complete that, and we will consider it.
19 I. will ask for your advice, too, before we do
20 that on the requests to hold the record open for 2 weeks,
21 and the request that no determinations be made on this
22 thermal question until we receive that at the end of 2
23 weeks.
24 Now, obviously, if I make that first ruling, it
25 won't be pertinent to have the Executive Session, so I am
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]_ Murray Stein
2 going to try to canvass the conferees and get their views
3 on both these and determine how we will proceed,
4 Mr. Mayo, do you want to start?
5 MR. MAYO: I beg your pardon.
6 MR. STEIN: Do you want to comment on that?
7 MR. MAYO: Well, Mr. Chairman, I feel there is
$ an obligation on the part of the conferees to leave this
9 session with the strongest possible recommendations that
10 they can make to the Administrator — (Applause) — for
11 a package of corrective actions relating to thermal dis-
12 charges.
13 The request for the keeping of the record open
14 for another 2 weeks on its face is not reasonable.
15 I do feel, however, that the conferees can proceed, at
16 this point, on a very deliberate and productive discussion
17 of specific recommendations to be made to the Administrator
IB and the record also be kept open for the submission of
19 whatever additional materials the power industry people
20 think are in their best interests.
21 But I do feel that there is a burden on the
22 conferees to face up to this issue this morning and to
23 develop a set of meaningful and specific recommendations.
24 MR. STEIN: Mr. Purdy. Do you care to comment on
25 the full proposal, not necessarily Mr. Mayo's comments?
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Murray Stein
2 MR. PURDY: Well, I hope the remarks are not taken
o to mean that the conferees have been unwilling to face up
• to this in past meetings,
c FROM THE FLOOR: Only a year.
MR. PURDY: There have been many confusing
positions placed before the conferees at the last moment,
H and I think the conferees have attempted many times to
resolve this matter.
I do recognize the desirability of allowing every-
-,-, one the opportunity to give the conferees the greatest amount
-, 2 of guidance. However, if we leave or postpone the decision
for 2 weeks for some additional information, I am fearful
, , that at that point in time there would be a request by others
-, r for another 2 weeks to file additional information to
respond to what would be received at that time,
, 7 I do have the feeling that in the last several
meetings, I am hearing the same things that we have heard
jo at earlier meetings, I do recognize, I believe, that this
20 Conference is not a standard-setting Conference, but it
is one that will make recommendations to the Administrator
22 for him to forward back to the States for implementation
23 under State laws, and that in the standard-setting pro-
cedures under the Federal law, the States must hold public
25 hearings, and that any additional information that might
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1 Murray Stein
2 be pertinent to the guidance of the States and the adoption
3 of standards can be presented to the States at their public
4 hearings. And so, therefore, I feel that we ought to move
5 forward at this time.
6 MR. STEIN: Thank you. (Applause)
7 Mr. Miller.
g MR. MILLER: Mr. Chairman, conferees, I too feel
9 that we have been on this subject long enough, and that
10 we are now at the stage where we can adopt some recommenda-
11 tions to the Director of EPA and that these, then, will
12 come back to the States, and there will be time for public
13 hearings and actions.
14 As you probably know, we in Indiana have been
15 delaying amendment to the Lake Michigan Water Quality
16 Standards, Requests for improvements in these were made a
17 little over a year ago pending decisions that would be
l£ made by this Conference.
19 I think that it is perfectly in order that the
20 record be held open for a 2-week period for information
21 which could be used for guidance both by the Director of
22 EPA and to the various State water pollution control
23 agencies in carrying out the recommendations of the
24 Conference, And I would, therefore, recommend that the
25 conferees come to grips with the decision this morning.
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Murray Stein
2 MR. STEIN: Thank you. (Applause)
o Mr* Currie.
• MR. CURRIE: I wonder, Mr. Chairman, whether
c those who gave us a brand new proposal at the last minute
really expected that we would be able to evaluate and
approve it intelligently overnight. But I do think it is
time we got down to brass tacks and started talking about
the substantive thermal issue.
10 MR. STEIN: Mr. Frangos.
MR. FRANGOS: Mr. Stein, I concur in the suggestior
that we move into an Executive Session to discuss the Federal
13 proposal for coming up with some recommendations. I also
would agree that we ought to leave the record open for 2
TC weeks so that the companies and any others who want to add
to the record may be able to do so.
I would further suggest that perhaps we might
start the Executive Session by having a review from the
no Federal conferee of not only the proposal as he understands
20 it and as it perhaps defines Mr. Ruckelshaus* recommenda-
tions to us, but also what the mechanics of our recoramenda-
22 tions mean, and exactly what we are going to be doing here
23 in the Executive Session.
MR. STEIN: All right. Before we go, I think,
25 Mr. Frangos, you might take into account Mr. Purdy's
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, Murray Stein
2 statement of what he thought we were doing here, and, as far
3 as I see, that is the way I read the law. That is, under
, the law, in the Conference procedure you make a recommenda-
c tion to the Administrator, who in turn sends back a recommen-
dation to you, which may be the same one or a modified one,
for appropriate action under the State and local law. But
we will let the Federal conferee expand that, but I think
o that is a bare statement of what the law provides and, as
10 you know* this law we are operating under is a very detailed
statute. It doesn't leave much leeway
12 I think the Congress, as it said, in passing the
law, made it so detailed because they wanted to ensure that
certain specific procedures were followed.
Let's get on. I think in view of the statements
of the conferees, the record will be held open for 2 weeks.
17 All of the people here who indicated that they wanted to
put in additional information should send that in. That wil
be included in the transcript which will be sent to the
20 Administrator.
21
22
23
24
25
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642
Executive Session
MR. STEIN: At the present time, we are standing
in Executive Session* To people who are not familiar with
our procedure we operate very often on the fishbowl technique
where we have these Executive Sessions that are open* The
people whom we call on in Executive Session are the conferees
who, of course, may call on any technical backup that they
may have brought with them and the rest of the people, of
course, are privileged to visit.
I think in opening the Executive Session, we might
follow the suggestion of Mr, Frangos and ask Mr* Mayo if he
wants to lead off*
MR. MAYO: Your remarks, Mr* Frangos, were
directed, I think, to two parts: 1) a review of the
1 proposed recommendations and 2) a detailing of
17 the conference procedure and its relationship
to the States in terms of their obligations and commitments*
I prefer to speak to the first part and defer to
Mr* Stein for the second part*
MR. FRANCOS: I am wondering, could we have that
second part first?
MR* STEIN: All right* Do you have any other
specific questions other than the ones I —
MR, FRANGOS: Well, let me ask the
Independent consecutive pagination due to urgency of
transcription of the Executive Session*
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Summary and Conclusions
specific question. In the past, the way we have operated
in this conference and in others is when we have come up
with a set of recommendations that we have concurred in we
5 have submitted these to the Administrator (now),and he reviews,
and then in accordance with Federal statute he approves,
and those, then, have some legal significance in terms of
the way State law and Federal law may operate.
But let me give you an example. If we require
secondary treatment by a municipality by a date certain,
the very adoption by the Secretary*of that recommendation
means that there is now a clearcut Federal jurisdiction in
terms of enforcement, and this is the procedure that we
are going through right now.
Now, here we have a proposal in front of us
that in the details we will come up with some kind of
specific dates that something has to be done by individual
power companies.
Now, my question is: If this schedule goes in to
Mr. Ruckelshaus, do we treat that time schedule legally
in the same fashion that we have treated a municipality?
MR. STEIN: Yes.
MR. FRANCOS: Then indeed these are more than
standards within that section of the Federal law.
MR.. STEIN: I never said they were standards.
*Aclnrni''iti—-tor1, T5FA
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Summary and Conclusions
2 I have to make that clear. I think a lot of you people
o feel you are talking in terms of regulations, which they
are not, are talking in terms of standards, which they
are not. What we are doing is you are making recommenda-
tions to the Administrator. The Administrator, in turn,
if he believes that effective progress in abatement of
pollution is not being made, he makes recommendations
to the various States to take action under State and
local law.
Now, most of the time but not all the Adminis-
trator has approved the recommendations sent forward. The
•10 chances of approval by the Administrator, of course, have
.,, always increased, as the past record shows, if the States
,c are unanimous. If the States aren't unanimous then
, >• obviously a judgment has to be made.
._ The State is given an opportunity to take
action under State and local law within at least 6 months.
-Q If after the termination of that 6 months the Federal
_~ Government or the Administrator does not believe that
effective progress is being made, he can call a public
22 hearing. The hearing, of course, changes the
entire character. We don't just deal with the States but
, the alleged polluters become parties, as well as the States
and the Federal Government at the public hearing. If
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1 Summary and Conclusions
2 satisfactory action is not being taken we can go to court
action.
/,. However, not to give you just part of the picture
5 we independently have standards violations. If you have a
6 violation of standards, we can have 180-day notice action,
7 or that of the River and Harbor Act, which means if anyone
., s discharging wastes other than sewage in a liquid form
coming from pipes without a permit from the Corps of
Engineers we can proceed to court. We have done so in
seeking a fine under criminal provisions and also an in-
junction under the River and Harbor Act of 1&99 as the
case may be.
Now, these are independent actions. If we are
thinking in terms of a standard, either the State has to
request — and you all have standards for your States —
has to request a modification of the standards already
approved in your State and, just for the purposes of
example, you would have to ask in Wisconsin that we modify
2Q the standards and we would have to hold a hearing and
accept them. Or if the Administrator felt that you weren't
22 forthcoming with the standards in a reasonable time, he
could call for a conference of this kind and set the Federal
standards himself with you and the other parties partici-
pating and then we could proceed.
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646
1 Now, I know this sounds complicated, but that is
2 because the law is complicated, and I have outlined to you
3 what would happen. To recap this, we are in a conference
procedure here making recommendations to the Administrator.
5 The Administrator is obliged to do two things. He is oblige
5 to make a summary of the conference under the law, and then
7 if the Administrator* believes that effective progress toward
abatement of pollution is not being made, he is obliged to
Q make a recommendation to the State to appropriate action and
J_Q give it at least 6 months to take such action before he is
authorized to take any further action under this provision
12 of the law.
Again, let me make this plain: That 6-month
ji provision does not hold if you move under another provision
of law such as 1$99 Refuse Act. It applies just under
the conference procedure.
MR. FRANGOS: Well, thank you. That has been
very helpful, Mr. Chairman.
MR. STEIN: Mr. Mayo.
2Q MR. MAYO: As you know, in the past, there have
2-, been a variety of opportunities for even the Federal Govern-
22 ment or the individual States to suggest or lay on the
table proposed recommendations for the conferees to consider
On occasion, this might be done prior to the actual business
of the conference as material that the conferees could
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1 Summary and Conclusions
2 appropriately address themselves to during the course of the
3 particular conference session, and it is not unusual as a
4 consequence of the session discussions and deliberations
5 for those recommendationsi whether they are put forth by
6 the Federal Government or by the individual States, to be
7 modified in terms of having them in keeping with the best
# judgment of the conferees in terms of the family of knowledge
9 and facts that is available to them.
10 The material that was presented to the conferees
11 at the opening of the session and made available to them the
12 day before, was offered in that context as a package of
13 prospective recommendations for the conferees to collectively
14 consider, to give their best judgment to, and to use as
15 effectively as they might be used as a focal point for the
16 subsequent discussion and for the development of the
17 recommendations that hopefully would go forward to the
lo Administrator• So that the package of recommendations that
19 were offered to the conferees were offered in that light,
20 As a consequence of the deliberations of the con—
21 ference up until now, opportunities to have some discussion
po
*•*• with the technical people who are available and to have some
23 discussion with the State representatives, we would like to
24- offer some modifications to the material that was made
25 available to you for your consideration at the beginning of
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1 Summary and Conclusions
2 the conference session, and we gave each of the conferees
3 this morning an amended draft of these proposed recommenda-
4 tions.
5 FROM THE FLOOR: Mr. Chairman, is there any
6 obligation to furnish to those who are affected by these
7 modifications a copy of them?
8 MR. STEIN: I thought there was a glass wall
9 between us. We are in Executive Session. You are privileged
10 to see what we are doing in the Executive Session, but this
11 is an Executive Session,,
12 FROM THE FLOOR: All right. I would like to have
13 the record show that copies of the modifications were not
14 made available to anybody —
15 MR. STEIN: Sir, I thought I indicated that for
16 the Executive Session we are just going to hear from the
17 conferees. Executive Sessions ordinarily are held behind
IS closed doors. In very, very many instances, we hold
19 Executive Sessions out in the open. I strongly endorse
20 that procedure. But I ask the cooperation of all concerned.
21 Mr« Mayo.
22 FROM THE FLOOR: May I just note an objection to
23 this as another example of arbitrary and capricious
24 procedure.
25 MR. STEIN: Mr. Mayo.
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1 Summary and Conclusions
2 MR. MAYO: If I may, gentlemen, in keeping with the
3 open nature of the Executive Session, I would like to read
4 through with you, for you, each of these items. Perhaps we
5 can take them one at a time as we proceed and have whatever
6 substantive discussion you feel you want to apply yourselves
7 to.
# In order to — now, I will begin to read from the
9 proposed recommendations.
10 Let me back up just a minute to Mr. Frangos1
11 question about what main points we are addressing ourselves
12 to.
13 In Mr. Ruckelshaus* letter to the conferees, he
14 highlighted two specifically: 1) stringent standards be
15 established to prevent damage from thermal discharges, and
16 2) the need to place limitations on large volume heated
17 water discharges by requiring closed cycle cooling systems
13 using cooling towers or alternative cooling systems on all
19 new power plants and additions of such cooling facilities
20 on plants now under construction.
21 This package of recommendations addresses itself
22 specifically to those two points. And I will begin to
23 I read from the recommendations.
24 In order to protect Lake Michigan, the following
25 controls for waste heat discharges are recommended by the
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1 Summary and Conclusions
2 conferees* Municipal waste and water treatment plants,and
3 vessels are exempted from these recommendations«
4 I* Applicable to all waste heat discharges except
5 as noted above:
6 1. /it any time, and at a maximum distance of
7 1,000 feet from a fixed point adjacent to the discharge,
S (agreed upon by the State and Federal regulatory agencies),
9 the receiving water temperature shall not be more than 3° F,
10 above the existing natural temperature nor shall the maxi-
11 mum temperature exceed those listed below whichever is
12 lower:
13 And then there are listed the monthly maximum
14 temperatures as they appeared in the earlier draft* There
15 was a modification to the January — measured in the surface
16 feet: January, 45° J February, 45° J March, 45° J April, 55° J
17 May, 60°* June, 70°; July, SO0; August, S0°j September,
13 #0°; October, 65°; November, 60°j December, 50°«
19 There was a modification here in the form of
20 the parenthetical material that was not included in the
21 recommendation that was originally presented to you*
22 The parenthetical material says "agreed upon by
23 the State and Federal regulatory agencies,"
24 Now, may we —
25 MR, STEIN: Do you want to take one of these at
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651
Summary and Conclusions
a time, or do you want to read them all first?
MR, MAYO: I think it would be appropriate to take
them one at a time, Mr* Chairman.
MR, STEIN: If that is agreeable — unless there
is an objection to this procedure from the conferees, are
there any comments on I, 1* as read by Mr, Mayo?
MR, GURRIE: Mr* Chairman,
MR, STEIN: Yes.
MR, CURRIE: As I have already stated, I see no
reason for imposing limitations like this on existing
powerplants. It seems to me that the problem which we face
is one of proliferation and that any effects from existing
powerplants are minor and local, and it is not worth the
money to require the corrections that are indicated here,
I also have some technical questions about ths
recommendations* For example, the definition of the
mixing zone remains wholly ambiguous* so that no one can
ascertain the impact of the proposal upon existing plants,
If there is going to be a mixing zone, it ought
to be defined specifically,
MR, STEIN? Are there any other comments on this
proposal?
(Whereupon, the Executive Session was interrupted
by colloquy from the floor*)
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1 Summary and Conclusions
2 MR. STEIN: Mr. Frangos.
3 MR, FRANCOS* Well, Mr. Chairman, I would like to
4 ask Mr. Mayo to perhaps repeat again what he was talking
5 about — the parenthetical phrase that appeared in the
6 original proposal, I just missed that, I would like t©
7 hear that again, please,
8 MR. MAYO: Do you have a copy of the original?
9 MR. FRANGOS: Yes, I do*
10 (Whereupon, the Executive Session was interrupted
11 by colloquy from the floor.)
12 MR. MAYO: Mr. Frangos, if you have the two copies,
13 after the word "discharge" in the second line would be
14 added the M.,, (agreed upon by the State and Federal regu-
15 latory agencies)w.
16 The difference is in the form of the inserted
17 language in the front,
18 MR. FRANGOS: Well, I don't have any parentheses,
19 That is my problem*
20 MR. MAYO: Well, let's get you a set of paren-
21 theses.
22 (Whereupon, the Executive Session was interrupted
23 by colloquy from the floor.)
24 MR. FRANCOS: I'm sorry* This is different from
25 mine.
-------
_653
1 Summary and Conclusions
2 (Whereupon, the Executive Session was interrupted
3 by colloquy from the floor.)
4 MR, STEIN: Do you have a question now, Mr,
5 Frangos?
6 MR* FRANGOS: Yes, I have a question, then, beyond
7 the parentheses, and that is the definition of this fixed
# point,
9 MR, NATO: The intent here is to provide to the
10 regulatory agencies and the discharger some flexibility in
11 the establishment of the fixed point from which the 1,000
12 foot distance would be measured in order to accommodate
13 what would be a reasonable limitation for the size of the
14 plume for that specific discharge within the context of
15 1,000 feet.
16 MR, FRANGOS: Does this, then, suggest 1,000 feet
17 would be the maximum area irrespective of the method or
13 point of discharge?
19 MR, MAYO: Measured from this fixed point. Now,
20 the fixed point might be at the end of the discharge pipe
21 for a particular discharge, depending on what it is going
22 to be. If it is a discharge that has a configuration of
23 diffusers, then there would be an opportunity to select
24 a fixed point that is in keeping with the configuration of
tlle diffuser and provide as a focus against which the 1,000 j
-------
654
1 Summary and Conclusions
2 foot distance becomes a limitation, because we can envision
3 that the discharge facility might take a variety of forms
4 or a variety of configurations and the need for at least
5 this kind of flexibility in establishing a specific point
6 of reference from which the 1,000 feet applies*
7 MR. FRANCOS: So that the aerial extent of the
8 mixing zone could exceed 1,000 feet?
9 MS, MAYO: In any one direction?
10 MR. FRANCOS: In any direction*
11 MR* MAYO: No. It might be circular and have a
12 diameter of 2,000 feet, but the maximum distance would be
13 1,000 feet from the identified fixed point*
14 MR0 FRANCOS: Would the maximum area of any
15 mixing zone or the maximum diameter be 2,000 feet then?
16 MR. MAYO: Yes, under this, that is what it would
17 be.
13 MR. FRANCOS: And if it were onshore, for example,
19 then it could only be 1,000 feet* Would the maximum radius
20 be 1,000 feet?
21 MR* MAYQt Yes.
22 MR, FRANCOS: And the maximum diameter would be
23 2,000 feet?
2/«- MR. MAYO: Yes*
2 5 MR. STEIN: May I ask Michigan, do you have any
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655
1 Summary and Conclusions
2 comment on this first point as written or proposed?
MRo PURDY: I am trying to get clear on what has
been said*
MR. STEIN: Well, the glass wall isn»t impervious
to sound.
MR. PURDY: Well, I thought I was clear a couple
of days ago on the wording, at that time, and I am wondering
why the change?
10 It seems to me that this now has become more
11 restrictive than the wording presented to us and explained
12 to us the other day.
13 MS. MAYO: Well, all that is added is "... (agreed
upon by the State and Federal regulatory agencies)*w Just
15 the parenthetical material is all that was added.
16 MR. PURDY: Okay.
17 MR. MAYO: Okay?
MR. PURDY: Yes.
19 MR. STEIN: Mr. Miller.
20 MR. MILLER: I don't have any questions* no*
21 MR. STEIN: Well, I am going to ask now;, presum-
22 ably —
23 MR0 FRANCOS: I am sorry. Can I just try this
24 once again?
25 MR. STEIN: Yes, sir.
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656
1 Summary and Conclusions
I
2 I MR. FRANGOS: That fixed point could not exceed
i
o 1,000 feet from the shore, is that correct?
MR. MAYO: No, no, no.
Take for example — say there were a discharge
pipe. In order to meet the following requirements for
maximum monthly temperatures, that fixed pipe — that dis-
charge pipe might be 1,500 feet long, or it might hare at
its terminus a configuration of diffuser facilities, the
10 discharge being at the terminus,
11 If you were to apply the 1,000 foot limitation
12 and the location of the fixed point at the diffuser at some
reasonable point, so you may have a diffuser here, here,
here and here (indicating), a selected fixed point, and
15 apply the 1,000 feet as the maximum distance from that
16 point* And it could result in a 1,000 foot radius circule
17 as the zone in which the maximum monthly temperature limi-
tations would apply,
19 MR, FRANCOSj Okay, I think that does it*
20 MR, STEIN: Let me go through this again and
_., see — I assume, Mr. Mayo, that as you obviously put
22 this forward you are proposing this. Now, let me
23 check. Let me go down this side of the
24 table, Mr, Purdy, do you hare an objection to this, or
25 are you willing to accept No. 1?
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657
-1 Summary and Recommendations
2 MR. PURDY: Ready to accept No. 1. I do find it
3 rather odd that we are going through recommendations before
4 making findings but —
* MR. STEIN: I don't think there are — why don't
6 you talk? Are there any findings here?
7 MR. MAIO: No, we have gone directly into the
g recommendations* I am open to whatever recommendations Mr*
9 Purdy or the conferees want to make on that point*
10 MR, PURDY: Well, it seems that we have totally
11 ignored, at least right now, the report of the technical
12 committee* There are a number of findings in that* There
13 are some findings in Dr. Mount's paper, and it seems that
14 someplace along the line that we have to make some findings
15 to go along with our recommendations so that there is some
16 basis for the recommendations*
17 MR. STEIN: Mr. Mayo?
lg MR. MAYO: Well, I would like to, at this point,
19 offer for your consideration two findings very simply
20 stated: 1) that there is a need for stringent and uniform
21 standards for the control of waste heat into Lake Michigan
22 from sources other than municipal waste and water treatment
23 plants and vessels, and 2) that there is a need to place
24 limitations on large volume heated water discharges by
25 requiring closed cycle cooling systems on all new
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653
1 Summary and Conclusions
2 powerplants, and addition of such cooling facilities to
3 plants now under construction.
4 MR. BOILER: Can you go through those again?
5 MR, STEIN: Why don't we take them one at a time*
6 MR. MAYO: Take them one at a time?
7 MR. STEIN: Yes, Mr* Mayo.
g MR. MAYO: There is a need to establish stringent
9 uniform standards for the control of waste heat discharges
10 into Lake Michigan from sources other than municipal waste
11 and water treatment plants and vessels.
12 MR. STEIN: Are there any comments on that?
13 MR. CURRIE: Yes, Mr. Chairman. It seems to me
14 if we are going to make findings of fact which will later
15 toe. lead to recommendations, the findings should not them-
16 selves be phrased as recommendations, but they should go
17 back to more basic facts such as: What is the need? What
lg is the reason for the need which is suggested in these
19 proposed findings?
20 MR. STEIN: Before we do this, I womld like to
21 read a letter from a member of the press,
22 and I do this for tne consideration of the conferees.
23 He says: "It does absolutely no good to hold your Execu-
24 tire Session in the open if you, are discussing documents
25 not generally available. We in the press for one can't be
-------
659
Summary and Conclusions
2 expected to follow what you are doing unless we haTe copies
3 of the proposal and want to register a request that copies
A of your amended proposal be made available during your
5 deliberationsi otherwise your session might as well be
closed*"
There is no objection, of course, for any distri-
but ion of any document here, whether we are in open or
closed session. But this is a prerogative of the people who
10 prepare that aocumont*
MR. MAYO: I would have no objection to that, Mr«
12 Chairman, if the other conferees do not object*
13 MR. STEIN i Well, you can do what you wish. It
is your proposal. Do you have copies?
15 MR. MAYO: All right.
16 MR, BRYSONt I can get some made.
17 MR. STEIMt Will you continue with the discussion,
please?
19 MR. MAYQs Would you repeat —
20 MR« CURRIE: It seems to me if we are going to
21 be making findings, we ought to be n^ing findings as to
22
basic facts and not findings that read as if they were
2*5
^ recommendations and state merely the conclusion. I would
O I
^ be interested to know what are the facts which lead the
25
Federal conferee to the recommendations which he is proposing
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660
2
3
5
6
7
9
10
11
12
13
15
16
17
IB
19
20
21
22
23
24
25
Summary and Conclusions
and I would like, again, to ask my question: What are the
reasons which cause the Federal conferee to depart from the
conclusions of the technical committee*
MR, BANEt I would like to have the record show,
at this point, that copies of the amendment were distributed
to the press but were not offered to the members of the
public or to any institution that is affected by the regula-
tions*
MRo STEIHs I think everyone should be on notice
here that the record will show what the members of the
Executive Session say. If anyone wants to get a message
into the Executive Session, he may follow the procedure
we just did — the press did — and get a message
in so that a member here can read it*
Mr* Mayo*
MR. MATO: By way of a response, Mr* Currie, I
think it is obvious that there do not now exist uniform
State requirements in the form of Water Quality Standards
for the control of waste heat discharges into Lake Michigan.
The standards that were adopted by the States of
Indiana, Illinois, Wisconsin, were approved by the Secretary
of Interior* The standards for waste heat discharges pro-
posed by the State of Michigan was not approved* I feel
there is a definite need for the States to address
-------
661
1 Summary and Conclusions
2 themselves to a package of reasonable uniform criteria which
o thej feel they can individually adopt for the control of wastb
heat discharges into Lake Michigan.
The data that is proposed in section 1 point 1
5 here — the first subparagraph — in my estimation, is not
7 in contradiction with the findings and recommendations of
the technical committee. So I think that by way of an
expanded finding, we might say that inasmuch as the States
10 of Indiana, Illinois, Wisconsin, and Michigan do not now
11 have uniform standards for the control of waste heat dis-
12 charges into Lake Michigan, and inasmuch as the Water
13 Quality Standards proposed by the State of Michigan for the
control of waste heat discharges into Lake Michigan have not
15 been approved by the Administrator, and in keeping with the
16 need for the development of the adoption of uniform strin-
17 gent standards for the control of waste heat discharges into
Lake Michigan, that the States adopt the following — and
19 that would be subparagraph !•
20 MR. CURRIEt Mr. Chairman, it seems to me that
21 the Federal conferee is once again stating the conclusion
22 without giving the reasons. What I would like is a state-
23 ment of what the evidence is of any need for strict controls
24 of existing sources*
25 It is implicit in the recommended finding that
-------
662
1 Summary and Conclusions
2 there is such a need, and I would like the finding as
3 proposed to include a statement of the reasons for the
need*
5 MR, MAYO: Well, the reason, I think, is as
6 obvious as the reason that the States have moved forward,
7 Illinois, Indiana, and Wisconsin have adopted waste heat
discharge requirements* I think the need to move, as has
9 been suggested, is just as obvious and in keeping with the
10 fact that the States have already moved, have taken
11 official action in that direction,
12 This is a desire and expresses a need for those
13 requirements to be uniform and puts them in the context
of the material that was presented by Dr, Mount as being
15 in keeping with the need for the protection of the aquatic
16 organisms,
17 I MR, STEIN: Mr. Mayo, I would like to interrupt
lg with a procedural matter,
19 I have received a note from the representative
20 of the Indiana Michigan Electric Company requesting a copy
21 of the revised proposal of the Federal conferee which has
22 been distributed this morning to the conferees and the
23 press,
24 You can act on that as you wish,
25 MR, MAIO: I have no objection, Mr, Chairman, We
-------
663
1 Summary and Conclusions
2 will make copies available and distribute them.
3 MR* STEIN: Are there any other comments on this?
4 Mr* Purdy.
5 MR. PURDT: Well, some of the remarks seem to
6 indicate that if Michigan had only adopted standards like
7 those of the other States that this issue would have been
8 settled.
9 I am not of the opinion that if we had adopted
10 them that it would have been settled. In fact it is my
11 very clear understanding in our public hearings that those
12 were not considered adequate by the Federal representatives
13 that appeared at our public hearing.
14 MR. STEIN: Gentlemen, may I make a suggestion to
15 you? I am prepared to stay here — I love Chicago — over
16 the weekend. Now, if you want to spend time in the Execu-
17 tive Session going about what happened in the past and not
IB look to the future that is great because I enjoy hearing
19 it. But don't come to me after late Friday night and say
20 I didn't get you home.
•21 MR. PURDI: Well, some of these findings have
22 found their way into public notices and also a review of
23 our State plan, and I felt that it was necessary to comment
24 on it.
25 From the standpoint of uniform standards, it is —
-------
1
2
9
10
12
15
16
17
lg
19
20
21
22
23
24
25
664
Summary and Conclusions
I am wondering if they must be uniform or if they must meet
a certain base level.
Would it be, say, impossible for a State to adopt
something more restrictive than what might be adopted by
another State or the other three States*
Aren't we talking about a compatible standard
that would meet a certain minimum requirement of the
Administrator that he could approve rather than a strictly
uniform?
MR, MAYO: The material, as you see it stated
here in subparagraph 1, I think, is obviously offered in
that context, and would come back to the States from the
Administrator if he agrees for the States to take before
their respective water pollution control agencies the hear-
ing processes to which they are obliged to follow. If
one of the States were to proceed with the adoption of the
criteria more stringent than these for later submission to
the Administrator's approval, I would be hard pressed to
see that there would be anything but approval.
MR. PURDY: Okay. Now, from the standpoint of
"the findings, it seems that there are statements in both the
technical committee's report and Dr. Mount's that are
significant. Dr. Mount, early in his statement, noted
that his discussion is based on an assumption that he
-------
665
1 Summary and Conclusions
2 thought was well accepted by informed people, and that is
3 that the lake as a whole will not be warmed except in
4 localized areas by powerplants} and although this may be
5 well accepted by informed people, I think it would be
6 valuable for the conferees to note this as one of the
7 findings,
g MR. STEINs Do you want to — may I suggest, Mr.
9 Purdy, if you have findings to suggest, you propose them to
10 the conferees and let's try to act on them so we can move
11 forward*
12 MR. PURDI: Okay. I am proposing this as one of
13 the findings of the conferees.
14 MR. STEIN: Would you read the finding as pro-
15 posed? I think you practically have it there.
16 MR, PURDY: The lake as a whole will not be
17 warmed except in localized areas by the discharges of waste
1# heat from the powerplant?
19 MR. STEIN: Are there any objections to that
20 as adopted as a finding? If not —
21 MR. CURRIE: Mr. Chairman.
22 MR. STEIN: Yes, sir.
23 MR. CURRIE: I certainly agree with that finding.
24 But it seems to me we should not proceed piecemeal about
25 this without a full set of recommended findings.
-------
666
1 Summary and Conclusions
2 MR. STEIN: I think that is a — yes, sir — we
will —- I will check each one for an objection and then we
will come back and give you an opportunity to look at the
whole set* Okay?
MR. CURRIE: I would like to suggest, Mr* Chairman,
that there is an elaborate set of findings in a letter which
the Illinois Pollution Control Board sent to you on February
o, 2, 1971» and I would like to suggest that the conference
10 adopt that letter as its findings with regard to this
11 conference*
12 MR. STEIH: Let me suggest this* Mr. Purdy has
the floor now suggesting his findings. If he wants to
waive that to consider that procedure, it is all right. Or
15 we can go with Mr* Purdy1s and take your suggestion uj
*
16 later* We can make Mr. Currie's letter part- of the record.
17 MR. PURDYj Well, any way that we can speed this
13 up and I don't have a written set of findings to work from
19 and right at the moment I don»t have Mr* Currie's February
20 2 letter and if he could furnish copies ©f this it might
21 speed it up*
22 MR* STEIN: Do we have copies of that to dis-
23 tribute so people could look at it? I am talking about the
24 mechanics of that*
25 MR. CURRIE: We can get them for you very quickly.
* The February 2, 1971 letter follows.
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667
STATE OF ILLINOIS
JPO1.MJTIOW GOWFMOl,
189 WEST MADISON STREET SUITE 9OO
DAVID P. CURRIE,CHAPMAN CHICAGO, ILLINOIS 6 O6O2 TELEPHONE
SAMUEL R.ALDRICH 312-793-3680
JACOB D. DUMELLE
R,CHARD J. KlSSEL
SAMUEL T. LAWTON.JR.
February 2, 1971
Murray Stein, Esq.
Chief Enforcement Officer
Federal Water Quality Administration
United States Department of the Interior
Washington, D. C. 20242
Dear Mr. Stein:
The Illinois Pollution Control Board, as the body charged
with exclusive state authority to adopt water quality standards,
effluent standards, and other regulations relating to water
pollution in the Illinois portion of Lake Michigan, will attend
and expects to participate as a conferee in the coming sessions
of the Lake Michigan Conference, as it did in the Conference
sessions held in Chicago last Fall. Please inform me as to the
agenda as soon as possible so that we may be prepared to discuss
whatever subjects you expect to consider.
On the assumption that one purpose of the coming sessions
is to attempt a resolution of the pending controversy over thermal
standards for the Lake, the Board has authorized me to make the
following statement, which we are sending to all the Conferees
and which I ask that you make a part of the record.
The Illinois Pollution Control Board in late 1970 conducted
four days of public hearings on various proposed thermal standards
for Lake Michigan and participated actively in the five-day Conference
proceedings on the same subject. We have carefully studied the
record in those proceedings, and we are agreed on the following
points:
1. The area that would be raised in temperature more than
5° by the heated discharge from a 1000 mw nuclear plant, designed
so as to maximize dilution, could be limited to the order of ten
and the area raised 2° to the order of 100 acres.
-------
668
-2-
2. Such a plant could be built so that any given particle
of water, or any organism, drawn through its condensers would
be exposed to temperatures 20° above ambient for two minutes
during passage, and any particle or organism discharged or en-
trained would be -exposed thereafter to temperatures more than
10° above ambient for the order of forty-five seconds, more
than 5° for six minutes, and more than 2° for one and a half hours.
3. A properly designed discharge structure can avoid any
significant increase in temperature on the lake bottom or along
the shore.
4. The lake as a whole would not be perceptibly warmed by
even a tenfold multiplication of present generating capacity on
the lake with once-through cooling, if there were perfect mixing.
5. Perfect mixing, however, is not possible. Consequently,
if no limits are imposed the proliferation of electric plants
along the lake may result in the warming by several degrees of
a large fraction of the inshore waters, especially in the southwest
portion of the lake.
6. The interaction of two or more thermal plumes may have
a more than linear effect on the area affected by a rise in
temperature and on the residence time of any particle at elevated
temperatures.
7. A single 1000 mw nuclear plant will create a zone of a
few acres uninhabitable by fish during the warmer months and
unsuitable for spawning and other significant fish activities at
various times.
8. Many, but an unknown percentage, of organisms passing
through the condensers of such a power plant will be killed or
damaged by heat and by physical shock.
9. A single large plant located in a spawning ground or
across a migratory route would significantly disrupt the balance
of the affected species throughout the lake.
10. The residence time of algal cells in the heated plume
from a properly designed single 1000 mw plant is too short to
cause any detectable shift to less desirable species, and no
increase in total algal mass is to be expected.
11. Unless it is located so as to interfere with spawning or
migration, a single 1000 mw plant will have local effects as
noted above but will not upset the balance of the lake as a whole.
-------
669
-3-
12. Unlimited proliferation of electric plants along the lake
could seriously worsen the problem of nuisance algae by favoring
the less desirable species and CQuld seriously alter the balance
of fish and other organisms in the lake as a whole.
13. Various alternative methods of heat disposal are technically
feasible, including wet and dry cooling towers, cooling ponds, and
spray caiaals. The backfitting of all but dry towers is feasible.
14. To backfit wet towers at the 2200-mw nuclear plant,now
under construction at Zion, Illinois, would cost somewhere from
fifteen to seventy-five million dollars; at a maximum this would cost
residential customers each sixty-nine cents per month.
15. All alternative cooling means may have some undesirable
environmental effects. Wet towers can cause fog problems; the
Commonwealth Edison Company estimates fog from a wet tower on five
to thirty mornings per year at Zion, usually in unpeopled areas.
All towers discharge some polluted blowdown water that must be
treated before release. Dry towers may cause as yet undetermined
meteorological changes. Both wet and dry towers are bulky and
unattractive additions to the lakefront» Evaporation from wet
towers or spray canals arguably would be charged against Illinois'
limited authority to divert water from Lake Michigan. Cooling ponds
consume about two acres of land per megawatt, land that could be
put to productive use.
The Board is agreed that, based on the above facts, the following
alternatives are open to the Conference and to the Board.
A. Impose no limit on heated discharges to the lake. This
alternative is wholly unacceptable, since unlimited proliferation
of heat sources could very well have a very substantial detrimental
effect on the ecology of the lake as a whole.
B. Outlaw all heated discharges to the lake, or all discharges
above a given temperature (e.g., 1° or 5° above ambient), or
above a given volume (e.g., 50 gallons per hour), with or without
a grandfather clause. Such an approach would have the virtue
of avoiding a later difficult and uncertain decision as to when
the point of serious ecological risk is reached by a firm and
early declaration that no significant thermal sources are to be
allowed, and it would establish the position that not even a
small percentage of the lake is to be sacrificed in the interest
of inexpensive cooling.
C. Attempt to determine today the approximate thermal input
that can be tolerated without harming the lake as a whole and
without sacrificing undue percentages of the lake in the interest
of inexpensive cooling, for example by limiting inputs to fifteen
billion btu per hour within each twenty-mile stretch of lakeshore.
This approach, while necessarily arbitrary in the same sense as
is setting the voting age at 18 or at 21 years, has the advantage
-------
670
of attempting to avoid overall lake damage while accepting the
argument that it is not worth millions of dollars to avoid
making perhaps twenty acres uninhabitable by fish, and while
allowing considerable use of a valuable natural resource, the
cooling capacity of Lake Michigan.
D. Accept the Committee proposal to defer decision a few
years in the hope that more complete information will be obtained,
by placing the burden of proof on those discharging or planning
to discharge heated effluents to show that their action will
not cause ecological damage. This alternative preserves maximum
flexibility to accommodate new knowledge, with a concomitant
increase in uncertainty.
The Board has not yet reached agreement as among alternatives
B, C, and D. With the help of arguments presented at the coming
Conference sessions, we plan to take a vote on these alternatives
within the next few weeks and to publish a proposed final draft
of the new regulation during the first week in March. In any
event, it seems highly likely that the Board will prescribe at
least the following restrictions:
1. Neither the bottom nor the shore shall be affected by
a new heated discharge of significant proportions.
2. No new heated discharge of significant proportions shall
be located so as to affect spawning grounds or migration routes.
3- Discharge structures shall be so designed as to maximize
short-term mixing and thus to reduce the area significantly
raised in temperature.
4. No discharge of significant proportions shall exceed
ambient temperatures by more than 20° F.
5. No new heated dishcarge of significant proportions shall
interact with any other heated discharge of significant proportions
6. Backfitting of alternative cooling devices will be
required if significant damage is shown fr:om existing or future
heated discharges.
7, All reasonable steps shall be taken to reduce the number
of organisms drawn into or against the intakes.
8. Physical, not chemical cleaning of condensers will be
required.
-------
671
-5--
Th e Illinois Pollution Control Board recognizes the desirability
of uniform or compatible action by the four Lake Michigan states
to preserve and to restore the quality of our common resource,
and with this policy in mind we shall work toward a common standard
that is strict enough to assure protection against significant lake
degradation. It is our hope and expectation that the other states
share this policy and that they will work toward the same goal of
uniformity in such important areas as phosphate standards, in which
the Illinois provision is currently far more strict than those of
the other Lake Michigan states.
David P. Currie
Chairman
DPC:jc
cc: all conferees
-------
672
1 Summary and Conclusions
2 MR, STEIN: I know we can.
3 MR, CURRIE: They were sent to the conferees and
4 to the Chairman of the conference on February 2,
5 ME, STEIN: I understand that, I am not sure
6 that the conferees have these copies before them now. My
7 guess is they don*t. So if we are going to propose that
g as a working operation, I suggest we get those duplicated
9 as rapidly as possible,
10 While that is being done, what do you want to do?
11 Do you want to recess until that gets done, or do you want
12 to see if we can proceed?
13 What is your view on that? Do you want to proceed
14 on the findings, or do you want to wait for Mr, Gurrie's
15 paper,
16 MR, PURDYs I have a copy of it now that I found
17 in my files, I would like to take a moment to read it
IB through,
19 MR, STEIN: I think you all have to have copies if
20 we are going to follow this intelligently,
21 MR, PURDY: Does Mr, Frangos have one?
22
MR, STEIN: Do you have one, Mr, Frangos?
23
MR, CURRIE: We have sent someone to get additional
24
copies of this. It should be back in 10 minutes,
25
-------
673
1 Summary and Conclusions
2 MR. STEIN: What do you want to do? All right.
3 Now, let me ask you: What do you want to do? Do you want
4 to proceed?
5 MR. PURDY: Let's recess for 10 minutes.
6 MR. STEIN: We will recess for 10 minutes.
7 (Short recess.)
3 MR. STEIN: Let's reconvene*
9 I think as this is coming in, I think that Mr.
10 Purdy has a suggestion that we may be able to consider,
11 and we will consider Mr. Currie's suggestion when it
12 comes in.
13 Mr. Purdy, do you want to make your proposal?
14 MR<> PURDY: Yes, on the first one that I offered,
15 it has been pointed out to me that you can postulate an
16 infinite number of plants and if you do so that certainly
17 the lake — there is the possibility that the lake as a
1# whole will not be warmed. So I would say that instead of
19 "by the1'-- if you would say 'by powerplants^ if you would
20 say "by existing and presently proposed discharges from
21 powerplantSa"
22 Then, in addition to that, to get something
23 moving along in the way of findings, I would suggest that
24 we — or I would offer those that Dr. Mount has offered in
25 his statement on page 3 in the middle of that page — and
-------
674
1 Summary and Conclusions
2 he states that they are key points of concern regarding the
3 temperature standards on Lake Michigan, and I would suggest
4 that we look at those seven — all of his findings*
5 MR, STEIN: I suggest, Mr, Purdy, that with your
6 first one, why don't you read your whole package — that
7 shouldn't take more than a few minutes — then we will get
# the idea and either we will consider it as a whole or in
9 part,
10 MR* PURDI: Well,"first of all, that the lake as
11 a whole will not be warmed except in localized areas by dis-
12 charges of waste heat from existing and presently proposed
13 powerplants*
14 Following that,"that safe lake temperatures vary
15 with season and species — that would be number 2*
16 "Third, heat is not persistent,
17 "Four, timing of food and fish hatching is pre-
16 carious*
19 "Five, in the summer, Lake Michigan is a lake over
20 a lakej the top one is much warmer than the bottom one*
21 "Six, maximum temperatures are not safe for long
22 periods* Lethal temperatures must be related to time*
23 'Seven, mean temperatures must be lower than the
24 maximums*
25 "Eight, that fish kill hazards are greatest»in the
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1 Summary and Conclusions*
2 winter »v
3 MR. STEIN: All right, now, letfs put that in
4 abeyance for a bit,
5 Mr, Currie, would it be possible for us to hare
5 the package that you are proposing as findings now before
7 the conferees?
3 MR, CURRIE: Would you like me to read them?
9 MR, STEIN: Yes,
10 MR, CURRIS: These are the fact findings of the
11 Illinois Pollution Control Board on the basis of our four
12 days of hearings and the five days of Federal workshop. They
13 were sent to each of the members and the Chairman of the
14 conference February 2, 1971*
15 "1* The area that would be raised in temperature
16 more than 5° by the heated discharge from a 1,000 megawatt
17 nuclear plant, designed so as to maximize dilution,, could be
18 limited to the order of 10 acresj the area raised 2° to the
19 order of 100 acres,
20 "2, Such a plant could be built so that any given
21 particle of water, or any organism,drawn through its con-
22 densers would be exposed to temperatures 20° above ambient
23 for 2 minutes during passage, and any particle or organism
24 discharged or entrained would be exposed thereafter to
25 temperatures more than 10* above ambient for the order of
-------
676
1 Summary and Conclusions
2 45 seconds, more than 5° for 6 minutes, and more than 2°
3 for 1 and a half hours,"
4 Those two findings, Mr, Chairman, are based on
5 the uncontradicted testimony of Dr, Pritchard , which
6 in my view withstood rather vigorous cross examination,
7 "3« A properly designed discharge structure can
$ avoid any significant increase in temperature on the lake
9 bottom or along the shore,
10 "4, The lake as a whole would not be perceptibly
11 warmed by even a tenfold multiplication of present gener-
12 ating capacity on the lake with once-through cooling, if
13 there were perfect mixing,
14 And that is very similar to the finding suggested
15 by Mr, Purdy,
16 "5* Perfect mixing, however, is not possible<>
17 Consequently, if no limits are imposed the proliferation
18 of electric plants along the lake may result in the warming
19 by several degrees of a large fraction of the inshore
20 waters, especially in the southwest portion of the lake,"
21 I think it is important to make that point as
22 well as the point that the entire lake as a whole is not
23 likely to be affected,
24 " 6, The interaction of two or more thermal plumes
25 may have a more than linear effect on the area affected by
-------
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1 Summary and Conclusions
2 a rise in temperature and on the residence time of any
3 particle at elevated temperatures,"
4 And that again is based on the testimony of Dr,
5 Pritchard*
6 "7* A single 1,000 mw, nuclear plant will create
7 a zone of a few acres uninhabitable by fish during the
# warmer months and unsuitable for spawning and other signi-
9 ficant fish activities at various times,"
10 That is based on the testimony of Dr, Raney who
11 was a biologist testifying on behalf of Commonwealth
12 Edison,
13 "S, Many, but an unknown percentage, of organisms
14 passing through the condensers of such a powerplant will be
15 killed or damaged by heat and by physical shock,
16 "9, A single large plant located in a spawning
17 ground or across a migratory route would significantly
13 disrupt the balance of the affected species throughout the
19 lake,
20 "10, The residence time of algal cells in the
21 heated plume from a properly designed single 1,000 mw,
22 plant is too short to cause any detectable shift to less
23 desirable species, and no increase in total algal mass is
24 to be expected,
25 " 11* Unless it is located so as to interfere with
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1 Summary and Conclusions
2 spawning or migration, a single 1*000 mw, plant will have
3 local effects as noted above but will not upset the balance
4 of the lake as a whole*
5 "12* Unlimited proliferation of electric plants
6 along the lake could seriously worsen the problem of
7 nuisance algae by favoring the less desirable species and
3 could seriously alter the balance of fish and other
9 organisms in the lake as a whole*
10 "13* Various alternative methods of heat disposal
11 are technically feasible, including wet and dry cooling
12 towers, cooling ponds, and spray canals* The backfitting
13 of all but dry towers is feasible.
14 "14. To backfit wet towers at the 2,200 mw*
15 nuclear plant now under construction at Zion, Illinois,
16 would cost somewhere from $15 million to $75 million; at
17 a maximum this would cost residential customers each
IS 69 cents per month*
19 " 15« All alternative cooling means may have some
20 undesirable environmental effects* Wet towers can cause
21 fog problems; the Commonwealth Edison Company estimates
22 fog from a wet tower on five to thirty mornings per year
23 at Zion, usually in unpeopled areas* All towers discharge
24 some polluted blowdowa water that must be treated before
25 release* Bry towers may eamse as yet undetermined
-------
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1 Summary and Conclusions
2 meteorological changes* Both wet and dry towers are bulky
3 and unattractive additions to the lakefront. Evaporation
4 from wet towers or spray canals arguably would be charged
5 against Illinois1 limited authority to divert water from
6 Lake Michigan* Cooling ponds consume about 2 acres of
7 land per megawatt, lar.d that could be put to productive use,"
g Those, Mr* Chairman, are the findings of the
9 Illinois Pollution Control Board, and I should like to move
10 that they be made the findings of this Conference as well,
11 MR0 STEIN: Well, may I ask just a point of
12 clarification? Do you believe that this Conference has
13 before it the information on which to base all of these
14 findings?
15 MR, CURRIE: I certainly do, Mr* Chairman* All
16 that evidence is in the record presented to this Conference
17 during the 5 days of workshop last fall.
IB MR* STEINi Right*
19 All right, now, let us — do any other of the
20 conferees have findings to propose at the present time?
21 Well, I think we can do several things: 1) I
22 think we can either take Mr. Purdy*s proposed findings as
23 a package; or 2) these findings as a package? or 3) if they
24 are not mutually exclusive can put them together.
25 Now, I think when we talk in terms of findings,
-------
_____^_ 680
1 Summary and Conclusions
2 it possibly would be most productive to proceed one at a
3 time and if we can proceed -~ let's start with the numbers*
4 Mr. Purdy had eight, didn't you?
5 MR. PURDI: Tes*
6 MR* STEIN: And there were fifteen proposed by
7 Mr* Gurrie*
g Let us try this* Let's have your first one, Mr*
9 Purdy*
10 MR. PURDT: "The lake as a whole will not be warmed
11 except in localized areas by the discharges of waste heat
12 from existing and presently proposed powerplants*"
13 MR, STEIHi I suggest we take these all up* While
14 there may- be some of Mr* Currie's that come close with this,
15 let's try to follow these through in order. Then if we
16 have to do any editing later,after we have adopted then we
17 could do it*
l£ Are there any objections or any comments on that
19 proposed finding by Mr* Purdy of Illinois? Would you
20 accept that?
21 MR* MILLER: Were you asking Indiana?
22 MR* STEIN) Indiana* I am sorry* 1 was looking
23 I the wrong way* Indiana*
24 MR, MILLER: les, I would accept this*
25 MR, STEINi The Federal conferee*
-------
681
1 Summary and Conclusions
2 MR. MAYO: I missed the last of that statement*
3 ME* PURDY: "The lake as a whole will not be warmed
4 except in localized areas by the discharges of waste heat
5 from existing and presently proposed powerplants*"
6 MR. MAYOs I have no objection to this*
7 MR. STEIN: The question is: Will you accept that
g as a finding?
9 MR. MAYO: Yes.
10 MR. STEIN: Right*
11 Illinois, do you accept that as a finding?
12 MR. CURRIE: Yes*
13 MR. STEIN: Wisconsin.
14 MR. FRANCOS: Yes,
15 MR, STEIN: Let's go on to No* 2, Mr* Purdy.
16 MR, PURDY: Safe temperatures in the lake vary with
17 season and species*
18 MR, MILLER: I will accept this. Could we take
19 all of these at one time or not?
20 MR. STEIN: Well, I will accept that. If this
21 doesn't work we will go back*
22 Why don't you read them all and see if we can do
23 it that way* That and the other six,
24 MR. PURDT: "Heat is not persistent. Timing of
25 food and fish hatching is precarious* In the summery Lake
-------
1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
682
Summary and Conclusions
Michigan is a lake over a lake; the top one is much warmer
than the bottom one* Maximum temperatures are not safe for
long periods* Lethal temperatures must be related to time*
Mean temperatures must be lower than the maximums* Fish
kill hazards are greatest in the winter*"
MR. STEIN: Do you agree with all of those?
MR* MILLER} I would accept these as findings*
MR. STEIN: Mr. Mayo*
MR. MAYO: Yes, I agree*
MR* STEIN: Mr. Currie.
MR. CURRIE: I agree with these*
MR. STEIN: Mr* Frangos*
MR. FRANGOS: If you are talking of taking
judicial notice of those, yes* But would you repeat the
one about the minimum and maximum? It is about 7 or 8, is
it, Ralph?
MR. PURDY: "Maximum temperatures are not safe for
long periods* Lethal temperatures must be related to time.
And here again, in the editing, you might want to add "time
of exposure,1* or something, but I think we understand the
intent here*"
MR. FRANGOS: Okay, very good*
MR. STEIN: Do you accept those?
MR. FRANGOS: Fine*
-------
683
Summary and Conclusions
2 MR. STEIN: All right* We are all agreed on those*
o How, let us turn to Mr. Currie for the presenta-
• tion of No* 1* Do you want to present that, Mr* Gurrie, or
r do you want to propose that we handle them all together?
The same way? What do you suggest? Mr. Currie, what would
you suggest, that we do them all together or one at a time?
MR. CVRRIEi My preference would be to do them
9 all together, but I recognize that that might not meet with
10 the approval of other conferees.
MR. STEINj They may be complicated. What do
-L2 you think?
MR. P¥RDIi Mr* Stein, well, I feel that many of
these relate specifically to Illinois, and are not neces-
sarily conclusions and findings or findings that we in
16 Michigan are involved in*
17 MR. STKIH: All right.
MR. PURDI: And so, therefore, I am wondering
19 what additions Mr* Currie feels would be necessary to
20 those that have now been agreed to by the conferees*
2i MR* STEENt All right* Weuld that be agreeable
22 to you, in light of that comment, Mr* Currie, to indicate
23 maybe going along which ones in addition to the ones we
24 just adopted, and I think, Mr. Currie, I can sense this
25 as well as you can, I think it will move faster if we take
-------
684
1 Summary and Conclusions
2 them one at a time for the time being and come up with any
additions we think we should come up with«
MR, CURRIE: I think it is important, Mr* Chairman,
that we make specific findings as to the area that is likely
to be affected by a single plant* I think it is important
that we have a thorough and complete record of the facts
found by the conferees, and I don*t think, therefore, that
9 it is sufficient simply to say that the entire lake will
10 &ot be raised in temperature and that the effects will be
local without making some attempt to define what those
12 local effects will be both in terms of the physical behavior
13 of plumes and in terms of the effects of such a plume on
14 organisms* And, therefore, it seems to me that the first
15 finding is necessary* This is an attempt to delineate the
15 area that we are talking about when we say that there will
17 be local effects from a powerplant,
MR, STEIN: All right*
19 We have the first finding proposed* Are you pre-
20 pared to comment on that, Mr* Mayo, or do you want to
2i accept it?
22 ME, MAYO: This is item No* 1 at the bottom of
23 the page*
24 MR. STEINj Right*
25 MR, MAYO: As I understand the information on which
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2
3
4
5
6
7
0
9
10
11
12
13
14
15
16
17
Id
19
20
21
22
23
24
25
Summary and Conclusions
this is based, Mr. Currie, they design so as to maximize
pollution could be limited to the order of 10 acres. This
"could," as I understand it, is based on the theoretical
material that was presented by one of the experts — Dr.
Pritchard?
MR. CURRIE: That is correct.
MR. MAYO: Okay. I think if we would insert the
phraseology "could, if the theoretical evaluation is
correct, be limited to the order of."
MR<> STEIN: Do you want to accept that amendment
or not, Mr. Currie?
MR. CURRIE: Yes, that is certainly one of the
assumptions on which this is based. It is also true that
those theoretical assertions were mncontradicted in the
record.
MR. STEIN: Mr. Mayo.
MR. MAYO: In what record?
MR. CURRIE: The record of the workshop of this
Conference.
MR. MAYO: I think I would refer you to go back
to the record.
MR. CURRIE: In what respect?
MR. MAYO: Review the testimony of that session
on Wednesday evening*
-------
£86
1 Summary and Conclusions
2 MR. CURRIE: What is it you have in mind?
3 MR. MAYO: If the theoretical — if this hinges
4 on the correctness of the theoretical approach, I have no
5 objection to this,
6 MR. STEIN: Let me say this: If the recollection
7 of two of the conferees is different as to what the record
# is as to whether something was contested or not, I think
9 this shows it.
10 Now, what I am trying to do is see if we can come
11 to an agreement. Mr. Currie has made a proposal. There is
12 a modification suggested by Mr. Mayo.
13 Will you accept Mr. Mayo's suggestion, or do you
14 feel that that isn't appropriate?
15 MR. CURRIE: May I have the exact language?
16 MR. STEIN: Go ahead.
17 MR. MAYO: " ...could, if the theoretical appraisal
1^ is correct, be limited to ...1I
19 MR0 MILLER: Whereabouts are we, now?
20 MR. STEIN: Well, let me read the whole
21 thing, because the record isn't going to show this, and I
22 think we better do that when we start each one.
23 It reads: "The area that would be raised in
24 temperature more than 5° by the heated discharge from 1,000
25 megawatt nuclear plant designed so as t© maximize dilution
-------
687
1 Summary and Conclusions
2 could be limited to the order of 10 acres, and the area
3 raised 2° to the order of 100 acres,"
4 And the recommendation that Mr* Mayo had for a
5 change comes after the word wcould*M
5 Are we in agreement on the amendment to this?
7 MR* CURRIE: I would like to suggest one amendment
g to the amendment*
9 MR. STEIN: Yes*
10 MR<, CURRIE: I would like it to read "..» could,
11 if the only theoretical appraisal in the record is correct,
12 be limited .*,"
13 MR. STEIN: Why don't we identify it by name?
14 By the way, I am making this from a public point
15 of view to you people here. The difficulty is that we are
16 not putting out something with cross references and it
17 should be a self-contained document. Now, if you mean the
lg record could — if the theoretical appraisal made by Dr,
19 Pritchard — whatever his first name is — of Johns Hopkins
20 is correct, so people will know where to look when they
21 read this instead of skating around when they have a docu-
22 ment to discuss. And I say this just for purposes of clari-
23 fication if that is what you mean,
24 MR, MATO: I would not object to that.
25 MR, STEIN: Is that appropriate, Mr, Currie?
-------
688
1 Summary and Conclusions
2 MR. CURRIE: It is fine that the finding identi-
o fied Dr. Pritchard, I think it is also important that the
finding specify that there was no contrary evidence in the
record.
6 MR, STEIN: In other words, you want that to be
7 stated here? As far as — now, as I understand this, do
you agree, Mr. —
MR. MATO: No. There was testimony presented by
10 Mr. Callaway that was not in agreement with the theoretical
explanation that Dr. Pritchard offered.
12 MR. CURRIE: How large an area did Mr. Callaway
suggest would be affected?
14 MR. MAYO: I don't recall specifically what that
15 was.
15 MR. CURRIE: I suggest that he made no such sug-
17 gestion, I suggest that all Mr. Callaway said was that
modeling is a species of witchcraft and I don't consider
19 that to be a contradiction of the testimony that was pre-
20 sentedo
21 MR. STEIN: Let me say this. As I understand it,
22 I can see that we have a possible agreement if you and
23 Mr. Mayo can get together on the language.
24 Bo I take it — but I sense that if you say that
25 this stands uncontradicted in the record, you and Mr. Mayo
-------
689
1 Summary and Conclusions
2 very probably will not come to an agreement*
o Therefore, are you putting your proposal forward
• that without contradictions in the record or aot at this
4
c point? Then I will poll the conferees*
6 MR, CURRIE: I would like to say "... could, if
7 the only theoretical appraisal in the record is correct,
g be limited ..."
n MR. STEIN: That is your proposal?
10 MR, CURRIE: And I am willing to insert parentheses
H saying "...(that of Dr. D. W. Pritchard)..."
12 MR. STEIN: If any of the other conferees want
13 to speak up, you may.
1/f MR, FRANGOS; Mr. Stein, isn't the awkward word
15 here "could* and isn't that perhaps sufficient for the
16 purposes of the finding?
17 MB* MA10: Tes, but I think it is important at
lg this point in time, Mr. Frangos. to identify the character of
19 the material upon which that "could** is based and it is in
20 fact theoretical.
2i MR. STEIN: Didn't he say that ia his proposal?
22 MR* MATO: Tes.
23 MR. STEIN: Right*
24 Well, let me get to this. How do you feel, Mr.
25 Mayo, about the proposal that is made mow?
-------
690
1 Summary and Conclusions
2 MR, MAYO: I have some question in terms of the
3 limitation that's the only theoretical proposal because
4 there was a great deal of material presented and discussed
5 that Wednesday evening, that might fit the context of
6 theoretic discussion of theoretical — theoretical consid-
7 eration of alternatives other than that which Dr* Pritchard
g presented and I am more than willing to address ourselves
9 specifically to the Pritchard concept*
10 MR* STEINi Well, I think the key — and I am
11 trying to resolve this — the problem comes down to the
12 point of the word "only," Now, do you feel that tfeat is
13 essential to your statement here, Mr* Currie?
14 MR. CURRIE: les, I think without that we are not
15 making any finding at all*
16 MR. STEIN: All right.
17 MR. MAYO: I will agree to Mr. Carrie's presen-
lg tation.
19 MR* STEIN: Okay, Let's have that language again
20 so we can be certain we have it,
21 MR, CURRIE: "The area that would be raised in
22 temperature more than 5° by the heated discharge from a
23 1,000 mw« nuclear plant, designed so as to maximize
24 dilution, could, if the only theoretical appraisal in the
25 record (that of Dr. B. W. Pritchard) is correct, be limited
-------
691
Summary and Conclusions
2 to the order of 10 acres, and the area raised 2 to the
o order of 100 acres."
MR. STEIN: Mr. Mayo, do you agree with that?
MR. MAYO: Yes.
MR. STEIN: Mr. Purdy?
MR. PURDY: Agreed.
MR. MILLER: Agreed.
MR. STEIN: Mr. Miller.
Mr. Frangos.
MR. FRANGOS: Agreed.
MR. STEIN: All right. Let's go to the second
,- one.
-,, MR. CURRIE: I would be happy to insert the same
,f. cautionary clause in the second one; it is based on the
,/• same testimony.
,„ MR. STEIN: Why don't you read it as you would
like to put it? I think that would be faster. I think
we have to get this.
2Q Would you read it the way you would like to see
it put in? In light of the previous discussions, it
22 may be the one that has the best chance of adoption most
rapidly.
«, MR. CURRIE: "On the same assumptions made in para-
graph 1, such a plant could be built so that any given part:.cle
-------
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10
11
12
17
19
20
2i
22
23
24
25
692
Summary and Conclusions
of water, or any organism., drawn through its condensers would
be exposed to temperatures 20° above ambient for 2 minutes
during passage, and any particle or organism discharged or
entrained would be exposed thereafter to temperatures more
than 10° above ambient for the order of 45 seconds, more
than 5° for 6 minutes, and more than 2° for 1 and a half
hours* "
MR. STEIHj Would you care to comment on that, Mr*
Mayo?
MR. MATOj Ion would embrace the same insert*
MRe STEIN: Mo, no, he had a phrase "«*• on the
same assumptions as No* 1 . «*"
MR* CURRIEt "On the same assumptions made in
paragraph 1*»*
MR. STEIN: That that is the only testimony, the
only theoretical point on it.
MR* CURRIEj Of course, we could incorporate this
word for word and I would be happy to —-
MR. MAYO: I would like to see it incorporated
word for word*
MR* CURRIEj Fine*
MR* STEIN t Then let's get the exact language*
Will you give us that again?
MR. CTRRIE: All right*
-------
693
1 Summary and Conclusions
2 "If the only theoretical appraisal in the record
j (that of Dr. D» W, Pritchard) is correct, such a plant — ''
4 and then it proceeds from there according to the text*
5 MR. STEIN: Is that agreeable?
6 Well, I am sorry. I am going to have to ask for
7 a yes or no, not that I don't understand you, but it has
$ to get on the paper.
9 Mr. Purdy.
10 MR. PURDY: Agreed.
11 MR. MILLER: Agreed.
12 MR0 STEIN: Mr. Frangos.
13 MR. FRANGOS: Yes.
14 MR. STEIN: All right. No. 3.
15 MR. CURRIE: I would like to preface this one
16 with the same "if* clause* "If the only theoretical
17 appraisal in the record is correct"— sorry, "If the only
IB theoretical appraisal in the record (that of Dr, D. tf.
19 Pritchard) is correct, a properly designed discharge struc-
20 ture cam avoid any significant increase in temperature on
21 the lake bottom or along the shore*"
22 MR. MAIOt Yes, no objection*
23 MR. STEIN: Yes. All right*
24 MR* PURDY: Agreed*
25 MR* MILLER: Agreed,
-------
694
1 Summary and Conclusions
2 MR. FRAHGOS: Tes*
3 MR. STEIN: Let's go on,
4 MR. CURRIEt No, 4, I think, has been adequately
5 covered by Mr* Purdy's proposal.
6 MR. STEIN: All right,
7 MR. FRANCOS: Will that be added or deleted?
MR. CURRIE: I think this should be deleted,
9 MR. STEIN: All right. We won't consider it.
10 Go to the next one, No. 5,
MR. CURRIE: " No. 5, Perfect mixing, however, is
12 not possible. Consequently, if no limits are imposed the
13 proliferation of electric plants along the lake may result
14 in the warming by several degrees of a large fraction of
15 the inshore waters, especially in the southwest portion of
16 the lake. "
17 MR. STEIN: All right. Is that"southwest portion"
lg — is that "southwest portion"1 pertinent to all of the States
19 here?
20 MR» CURRIE: I would be happy to omit that,
2i MR, STEIN: Pat a period after "inshore waters"?
22 MR. CUSRIE: Yes,
23 MR. STEIN: All right. Why don't we consider it
24 that way, aad I am making no judgment but I am looking for
25 the applicability.
-------
695
'
.
Summary and Conclusions
With that deleted, this reads: " Perfect mixing,
however, is not possible."
Do we need that "however" there?
MRo CURRIE: I would be happy to omit the "how-
ever."
7 MR. STEIN: "Perfect mixing is not possible,
Consequently, if no limits are imposed the proliferation
n of electric plants along the lake may result in the warming
10 several degrees of a large fraction of the inshore
11 waters.'
12 Mr« Mayo
MR. MAIOs I agree.
MR. STEIN i Mr. Purdy*
15 MR. PURDT: Agree.
15 MR. MILLER: Agree.
17 MR. FRANCOS: les.
18 MR. STEIN: All right. Will you go on?
19 MR. CURRIE: les. Ho. 6 is again based on Dr.
20 Prit chard's testimony, so I would like to preface it with
2i the saae following phrases "If the only theoretical
22 appraisal in the record (that of Dr. D. W. Frit chard) is
23 correct, the interaction of two or more thermal plumes
24 nay have a more than linear effect on the area affected
25 by a rise in temperature and on the residence time of any
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3
4
5
6
7
9
10
11
12
13
15
16
17
19
20
21
22
25
696
Summary and Conclusions
particle at elevated temperatures,"
Dr. Prit chard made a special point about how
intersection of plumes ought to be avoided for the reasons
I have stated,
MR* MAYO: I don't think he was the only one that
made that point,
MR. CURRIE: Then I would be happy to omit the
qualifying phrase,
MR. STEIN: Well, without making a judgment here,
I think the Federal presentation, as I heard it, talked
about the overlapping of plumes — and several others at
the workshop. Would you want to submit that without the
opening phrase?
MR. CURRIE: Yes.
MR, STEIN: All right.
Let me do this, for purposes of the recerd from
now on, if we can keep moving. I am going to ask the
conferees if there is any disagreement with this, and if
there is, speak up. Otherwise, I would ask you to know
that the recorder is going to record you as ye*. Any
disagreement with that?
MR. MILLER: Hone.
MR, PURDY: Hone on the part of Michigan.
MR. FRANCOS: Ho.
-------
697
1 Summary and Conclusions
2 MR, STEIN: Well, we might as well go through
every one* That's all right*
4 ME, FRANCOS: No, I agree with that. I am sorry,
5 That procedure*
6 MR0 STEIN: I understand,
7 MR, CURRIE: "A single 1,000 raw, nuclear plant
will create a zone of a few acres uninhabitable by fish
9 during the warmer months and unsuitable for spawning and
10 other significant fish activities at various times,*'
That one, Mr* Chairman, is based on the uncon-
12 tradicted testimony of Dr* Raney and, of course, is sup-
13 ported as well by an abundance of Federal testimony,
14 MR, STEIN$ Are there any comments on this without
a modification, as it says — just a moment, I have a
16 request for some discussion on this one,
17 MR, PURDI: Mr, Stein, I would just as soon omit
that one as far as Michigan is concerned,
19 MR. STEIN: Right.
20 &® we have any comment from Indiana?
21 MR. MILLER: Well, I have problems with some of
22 the words but —
23 MR, STEIN: In view of the suggestion of Mr,
24 Furdy, Mr, Currie, do you want to omit this or —
25 MR, CURRIE: Certainly not.
-------
698
1 Summary and Conclusions
2 MR* STEIN: All right*
MR. CURRIE: What are the objections?
MR. PURDT: I think that there will be certain
species of fish that may find this particular zone to their
5 liking and therefore it is not uninhabitable*
7 MR. CURRIE: That is a perfectly acceptable
correction* "Uninhabited by certain species of fish*"
MR, STEINt Do you mean uninhabitable?
10 MR* CURRIE: Right*
11 MR* PURDT: Okay* Agreed now.
12 MR* MILLER: All right.
MR. MAYO: I have some question with the phrase-
14 ology **a few acres," I feel that we don*t have agreement
15 on that point* I think If we were to strike just the words
16 "a few acres* to "create a zone uninhabitable by certain
17 fish during the warmer months*"
MR* STEIN: Is that agreeable?
19 MR* MATOt I think that Ha few acres** is so sub-
20 jectire I don't know what it means*
21 MR. STEIH: Mr* Currie*
22 MR* CURRIE: I am not sure I understand the
23 objection*
24 MR* STEIN: This would read — let me try this,
25 maybe I can save time. MA single 1,000 mw* nuclear plant
will create a zone uninhabitable by certain species of fish
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1 Summary and Conclusions
2 during the warmer months* **
o MR, CURRIE: Ho, I don»t agree with that because
4 I I think one of the important points we should make here is
5 that according to the record this is a small area, and this
6 is based on — well, again, perhaps we should incorporate
7 the cautionary phrase that we started with because this,
g of course, is based on the assumptions as to the size of
9 the plume,
10 MR, MAYO: Can we say"a small zone?"
11 MR, CURRIE: *A small zone?" Yes*
12 MR. STEIN: All right, then, let me read this
13 again: "A single 1,000 nw. nuclear plant will create a
14 small zone uninhabitable by certain species of fish during
15 the warmer months, and unsuitable for spawning and other
16 significant fish activities at various times*"
17 Is that an agreeable proposal by you, Mr* Currie?
18 ME. CURRIE: Yes, it is.
19 ME. STKEM: Mr. Mayo?
20 ME. MAYO: Yes.
21 MR, STEIN: Without objection, we will say all
22 of the conferees said*yes*on that.
23 Let*s go on to the next one, Mr. Currie.
24 ME. CURRIEz "Many, but an unknown percentage,
25 of organisms passing through the condensers of such a
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Summary and Conclusions
powerplant will be killed or damaged by heat or by physical
shock," and the "and1* should read "or*"
MR* MILLERs Mr* Chairman*
MR* STEIH: Tes*
MR* KILLER: I wonder, since we don't know the
percentage whether we should say "Many, but ,**" or just
say, "An unknown percentage of organisms passing through
the condensers •••"
MR* CHRRIEs That is acceptable to me*
MR. STEINs Stop with "An unknown percentage *«."?
MR* MILLERs Yes*
MR. STEIN s All right* And the last "and" is
changed to "or*"
Any other changes?
MR* MATOs I think we ought to take into account
the chemical impact, the impact of chemicals added* So it
might read "*,* would be killed or damaged by heat, physical
shock or chemicals*"
MR* GURRIE: That is acceptable*
MR. STEIMs All right*
MR* MILLERs We still hare one other word that we
are worrying about and this is in the second line* "Such
a powerplant may be killed or damaged*"
MR. STEEHs Instead of "will"?
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1 Summary and Conclusions
2 MR. MILLER: Instead of "will."
3 MR. STEIN: Okay, do you accept that?
4 MR. CURRIE: That is all right.
5 MR. MAYO: I would like to raise —
6 MR, STEIN: Tom are making all your findings with
7 "could" and "may" — I think these words speak for them-
8 selves but that is up to the conferees*
9 ME* MAYO: I feel that there was enough material
10 presented at the workshop session to speak clearly to the
11 fact that organisms will be damaged*
12 MR. CURRIE: Well, I would prefer "will*"
13 MR* STEINi Would you accept "will"?
14 MR* MILLER: I will accept it*
15 MR* STEIN: Let me read it as we hare it now*
16 "An unknown percentage of organisms passing through
17 the condensers of— can we strike "such" —"of a power-
Id plant —"
19 MR* CURRIE: Yes*
20 MR* STEIN: "— ©fa powerplant will be killed or
21 > damaged by heat, physical shock or chemicals."
22 Without objection this will be adopted*
Mr* Cmrrie, will you go on to the next one?
MR* CIBRISt "A single large plant located in a
spawning ground or across a migratory route would"— and
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Summary and Conclusions
I would like "would* to be changed to "could" —"signifi-
cantly disrupt the balance of the affected species through-
out the lake*"
ME* STEIN: Is there any objection to that?
If I hear none, I will assume it is accepted*
Is that all right?
ME* MAYO: Just a moment*
ME* STEIN: We are not rushing* Go ahead*
MR, MA10: Maybe I need to ask for some clarifi-
cation. Is it intended that only if a plant is
located in a spawning ground or across a migratory route
there would be significant disruption?
MR* GURRIE: What I am suggesting is this is a
special problem* We know that there is a very serious
danger if a plant is located in such an area* I think we
should make a special finding to that effect to emphasize
the plants ought to be kept out of those areas, even if we
cannot make a firm determination as to the effects of
plants situated in other areas*
MR* MATO: Okay* But would there also be an
acknowledgment that plants situated at other locations
could hare a significant enough impact to disrupt?
MR, CURRIEt There is a finding to which we have
already agreed that if there is a proliferation of plants,
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1 Summary and Conclusions
2 there is such a danger regardless of their location, I
3 doubt that the conference can reach unanimous agreement on
4 the further proposition that you suggest,
5 MR, MAYO: Well, I am willing to risk the hazard
6 of not having unanimous agreement if, in fact, the point is
7 substantive, I want to make sure that we are not ruling
# out the possibility that a plant — a single plant located
9 at a point other than on a known spawning ground or migra-
10 tory route could have a significant impact,
11 I don't think any of the presentations made to
12 the Conference have been so exclusive as to say to the
13 conferees that only those plants located in known spawning
14 grounds or migratory routes are likely to have a significant
15 adverse impact, and I would like to get some comment from
16 other conferees on this point,
17 MR. STEIN: The floor is open,
lg MR. CURRIE: My own view, Mr. Chairman, is that
19 there is not evidence to support the proposition that a
20 single powerplant other than those located in the areas
21 specified would have such effects,
22 I have submitted findings which have been approved
23 already that delineate some of the effects that such a
24 single plant would have, and I also would like us to make
25 a special finding as to the special dangers of building plantls
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1 Summary and Conclusions
2 in spawning and migration areas and I would suggest no
3 finding on the other pointo
4 HE. MAIOj Well, would you agree that there has
5 not been a demonstration that single plants located in
6 other than spawning grounds or migratory routes would not
7 have a significant impact on the balance of the affected
8 species?
9 ME, CURRIE: Mo, I would not agree with that*
10 HE* FRANCOS: Is ther* any place along the lake
11 that is not at one time or another a migratory route -—•
12 MR* STEINt Is there any answer to that?
13 ME* FRAHGOSt — for some species of fish that
14 inhabit the lake?
15 ME* STEIM* Veil, maybe we can ask Br* Mount or
16 one of the experts about this*
17 I think perhaps, Mr* Frangos, we could put this
18 another way. Is there any place along the lake that we
19 can saftly say with advance prediction is not a migratory
20 route? There might be some that are, but who is going to
21 be the one to pick the spot and say it is not a migratory
22 route? I don*t know and I think maybe you are straining
23 at something here which may or may not be too significant
24 in the total operation,
25 What I am trying to see: Can we get agreement on
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705
Summary and Conclusions
the statement or not or don't you like the implication?
MR. MAYO: I don't like the implication.
MR. STEIN: Do you want to change that or do you
want to reject it?
MR. MAYO: Let me have a moment to take a look at
this.
MR. STEIN: Well, I think we better just proceed
one at a time. Take your time.
By the way, I haven't been in any colloquy but
looking at this myself, I will just throw this in as a lega
draftsman that may assist us to get at it. If we broaden
the statement and if we say "Plants" just generally or
"Electric plants located in spawning grounds or across a
migratory route could significantly disrupt the balance
of the affected species throughout the lake."
I just throw that out as a possible kind of
thing you may want to say.
MR. CURRIE: How about "Even a single large plant
Mo
... :
MR. STEIN: tfe-.l, I don't object. They are
looking for implicatic-' •• ^nd I am trying to give you something
to do that.
Let's wait. If that doesn't work, let's see what
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1 Summary and Conclusions
2 Mr* Mayo — how do you want to do this?
3 MR* MA10: Mr« Stein, your suggestion would be
4 acceptable* I want to reserve the opportunity to offer
5 perhaps a companion piece ~~
6 MR. STEINi All right»
7 MR* MAYO: — to this,
8 MR, STEIN: All right. Now, would that be agree-
9 able to you if we said "Plants »«*"?
10 MR, CURRIE: I am trying to make another point
11 here*which is there are certain circumstances under which
12 a single plant may be dangerous,and I think we ought to say
13 that, and I don't see why one needs to read anything else
14 into this* It might help, however, if I called attention
15 now to paragraph 11, which does state very specifically the
16 negative implications that Mr, Mayo opposes*
17 MR. STEIN: Well —
13 MR. CURRIEi It seems to me that is where we
19 should fight the battle rather than on the wording of
20 this one*
21 MRo STEIN: I know, but everyone has to make his
22 own judgment, Mr* Currie, where he is going to fight
23 his battle. I think this is Mr0 Mayo's judgment.
24 The question here I have raised for you is that you
25 can say "a plant1* or "plants," it seems to me the plural
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1 Summary and Conclusions
2 sustains the singular in this kind of a finding or just as
3 a drafting —-
4 MR* MAYQt I think what I am concerned about can
5 be addressed in item 11*
6 MR, STEIN: Do you want to leave this then?
7 MR, MAYO: Yes.
8 MR, STSIN: Now, let's see, as this reads now:
9 "A single large plant located in a spawning ground or across
10 a migratory route could significantly disrupt the balance
11 of the affected species throughout the lake^'
12 MR, MAYO: A technical point, Mr, Currie. This
13 plant that is located across the spawning ground —
14 MR. STEIN: You mean discharges from a single
15 large plant? Is that what you want to say?
16 MR. MAYO: It just isn*t technically —
17 MR, CURRIE: That's fine.
18 MR, STEIH: All right* You've got what you want
19 to say, let's say it. "Discharges from a single large plant
20 located in the spawning ground or across a migratory route
21 could significantly disrupt the balance of the affected
22 species throughout the lake,"
23 Are there any objections to this as this stands?
24 If not, I'll assume you all say •yes."
25 Will you go on, please.
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1 Summary and Conclusions
2 ME* CURRIE: Paragraph 10 is am important one
3 and again should be prefaced with the "if" clause that we
4 attached to Nos« 1 and 2* I hare been asked what is the
5 basis for Ho* 10? It is based on the testimony of Dr.
6 Pritchard as to residence time, as to which we hare already
7 adopted a finding, and on the further testimony of biolo-
gy gists that given that short residence time we are not going
9 to hare any detectable algae problems*
10 So that I will read it as amended: "If the only
11 theoretical appraisal in the record (that of Dr. B* V*
12 Pritchard) is correct, the residence time of algal cells
13 in tko heated plume from a properly designed single 1,000
14 mw* plant is too short to cause any detectable shift to
15 less desirable species, and no increase in total algal
16 mass is to be expected*"'
17 I should say, Mr* Chairman, that I Tiew that as
1$ one of the most critical findings and that if I did not
19 agree with that finding I might be sorely tempted to change
20 "7 position on the backfitting of plants now under een~
2i struction.
22 If v* were really going to create a little algae
23 factor at each one of these things where enormous masses
24 of algae could break loose and float all orer the shore
2^ and foul the beaches, then I think it might Tory well be
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o convinced on the basis of the record that that will not be
•
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Summary and Conclusions
worth $20 million to $40 million to avoid it. But I am
so, that there is a striking difference between a standing
pool of water that would be created by a discharge of this
magnitude into a small lake, and the kind of short-term resi-
dence of any given particle in the plume as it is mixed
with lake water that would occur with a well designed plant
discharging to Lake Michigan*
MR. STEIN t Are there any comments on this?
MR« MAYO: Yes, I have a couple of questions*
When you say — use the words "*•» too short to
cause any detectable shift .*•" are you talking about the
lake as a whole or the small area?
MR* CURRIE: No, I am talking about the small
area, and that was the only testimony in the record on
that point, and I would be perfectly happy to preface that
with the same "if clause that we used before*
MR, STEIN s I thought that was your proposal*
* CURRIE: It was*
MR* STEIN i Thank you*
X£* MATO: Well, we are concerned on tw* points:
1) the element of probability in the context of that
presentation; and 2) the element of significance in any
increase — and I would like to suggest that we insert in
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1 Summary and Conclusions
2 the second line between the words "is" and "too* the word
"probably" ~ "»*, is probably too short *»*"»
MR* CURRIE: That is fine*
5 MR. MAYO: And after the word "no" in the third
5 line "significant,"
7 MR. CURRIE: That is also fine*
MR. STEIN: All right« Are these the only changes
you have, or suggestions?
MR. PURDT: Mr* Stein, could I hear those again,
please?
12 MR. STEIN: There is in the second line — "•*«
13 is too short ..." — after "is", ".», is probably too short
14 • ••"» and then at the end of the third line "... and no
significant increase ««.".
16 Mr. Mayo.
17 MR. MAYO: This would be prefaced -~ what would
the preface be again, Mr* Currie?
19 MR. CURRIE: " If the only theoretical appraisal
20 *•» the record (that of Dr* D* W» Pritchard) is correct —**
21 MR* MAIO: Okay.
22 MR. STEIH: All right.
23 Mow, let me read this with that preface: "The
24 residence time of algal cells in the heated plume from a
25 properly designed single 1,00 aw* plant is probably too
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16
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23
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711
Summary and Conclusions
short to cause any detectable shift to less desirable
species, and no significant increase in total algal mass is
to be expected."
MB. MILLER: lou read'100 megawatt;1 You mean"l,OOC
MR. STEIH: "A thousand** I am sorry.
Are there any objections?
That is even truer for 100.
If there are no objections, let's go on to 11.
MR. CURRIE: "Unless it is located so as to inter-
fere with spawning or migration, a single 1,000 mw. plant
will have local effects as noted above but will not upset
the balance of the lake as a whole."
ME. STEIMj Mr. Currie, let me ask you a question
OB this: Is there a way in siting the plants that we can
tell whetfier they are going to interfere with spawning
or migration or not?
MR. CURRIE: I think that is an interesting
question
.
ME. STEIN: That is why I asked it.
ME. CURRIE: And I don't think it is fully
answered in this record. There were a number of questions
directed to various witnesses about where the spawning
grounds were, and ay assessment of the record is that
nobody adequately answered that question.
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Summary and Conclusions
MR, STEIN: Right. But, sir, I think you have th
key to the case here. Although I disagree with your
analysis, it seems to me, from hearing this from all sides,
we maybe come up with the notion that if all these
assumptions are true,' and I think we get down to the key
one here, that we don't really know whether we are going
to site someplace that is going to interfere with spawning
or migration or something else. The question is whether
you apply a regulation to everyone and someone is going to
Ti figure this out sometime, or you are going to let the
plant go in and then look around and see.
I just want to cite this here. The problem that
I have is that I wonder how far these findings are going
, c to get us, in order to come up with the solution when
we get to it. I am just looking ahead a little.
,« Well, I think I have given the Federal people
enough time to think about this. What do you think about
•jo the specific proposal, not what I just said?
MR. MILLER: I agree.
MR. STEIN: All these findings are great, but
22 I think we have to come up with some conclusions based
on them. I hope this is leading to that.
24
25
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1 Summary and Conclusions
2 Do the Federal people want to say anything?
I think what I just said is the key to the whole
case.
5 MR, PURDY: Is there a time limit for objections?
6 MR. STEIN: Well, we will give you 2 weeks, but —
7 MR. MAYO: I would like to suggest that we con-
sider two insertions. To begin with, start the item out
9 with "On the basis of information currently available . •»"
10 and in the last sentence instead of the word Hwillw insert
the word "may0"
12 MR. STEIN: Is that agreeable?
13 MR. CURRIE: I certainly agree with the first
14 suggestion which I think improves the finding. I would
15 like to be stronger than "may." I would suggest Mis not
16 likely to."
17 MR. MAYO: I wouldn't agree with that. I think
the word "may" adequately assesses the information that is
19 available to the conferees.
20 MR. STEIN: Can we get agreement on that?
21 MRo CURRIE: Not from me.
22 MR* STEIN: What?
23 MR. CURRIE: Not from me. I think that is a very
24 important point,
25 MR. STEIN: All right.
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1 Summary and Conclusions
2 MR. CURRIE: If I thought there were a significant
3 possibility that a single plant would damage the lake as a
4 whole I would not have recommended the ultimate decision I
5 have recommended*
6 MR. STEIN: Well, all right, now, we have got two
7 propositionso I think we can read the first — what did
g you say,"on the basis of current information,'* or what?
9 MR. MAYO: *X)n the basis of information currently
10 available*"
11 MR. STEIN: "Currently available, unless it is
12 located"— and so forth« We have two propositions, unless
13 you have another one.
14 "Unless it is located so as to interfere with
15 spawning or migration, a single 1,000 mw. plant will have
16 local effects as noted above but will not upset the balance"
17 is one proposition — or "may not upset the balance of the
lg lake as a whole."
19 I think what we will do is record the States on
20 the findings here, if we can't get agreement*
21 MR. CURRIE: May I suggest, Mr« Chairman, that I
22 would prefer to modify that so that it does not say "will
23 not* but "is not likely to"*
24 MR. MATO: I don't agree with that.
25 MR* STEIN: Can we come to an agreement on this,
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1 Summary and Conclusions
2 or — I tell you what I can do on this if you fellows want
3 to do this. We can go through ohe rest of them — we know
4 what the issue is here — and let's try going through the
5 rest of these, and during the lunch recess if you can work
6 out a formula you can agree on, I will poll the conferees.
7 If not, I will present the two cases to them,
8 Let's defer that and go to 12.
9 MR. PURDY: Mr. Stein, before you move on, and if
10 they are going to deliberate this during the lunch period,
11 there is a thought that I would like to have them consider,.
12 And it seems to indicate in this sentence that the only
13 local effects are those that have been delineated above,
14 and there are other local effects that may have to be taken
15 into consideration.
16 For example, along our western shoreline the
17 ice shelf is important from the standpoint of protecting
1& the shore line for erosion. There may be swimming beaches
19 that are adversely affected, and so forth. And I wouldn't
20 want that to be so limited.
21 MR. STEIN: Can we strike "as noted above"?
22 MR, CURRIE: I think that is an excellent sug-
23 gestion. Could we say "...will have local effects some of
2^ which have been noted above."?
25 MR. STEIN: Will that satisfy you?
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1 Summary and Conclusions
2 MR. PURDY: That is fine*
3 MR. STEIN: All right. I hope Illinois and the
Federal people will be able to get together, and if you can
5 work out a formula that you can both agree on,I will present
5 it to the conferees or else I will poll the conferees on
either of the alternatives you have proposed. Of course,
they can give any alternates that they wish, any variance
on that*
10 May we go to 12, sir?
MR. CURRIE: "unlimited proliferation of electric
12 plants along the lake could seriously worsen the problem
13 of nuisance algae by favoring the less desirable species
and could seriously alter the balance of fish and other
15 organisms in the lake as a whole*"
15 MR, STEIN: Any problems with that from any of
17 the conferees?
MR. MAY0: Could you strike the word "unlimited1*?
19 MR» CURRIE: Yes*
20 MR. STEIN: Any other comments from the
2i conferees?
22 If there are no other comments, let me read this:
23 "Proliferation of electric plants along the lake could
24 seriously worsen the problem of nuisance algae by favoring
25 the less desirable species and could seriously alter the
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1 Summary and Conclusions
2 balance of fish and other organisms in the lake as a whole.
3 Unless I hear dissent —
4 MR, MAYO: I think there is a significant techni-
5 cal point here. This isn't the proliferation of electric
6 plants, it is the proliferation of waste heat discharges
1 from electric plants.
# MR. CURRIE: That is correct.
9 MR. STEIN: All right. If you want to read it
10 that way: "Proliferation —"
11 MR. CURRIE: I am glad, Mr. Chairman, I have all
12 these lawyers here to help me0
13 MR. MAYO: I aui not a lawyer, maybe that is why
14 I am not being so much help.
15 MR. CURRIE: Well, I can say this improves the
16 recommendation.
17 MR. STEIN: Well, I hope it does improve it. I
13 guess when we write these there are certain phrases in the
19 English language that describe certain grammatical struc-
20 tures, like hyperbole.
21 We will say "Proliferation of discharges from
22 electric plants along the lake could seriously worsen the
^3 problem of nuisance algae by favoring the less desirable
2^ species and could seriously alter the balance of fish and
^ other organisms in the lake as a whole."
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Summary and Conclusions
2 Without a dissent, I assume everyone is going to
3 say yes to that.
No dissent* Will you go on?
5 MR. CURRIE; "Various alternative methods of heat
6 disposal are technically feasible, including wet and dry
7 cooling towers, cooling ponds, and spray canals. The back-
fitting of all but dry towers is feasible*"
MR0 STEIN: Are there any ~
MR. MAI0: Excuse me, Mr* Chairman* In the pre-
11 vious item when you read it, you left out the term "waste
12 heat1* — "Proliferation of waste heat discharges *•<»"
MR. STEINj All right. That may be amended to
14 "•*• waste heat discharges • «."
MR. PURDY: I might ask Mr. Currie on "is
16 feasible," is he reaching a conclusion that it is econ-
17 omically and technically feasible or technically feasible?
MR. CURRIE» Technically feasible.
MR. STEIN: Do you want to put that word in?
20 Is that a suggestion?
2i MR. CURRIEt It is in the first sentence. Let's
22 put it in the second as well.
23 MR. STEIN: «... is technically feasiblle."
24 Let me read it again: "Various alternative methods
25 of heat disposal are technically feasible,including wet and
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1 Summary and Conclusions
2 dry cooling towers, cooling ponds, and spray canals* The
backfitting of all but dry towers is technically feasible,"
Any dissents? If not, we are assuming you all
5
5 Let's go on to 14
7 MR, CURRIE: Fourteen, I would like to amend from
the written draft you have before you because as written it
9 is too specific to one State,
10 The amended version is as follows: "To backfit
11 wet towers at a single 2,100 mw, plant would cost somewhere
12 between $20 mill-ion and $120 million. This would cost
13 residential customers each somewhere between 10 and 69
cents per month,"
Now, that does, I think, allow for considerable
16 difference of opinion as to what the actual costs will be,
and I think that is justified because we have some very
lg conflicting assertions as to cost,
19 I think it is important, however, that we make
20 some general statement of the range of values we are talk-
21 ing about so that the public knows that we are not talking
22 about $1 billion for a single plant on the one hand, or
23 about an inexpensive proposition on the other,
2k MR, STEIN j What did you say was the maximum?
25 MR, CURRIE t One hundred twenty,
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1 Summary and Conclusions
2 MR. STEIN: No, no, no, I understand it. But
3 in your last sentence, the maximum, you said, this "would"
4 cost or "could" cost?
5 MR. CURRIE: Would cost somewhere between 10 and
6 69 cents. Those are the extreme estimates we have heard.
7 MR. STEIN: No, then you want the maximum don't
you, out? If you are saying between 10 and 69> it doesn't
read —
1Q Mr. Currie, I just ask this, but do you mean
that? Maybe the conferees are ready to make an economic
12 judgment of what this is going to cost the customer each
month, on the basis of what we have heard here. I don't
know that we have had a rate hearing or cost hearing, where
15 we are going to say what the minimum and what the maximum
is. In light of the questioning, I think that I did,
17 for clarification, and Mr. Purdy did in probing — that
as you get one or another of these plants going on, on the
•jo same system, that the costs are going to be cumulative, and
2Q this applies to all of the customers in the system as
a whole.
22 I am not making any judgment here, but I raise
23 with the conferees whether we have heard enough economic
data to make a finding on cost. I might remind you that
25 I think, from my point of view — I won't speak for the
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1 Summary and Conclusions
2 rest of you people — but costs are outside my field of
3 expertise in order to make a finding* Now, the other
4 people may have that. I: think costs are things we have to
5 consider, but these are findings of a pollution conference,
6 MR, CURRIE: I think, Mr. Chairman, that in what
7 you have said there is one very valid point, and that is
g that these costs per customer were based on a particular
9 plant and its relation to its entire distribution system
10 and therefore are not translatable to the general case,
11 So I would like to omit that but retain the first part of
12 the statement:
13 "To backfit wet towers at a single 2,100 mw
14 plant would cost somewhere between $20 million and $120
15 million,"
16 MR. STEIN j Now, we will ask the conferees to —
17 MR. MAYO: I want to get the words down so I
lg can get them in the proper context.
19 MR0 CURRIE: "To backfit wet towers at a single
20 2,100 mw plant would cost somewhere between $20 million —
21 MRo MAYO: "Megawatt nuclear plant?"
22 MR. CURRIE: ''Nuclear,13 Thank you,
23 " — would cost somewhere between $20 million and
24 $120 milliono"
25 MR. MAYO: Somewhere from —
-------
722
1 Summary and Conclusions
2 MR. CURRIE: T.he 20 was the low figure mentioned
3 yesterday — day before yesterday — by Mr, Tichenor, and
4 the 120 was Commonwealth Edison's estimate,
5 The last sentence is omitted,
6 MR, MAIOz In terms of the monthly rate —
7 MR, CURRIE: Yes,
8 MR, MAYO* If what we are after here is to give
9 a measure of the demonstration — demonstrate a measure of
10 cost, then we have had those costs expressed in two con-
11 texts: 1) the cost to the company in terms of the $20 to
12 $120 million. But I think it is also important to trans-
13 late the range of that cost to the residential user,
14 MR, CURRIE: I think so, too.
15 MR, MAYO: And I think it is appropriate to leave
16 in here the range of cost between 10 and 69 cents, because
17 it is no less valid than the other comparison,
18 MR, CURRIE: I think the figures might be signi-
19 ficantly different in regard to the costs to the individual
20 customer if we were talking about all of the facilities
21 of a given powerplant being backfitted*
22 In the case of Commonwealth Edison, we are talk-
23 ing about distributing the cost of backfitting one plant
24 over the customers of a large number of plants, I would
25 be very happy to leave in something about the amount it
-------
723
1 Summary and Conclusions
2 is going to cost the customer if we could make that
j generally applicable or if we could say thaf'in one case
4 which has been studied by the conferees, the cost per
5 customer ranged from 10 to 69 cents*'
6 MR. PURDTx Mr. Currie.
7 MRo CURRIE: Yes.
£ MR. PURDY: Would you object to having: " At the
9 Zion plant this would cost the residential customer some-
10 where between 10 and 69 cents per month?"
11 MR, CURRIE: Perfectly acceptable.
12 MR, MAYO: Okay.
13 MR. STEIN: All right.
14 Do you want to read that again, Mr* Currie?
15 MR. CURRIE: 'To backfit wet towers at a single
16 2,100 mw nuclear plant would cost somewhere between $20
17 million and $120 million. At the Zion plant, this would
1# cost residential customers each somewhere between 10 and
19 69 cents per month.'*
20 MR. CURRIE: Should we say then the "average1*
21 residential customers?
22 MR. STEIN: Yes.
23 MR. CURRIE: That is fine with me if it meets
24 with approval*
25 MR. STEIN: All right. Why don't you read that
-------
724
1 Summary and Conclusions
2 again, because otherwise I think that may be subject to
n misinterpretation, Mr* Currie,
• MR, CURRIE: Well, pursuant to the suggestion of
c the Chairman, the amended finding is as follows: "To backfit
wet towers at the single 2,100 mw0 nuclear plant would cost
somewhere between $20 million and $120 million. At the Zion
plant, this would cost the average residential customer
somewhere between 10 and 69 cents per month*"
MR, MAYO: Would you say "this is estimated to
cost?**
12 MR. CURRIE: Yes.
MR. STEIN: All right, if we could change that,
"This is estimated,"
If there is no objection, we consider that
16 accepted. Let's go to 15*
17 MR. CURRIE: There is a change in 15 as well but
basically it is as written.
19 " All alternative cooling means may have some un-
20 desirable environmental effects. Wet towers can cause fog
2i problems. All towers discharge some polluted blowdown
22 water that must be treated before release. Dry towers may
23 cause as yet undetermined meterological changes. Both wet
24 and dry towers are bulky and unattractive additions to the
25 lakefront. Evaporation"— well, let's leave the last
-------
725
1 Summary and Conclusions
2 sentence. Let's leave out the next sentence about evapora-
3 tion. That is a peculiarly Illinois problem unfortunately.
4 "Cooling ponds consume about 2 acres of land per
5 megawatt, land that could be put to productive use."
6 MRo FRANGOSs Mr. Chairman, I would suggest that
7 perhaps we might want to delete a reference to the esthetics
£ of a cooling device.
9 MRo CIJRRIE: It seems to me that is a very impor-
10 tant consideration,, One of the reasons that I am not so
11 eager to jump into the backfitting of existing or under
12 construction plants is because I think there are serious
13 drawbacks to having large cooling towers on the lake,
14 environmental problems, one of which is that they are just
15 big and ugly and they don't belong on the lakefront if we
16 can avoid it.
17 MR. FRANCOS: Well, I think the thing is so
13 subjective that someone else may think you could design one
19 that might very well be pleasing.
20 MR» CURRIE: Do you believe that?
21 MR. FRANCOS: Yes, I do.
22 MR. MILLER: I have had people tell me the ones
23 at DuQuesne are pleasing.
24 MR. STEIN: Well, the suggestion that I get here
25 is that you consider striking: "Both the wet and dry towers;
-------
726
± Summary and Conclusions
2 are bulky and unattractive additions to the lakefront?"
3 MR, CURRIE: How about "... bulky additions to
4 the lakefront.11? I don't think anyone would dispute their
5 size.
6 MR. STEIN: All right. That is as close as we
7 can get. Can we strike "unattractive"?
3 MR. MAYOi Could we say "less bulky additions
9 than the Big John"?
10 MR. STEIN: No, no, no, no, (Laughter)
11 Let's see*
12
12 "Both wet and dry towers ..." —• let's see —
14 you are ready to say strike "unattractive."
15 "Both wet and dry towers are bulky additions
16 to the lakefront." Now, do you want to leave that in?
17 MR. CURRIEs Yes.
lg MR0 STEIN: Is that acceptable, Mr. Frangos?
19 MR. FRANGOS: He is insisting on "bulky"?
20 MR. STEIN: That is a color wordo
2i MR0 FRANGOS: Okay, fine. I think that is
22 agreeable.
23 MR. STEIN: All right. Now, are there any other
24 suggested changes here?
25 MR. PURDY: Mr. Stein.
-------
727
1 Summary and Conclusions
2 MR. STEIN: Yes.
3 MR, PURDY: To my knowledge, at least I don't
4 know that I have reached a conclusion that the blowdown
5 water from the towers must be treated before release.
6 Possibly they need to be controlled in some fashion, but
7 to indicate at this point in time that they must be
$ treated, I don't know as I am ready to agree to that.
9 MR. STEIN: Would you suggest "control" there or
10 what?
11 MR. CURRIE: How about "...that may require
12 treatment before release"?
13 MR* PURDY: Okay.
14 MR. MILLER: Mr. Chairman.
15 MR, STEIN: Wait a minute.
16 MR. MILLER: Okay.
17 MR. STEIN: All right.
1# MR. MILLER: When you get down to the last
19 sentence that is that "Cooling ponds consume about 2
20 acres of land per megawatt, land that could be put to
21 productive use," I don't know whether that would always
22 be necessarily true, that w«..could be put to productive
23 use."
22f MR. CURRIE: Let's omit everything after the
25 comma so that this reads: uCooling ponds consume about 2
-------
A
5
728
Summary and Conclusions
acres of land per megawatt."
MR. STEIN: That is fine.
Any other comments?
MR. MAYO: Yes.
It appears that there may be opportunities, if
you have the right water conditions, that there is not goin
to be polluted blowdown from towers under certain circum-
stances. So that the word "all" seems to be inappropriate.
If we could find —
MR. MILLER: I think we had testimony at the 5
days of hearing and I certainly would concur with the use
of the water around Lake Michigan that you are going to
,, have blowdown.
MR. STEIN: No, the question here is, Mr. Miller,
,x
,-
22
2«
-,
whether all towers discharge polluted blowdown water.
Again, I am not making a judgment, but you have the phrase
"All towers discharge some polluted blowdown ...".
Now, the contention is that every tower does not
necessarily have to discharge polluted blowdown water. I
don't know what the validity is, but I do know that at
least in a formal logic course you have a pretty strong
statement here when you say "All towers discharge some
polluted blowdown water" and if that is what you mean
you should state it.
-------
729
Summary and Conclusions
MR. CURRIE: "... towers are likely to discharge
polluted blowdown water ..."?
4 MR. STEIN: What do you want to say?
5 MR. CURRTE: "... towers are likely to discharge
6
7 MR. STEIN: Is that agreeable?
All right. Say, "Towers are likely to discharge
..." — do you want to strike the "some polluted blowdown
water" — or riot — or "some"?
MR. PURDY: Can we get away from some of this
•i 2 hangup, Mr. Stein, by just leaving out the "polluted."
That "towers discharge blowdown water that may require
TI treatment before discharge?"
MR. STEW: Yes. Is that agreeable? "Towers
discharge blowdown water that may require treatment before
discharge?"
MR. CURRIE: That is all right with me.
MR. MILLER: All right.
20 MR. STEIN: All right. That will be: "Towers
discharge polluted blowdown water — "
MR. PURDY: Not "polluted."
23 MR. STEIN: No. "—discharge blowdown water
that may require treatment before release." All right.
_. Are we all set?
-------
730
1 Summary and Conclusions
2 Any other comments? Yes*
MR. MAYO: I have reservation? about the end of
the last sentence* When we say, "Cooling Ponds consume
about 2 acres of land per megawatt, land that could be
put to productive use" «—
MR, STEIN: No, we put a period after "megawatt,"
MR. MAYO: Okay, fine* Thank you*
o, MR, STEIN: Let me be brave and try this* Are
10 there any other comments before I start? These delayed
11 reactions hold me up, fellows. Do you have any more on
this?
Let me read this, and X hope I am not rushing
14
"All alternative cooling means may have some
16 undesirable environmental effects* Wet towers can cause
17 fog problems; the Commonwealth Edison"
*,* Cries of "No, no" ,•*
19 MR, STEIN: I am sorry* Go ahead* Correct me,
20 MR, CURRIE: 'Towers discharge blowdown water*
2i MR, STEIN: "Wet towers can cause fog problems*"
22 And then we strike*
23 "Towers discharge blowdown water that may require
24 treatment before release* Dry towers may cause as yet
25 undetermined meteorological changes* Both wet and dry
-------
731
. .
Summary and Conclusions
2 towers are bulky additions to the lakefront. Cooling ponds
o consume about 2 acres of land per megawatt.
Without objection, I assume we all approve that,
c Now, before we recess for lunch, when we come
5 back from lunch we will take up No* 11, I ask that the
7 Illinois and the Federal conferee and their staffs get
together and strive with might and main, if you can, to
o come up with a formula we can propose. Then I am going
10 to put the alternates out for the conferees. We are not
11 limited just to voting on the alternates. You may come
12 up with any variation you want if you don't like these.
In addition to this, these conclusions are not
locked up yet. That is, if you want to, you can have
more, or if you want to have a second thought on any of
16 these, come back and we will reconsider them. But I ask
17 you in the name of humanity to keep the last thing to the
minimum,
19 With that — now, let's see if we can come back
20 in aa hour and a quarter. Let's try a quarter to 2:00,
21 Okay? We recess until a quarter to 2:00,
22 (Noon recess,)
23
24
25
-------
732
1 Summary and Conclusions
2
3 AFTERNOON SESSION
4 Executive Session, Continued
5
6 MRo STEIN: Let's reconvene,
7 I would like to check, I think we were talking
8 about Finding No, 11 — and I am just using this number
9 for identification purposes. This won't be what it comes
10 out as because we have had eight before this, but it is
11 No» 11 in the letter that Mr, Currie had sent,
12 Now, have the Federal and State people come to
13 an agreement? If not, will Mr, Currie make his proposal?
14 If you have, will you announce the agreement?
15 MR, CURRIEj Well, Mr, Chairman, we spoke about
16 this over the lunch break, and there does seem to be a
17 difference of opinion between us and the Federal conferee
18 on this pointo
19 I would like to suggest one possible alternative
20 for consideration. On the basis of information currently
21 available, unless it is located so as to interfere with
22 spawning or migration, a single 1,000 mw plant will have
23 local effects some of which have been noted above but we
24 cannot predict that it will upset the balance of the lake
25 as a whole.
-------
733
1 Summary and Conclusions
2 MR, MAYO: We cannot predict that it will upset?
3 MR. CURRIE: Yes.
4 MR. MAYO: I think we are back where we started
5 because I would feel obliged to say we cannot predict that
6 it will not upset the balance of the lake, or may not
7 upset the balance of the lake*
# MR. STEIN: Well, unless you can come to an
9 agreement with me, we have a proposal on the way you want
10 it stated, and may we have counter proposals —• and I will
11 put all of the proposals — or any of the States can have
12 the modification of that* What is the finding that Illinois
13 would like to make on this point, Mr. Currie?
14 MR. CURRIE: "On the basis of information
15 currently available, unless it is located so as to inter-
16 fere with spawning or migration, a single 1,000 mw plant
17 will have local effects as noted above but is not likely
l£ to upset the balance of the lake as a whole."
19 MR. STEINs All right. Would the Federal Govern-
20 ment conferee like to make a recommendation on that point
21 or do you have an alternate, or do you want to associate
22 yourself with it?
23 MR. MAYO: What was that last — "not likely to"?
24 MR. CURRIE: Yes*
25 MR. MAYO: I would like to suggest some different
-------
734
1 Summary and Conclusions
2 language and say, ".,, but the effect on the balance of the
3 lake as a whole is not known at this time,"
4 MR, CURRIE: I think I prefer your earlier
5 language about "may not affect," if we have to make a
6 decision on that basis* I think we could all agree that
j it may not affect the balance of the lake as a whole, and
$ I would prefer to see the conferees make a stronger state-
9 ment, but I am willing to go along with what you earlier
10 suggested as something as to which all of us can agree*
11 MR, STEIN: I think I am going to exercise the
12 prerogative of the Chairman because I see a chance of
13 agreement* If we strike out "will" and make it "may,"
14 are both of you people in agreement on the proposal?
15 MR<> CURRIE: Fine with me,
16 MR. MAYO: No,
17 MR. STEIN: Not yet?
18 MR. MILLER: That is what he said before lunch*
19 MR. MAYO: Well, that was before lunch, Perry*
20 (Laughter)
21 I feel that seriously the substance of this
22 recommendation is a focal point of our whole consideration
23 this morning and is not to be taken lightly*
24 I would suggest the alternate language that would
25 read: *•* but the effect on the balance of the lake as a
-------
735
Summary and Conclusions
whole is not known at this time."
MR. STEIN: Can we reach agreement on that? If
not, I am just going to have to move.
5 MR. CURRIE: No, I don't think that meets with
6 the findings of our Board.
•7 MR. STEIN: All right, I am going to ask you
again — and I would ask the other conferees to listen,
in case any of the other conferees want to put in a
proposal — I am going to ask Illinois to put forth its
recommended finding; I am going to ask the Federal conferee
to put forth his Federal finding; and then I am going to
TO poll the other conferees and see if they want to
TI associate themselves with either finding, have an alternate
or remain silent on this point.
Mr. Currie, may we have your conclusion?
MR. CURRIE: "On the basis of information
currently available, unless it is located so as to interfere
with spawning or migration, a single 1,000 mw plant will
2Q have local effects some of which have been noted above but
may not upset the balance of the lake as a whole."
22 MR. STEIN: Mr. Mayo.
20 MR. MAYO: We would propose and agree that: "On
the basis of available information, unless it is located so
as to interfere with spawning or migration, a single 1,000
-------
736
1 Summary and Conclusions
2 mw plant will have local effects some of which have been
3 noted above but the effect upon the balance of the lake
4 as a whole is not known at this time» "
5 MR. STEIN: All right.
6 Mr. Purdy.
7 MR. PURDY: I concur in the Illinois wording.
a MR. MILLER: I will concur in the Illinois
9 wording.
10 MR. STEIN: Wisconsin.
11 MR. FRANCOS: I will concur with the Federal
12 wording.
13 MR0 STEIN: That's a nice balance* (Laughter)
14 Are there any other findings which you think
15 should be appropriate other than the ones we have considered?
16 MR. MAYO: Yes. I have some additional findings,
17 Mr. Chairman.
18 MR0 STEIN: Mr. Pratt —
19 FROM THE FLOOR: May we have the additional
20 findings, please?
21 MR. STEIN: The Chairman has trouble getting
22 them*
23 Let's continue.
24 MR. MAYO: There are several additional findings
25 that we would like to have the conferees consider, Mr.
-------
737
Summary and Conclusions
Chairman, and each has a copy.
The first is, and I quote: "The existing
federally-approved water quality standards to control waste
5 heat discharges do not offer adequate protection for the
6 waters of Lake Michigan and its continued beneficial uses,"
7 I think it is important at this juncture to
recognize that while there are federally-approved standards
9 for three of the States, the standards were approved, I
10 think, back in about 1963, that in the face of the informa-
tion now available to the conferees, that this is a reas-
12 enable finding*
13 MR. STUN: Any discussion?
14 MR. CURRIE: Mr. Chairman, I think that is a very
important point* I agree with it 100 percent*
16 MR. STEIN: Any other discussion?
17 Now, let's start at the other end of the
table. Mr. Frangos, how do you vote on this one?
19 MR, FRANGOS: That is fine* Yes*
20 MR, STEIN: Mr* Currie?
21 MR. CURRIE: Yes.
22 MR. STEIN: Mr. Mayo?
23 MR. MAYO: Yes*
24 MR. STEIN: Mr, Miller?
25 MR, MILLER: Yes*
-------
738
1 Summary and Conclusions
2 MR. STEIN: Mr. Purdy.
3 MR. PURDY: In the unique position of not having
4 federally-approved water quality standards, I have no
5 objection.
6 MR. STEIN: Can we say it is a yes vote?
7 MR, PURDY: It is a yes vote.
B MR. STEIN: All right. Go on.
9 MRo MAYO: The next finding: "The effective man-
10 agement of waste heat discharges into Lake Michigan makes
11 it desirable for the States to adopt reasonably uniform
12 water quality standards0"
13 MR. STEIN: Any discussion?
14 MR. CURRIE: Yes, Mr. Chairman. I think that the
15 important qualifications should be made that I believe some-
16 one raised earlier that what we want to be uniform are
17 minimum standards and that any State may impose higher
18 requirements if it so desires.
19 MR. STEIN: That is true. I think it is clear
20 that our law provides that.
21 Do you want to make a special point in this
22 here?
23 MR. CURRIE: I think insert the word "minimum"
24 after "uniform."
25 MR. STEIN: Is that okay with you?
-------
739
1 Summary and Conclusions
2 MR0 MAYO: Yes.
3 MR0 STEIN: Is that all right? Any other dis-
4 cussion? All right*
5 Now, let me go along this way* Again, we have
6 a request that these be made available to the people who
7 are here*
3 MR0 CORRADO: They are making up more copies nowa
9 They will be down as soon as possible*
10 MR. STEIN: This reads: "The effective management
11 of waste heat discharges into Lake Michigan makes it
12 desirable for the States to adopt reasonably uniform
13 minimum water quality standards,/'
14 Do I hear an objection to that? If not, I con-
15 sider all of you said "yes,1 Let's go on*
16 MRa MAYO: The next item — the next finding:
17 "The evidence presented to the Conference does not permit
13 a determination of the overall damage of large waste heat
19 discharges to Lake Michigan from existing or planned power
20 generation plantSo*
2i MR* CURRIE: I would take issue with that, Mr.
22 Chairman* I think I could accept a modification of it
23 that would read as follows: "The evidence presented to
24 the Conference does not permit a quantification of the
25 overall damage of large waste heat discharges to Lake
-------
740
Summary and Conclusions
Michigan from any particular number of planned power gen~
eration plants*,"
I think we know a great deal about the effects of
waste heat on Lake Michigan0 I think we do not have full
information as to quantification*
MR. MAYO: But do you feel that quantification
extends to the overall ecological impact, or that that
a quantification is really fairly specific?
10 MR* CURRIE: I am not sure I understand the ques-
11 tion*
12 MR* MAYO: Well, do you feel that we are lacking
only quantification on the overall damage? Say that again
the way you had it*
MR* CURRIE: "The evidence presented t© the Con-
ference does not permit a quantification of the overall
17 damage of large waste heat discharges to Lake Michigan
from any particular number of planned power generation
plants*^
20 MR. MAYO: How about "existing? "
MR* CURRIE: Well, there you see I think we may
22 have a disagreement* I think the evidence is fairly clear
23 that there is no substantial harm done to the lake by
24 existing powerplants*
25 MR* MAYO: This presumes that all of the important
-------
1
2
o
i
c
10
12
14
17
19
20
22
23
24
25
741
Summary and Conclusions
parameters that need to be examined have been considered
and have, in fact, been examined, and I would have to
disagree on that point.
MR. STEXNs All right, then, let's have your
proposal.
MR. MAYQj I think that what Mr* Currie has sug-
gested would be all right with me if we leave in the word
"exi sting* "
MR, STEIN s Mr. Currie
*
MRo CURRIE: I think I would agree with the pro-
posal that way, if it said something about the "Conference
will reasses the effect of large waste heat discharges
from existing or planned power generation plants in the
light of future evidence.*'
I think that on the basis of the evidence we
have before us we can be fairly confident that there is no
serious harm from existing powerplants. But I do think
we ought to make it clear that we expect to reasses that
®n "&ne basis of future evidence*
MR. MAYO; Will you write out what you have — •
MR. CURRIE: "The Conference will reasses the
overall damage of large waste heat discharges to Lake
Michigan from existing or planned power generation plants
in the light of future — additional future evidence.^
-------
742
1 Summary and Conclusions
2 MR0 MAYOs You would offer that as a substitute
3 for what you —
4 MR. CURRIE: Yes, I would,
5 MR, MAYO: I would accept that in addition to
5 what I have said,
7 MR* STEIN: Let me see if I can have a clarifi-
$ cation, Mr, Currie,
9 If your contention is that there is
10 no damage from existing plants that
11 has been demonstrated, and we are going to reassess it,
12 then if we adopt these findings,it would seem to be more or
13 less the point of the conclusion that the Federal people
14 and others are going to agree that they are not going to
15 ask for any backfitting until there is a reassessment*
16 MR, CURRIE: Well, that, of course, would be what
17 I would recommend to the Conference,
lg MR. STEIN: That is right and if that is what the
19 Federal people want to do, let's go ahead*
20 MR, MAYO: I would have to stick with the — or
2i offer the finding as it stands,
22 MR, CURRIE: Well — and I would have to dissent,
23 MR, STEIN: All right, then, let's go on,
24 The finding says: ''The evidence presented to the
25 Conference does not permit a determination of the overall
-------
743
-i Summary and Conclusions
2 damage of large waste heat discharges to Lake Michigan from
3 existing or planned power generation plants*"
. Either signify you agree} you don't agree; you
5 don't want to associate yourself with it; or you have a
5 substitute*
Mr* Purdy.
MR. PURDY: I would like to omit this one.
9 MR. STEIN: All right.
10 MR. MILLER: I think I would just as soon omit
11 ^*
12 MR. STEIN: Mr. Currie*
MR. CURRIE: I agree with Mr. Purdy.
MR. STEIN: Mr* Frangos*
15 MR. FRANGOS: Let's omit it*
MR. STEIN: Do you still want to keep this in?
17 MR. MAYO: I would like it to show that as far
as the Federal conferee is concerned*
19 MR. STEIN: All right* This will show. Go on.
20 MR. PURDY: Mr. Stein, yesterday I kept quiet all
2i day on one particular point* It seems to me that this
22 weakens our position quite a little bit and, in fact, as
23 I listened to the "Today" show yesterday and heard Senator
24 Buckley defend the Administration position, including that
25 of the Environmental Council, with matters relating to the
-------
744
1 Summary and Conclusions
2 SST, we had to more forward on the SST so that we could
3 have some good hard facts and determine the overall damage
4 that might be caused by thisj and I think this one weakens
5 our position to state it in this fashion*
6 It seems to me — if this represents Administra-
j tion position it seems to be 1#Q° opposite from that taken
$ with respect to the SST,
9 MR. MAYO: Well, I would have to offer the rejoinder^
10 Mr* Purdy, that responsible people have to follow their con*
11 victions.
12 MR. PURDY; Okay.
13 MR. STEIN: All righto We have this*
14 Let me clarify something for the record. This
15 presents the finding recommended by the Federal conferee.
16 I think when the Administrator acts on this we can be
17 reasonably assured we would have the Federal position.
lg Let's go on.
19 MRo MAYO: The next suggested amendment or
20 addition to the item No. B in the findings that Mr. Currie
21 offered —
22 MR. MILLER: What is this now?
23 MR. MAYO: No. 3.
24 MR. MILLER: Of which set?
25 MR. MAYO: Of Mr. Currie1s»
-------
745
Summary and Conclusions
MRo STEIN: Eight reads, as I have it —• check
me if I am wrong, because I am working from notes here —
4 "An unknown percentage of organisms passing through the
5 condensers of a powerplant will be killed or damaged by
•^ i
5 heat, by physical shock, or chemicals1'— period — or maybe
7 semicolon --"Therefore, the damage is likely to be pro-
portional to the volume of water intake,"
a That is added to the end of the proposal*
10 MR. MAIOj Yes.
MR0 GURRIE: That is fine with me* It is also
12 proportional to a number of other things, of course*
MR* STEIN: Are there any other comments?
14 Mr* Purdy,
MR. PURDY: Okay*
MR. STEIN: Okay*
17 MR. MILLER: Okay.
MR. STEIN: How about Mr, Frangos?
19 MR, FRANGOS: May we strike "therefore"?
20 MR* STEIN: What do you think about that? Start
21 a new sentence with "Damage*"
22 MR. MAYO: I like "Therefore" for the continuity
23 of thought,
24 MR. FRANGOS: Let's strike it.
25 MR. STEIN: Do we get agreement on that or not?
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746
j
Summary and Conclusions
2 MR, FRANCOS: Okay, leave it in.
o MR<> STEIN: Okay, Let»s go. Next one,
• MR« MAYO: The next one is a suggested addition to
c Mr, Gurrie's item Mo, 5 which I think makes the statement
more correct. We add that after the word "proliferation"
— "»», proliferation of waste heat discharges from electric
plants ,,,"0
n MR, STEIN: All right. Here is the way — let
10 me read the whole thing: "Perfect mixing, however, is not
possible0 Consequently, if no limits are imposed, the
proliferation of electric plants along the lake may result
in the warming by several degrees of a large fraction of the
inshore waters especially in the southwest portion of the
lake."
This would read, with the proposed amendment:
Consequently, if no limits are imposed, the proliferation
of waste heat discharges from electric plants along the
lake may result"— and so forth,
20 MR, CURRIE: That is fine,
21 MR, PURDY: Good,
22 MR, STEIN: Are there any objections? If not,
23 we will accept this,
MR. MAYO: If I recall, Mr, Chairman, the earlier
25 agreement stopped after the words "inshore waters,1*
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747
1 Summary and Conclusions
2 MR0 CURRIEi Yes.
o MR0 STEINj Yes, that is correct*
• MR. MAYO: The next recommended finding is as
c follows? "The behavior of waste heat plumes during winter
months is substantially unknown and therefore the impact
on the ecology of Lake Michigan is not now assessable*"
MR, CURRIEi On that one, Mr« Chairman, I sympa-
n thize with the thoughts I recall that substantial ques-
10 tions have been raised as to the different behavior of
plumes in the wintertime, particularly with respect to their
12 sinking and rising under different temperature conditions.
So I would agree to this with a small modification to read
as follows: "Additional evidence is desirable as to the
behavior of waste heat plumes during winter months and as
to their impact on the ecology of Lake Michigan,"
17 MR. STEIN: Do you accept that?
MR0 MAYO: No, I would prefer to take what we
have here as "not now assessable" and "Additional evidence
20 is desirable,1*
2i MR0 CURRIE: The reason for my suggested amendment
22 is that I would not like to suggest that we are in no
23 position to make any kind of decision on this, I think we
24 know enough about it to make a tentative evaluation of it
25 subject to correction in the light of later additional
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748
1 Summary and Conclusions
2 evidence* So if you wanted to say: "Additional evidence
3 desirable and the impact is not now fully assessable" or
4 "finally assessable," I would agree*
5 MR, MAYO: Could we write that down?
6 MR0 CURRIE: "Additional evidence is desirable as
7 to the behavior of waste heat plumes during winter months,
$ Their impact on the ecology of Lake Michign is not now
9 fully assessable,,"
10 MR, MAYO: Okay,
11 MR, STEIN: The word "ecology,* we are advised
12 by our biological experts — scientists — that the word
13 "ecology" should be changed to "ecosystem**1
14 All right. Are there any objections to that?
15 If not, let's go on. Let's go on with the next one,
16 MR, MAYO: The final recommendation for the
17 finding is one that I would hope we have no disagreement
IB on. It is as follows: "It is the established policy of
19 the regulatory agencies parties to this Conference that
20 pollutants shall not be discharged to public waters until
21 there is firm understanding of the detrimental effects of
22 such discharges,"
23 MR. CURRIE: Mr. Chairman, again, I think the
24 additional one word would make that not only agreeable to
25 me but very definitely desirable, and the word is
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749
1 Summary and Conclusions
2 "reasonably," and it should be inserted before the word
"firm," so that it reads "«<>• until there is reasonably
firm understanding of the detrimental effects of such dis-
5 charges*"•
6 I am afraid that the proposed form without that
7 amendment suggests that we must put a stop to a large number
of human activities until there is the kind of conclusive
9 proof which I believe you will never have on any subject.
10 MR0 MAYO: I would agree*
MR* STEIN: Are there any other comments? Are
12 there any objections to this?
13 MR. FRANCOS: I have a question. What is the
14 purpose of this finding?
MR. MAYO: I think it is intended on my part, on
16 the Federal part, to put into perspective the sense of
17 responsibility for the agencies, the parties to the Con-
ference, simply stated as such.
19 MR. STEIN: Are there any questions?
20 MR. MILLER: Mr. Chairman, I have some question heife
21 Here it says"it is the established policy of the regulatory
22 agencies," and this would imply that it is already an estab-
23 lished policy.
24 MR. STEIN: That is the finding that it makes here*
25 MR. MILLER: And this may present some difficulty.
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1 Summary and Conclusions
2 The other factor would be that I wonder how much different
this is than the antidegradation policy we have already
4 included in the standards that we have approved*
5 MR, MAYO: I was not intending to reinterpret any
5 of the standards. I was intending to put into the findings,
7 state very straightforward a statement of the sense of
responsibility of the agencies party to the Conference,
o, MR* MILLER: I think unless we accept the anti-
10 degradation, that we are then saying today as conferees we
11 are establishing a policy for the regulatory agency, and I
12 don't know whether I can do that or not*
MR, MAYO: Could we say it is the already estab-
lished policy?
15 All I am trying to relate this to, Perry, is the
16 sense on my part that, as regulatory agencies, we are already
committed to this sort of thing,
MR, MILLER: Well, that is partly my point, I
19 think we have already done this by the antidegradation
20 clause that we have so maybe —
2i MR, STEIN: What are you suggesting, Mr. Miller,
22 that we don't need this?
23 MR, MILLER: I wonder if we need it,
24 MR, STEIN: What do you think?
25 MR, MILLER: Well, I think that we already have it
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751
, Summary and Conclusions
- in Indiana*
MR. STEIN: That is the way I read what this says,
, that you have it in Indiana. It makes a finding of what you
c have as your established policy of Indiana, and you are con-
/• curringo
„ I think the question — maybe we can clarify the
H language. It is not so much what it says, but Mr* Miller
raises the question of whether this is neededo
MR. MAYO: Well, if the conferees feel this is a
,, redundancy, I will withdraw it*
12 MR0 STEIN: Well, will you withdraw it?
MR. MAYO: I would like to hear from them, if I
,, may, whether they think it is a redundancy,
15 MR, FRANCOS: Well I do. I don»t think it is
adding anything to the process. If you would like it for
, „ the record, please to agree that it is indeed the policy of
, A the Wisconsin Department of Natural Resources, that
pollutants shall not be discharged to public waters until
2Q there is a reasonably firm understanding of the detrimental
effects of such discharges,
22 MR, STEIN: Mr, Mayo.
MR, MAYO: Well, I will withdraw it if it is the
2L general consensus it is redundant,
25 MR. STEIN: Are there any other findings that you
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752
1 Summary and Conclusions
2 want to make before we go on to the recommendations?
3 I would like to make one other observation here
4 from the Chair. I think this conference has done one
5 thing;, and we have had a lot of conferences and a lot of
6 conference sessions. We have broken the all-time record
7 for findings. I guess you exercised your best judgment.
But it remains to be seen whether extensive findings of
9 this kind and findings which, in many measures, are qualifi*
10 conditions, including some which are hara-kiri in nature
and cover page after page, are going to form a firm basis
12 for decision and whether they might not form hooks as a
refuge for people who don't want to comply or can point to
something to buttress their case. I think we are going to
15 have a very interesting time but I commend you on your
16 efforts.
MR. CURRIE: If I may make an observation, Mr.
Stein, I think that we have made a substantial step forward
by adopting specific findings, so that we know and the publ:.c
2Q knows what the facts are on which we base our decision.
I think it obvious at this point that reasonable
22 men can differ and very likely will differ as to what polic1
23 conclusions should be drawn from these factual findings.
And with that in mind, I would like to move that the follow--
25 ing recommendation be made by this conference as its sole
recommendation.
-------
753
1 Recommendations
2 MR0 CURRIE: The recommendation is the following:
o "Limitation should be placed on large volume heated water
discharges by requiring closed cycle cooling systems using
5 cooling towers or alternative cooling devices on all new
5 powerplants not yet under construction*"
7 MR0 STEIN: Are there any comments on that?
MR, MILLER: He makes this as the sole —
o, MR. STEIN: The sole recommendation,
10 MR<> CURRIE: I would be happy to take a vote on
this as a recommendation because I think, judging from the
12 comments that have been made so far by all conferees, that
this is one matter and one most important matter on which
all of the conferees should be able to agree,
15 I think we all agree that we do not want prolif-
16 eration of new nuclear powerplants without alternative
cooling devices around the lake, I think it imperative
lg that the conference go on record to that effect by drawing
19 that firm line today. And my recommendation is drawn almost
20 word for word from the communication to the conferees by
21 Administrator Ruckelshaus except, of course, that I have
22 limited it to plants not under construction,
23 MR. STEIN: Well, I think it is goin^ to be significant
i
24 whether we make this a sole recommendation. Your
25 , proposal is for a recommendation, as
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5
6
7
9
10
11
12
13
15
16
17
19
20
21
22
23
24
25
754
Recommendations
a sole recommendation. Do you want to clarify that of how
you want me to put this forward?
MR, CURR1E: I move that the Conference make the
recommendation which I have suggested,,
MR, STEIN: But you are not limiting this to be
the sole recommendation?
MR0 CURRIEj Noo
MRo STEIN: Now, let me — one clarifying points
What do you mean by "plants under construction"? What's
the line on that?
MR. CURRIE: Plants as to which no construction
work has been done as of today's date*
MR, MAYO: Mr, Chairman, I want to raise a point
of order o Generally we don't get involved in parliamentary
problems in connection with motions that are made, and I
don't want to set any precedents here that lead us down a
future path of controversy,
I would like to offer, at this point, if I may —
and if it is parliamentarily correct — a substitute for Mr,
Currie's motion,
MR, STEIN: Well, if we are going this way, we are
going this way. If you want to, I think we are going to —
you are perfectly privileged to do this, and you can offer
an amendment or a substitute at this time and we will
-------
755
1 Recommendations
2 consider both* Go ahead. Why don't we put this on the
table?
MR0 MAYO: I would like to offer as a substitute for
Mr. Currie*s motion the full package of the recommendations
5 that were laid on the table by the conferee at the beginning
7 of the Executive Session wifch the following amendMent —-
MR0 STEIN: You know, this is -so far away in the
o record, I am going to hare to ask you to do as Mr. Currie
10 did •— to read your entire language, so it is going to be
comprehensible to anyone who reads the record.
12 MR. MAYO: Okay. "In order to protect Lake Michigan:
13 the following controls for waste heat discharges are
recommended by the conferees. Municipal waste and water
treatment plants,and vessels are exempted from these
recommendations*
17 "I. Applicable to all waste heat discharges except
as noted above:
"1. At any time, and at a maximum distance of
20 1,000 feet from the point of discharge (agreed upon by the
2i State and Federal ;'
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756
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2
3
4
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6
7
S
9
10
11
12
13
14
15
16
17
IS
19
20
21
22
23
24
25
Recommendations
Surface 3 feet
- — — -*-•aawar- '—
45°
45°
45°
55°
60°
70°
30°
80°
80°
65°
60°
50°
January
February
March
April
May
June
July
August
September
October
November
December
"2. Water intake shall be designed and located to
minimize entrainment and damage to desirable aquatic
organisms. Requirements may vary depending upon local
situations but, in general, intakes are to have minimum
water velocity, shall not be influenced by warmer discharge
waters, and shall not be in spawning or nursery areas of
important fishes. Water velocity at screens and other
exclusion devices shall also be at a minimum*
'3. Discharge shall be such that geographic areas
affected by thermal plumes do not overlap or intersect.
Plumes shall not affect fish spawning and nursery areas
-------
757
1 Recommendations
2 nor touch the lake? bottom*
3 "4, Each discharger shall complete preliminary
plans for appropriate facilities by December 31, 1971» final
5 plans by June 30, 1972, and place such facilities in oper-
5 ation by December 31, 1973»
7 '5o All facilities discharging more than a daily
average of 005 billion B*t»u»/hour of waste heat shall
o, continuously record intake and discharge temperature and
10 flow and make those records available to regulatory agencies
upon request*
12 "II, Applicable to all new waste heat discharges
13 exceeding a daily average of 1/2 billion B,t,u./hour,
except as noted above, which have not begun operation as
15 of March 1, 1971» and which plan to use Lake Michigan
16 waters for cooling:
17 " 1, Cooling water discharges shall be limited to
that amount essential for blowdown in the operation of a
19 closed cycle cooling facility*
20 "2, New applications for powerplant construction
21 permits must be submitted in the context of a regional
22 power expansion plan and must provide evidence of participation in
23 site planning by the State and Federal regulatory agencies*
24 Public notice of proposed sites is to be given at least 5
25 years in advance of construction.
-------
758
1 Recommendations
2 "3. Plants not in operation as of March 1, 1971,
3 will be allowed to go into operation provided they are
committed to a closed cycle cooling system construction
schedule approved by the State regulatory agency and EPA.
5 In all cases, construction of closed cycle systems and
7 associated intake and discharge facilities shall be com-
pleted by December 31, 1974, for facilities utilizing
natural draft towers and December 31, 1973, for all other
10 "types of closed cycle systems.
"III. The States agree to file with EPA within
° months a plant-by-plant program identifying corrective
actions for the modification of intake facilities, includin
•ii powerplants and municipal and industiral users, to minimize
ic the entrainment and damage to desirable aquatic organisms,
•i/; and the modification of condenser cleaning systems for the
use of inert mechanical devices in lieu of chemicals.
MR. STEIN: Thank you, Mr. Mayo.
•jo Now, as you know, we cannot — at least I don't
2Q think we can, if we are going to get a meaningful summary
here — proceed in the usual term of voting on amendments
22 and motions, and so forth, and so on.
To prepare a summary, we are going to put out
with care Illinois' point of view, the Federal conferee's
point of view — if they differ or are the same — and
-------
759
n Recommendations
2 any other points of view — and we are going to direct thes
•3 discussions and procedures so that everyone can be on recor|d
, so we give a summary of the points of views of the conferee
c That is the purpose here, We are not a deliberative vote-
/• taking body, per se, as the first view.
7 Therefore, first I would ask the other conferees
if they feel they can associate themselves in one measure
or another; or even if they can't, whether they have
suggestions or amendments they might want to make to either
.... one of these proposals, and then we will have a discussion.
-._ Mr. Purdy, do you want to speak to that?
MR. PURDY: Well, I am ready to take back to my
, . Commission for public hearings general recommendations made
14
by the Federal conferee. I would note that under item No.
for appropriate facilities by December 31, 1971 > final plan
,, 4 that each discharger shall complete preliminary plans
lo
17
H by June 30, 1972, and place such facilities in operation by
December 31, 1973 — that the only way that this could be
accomplished is to assume that none of the facilities that
might be included under item k would have to go to a wet
draft or to a wet natural draft cooling tower.
£* £
_, I think it is quite clear from the information
that has been presented here in the last several days that
24
25
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9
10
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12
13
14
15
16
17
IS
19
20
21
22
23
24
25
760
Recommendations
42 months is apparently a reasonable time to look at for
such facilities.
And I also recognize that if it is a modification
of the outlet structure that it could be less time than the
42 months.
So with this full understanding, I would suggest
that this would read: ",,, in operation no later than
December 31, 1974." Again, with the full understanding that
the final date would depend upon the type of facility needed,
MR, MAYO: May we make a response there? I think
December 31, 1974, would be fine if we would just add some-
thing to the effect that if natural draft towers are
required, and then it would relate it to that specific item,
MR, PURDY: Fine.
MR, STEIN: "Place such facilities"— how about
this — and I don't want to do the drafting for you, but
I think I get what you are saying, and I have no — again,
I want all of the conferees to understand that what I am
saying now is in the sense of drafting and not plugging
for any points,
%,, such facilities to be in operation by
December 31, 1973* However, in cases where natural draft
towers are needed, this date shall be December 31, 1974,"
MR, PURDY: Fine.
-------
761
1 Recommendations
2 MR. STEIN: All right, now, do you have any other
3 comments?
4 MRo PURDY: Yes. On II. 2. "New application.for
5 powerplant construction permits must be submitted in the
6 context of a regional power plan and must provide evidence
7 of participation in site planning by the State and Federal
g regulatory agencies* Public notice of proposed sites is
9 to be given at least 5 years in advance of construction,
10 If this were a conference that involved its
11 inland use, I would then think that possibly this might be
12 an appropriate recommendation. But I do not, at this
13 point, see where it is an appropriate recommendation with
14 respect to water pollution control*,
15 MR. STEIN: Mr. Mayo.
16 MR. MAYOi I. think one of the objections of this
17 that faces the conferees is the current lack of really
lg meaningful controls on the planning for the siting of
19 power generation plants on Lake Michigan.
20 Would it be acceptable to you if we could modify
21 this in some way to say'It is desirable that new applica-
22 tions for powerplant construction permits be submitted?"
23 MR. PURDY: Certainly I think this is a desriable
24 objective but from the standpoint of the Michigan Water
25 Resources Commission, as I understand their authority —
-------
762
1 Recommendations
2 having been with them for some 20 years — it is not my
3 opinion that the Michigan Water Resources Commission could
4 adopt this as a standard, as a requirement, and as such I
5 do not feel that I could recommend this in good faith to
6 the Administrator*
7 MR0 MAYO: I think your point is well taken, Mr.
g Purdy. What I would suggest would be that we delete that,
9 and then I would recommend to the Administrator, in his
10 transmittal back to the States, to the conferees, that he
11 point this out as being desirable,
12 MR. PURDY: Fine.
13 MR0 MILLER: Fine.
14 MR. STEIN: Let me make a comment on that, and I
15 just make this as a general observation. Of course,
16 there is a temptation in Conferences to take on the whole
17 world because we are very flexible, and we have done this
13 before. We have tried to get at land use, at acid mine
19 drainage, and a lot of monitoring studies.
20 But, again, I think it has been my observation
21 on the record in the past, the farther the Conference
22 strays from its statutory -~ specific statutory authority,
23 and the core of this statutory authority to abate pollution,
24 the least effective it is. And I think possibly —- and I
25 recognize what Mr, Purdy is saying* The question of land
-------
763
1 Recommendations
2 use is really a — of whether the States and Federal Govern-
3 raent or localities are going to regulate land use for
L ecological reasons is a burning issueo Much legislation has
5 been passed or proposed on this, but I also think it is fair
6 to say that when the State water pollution boardsthat we
7 have here were formulated, and our Federal legislation was
g formulated, at least the intrinsic underlying philosophy
9 was that land use for us was — and I hate to use another
10 Latinism — was ultra vires or beyond the scope of authority
11 of the agency that was left somewhere else. So I think
12 perhaps you, Mr<> Mayo, in your response, have come up with
13 a happy solution, because I think while this might be
14 totally appropriate for the Administrator to suggest this
15 in a letter, I think we may be stretching ourselves a little
15 bit in the Conference,
17 So, as I understand this, you have agreed to
lg eliminate 2 and 3 will become 2,
19 MR, MAYO: Yes, sir, under II,
20 MR, STEIN: Are there any other —
21 MR. PURDY: Yes,
22 I hate to have you use those Latinisms, too, Mr,
23 Stein, because I don't understand them. But on Roman
24 numeral III —
25 MR, STEIN: That is a Latinism, too, Roman
-------
764
1 Recommendations
2 numeral —
3 MR, PURDIz — The States agree to file with EPA
4 within 6 months a plant-by-plant program identifying cor-
5 rective actions for the modification of intake facilities
6 to Minimize the entrainment and damage to desirable aquatic
7 organisms and the modification of condenser cleaning
g systems for the use of inert mechanical devices in lieu
9 of chemicals*
10 I would prefer to see that sentence end after
11 "desirable aquatic organisms,"
12 MR0 MAYO: Could you give me something in the way
13 of some rationale?
14 MR0 PURDY: Well, at this point in time, I am not
15 convinced from the information that I have at hand that we
16 should or have to go into the specification of use of inert
17 mechanical devices, I think, under our present standards
lg that have been approved in all of the States that if there
19 is not something specific from the standpoint of toxic
20 substances, that there is at least a general statement with
21 respect to toxic substances that will spell out that dis-
22 charges to waters of the State shall meet some sort of
23 96 hour TI^ or some other restriction, and it does not
24 have to be dealt with here,
25 MR, MAYO: I will agree to that.
-------
765
1 Recommendations
2 MR0 STEIN: That we put a period after "organisms"
o on the proposal,
• Mr, Purdy, any other comments?
MR0 PURDY: None,
MR, STEIN: Mr, Miller, do you want to make any
statement?
MR. MILLER: Mr* Chairman, I think that I certainlj
concur with the proposals made by the Federal conferee, as
amended by Mr0 Purdy, and take these back to the Indiana
11 Stream Pollution Control Board with the recommendation that
12 these be proposed and go to public hearing for adoption,
MR, STEIN: Mr, Frangos,
MR, FRANGOS: Yes, Mr, Stein* As you know, we
have been urging something more and something sooner, but
I think we also are anxious to arrive at some kind of
17 consensus through this Conference mechanism, and, there-
fore, we would concur in this proposal as amended by Mr,
19 Purdy1s suggestion,
20 However, I would suggest that perhaps in III, we
2i would also request that there be appraisal by each State
22 °£ water supply intakes at all major water supplies using
23 the lake, and to begin an assessment of whether there ought
24 to be corrective actions on those facilities as well, I
25 can't see the distinction between power facilities and any
-------
766
1 Recommendations
2 other large user as it relates to III* That language may
3 not have been very good ~
4 MR. STEINj No, I am trying to see a modification
5 to meet — a modification of intake facilities including
6 powerplants. What else do you want,"water purification
7 plants?"1
S MR. FRANCOS: Okay.
9 MR0 STEIN: "Including powerplants and water puri-
10 ficatlon plants." Is that enough?
11 MR. FRANCOS: "And industrial users."
12 MR. STEIN: "Including powerplants and municipal
13 and industrial users,"" right?
14 MR. FRANCOS: Okay. Good.
15 MR. STEIN: All righto Add that in.
16 MR. MILLER: Where do we add this?
17 MR0 STEIN: After "facilities." "... for the
lg modification of intake facilities «.." — after that,
19 comma — "<».. including powerplants, municipal and indus-
20 trial users, to minimize ,?«"• Okay, that is just a
21 modification*
22 Is that acceptable with you, sir?
23 MR. KAYO: Yes.
24 MR. STEIN: All right. Now, are there any other
25 comments?
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767
1 Recommendations
2 MR, CURR1E: Yes, Mr. Chairman.
3 MR. STEIN: Again, I think this has gone a long
4 way and we have to come around again to Mr. Gurrie.
5 MR. CURRIEj I don't think it is sufficient for
6 this Conference simply to take these recommendations back
7 for public hearing purposes. I think it is important that
g we go on record as a body opposing proliferation of nuclear
9 powerplants with once-through cooling on Lake Michigan. I
10 think we should recommend to the individual States that they
11 adopt a firm approach of that nature.
12 I think we have had a lot of tough talk here about
13 the necessity for protecting the lake* I think we have an
14 obligation to enunciate a firm policy, not simply a u\\g~
15 gestion that we go back and think about it through the
16 public hearing process.
17 I think moreover that our problem is essentially
lg one of proliferation; it is not a problem with existing
19 plants. I think we should deal with the problem of pro-
20 • liferation and deal with that firmly and only. I think we
21 should not spend unnecessary money on backfitting, and I
22 think we should deal with the entire problems of prolifer-
23 ation, and I do not believe that the Federal proposal is
24 strong enough on the issue of proliferation.
25 The Federal proposal with regard to new plants
-------
10
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12
13
14
15
16
17
18
19
20
22
23
24
25
768
Recommendations
in II. 2. contains an exemption for discharges under 1/2
billion B.t.u./hour. Working backward from the figures in
the record with regard to the Zion plant, I conclude that is
an exemption of any new powerplant of 70 megawatts or below,
I see no excuse for that, I think we ought to take a firm
policy against all new powerplants and, in fact, I see no
reason why it should be limited to powerplants.
Again, I would ask — because I believe that we
can reach agreement on one firm and important matter of
principle — that we take a vote first before we consider
all of the details of the Federal proposal on what I believe
we can all agree on, which is the recommendation that I
made a moment ago, that limitations should be placed on
large volume heated water discharges by requiring closed
cycle cooling systems using cooling towers or alternative
cooling systems on all new powerplants not yet under con-
struction,
MR, STEIN: Are there any other comments?
I want to make one thing clear, I would hope that
21 we all understood what we are doing here at this con-
ference is making recommendations for me to take back to
the Administrator of the Federal Environmental Protection
Agency. I know that many of the conferees who have been in
other conferences know that. I took it when they
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769
1 Recommendations
2 said they could take this back to their Board that they
o were facing reality and know in addition to that they
4 would have to go back and face their Board. But I don't
5 think anyone should be under the illusion that we are just
voting here or coming to a determination of a recommendation
for a State to take back to its Board, because I am going to
take a recommendation back to the Administrator.
9 Now, I would like to accommodate this but, Mr.
10 Currie, I think we have a dilemma. If we were going to
follow parliamentary rules, we have to operate on the
12 amendment first. But I don't think what we want to do is
have a vote« We want to have a position you adopted here.
14 Now, I am going to ask the conferees whether they
15 want to adopt this position or your position When we
16 are through with that I will be glad to have them record
17 themselves on a vote on your proposition for you. But I
lg think the obligation that we have under the Federal law —
19 and that is the one I have to observe — is to bring back
20 a summary of the views of the conferees. They may be a
21 yes or no vote, or they may be just expressing different
22 opinions, and I sense that what we have here is a judgment
23 of two different approaches and two different opinions to
24 the Administrator, and if we have two or more I bring them
25 to the attention of the Administrator and he makes his
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1 Recommendations
2 judgment.
3 Now, with that, unless there is further discussion,
4 I am going to call — Mr, Mayo, you have heard Mr, Currie*s
5 proposal, and your proposal with the amendments made by the
6 various States which you have accepted. Which do you propose
7 to adopt?
8 MR, MAYO: That which I introduced as amended by
9 Mr, Purdy and Mr. Frangos,
10 MRo STEIN: Mr, Purdy, which one will you?
11 MR. PURDY: Well, on the basis of the proposal of
12 Mr, Currie -~ that is without his explanation as to the
13 reason why — I don't see that his proposal is, say, in
14 very drastic conflict with that of the Federal conferee,
15 and I would have no objection in including his statement as
16 such without his reasons for it to be included as a part of
17 our concurrence0
IS MR, STEIN: But let me ask you two questions,
19 Do you concur with this proposal as it stands» with the
20 amendment?
21 MR. PURDY: Yes.
22 MR, STEIN: And you also make the proposal that
23 in addition to this we use the statement made by Mr, Currie.
24 MR, PURDY: Yes,
25 MR. STEIN: All right.
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Recommendations
2 Now, Mr. Miller.
3 MR. MILLER: I concur that we can use the proposal
4 as submitted by the Federal conferee, arid I also believe, as
5 Mr. Purdy has stated, that the explanation by Mr. Currie is
6 also consistent with what I see is meant in II.
7 MR. STEIN: Mr. Frangos.
MR. FRANGOS: Well, I would like to ask Mr. Currie
9 to read the statement, again, please.
10 MR. CURRIE: Yes, and the statement is once again
11 word-for-word that of Administrator Ruckelshaus,, except as
12 to its application to plants now under construction, which
13 is a separate issue. And what I am asking now is agreement
with Commissioner Ruckelshaus as to new sources.
15 ^Limitation should be placed on large volume heated
water discharges by requiring closed cycle cooling systems
17 using cooling towers or alternative cooling systems on all
new powerplants not yet under construction."
I wonder if Mr. Mayo really disagrees with that.
20 MRo STEIN: Well, I want to ask — pardon me.
Mr. Frangos asked a question --
22 MR. FRANGOS: Well, I concur with the position
that we could include both of those and I don't see that
* these are necessarily in conflict.
25
' MR. MAYO: I would like to ask Mr. Currie if he
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1 Recommendations
2 feels that that additional statement is in any way in con-
3 flict with the material covered under II?
4 MR. CURRIE: Yes, I do because II contains an
5 exclusion for plants not exceeding a daily average of one-
6 half billion B.t.u./hour. In other words, I think that the
7 specific propo'sal in II does not live up to the promise in
g Administrator Ruckelshaus' letter.
9 MR. MAYO: So that you would consider that the
10 terminology "large volume heated discharges" — "limitations
11 would be placed on large volume heated discharges" is not
12 in harmony with the one-half billion B.t.u./hour.
13 MR. CURRIE: I am referring to the additional
14 language where it says "requiring closed cycle system on
15 all new powerplants."
16 I would adhere to that request of the Adminis-
17 trator.
IB MR. MAYO: I am still not sure that I follow you.
19 MR. STEIN: Let me again try to assist on this. Maybe
20 you can't be brought together. B ut if the issue here is
21 the difference between the daily average of a half-billion
22 B.t.u./hour, if you would substitute for that the language
23 — what is that word?
24 MR. CURRIE: ^Al$ is the word — "all new power-
25 plants."
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Recommendations
MR. STEIN: "Applicable to all new powerplants
except as noted above"-- what is that "noted above"?
"Applicable to all new powerplants which have not begun
operations"— and you had something on construction, but
we can handle that, ano"which plan to use Lake Michigan
water for cooling," Then you can use 1 and 2 and be there.
Is that correct?
o, MKo CURRJE: I am suggesting that II raises a
10 number of different questions which I don't think we have
11 to get into right now about plants that are presently
12 under construction*
I would like, first of all, to have the conferees
14 agree that we don*t want any new powerplants on Lake Michigar.
using once-through cooling, and by "new" I mean those not
16 under construction, I thought that was what we had agreed
17 on, I thought that was what this Conference was specifi-
cally about «— proliferation — that we should stop it now,
19 MR, STEIN: Well, Mr, Currie, I am not arguing
20 with your conclusion, but I think — I have to state that
2i the scope of the Conference is not just new powerplants or
22 proliferation, but from all sources of pollution existing
23 as well as otherwise or any other source,
24 MR, CURRIEi Yes,
25 MR, STEIN: Now, I understand your view. What
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a
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774
Recommendations
Mr, Currie is saying: If you adopt what Mr. Mayo has
proposed, as amended — Mr, Mayo's proposal and his proposal
and you put them both together, there may be a conflict in
II in the Mayo proposal with the proposal of Mr. Currie.
that?
Do you find that to be so, or can you adjust
MR. CURRIE: Mr. Chairman, we have some disagree-
ments which I view as relatively minor, with regard to
what should be done with existing plants and those under
construction. I am simply asking that we complete the polling
of the Conference on the issue which I thought we all agreed
on which was no new powerplants not yet under construction
using once-through cooling. Can we simply face that
proposition and decide it?
MR» STEIN: Well, we are facing it and we are
going through, I thought — I had at least polled three of
the States — all of the other States — and they seem to
agree with you on this. We have got to deal with the fourth
State and as soon as we get through w^th that, I will go
to Mr. Mayo.
MR. CURRIE: Well, I agree with my proposal.
MR. STEIN: Mr. Mayo, what do you want to do?
MR. MAYO: Well, I am not sure I understand Mr.
Currie's proposal, and I would not object to a modification
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1 Recommendations
2 that doesn't build any contradiction, and I haven't yet got
3 the assurance that what is here now and what Mr, Currie is
4 proposing aren't in conflicto
5 MR. CURRIE: What is it about Administrator
6 Ruckelshaus' language that you find contradictory?
7 MR. MAYO: Well, I am not sure about the way you
g are putting it together is what concerns mef because you
9 are taking it in part> I think, and adding to it in a way
10 that may change its sense. I want to be sure that that
11 sense is not changed. I f it is changed, that we don't
12 build in a contradiction to what we have already addressed
13 ourselves to.
14 MR. CURRIE: Then, am I — let me ask Mr<> Mayo:
15 Are you insisting that there be an allowance of prolifera-
16 tion of small plants?
17 MR, MAYO: No, I am not,
lg MR. CURRIE: Then, why do you object to my
19 proposal?
20 MR, MAYO: Not in any sense, I am concerned —
21 I am not assured that there isn't a contradiction here.
22 MR0 STEIN: Let me ask both of you people — and
23 I would like to get this through — I think what we are
24 doing is —
25 MR, MAYO: We are very close to agreement, Mr,
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1 Recommendations
2 Chairman.
MR. STEIN: Just a moment. I think we are in a
situation here in which we don't have any substantive agree-
5 ment. I think with an issue like this, it may be a
5 technical problem on drafting. We have gone through all
7 of the States and the Federal conferee and you are all in
agreement. The sole question that I find in the question
of drafting is whether this language proposed by Mr. Currie
which everyone seems to think is appropriate, is in any
•i-i way in conflict with your proposal, Mr. Mayo, of particularly
II* Now, if it is, and you have no substantial agreement,
let's get that language together.
I am going to recess the meeting for 10 minutes.
(Short recess.)
MR. STEIN: Let's reconvene.
,« I think the conferees have had an opportunity to
try to get together during this recess. I was generous
with the time.
Now, my recommendation would be that as soon as
«, possible we come up with the question, and, if there
22 are any differences, I will poll the conferees. I am
not sure, unless you want to go forward, that any further
«, discussion is going to get you any closer. We are
as close as we can get now possibly at this meet.ing.
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4
5
6
7
9
10
12
15
16
17
19
20
21
22
23
24
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777
Recommendations
Mr«, Mayo, may I ask you to go ahead?
MR. MAYOs I certainly concur with Mr, Currie's
concern about the conferees needing to express themselves on
the subject matter of proliferation.
I feel this could be done very adequately by
adding the Roman numeral IV which would read as follows:
"The States agree that there should not be a proliferation
of new powerplants on Lake Michigan, and that in addition
to "tne above controls limitation should be placed on large
volume heated water discharges by requiring closed cycle
cooling systems, using cooling towers or alternative cooling
systems on all new powerplants."
Now, that statement would make abundant use of the
language in Mr, Ruckelshaus1 letter, but it would make it
clear that this would be a limitation in addition to those
that were stated earlier in the recommendations*
MR. STEIN: And this would be Roman numeral IV?
MR. MAYO: Yes.
MR. STEIN: All right, now, I would like to
correct the record. This has been called to my
attention during the recess. There was a contention that
when you read this, Mr. Mayo, that there may have
been a little slip in the readings
Let me just go through to get this — this is just
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778
1 Recommendations
2 for technical purposes.
On No, 1, where you say "Applicable to all waste
heat discharges except as noted above:" this reads:
5 "1. At any time, and at a maximum distance of
6 1,000 feet from a fixed point adjacent to the discharge,
7 (agreed upon by the State and Federal regulatory agencies),"*
and the rest is all right* Is that correct?
9 MR. FETTEROLF: Yes, sir.
10 MRo STEIN: And I think we have the record correct*
11 Now, I think now what we have before us — let me
12 trv to do this, and we will give Mr. Currie the floor in a
13 moment. I just want to set this straight.
With that correction and Mr. Mayo*s proposal No<>
15 IV, if the amendments and modifications he suggested are
— this is one proposition which presumably, Mr. Mayo, you
17 believe covers Mr. Currie1s point as far as you can go.
MR. MAYO: Yes.
19 MR. STEIN: Okay. I don't know what Mr. Currie
20 thinks, but Mr. Currie, do you want to speak to this? What
21 I propose to do is call for an expression on Mr. Mayo's
22 proposal with the amendments, including his paragraph IV,
23 to call on the conferees for an expression of an endorsement
24 of your proposal and see if they want to pick one or the
oth er or both.
P.
-------
779
1
2
A us and make it the conferees rather than the States?
5
6
7
o,
10
11
12
19
20
2i
22
23
24
25
Recommendations
MR. FRANCOS: Mr. Stein, could I just interject
a moment here on Mr. Mayo's IV? Can we have him join with
MR. MAYO: Okay. It was not in the context of —
MR. FRANCOS: III. Very good.
MR. STEIN: Are there any other comments?
MR. CURRIE: Yes, Mr. Chairman.
MR. STEIN: Yes, Mr. Currie.
MR. CURRIE: What bothers me about that proposal
is that it is an attempt to make it impossible to express a
view against proliferation without agreeing with Mr. Mayo
on all of the other points in his document, and I think
this is totally unnecessary. I would be happy to agree
to his statement if we are talking about a vote on his
proposition No. IV only, leaving the other issues to be
resolved later, and if the words "in addition to" are
omitted. If he wants to say "as a minimum," that is all
right, so as to indicate that this is a vote taken without
prejudice to anything the conferees may later choose to do on
many of the other issues before them. But I don't think it
is fair to ask us to commit ourselves on other issues in
order to express ourselves on this one.
MR, STEIN: No, sir, I am not going to put the
expression that Mr. Mayo has made as a proposal, I, II, III,
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780
•i Recommendations
2 and IV, with several subproposals. Any of the conferees
can agree to all of these or none of them or any part they
• wish. This is not the question of a vote where you are
c and this is what I tried to make clear -- what we want is a
full and complete expression of each conferee's view, and you
do not have to swallow this whole one way or the other. You
can take any part or none of it.
With that, I just feel like ole Al Sabath from
10 Chicago, who used to say, "I guess it is time to call the
11 roll."
12 Mr. Mayo, I take it — how do you feel about
your I} II, III and IV you propose?
MR. CURRIE: How does he feel about the motion on
the floor?
MR. STEIN: Well, I don't know we are dealing with
motions, sir.
MR. CURRIE: I have moved one.
MR0 STEIN: Well, if you want to go with motions,
20 repeat your motion and we will go that way, Mr* Currie.
MR. CURRIE: I move that the Conference recommend
22 that the States adopt the following policy: "Limitations
23 should be placed on large volume heated water discharges
24 by requiring closed cycle cooling systems using cooling
25 towers or alternative cooling systems on all new sources
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1 Recommendations
2 discharging more than a daily average of 1/10 billion
3 B.t.u./hour, and not yet under construction."
4 MR. STEIN: Any seconds to that motion?
5 I hear none,
6 Mr. Mayo,
7 MR. MAYO: Mr, Chairman, I move that we proceed
g with the adoption of the recommendations offered by the
9 Federal conferee with the amendments offered by Mr. Purdy
10 MR. STEIN: Unless you want to, I would not place
11 this in the form of a motion, Mr. Mayo<> I would like to
12 follow our usual procedure and poll the conferees.
13 How do you feel about this? I guess you are in
14 favor of it,
15 MR. MAYO: Yes, I am,
16 MR. STEIN: Mr. Purdy.
17 MR. PURDY: We are talking about I, II, III, and
18 IV?
19 MR0 STEIN: Yes, sir.
20 MR. PURDY: Fine. Good idea.
21 MR. STEIN: Mr. Miller,
22 MR0 MILLER: I will concur with I, II, III, and
23 IV.
24 MR. STEIN: Mr. Frangos.
25 MR. FRANGOS: Yes, I concur, but I just offer
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1 Recommendations
2 the observation that I am puzzled why we can't perhaps
o accommodate Mr. Currie in his recommendation* I think we
are trying hard, and I think we are awfully close.
MR. STEIN: Well, the Chair is puzzled, too,
but I am inhibited by the position I hold here. I suspect,
as J pointed out before the recess, and that is why I tried
to do it, that the differences were more apparent than
o, real. But I aIPO think we are grinding on here. We have
10 people who have come to testify on various aspects, and
we just have to do the best we can in a reasonable time.
12 Again, I go back to Al Sabath , who was a wise
old man and Dean of the House for many years — "You can
go so long and then you have to call the roll." And I
think that is where we are now.
Do I take it, Mr. Frangos, you concur?
MR. FRANGOS: Yes, I do,
MRe STEIN: Mr. Currie.
19 MR. CURRIE: I do not concur0
20 MR* STEIN: Right. Do you want your motion to
2i be put in the form of your recommendation for the conferees
22 as the recommendation to go to the Administrator?
23 MR. CURRIE: Yes, I do. Thank you.
24 MR. STEINi Yes, the record will so show this,
25 This completes the recommendation on the thermal
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783
Recommendations
2 pollution question.
o Now —
MR. FRANCOS: Mr. Stein, I am wondering, would it
be possible to secure from your agency those recommendations
as soon as possible?
MR. STEIN: I am piad you said "as soon as
possible."
Now, I would suggest, in view of the interest
on this, we charge the Region with this? I know we have
•i-t kept notes. I have notes. You may want to send an outpost
"to Columbus, Ohio, to keep Mr. and Mrs. Hall company, but
I think that we should try to assemble the findings and
TI the conclusions together which may be a little difficult
,c very rapidly. What is today, Thursday? We should try to
do this by this week.
^~ Now, I would ask in view of the complexity of thij,
the better part of valor would be if you could circulate
this rapidly to the States. I ask the States to respond
2Q very rapidly and confine themselves to what their recollection
is. If their notes change, don't change your ideas. I
22 think if we operate in this manner with judicious use of thf:
telephone, teletype, etc., we should be able by Monday to
2, be able to have clean copies of this.
25
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784
WATER Q'JAITTY OFFICE
33 EAST CONGRESS PARKWAY, ROOM 410
CHICAGO, ILLINOIS 60605
April 30, 1971
TO: CONFEREES - LAKE MICHIGAN ENFORCEMENT CONFERENCE
Enclosed find copies of the findings and recommendations of the
Lake Michigan Enforcement Conference meeting on ilarch 25, 1971 in
regard to thermal discharges as revised from the transcript. Two
small changes in language on findings 3 and 6 proposed by the
Michigan Conferee are included.
Jamaa 0. McDonald
Regional Regulatory Programs Director
Office of Regulatory Programs
Enclosure
ccs: Ralph W. Purdy
Perry Miller
David P. Currie
William L. Blaser
Thomas G. Frangos
Francis T. Mayo
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785
REVISED FROM THE TRANSCRIPT
LAKE MICHIGAN ENFORCEMENT CONFERENCE
FINDINGS
1. That the lake as a whole will not be warmed, except in localized areas
by discharges of waste heat from existing and presently proposed power
plants.
2. Safe temperatures in the lake vary with season and species.
3. Heat is not persistent in the lake.
4. Timing of food and fish hatching is precarious.
5. In the summer, Lake Michigan is "a lake over a lake," the top one
is much warmer than the bottom one.
6. Maximum temperatures are not safe for long periods — lethal temperatures
must be related to time of exposure.
7. Mean temperatures must be lower than the maximums.
8. Fish kill hazards are greatest in winter.
9. The area that would be raised in temperature more than 5° by the heated
discharge from a 100 mw nuclear plant, designed so as to maximize dilu-
tion, could if the only theoretical appraisal in the record (that of
Dr. D. W. Pritchard) is correct, be limited to the order of ten acres,
and the area raised 2° to the order of 100 acres.
10. If the only theoretical appraisal in the record (that of
Dr. D. W. Pritchard) is correct, such a plant could be built so that
any given particle of water, or any organism, drawn through its conden-
sers would be exposed to temperatures 20° above ambient for two minutes
during passage, and any particle or organism discharged or entrained
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786
would be exposed thereafter to temperatures more than 10° above ambient
for the order of forty-five seconds, more than 5° for six minutes, and
more than 2° for one and a half hours.
11. If the only theoretical appraisal in the record (that of
Dr. D. W. Pritchard) is correct, a properly designed discharge structure
can avoid any significant increase in temperature on the lake bottom or
along the shore.
12. Perfect mixing is not possible. Consequently if no limits are imposed
the proliferation of waste heat discharges from electric plants along
the lake may result in the warming by several degrees of a large fraction
of the inshore waters.
13. The interaction of two or more thermal plumes may have a more than
linear effect on the area affected by a rise in temperature and on the
residence time of any particle at elevated temperatures.
14. A single 1000 mw nuclear plant will create a small zone uninhabitable
by certain species of fish during the warmer months and unsuitable for
spawning and other significant fish activities at various times.
15. An unknown percentage of organisms passing through the condensers of
a power plant will be killed or damaged by heat, physical shock, or
chemicals. Therefore the damage is likely to be proportional to the
volume of water intake.
16. Discharges from a single large plant located in the spawning ground or
across a migratory route could significantly disrupt the balance of
the affected species throughout the lake.
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787
17. If the only theoretical appraisal in the record (that of
(Dr. D. W. Pritchard) is correct, the residence time of algal cells
in the heated plume from a properly designed single 1000 raw plant
is probably too short to cause any detectable shift to less desirable
species, and no significant increase in total algal mass is to be
expected.
18a. On the basis of information currently available, unless it is located
so as to interfere with spawning or migration, a single 1000 mw plant
will have local effects some of which have been noted above but the
effect on the balance of the lake as a whole is not known at this time.
(U.S. Environmental Protection Agency & Wisconsin - Yes //
Other 3 States - No)
18b. On the basis of information currently available, unless it is located
so as to interfere with spawning or migration, a single 1000 mw plant
will have local effects, some of which have been noted above, but may
not upset the balance of the lake as a whole.
(Illinois, Michigan & Indiana - Yes //
EPA & Wisconsin - No)
19. Proliferation of waste heat discharges from electric plants along the
lake could seriously worsen the problem of nuisance algae by favoring
the less desirable species and could seriously alter the balance of
fish and other organisms in the lake as a whole.
20. Various alternative methods of heat disposal are technically feasible,
including wet and dry cooling towers, cooling ponds, and spray canals.
The backfitting of all but dry towers is technically feasible.
21. To backfit wet towers at a single 2100 mw nuclear plant would cost
somewhere between $20 million and $120 million. At the Zion plant this
is estimated to cost average residential customers somewhere between
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788
10c and 69c per month.
22. All alternative cooling means may have some undesirable environmental
effects. Wet towers can cause fog problems. Towers discharge blowdown
water that may require treatment before release. Dry towers may cause
as yet undetermined meteorological changes. Both wet and dry towers
are bulky additions to the lakefront. Cooling ponds consume about two
acres of land per megawatt.
23. The existing Federally approved water quality standards to control
waste heat discharges do not offer adequate protection for the waters
of Lake Michigan and its continued beneficial uses.
24. The effective management of waste heat discharges into Lake Michigan
makes it desirable for the states to adopt reasonably uniform minimum
water quality standards.
25. The evidence presented to the Conference does not permit a determination
of the overall damage of large waste heat discharges to Lake Michigan
%
from existing or planned power generation plants. (U.S. Environmental
Protection Agency - Yes// States - No)
26. Additional evidence is desirable as to the behavior of waste heat plumes
during winter months. Their impact on the ecosystem of Lake Michigan
is not now fully assessable.
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789
REVISED FROM THE TRANSCRIPT
LAKE MICHIGAN ENFORCEMENT CONFERENCE
RECOMMENDATIONS
(Concurred in by Indiana, Michigan, Wisconsin & EPA)
In order to protect Lake Michigan the following controls for waste heat dis-
charges are concurred in by the Conferees. Municipal waste and water treat-
ment plants, and vessels are exempted from these recommendations.
I. Applicable to all waste heat discharges except as noted above:
1. At any time, and at a maximum distance of 1000 feet from
a fixed point adjacent to the discharge, (agreed upon by
the State and Federal regulatory agencies), the receiving
water temperature shall not be more than 3°F above the
existing natural temperature nor shall the maximum tempera-
ture exceed those listed below whichever is lower:
Surface 3 Feet
January 45
February 45
March 45
Apri1 55
May 60
June 70
July 80
August 80
September 80
October 65
November 60
December 50
2. Water intake shall be designed and located to minimize entrain-
ment and damage to desirable aquatic organisms. Requirements
may vary depending upon local situations but, in general, intakes
are to have minimum water velocity, shall not be influenced by
warmer discharge waters, and shall not be in spawning or nursery
areas of important fishes. Water velocity at screens and other
exclusion devices shall also be at a minimum.
3. Discharge shall be such that geographic areas affected by thermal
plumes do not overlap or intersect. Plumes shall not affect fish
spawning and nursery areas nor touch the lake bottom.
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790
4. Each discharger shall complete preliminary plans for appropriate
facilities by December 31, 1971, final plans by June 20, 1972,
and place such facilities in operation by December 31, 1973.
However in cases where natural draft towers are needed, this date
shall be December 31, 1974.
5. All facilities discharging more than a daily average of 0.5
billion BTU/hour of waste heat shall continuously record intake
and discharge temperature and flow and make those records
available to regulatory agencies upon request.
II. Applicable to all new waste heat discharges exceeding a daily
average of 1/2 billion BTU/hour, except as noted above, which
have not begun operation as of March 1, 1971, and which plan to
use Lake Michigan waters for cooling:
1. Cooling water discharges shall be limited to that amount
essential for blowdown in the operation of a closed cycle
cooling facility.
2. Plants not in operation as of March 1, 1971 will be allowed
to go into operation provided they are committed to a closed
cycle cooling system construction schedule approved by the
State regulatory agency and EPA. In all cases construction
of closed cycle systems and associated intake and discharge
facilities shall be completed by December 31, 1974 for
facilities utilizing natural draft towers and December 31, 1973
for all other types of closed cycle systems.
III. The States agree to file with EPA within six months a plant by plant
program identifying corrective actions for the modification of intake
facilities, including power plants, municipal and industrial users,
to minimize the entrainment and damage to desirable aquatic organisms.
IV, The Conferees agree that there should not be a proliferation of new
power plants on Lake Michigan and that in addition to the above con-
trols, limitations should be placed on large volume heated water dis-
charges by requiring closed cycle cooling systems, using cooling
towers or alternative cooling systems on all new power plants.
RECOMMENDATION PROPOSED BY ILLINOIS
Limitations should be placed on large volume heated water discharges by re-
quiring closed cycle cooling systems, using cooling towers or alternative
cooling systems on all new sources discharging more than a daily average of
0.1 billion BTU/hour and not yet under construction.
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791
WATER QUALITY OFFICE
33 EAST CONGRESS PARKWAY, ROOM 410
CHICAGO, ILLINOIS 60605
March 30, 1971
Mr. Perry Miller
Technical Secretary
Stream Pollution Control Board
Indiana State Board of Health
1330 West Michigan Street
Indianapolis, Indiana 46207
Dear Mr. Miller:
Attached are the Findings and Recommendations from the
Lake Michigan Enforcement Conference. These were
developed from toy notes and not from the transcript.
Please let me know as soon aa possible If your notes
show a deviation from these.
Sincerely yours,
Dale S. Bryson
Deputy Director
Office of Regulatory Programs
Attachments
Findings
Recommendations
DSBryson/jm
IDENTICAL LETTERS SENT TO MILLER, PURDY, FRANCOS, CURRIE w/copy to.Blaser
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792
following was prepared from notes taken at the Conference
and not from the transcript.
LAIffi MICHIGAN ENWRCEMENT CONFERENCE
RECOMMENDATIONS
(Concurred in by Indiana, Michigan, Wisconsin & USEPA)
In order to protect Lake Michigan the following controls for waste heat dis-
charges are concurred in by the Conferees. Municipal waste and water treat-
ment plants, and vessels are exempted from these recommendations.
I. Applicable to all waste heat discharges except as noted above:
'1. At any time, and at a maximum distance of 1000 feet from
a fixed point adjacent to the discharge, (agreed upon by
the State and Federal regulatory agencies), the receiving
water temperature shall not be more than 3°F above the
existing natural temperature nor shall the maximum temperature
exceed those listed below whichever is lower:
Surface 3 Feet
January 45
February 45
March 45
April 55
May 60
June 70
July 80
August 80
September 80
October 65
November 60
December 50
2, Water intake shall be designed and located to minimize entrain-
ment and damage to desirable aquatic organisms. Requirements
may vary depending upon local situations but, in general, intakes
are to have minimum water velocity, shall not be influenced by
warmer discharge waters, and shall not be in spawning or nursery
areas of important fishes. Water velocity at screens and other
exclusion devices shall also be at a minimum.
3, Discharge shall be such that geographic areas affected by thermal
plumes do not overlap or intersect. Plumes shall not affect^ fish
spawning and nursery areas nor touch the lake bottom.
4. Each discharger shall complete preliminary plans for appropriate
facilities by December 31, 1971, final plans by June 30, 1972,
and place such facilities in operation by December 31, 1973,
however in cases where natural draft towers are needed, this
date shall be June 31 , 1974.
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793
5. All facilities discharging more than a daily average of 0.5
billion BTU/hour of waste heat shall continuously record intake
and discharge temperature and flow and'make those records
available to regulatory agencies upon request.
II. Applicable to all new waste heat discharges exceeding a daily
average of 1/2 billion BTU/hour, except as noted above, which
have not begun operation as of March 1, 1971, and which plan to
use Lake Michigan waters for cooling:
1. Cooling water discharges shall be limited to that amount
essential for blowdown in the operation of a closed cycle
cooling facility.
2. Plants not in operation as of March 1, 1971 will be allowed
to go into operation provided they are committed to a closed
cycle cooling system construction schedule approved by the
State regulatory agency and EPA. In all cases construction
of closed cycle systems and associated intake and discharge
facilities shall be completed by December 31, 1974 for facilities
utilizing natural draft towers and December 31, 1973 for all
other types of closed cycle systems.
III. The States agree to file with EPA within six months a plant by plant
program identifying corrective actions for the modification of intake
facilities, including power plants, municipal and industrial users,
to minimize the entrainment and damage to desirable aquatic organisms.
IV. The Conferees agree that there should not be a proliferation of new
power plants on Lake Michigan and that in addition to the above controls
limitations should be placed on large volume heated water discharges
by requiring closed cycling cooling systems, using cooling towers or
alternative cooling systems on all new power plants.
RECOMMENDATION PROPOSED BY ILLINOIS
It is recommended that limitations should be placed on large volume heated
water discharges by requiring closed cycle cooling systems, using cooling
towers or alternative cooling systems on all new sources discharging more than
a daily average of 0.1 billion BTU/hour and not yet under construction.
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794
NOTd: The following was prepared from notes taken at the Conference
and not from the transcript.
LAKE MICHIGAN ENFORCEMENT CONFERENCE
FINDINGS
1. That the lake as a whole will not be warned, except in localized
areas by existing and presently proposed power plants.
2. Safe temperatures vary with season and species.
3. Heat is not persistent.
li. Timing of food and fish hatching is precarious.
£. In the summer, Lake Michigan is "a lake over a lake," the top one
is much warmer than the bottom one.
6. Maximum temperatures are not safe for long periods — lethal
temperatures must be related to time.
7. Mean temperatures rust be lower than the maximums.
8. Fish kill hazards are greatest in winter.
9, The area that would be raised in temperature more than 5° by the
heated discharge from a 1000 nw nuclear plant, designed so as to
maximize dilution, could if the only theoretical appraisal in the
record is correct (that of Dr. B. W. Pritchard) be limited to the
order of ten acres, and the area raised 2° to the order of 100
acres.
10. If the only theoretical appraisal in the record is correct (that of
Dr. B. W. Pritchard), such a plant could be built so that any given
particle of water, or any organism, drawn through its condensers
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795
would be exposed to temperatures 20° above ambient for two minutes
during passage, and any particle or organism discharged or entrained
would be exposed thereafter to temperatures more than 10 above
ambient for the order of forty-five seconds, more than y for six
minutes, and more than 2° for one and a half hours.
11. If the only theoretical appraisal in the record is correct (that of
Dr. B. W, Pritchard), a properly designed discharge structure can
avoid any significant increase in temperature on the lake bottom or
along the shore.
12. Perfect mixing is not possible. Consequently if no limits are im-
posed the proliferation of waste heat discharges from electric plants
along the lake may result in the warming by several degrees of a
large fraction of the inshore waters.
13. The interaction of two or more thermal plumes may have a more than
linear effect on the area affected by a rise in temperature and on
the residence time of any particle at elevated temperatures.
Ill, A single 1000 mw nuclear plant will create a small zone uninhabitable
by certain species of fish during the warmer months and unsuitable
for spawning and other significant fish activities at various times.
15. An unknovm percentage of organisms passing through the condensers
of power plants will be killed or damaged by heat, physical shock, or
chemicals. Therefore the damage is likely to be proportional to the
volume of water intake.
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796
16. Discharges from a single large plant located in a spawning ground or
across a migratory route could significantly disrupt the balance of
the affected species throughout the lake.
17. If the only theoretical appraisal in the record is correct (that of
Dr. B. W. Pritchard), the residence time of algal cells in the heated
plume from a properly designed single 1000 mw plant is probably too
short to cause any detectable shift to less desirable species, and no
significant increase in total algal mass is to be expected.
18. On the basis of information currently available, unless it is located
so as to interfere with spawning or migration, a single 1000 mw plant
will have local effects some of which have been noted above but the
effect on the balance of the lake as a whole is not known at this time.
(U.S. Environmental Protection Agency & Wisconsin - Yes //
Other 3 States - No)
19. Proliferation of waste heat discharges from electric plants along the
lake could seriously worsen the problem of nuisance algae by
favoring the less desirable species and could seriously alter the
balance of fish and other organisms in the lake as a whole.
20. Various alternative methods of heat disposal are technically
feasible, including wet and dry cooling towers, cooling ponds, and
spray canals. The backfitting of all but dry towers is technically
feasible.
21. To backfit wet towers at a single 2100 mw nuclear plant would cost
somewhere between $20 million and $120 million. At the Zion plant
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797
this is estimated to cost average residential customers somewhere
between IQfi and 69^ per month.
22 o All alternative cooling means way have some undesirable environmental
effects. Wet towers can cause fog problems. Towers discharge blowdown
water that may require treatment before release. Dry towers may cause
as yet undetermined meteorological changes. Both wet and dry towers
are bulky additions to the lakefront. Cooling ponds consume about
two acres of land per megawatt.
23. The existing Federally approved water quality standards to control
waste heat discharges do not offer adequate protection for the waters
of Lake Michigan and its continued beneficial uses.
2k• The effective management of waste heat discharges into Lake Michigan
makes it desirable for the states to adopt reasonably uniform minimum
•water quality standards.
25>. The evidence presented to the Conference doss not permit a qiiantification
of the overall damage of large waste hsat discharges to Lake Michigan
from any potential number of existing or planned power generation
plants. (U.S. Environmental Protection Agency - Yes//States - No)
26. Additional evidence is desirable as to the behavior of waste heat
plumes during winter months and therefore the impact on the
ecosystem of Lake Michigan is not now fully assessable.
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1 Murray Stein
2 (The succeeding pages contain that part of the
3 Conference which followed the Executive Session.)
4
5 MR. STEIN: Gentlemen, let me say this: We have
5 a Pesticide. Committee Report, Status of Compliance with
7 Conference Recommendations, Discussion of the Phosphorus
and Chloride Loadings in Lake Michigan, and other state-
ments.
MR. CURJU.E: Mr. Chairman,
MR. STEIN: Yes.
12 MR. CURRIE: Mr. James Vaughn of the city of
13 Chicago is here and would like to make a statement with
14 regard to water quality sampling. I wonder if this is
15 the time —
16 MR. STEIN: I was just going to suggest that,
17 Mr. Currie, that would just be fine.
I was going to make a general statement. I
19 think, in view of the time we took, if the conferees
20 would consider it appropriate, I would ask that requests
21 like Mr. Currie's be honored now and we ask all of the
22 conferees to call upon those outside people who have been
23 here waiting patiently to make statements and let them go
24 on first before we take up these other matters.
25 If I hear no objection, Mr. Currie, do you want
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799
Jo C. Vaughn
2 i to call Mr. Vaughn?
3 \: MR. PURDY: Mr. Stein, I would only say that I
4 i! can stay as long as you wish to operate tonight, but I
5 j| will not be here in the morning.
6 !| MR. STEIN: I understand that. But I really
7 j| do think we have an obligation to the citizens on time and
i
£ I think we have to let them go on first.
9
10 | STATEMENT OF JAMES C. VAUGHN, ENGINEER OF
I
11 i WATER PURIFICATION, DEPARTMENT OF WATER AND SEWERS,
I
12 | CITY OF CHICAGO, ILLINOIS
13 |
i
14 MR. VAUGHN: Mr. Chairman, some weeks ago, in
15 the absence of a plan to present to the people of this
16 Conference, we accepted a request of the American Water
17 Works Association to prepare and present a paper at their
lS section last week, which we did, and that paper is now in
19 the public domain and it is permissible to use it wherever
20 desired.
21 I will not read this entire paper. I would just
22 make a few remarks and read my conclusions, and request
23 that the paper in its entirety including tables and charts
24 be included in the record for whatever purpose.
25 MR. STEIN: Without objection this will be done.
(Mr. Vaughn's paper follows in its entirety.)
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800
STATUS OF WATER QUALITY AT THE SOUTHERN END OF LAKE MICHIGAN
Presented for the Record at the Four-State Pollution Conference at
Chicago, Illinois
March 25, 1971
Prepared for the Bureau of Water
Department of Water & Sewers
by
James C. Vaughn, Engineer of Water Purification
Philip A. Reed, Filtration Engineer V
City of Chicago
Department of Water & Sewers
Richard J. Daley, Mayor
James W. Jardine, Commissioner
Raymond D. Johnsos Richard A. Pavia
Deputy Commissioner for Water Deputy Commissioner for Water & Sewers
John B. W. Corey
Chief Water Engineer
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801
STATUS OF WATER QUALITY AT THE SOUTHERN END OF LAKE MICHIGAN
Presented at the 62nd Annual Conference of the Illinois Section
of the American Water Works Association
March 18, 1971
Prepared for the Bureau of Water
Department of Water & Sewers
by
James C. Vaughn, Engineer of Water Purification
Philip A. Reed, Filtration Engineer V
City of Chicago
Department of Water & Sewers
Richard J. Daley, Mayor
James W. Jardine, Commissioner
Raymond D. Johnsos Richard A. Pavia
Deputy Commissioner for Water Deputy Commissioner for Water & Sewers
John B. W. Corey
Chief Water Engineer
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802
STATUS OF WATER QUALITY AT THE SOUTHERN END OF LAKE MICHIGAN
This report on pollution of Lake Michigan and its tributary basin will be
similar in most respects to those presented previously. In general the story is
one of continuing improvement in water quality. However, increases in concentra-
tion of certain constituents make one anxious for the future. On the whole, the
record as summarized here suggests that gains have been made in improving water
quality of Lake Michigan, permits one to infer that further gains are possible,
and at the same time points out the directions in which gains in quality are
necessary. It provides grounds for hope, but not for complacency.
For orientation, Figure 1 locates Chicago with respect to major features
of the southwest part of Lake Michigan. The City, its intakes, and its treatment
plants are located between the Calumet industrial area and what is often called
the North Shore. Reference will be made to both areas later.
The next several figures describe certain parameters important to operation
of the South Water Filtration Plant (SWFP). Figure 2 demonstrates that the
bacteriological quality of the raw lake water continued to improve during 1970.
Previous improvements have often been followed, one can see, by deterioration,
but the fact that the most recent improvement has continued for three years
provides ground at least to hope that it will be permanent.
Figures 3, 4, and 5 illustrate the data in Table 2. Here again is continued
improvement. As Figure 3 shows, during 1970, both the number of "oil refinery"
odor days and of odor periods are much less than the corresponding values for 1969.
Similarly, in Figure 4, one can see clearly that the ammonia nitrogen
concentrations associated with hydrocarbon odors have continued to decline. These
two parameters (odor and ammonia nitrogen) are important for their effect on plant
and operating costs, since they profoundly affect the amounts of activated carbon
and of chlorine required for proper treatment of the water.
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803
It will come as no surprise by now to see that Figure 5 demonstrates that
in fact the maximum activated carbon dosage required for treatment of hydrocarbon
odors decreased during 1970 to a value below any previous one shown on the figure.
Figures 6 through 9 contain selected data related to water quality in the
Calumet industrial region, south of Chicago. Figure 6 is a map on which are
indicated water system intakes, standard sampling points, and the principal
waterways which connect to Lake Michigan. It is interesting to note at this time
some recent variations in parameter values at certain points. At Point 1, for
example, the cyanide values usually run less than 0.1 ppm. On January 12, 1971,
the value was 0.206 ppm and on February 4, 1971, the value was 0.202. At Point 9
the cyanide values have ranged from 0.228 ppm to 0.447 ppm. Point 13 on the
Indiana Harbor Ship Canal (IHSC) is below (in the direction of flow) the outfalls
of two municipal waste treatment plants. The ammonia nitrogen values of samples
taken at Point 13 often fall in the 3.0 - 8.0 ppm range. Some recent Nt^-N values
at this point are: February 4, 1971, 12.0 ppm; February 9, 1971, 11.0 ppm; and
February 18, 1971, 14.0 ppm. These values indicate the discharge of inadequately
treated wastes near these sampling points.
On Figure 7 one sees annual values for average coliform MPN at the mouth of
the IHSC and the mouth of the Calumet River. Here again, coliform MPN's have been
decreasing for three years.
The picture in Figure 8 is somewhat different. The annual average ammonia
nitrogen at the mouth of the Calumet River was near its 20-year peak in 1967 and
1968, but has decreased significantly in 1970. In the upper curve, the ammonia
nitrogen at the mouth of IHSC, which had actually been above the scale on the
chart in 1968 and 1969, has decreased noticeably. The values at the mouth of the
IHSC in 1970 are far higher than most historical ones, and certainly far higher than
one would wish to see, but at least there has been a relative improvement.
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804
In Figure 9 one notices that phenol concentrations at the mouth of the IHSC
have decreased somewhat in 1970.
Figures 10, 11, and 12 illustrate, in part, those changes in water quality
which should cause concern. As Figure 10 demonstrates, nutrient concentrations
are and have long been high enough to permit nuisance algae growths. The data
collected in 1969 suggested that numbers of plankton might be starting to
decline, but the data for 1970 contradict this interpretation. As the eye looks
over this bar chart, it automatically tends to see two continuous curves. The
annual averages would lie along a curve which tends to increase toward the right,
at first gradually, then more steeply. Examination of the bars for the maximum
day produces an effect which is generally similar but much more pronounced.
One is strongly tempted to conclude that the decrease in 1969 was merely a
statistical randomness of the kind one should expect in a curve which is increasing
at an exponential rate.
On examining determinations of phosphate in Lake Michigan water at Chicago,
one finds a possible explanation for the difference between 1969 and 1970 data.
Tabulated below are selected points from distributions of total phosphate for
the last three years:
PERCENTAGE POINTS OF DISTRIBUTION
Year 5% 50% (median) 95%
1968
1969
1970
0.01 ppm
0.01
0.03
0.05 ppm
0.04
0.06
0 . 14 ppm
0.12
0.23
A few other statistics are significant. The arithmetic average concentration
for total phosphate in 1969 was 0.05 ppm; in 1970 it was 0.06 ppm. In 1969, 60% of
determinations were above 0.04 ppm; in 1970, 85% have been above this value.
When one compares the data with the value of 0.03 ppm which is often quoted
as the threshold above which nuisance algal blooms may occur, an even more
depressing set of figures emerges. In 1968, 80% of determinations were above this
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805
limit. In 1969, 70% were higher. In 1970, 93% were higher.
Either the reduction in phosphate observed in 1969 was illusory and
merely a product of chance, or the ground gained in 1969 has been lost, and more
along with it. Whatever interpretation is correct, data collected at Chicago
provide no basis at present for asserting that any improvement, i.e. reduction,
in phosphate levels of Lake Michigan has occurred. On the contrary, they
suggest an increase of about 50% in the quantities of phosphorus entering the Lake.
One peculair aspect of these data becomes evident when one plots their size
distributions. In 1968 and 1969 the distributions were skewed to the right;
that is, there were more high values than would be expected from sampling in a
lake at equilibrium with respect to phosphate concentration. This could be
caused by irregular large inputs, by inadequate mixing of waters receiving
constant inputs, or perhaps for other reasons. In the 1970 data, this skewness
has been reduced. This suggests that the Lake is tending to approach equilib-
rium at its present concentration of phosphate. If this interpretation is correct,
there is reason for great concern over the future of the Lake in this region.
It would imply that one should expect nuisance algal growth, blooms, taste and
odor problems, and perhaps even periodic deoxygenation of parts of the Lake until
mixing with the deeper waters plus whatever processes may cause deposition in
sediments have reduced the concentration of dissolved phosphate below whatever
level is critical for Lake Michigan.
Surveys of Lake Michigan near Chicago
Figure 11, taken from the City's third report to this conference, represents
the trend of chloride and sulfate concentrations over the period 1860-1960. It
is worth noting that it shows the same sort of exponential increase in concentra-
tion as was suggested earlier in the discussion of plankton numbers.
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806
Portions of these curves, together with straight-line trends based on
a simpler method of interpretation.are shown in Figure 12. As suggested in
the third report, the sulfate concentrations continue to lie between the two
projections, while the chloride concentrations remain near the straight line.
Both have increased. Perhaps more significant, however, is the fact that
here again the variation has begun to resemble more closely that which one
would expect in sampling from an equilibrated system.
Figure 13, based principally on data in Table 4, may appropriately
conclude our discussion of data collected at Chicago water works intakes.
It illustrates, in terms of raw water odors and carbon usage, the improvement
that has taken place in one important characteristic of Lake Michigan at
Chicago. During 1970, odors were less frequent and less severe. On only one
day, April 20, 1970, was it necessary to feed more than 30,000 Ib of carbon.
This contrasts with ten days in 1969, and an average of 17 days per year for
the last 10 years. Further confirmation of improvement in raw water quality
will be noted if one examines Tables 3, 6, 7, and 8. Whatever may be in store
for the future, there is no denying that from the plant operator's point of
view, there has been improvement recently in the quality of raw water.
Turning now to measurements over a larger area, let us consider in
Figures 14-17 some of the data collected in our lake sampling programs.
The limits on the chart are those originally set by the Illinois Sanitary Water
Board for the open waters of Lake Michigan, and have received the approval of
the federal government. Clearly, at nearly every location covered by these
surveys, the phosphate concentration increased above the concentrations found
in 1969. At one point (8N) no change was observed. Clearly, too, concentra-
tions at all points were above the annual average concentrations in the
relevant Environmental Protection Agency (EPA) standard.
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807
In Figure 15, plotted in the same manner and showing average ammonia
nitrogen concentrations, there has been a small decrease in general compared
to 1969 measurements, although concentrations in general are equal to or
above the maximum annual average permitted by the federally-approved EPA
standards.
Figure 16 compares data for 1969 and 1970 on total and fecal coliform
organisms at the same locations. Obviously, even taking the logarithmic
nature of the scale into account, there has been a sharp decrease at every
point, except at Point 7N off Waukegan, as there have been decreases at
locations mentioned earlier.
Figure 17 illustrates average phosphate concentrations for surveys
during the year along the shore of the lake south of the area shown in
Figures 14, 15, and 16. Here phosphate concentrations at all points, except
3S at the mouth of the Calumet River, have declined slightly. All are above
the maximum annual average concentration of EPA standard, and most of the
averages are above the higher limit for daily values.
EPA Standards
Table 5 summarizes results of tests made for six years on 17 of the
parameters in the EPA standard for open waters of Lake Michigan. For each
fraction, the numerator is the number of days on which the standard was exceeded;
the denominator, the number of days for which tests were made. Data for
1965-1969 have been reduced to annual averages. The increases in permissible
concentration for chloride, sulfate, and filterable residue incorporated into
the EPA standard were assumed to take effect at the start of 1970.
In the main, these data confirm what has been said earlier. Changes in
bacteriological and most chemical parameters in 1970 suggest improvement in
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808
water quality of the Lake. It is interesting to note that chloride concentra-
tion which exceeded the 1965-1969 standard only once in five years, has
exceeded the more generous 1970 standard six times. Sulfate concentration,
which never exceeded the 1965-1969 maximum daily concentration, has exceeded
the larger permissible maximum daily concentration 22 times so far in 1970.
Filterable residue, which exceeded the 1965-1969 permissible concentration
only three times in five years, has exceeded a larger permissible concentra-
tion 66 times in 1970. And, of course, total phosphate, whose permissible
concentration remains unchanged at 0.04 mg/1 for daily samples, and which
exceeded this concentration nearly half the time in 1965-1969, is now ex-
ceeding that concentration about 72% of the time.
Following the report of finding mercury in the Lake St. Clair, Port Huron
and Sarnia Area, government, state, and municipal laboratories began testing
in various areas of the Great Lakes system. At the present time a total of
over 1000 tests have been run by the City of Chicago's Water Purification
Laboratory covering samples taken from Lake Michigan from the Wisconsin Line
to the Michigan Line. The surveys included the North Lake Survey, South Lake
Survey, North Harbor Survey, Mouth of the Chicago River, Navy Pier and the
Calumet-Indiana Harbor Ship Canal Survey. In addition, many raw water samples
were tested at Central, South, and Hammond intakes and outlet (treated) waters
were tested from Hammond, 73rd and 79th Street outlets of SWFP, and North and
Central outlets from CWFP. All samples were below the 0.1 ppb value for mercury.
Tests prior to August 21, 1970 were reported on a detectable limit of 0.5
ppb. Tests on and after August 22 through December 1970 (275 determinations)
reported mercury below 0.1 ppb, which is less than 0.1 microgram per liter.
Therefore, based on our tests, the southern end of Lake Michigan can be stated
to be free of mercury contamination at the present time.
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809
Costs
By observing Table 6 it can be seen that the required dosage of
activated carbon, coagulants and chlorine,while less in 1969 than in the
previous five years,was remarkably reduced in 1970. There have been a number
of days, even weeks, in which no activated carbon was used at either plant.
While the average coagulant dosage for 1970 was 10 ppm, there were periods of
2.5 to 5 ppm dosages. The chlorine demand of the water has often been less
than 1.0 ppm for the first time in the history of the South Water Filtration
Plant. All of this is reflected in the costs of chemical treatment as shown
in Table 7. While there have been steady increases in the prices paid for
chemicals, the total cost of chemical treatment had steadily declined as
shown in Table 8.
Conclusion
From the plant operator's viewpoint there has been a measurable and
continued improvement in water quality of Lake Michigan at Chicago. This
improvement started in 1969 and has continued through 1970, resulting in
considerable reduction in difficulty and cost of water treatment. Most of the
measured parameters of water quality have shared in this improvement.
Two sorts of water quality parameters, however, do not fit this pattern.
One group, related to the burden of dissolved solids, has showed a continuous
increase in concentration, perhaps even at an increasing rate. The other
group, consisting of algal nutrients, shows no improvement. In the case of
phosphate, there is evidence that the improvement observed in 1969 has been
lost, and that further increases in phosphate concentration have occurred in
1970. Furthermore, it may at least be conjectured that concentrations of
phosphate in the relatively shallow waters of Lake Michigan from which water
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810
supplies are drawn are tending toward an equilibrium concentration which
is well above the threshold concentration for nuisance algal growth.
The City of Chicago has always takpn *n aggressive position in
abating pollution of the Southern end of Lake Michigan and in maintaining
the best possible quality of water supplied to the consuming public. An
early step in this direction was the establishment in 1888 of what is now
known as the Metropolitan Sanitary District of Greater Chicago for the
purpose of taking Chicago's sewage out of Lake Michigan. This has been
accomplished. Again in 1924 the Water Purification Division was
established to keep tight control over Water Quality. (Since 1923 there
has not been a single death from Typhoid fever in Chicago that is
attributable to its water supply). Regular surveys of the Southern end
of Lake Michigan and its tributaries have been carried out since 1926.
Chicago's reports on Water Quality have been the basis of may conferences
and enforcement acts.
The City recently passed an ordinance banning the use of Phosphates
in detergents sold in the City after July 1, 1972. The Mayor of Chicago,
the Honorable Richard J. Daley, said in a T.V. interview on March 11, 1971,
"The use of Treatment chemicals in Chicago's water supply has been sub-
stantially reduced during the past year (1970). However, this doesn't
mean the lake has been saved, but the trend is in the right direction".
However, Chicago will continue its policy of intensive surveillance over
the quality of water in its Southern end of Lake Michigan.
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-------
815
TABLE 6
Annual Consumption of Activated Carbon,
Coagulants (Alum, Ferrous Sulfate), and Chlorine
1965-1970
Year
1965
1966
1967
1968
1969
1970
Total
Activated
Total Ib.
3,094,606
4,678,661
4,455,273
4,876,309
2,542,600
1,535,500
21,182,949
Average 3,530,491
Carbon
Ib/milgal
23
33
32
33
18
11
25
Coagulants
Total Ib.
14,279,870
16,445,820
15,778,872
15,907,820
14,701,900
12,105,800
89,220,082
14,870,014
Ib/milgal
104
116
112
109
104
84
105
Chlorine
Total Ib.
2,797,986
3,518,720
3,388,261
3,215,810
2,969,600
2,571,000
18,461,377
3,076,896
Ib/milgal
20.4
24.8
24.0
21.3
21.0
17.8
21.6
Total Water
Treated
(milgal)
136,895
142,084
141,107
146,166
141,779
144,826
852,857
Bureau of Water, Department of Water and Sewers, City of Chicago
-14-
-------
816
TABLE 7
Summary of Costs: Activated Carbon,
Coagulants (Alum, Ferrous Sulfate), and Chlorine
1965-1970
Activated Carbon Coagulants Chlorine
Year
1965
1966
1967
1968
1969
1970
Total
Total
$ 243,055
361,222
368,914
415,789
224,134
135,496
$1,748,610
$ 291,435
$/milgal
$1.78
2.54
2.61
2.86
1.58
0.93
$2.05
Total
$ 268,807
303,788
293,547
304,206
263,900
236,621
$1,670,869
$ 278,478
$/milgal
$1.96
2.14
2.08
2.07
1.86
1.63
$1.96
Total
$122,776
162,471
167,048
146,122
143,098
126,275
$867,790
$144,631
$/milgal
$0.90
1.14
1.18
1.00
1.01
0.87
$1.02
Bureau of Water, Department of Water and Sewers, City of Chicago
-15-
-------
817
TABLE 8
CONTRACT PRICES PER TON
Central & South Water Filtration Plants
1965-1970
Chemical
Year Alum (Soln)
1965 $39.07
1966 40.55
1967 41.85
1968 43.45
1969 43.75 *
1970 43.93 *
* average
Carbon
$156.18
156.70
166.60
178.00
173.00 *
173.00 *
TOTAL CHEMICAL COSTS
Central & South Water Filtration
1966-1970
Year Pump age /mil gal
1966 391,682
1967 393,656
1968 388,125
1969 385,775
1970 391,814
Total $
2,394,888
2,466,374
2,299,421
2,177,808
2,039,573
Chlorine
$96.74
95.20
97.20
93.40
95.40 *
98.50 *
Plants
$/mil gal
6.12
6.27
5.92
5.65
5.21
Bureau of Water, Department of Water and Sewers, City of Chicago
-16-
-------
818
FIGURE 1
WISCONSIN
ILLINOIS
WEST SHORE OF SOUTHERN PORTION OF LAKE MICHIGAN,
SHOWING DISTANCES BETWEEN MOUTHS OF INDIANA
HARBOR SHIP CANAL AND CALUMET RIVER AND
VARIOUS WATERWORKS INTAKES.
51 MILES
WAUKEGAN
NORTH CHICAGO
GREAT LAKES
LAKE FOREST
FORT SHERIDAN
HIGHLAND PARK
LAKE COUNTY
COOK COUNTY
LAKE
MICHIGAN
OLD TWO-MILE CRIB
C.Wf-R
68th ST. 8
DUNNE CRIBS
S.W.F.R
N
DEPARTMENT OF WATER 8. SEWERS
BUREAU OF WATER
CITY OF CHICAGO
JANUARY 31- I96B
-------
819
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FIGURE Z
-------
820
ABNORMAL "OIL REFINERY"
TYPE ODOR PERIODS
SOUTH WATER FILTRATION PLANT INTAKE
1950 - 1970
ISOr-
125
Q iOO
O
cr
LJ
Q_
UB»
s
75
LL.
O
o:
50
25
TOTAL DAYS ODORS
OCCURRED EACH YEAR
ODOR PERIODS EACH YEAR
1950'
DEPARTMENT OF WATER A SEWERS
BUREAU OF WATER
CITY OF CHICAGO
• ^ "I
YEAR
FIGURE 3
-------
821
FIGURE 4
MAXIMUM AMMONIA NITROGEN
DURING ABNORMAL "OIL REFINERY1'
TYPE ODOR PERIODS
SOUTH WATER FILTRATION PLANT INTAKE
I960 - 1970
0.7r
0.6
£ 0.5
Q.
Q.
LU
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FIGURE 5
MAXIMUM ACTIVATED CARBON
DOSAGE DURING ABNORMAL
"OIL REFINERY" TYPE ODOR PERIODS
SOUTH WATER FILTRATION PLANT INTAKE
I960 - 1970
822
I200r
1100-
1000-
900-
800
700
600 -
500-
40O
300
20O
100
1950
DEPARTMENT Of WATER & SEWERS
BUREAU OF WATER
CITY OF CHICAGO
'1955 I960
YEAR
1965
< I T
1970'
-------
823
WEEKLY POLLUTION SURVEYS - LOCATION OF SAMPLING POINTS
O 68 +h ST. CBIB
O
79th ST.
SAMPLING POINTS
SOUTH mm FILTRATION NJkNT
92n4 ST.
CITY OF CHICAGO
DEPARTMENT OF WATER AND SEWERS
FIGURE 6
.UtUE IH/-0 ttr
-------
824
o
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O
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ANNUAL AVERAGE COLIFORM
ORGANISMS PER 100 ml.
WEEKLY SANITARY SURVEYS
1950 "1970
MOUTH OF INDIANA HARBOR
SHIP CANAL-DICKEY RD. BRIDGE
MOUTH OF CALUMET
'RIVER-92nd ST BRIDGE
T I T
' '
'|9701
DEPARTMENT OF WATER • SEWERS
BUREAU OF WATER
CITY OF CHICAGO
YEAR
FIGURE 7
-------
825
ANNUAL AVERAGE AMMONIA NITROGEN
WEEKLY SANITARY SURVEYS
1950-1970
7.46
E
Q.
CL
UJ
8
Ct
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x
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3
s
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4.0
3.0
2.0
1.0
MOUTH OF INDIANA HARBOR
SHIP CANAL-DICKEY RD. BRIDGE
MOUTH OF CALUMET
RIVER-92nd ST BRIDGE
i95o>—I—i I
rises'
DEPARTMENT OF WATER a SEWERS
BUREAU OF WATER
CITY OF CHICAGO
YEAR
FIGURE 8
-------
826
ANNUAL AVERAGE PHENOL
WEEKLY SANITARY SURVEYS
1950-1970
© INDIANA HARBOR SHIP CANAL SAMPLING AT CANAL ST.
BRIDGE (1950-1959) AND DICKEY RD. BRIDGE (1960-1967)
©CALUMET RIVER SAMPLING AT 92"4 SI BRIDGE
(1950-1967)
0.25
0.20
Q.
0.
Q_
Ld
a:
£
^0.10
0.05
0.00
MOUTH OF INDIANA HARBOR
SHIP CANAL (D
MOUTH OF CALUMET RIVER
1 i r
1950
DEPARTMENT OF WATER A SEWERS
BUREAU OF WATER
CITY OF CHICAGO
1 I I
YEAR
' ' •
FIGURE 9
-------
827
o:
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CL
CO
5
CO
a:
o
o
QL
o
PLANKTON
MICROORGANISMS PER ml
SOUTH WATER FILTRATION PLANT INTAKE
XO.OOOr—1
16,000 r-
1950 - 1970
DEPAMTMCNT OF WATER A SEVEN*
BUREAU Of WATER
CITY OF CWCAfO
YEAR
FIGURE K>
-------
828
•I&4,1.',1 '.' ' M ' ' ' ' I-1 %
''*:,. •'*!•. • •&
Ld
S
(O
CD
5
35
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-------
30
829
45 YEAR RECORD OF CHLORIDE AND SULFATE
INCREASE AT DUNNE CRIB
— MAX. MONTHLY AVG.
X AVG. FOR YEAR
— MIN. MONTHLY AVG.
25
E 20
o.
Q.
Q
UJ
15
10
Oo
1920
1930
1940 I95O
YEAR
I960
1970
FIGURE 12
-------
830
40-
MAXIMUM ACTIVATED CARBON USAGE
SOUTH WATER FILTRATION PLANT
1958-1970
NO OF DAYS OVER 30,000 Ibs USAGE
(-800 MAXIMUM CARBON DOSAGE
•••• MAXIMUM THRESHOLD ODOR
35- \-700
UJ
I
o
o
Q.
s
en
UJ
§
V)
30-^1-600
UJ
25-o
-------
831
NORTH SHORE LAKE SURVEY
ANNUAL AVERAGE
I968H969-I970
PHOSPHATE
PPM.
«0*TM CHICACO
6ACAT LAKES
TftAMMNC
CENTER
COOK COUNTY
•EMLWOMTH
WILUCTTC
I I I I I I I I I I I I
0 .Ol .OZ .03 .04 .OB O« .OT .OC .Ot .K) .11 .It
ANNUAL
AVER ACE
LMIT
SINGLE DAILY VALUE
OR AVEMA8C LIIMT
WILWN Hit
CMB
\ >• OfVtII
r\ . CKIf
FIGURE 14
KATCH QUALITY SUftVCILLANCC SfCTON
-------
832
NORTH SHORE LAKE SURVEY
ANNUAL AVERAGE
1968-1969-1970
AMMONIA NITROGEN
PPM.
NORTH CHICASO/ f
SRttT LAKES
fMMAL THANH MS
CENTER
4N
RESTRICTED
AREA
HIGHLAND
PARK
LAKE_ COUNTY
COOK COUNTY
HUBtARO
WOODS
0 .01 .02 .03 .04 .09 .09 .07 .O« .00 .10 .11 .It
SIN9LE DAILY VDUOJE
OH WCRA«E LIMIT.
ANNUAL
AVERAGE
LIMIT
WILSON 4/C
cmi
STATUTE MILES
FIGURE 15
WATER QUALITY SURVEILLANCE SECTION
-------
833
I
NORTH CHtCAtO/ 0
CRCAT LAKES
NAVML TRAMHNS
CENTER
LAKE BLUFF
LAKE FOftCST
LAKt_ COUNTY
COOK COUNTY
NORTH SHORE LAKE SURVEY
ANNUAL AVERAGE
TOTAL COLIFORM S FECAL COLIFORM
NO/100 ml.
,970 LEGEND
MAXIMUM
NUMKM
ARITHMETIC '
AVERAGE
i
TC FC
••--I9W AVERAOC
TC • TOTAL COLIFORM M.F.
FC« FECAL COLIFORM M.F
SINGLE DAILY VALUE
OR AVERAGE LIMIT
K
ANNUAL AVCMA6C LIMIT
n
K
Q
2N I 3N I ION I 9N I 8N
DIRECTION
5N ! 6N |7N
WAUKEGAN.
OF TRAVEL
FIGURE 16
WATER QUALITY SURVEILLANCE SECTION
-------
d34
SOUTH LME SURVEY
AMMUAL AVERAGE
I9S8-1969-1970
PHOSPHATE
fj&i&Bi—
i&\SWWI ~—
0904 O« XM JO Jt .14 .» Jt .SO
LIHTT.
LEOCNO
r-n—r™i—r-i
FIGURE 17
-------
835
1 J, C. Vaughn
2 MR, VAUGHN: In the past 3 years, the lake has
been getting better in many ways, and generally quite
better. The chlorides continue to increase; the sulphates
continue to increase, greater than the projected rate.
The phosphates and the nitrogen compounds continue to
increase and, of course, the total dissolved solids that
are reflecting the chlorides and sulphate increase have
continued to increase and the plankton counts continue to
increase, and we still have the year-round plankton
11 nuisances,
12 I have, in the face of continued rise in chemical
13 cost — the costs of chemicals purchased — the total
chemical costs have steadily declined — gone down from
a million gallons in 1967 to $5*21 in 1970,
16 So I will now read my conclusion: From the
17 plant operator's viewpoint there has been a measurable
and continued improvement in water quality of Lake Michigan
at Chicago, This improvement started in 1969 and has
20 continued through 1970, resulting in considerable reduction
2i in difficulty and cost of water treatment. Most of the
22 measured parameters of water quality have shared in this
23 improvement,
24 Two sorts of water quality parameters, however,
25 do not fit this pattern. One group, related to the burden
-------
836
1 J. C, Vaughn
2 of dissolved solids, has showed a continuous increase in
concentration, perhaps even at an increasing rate. The
other group, consisting of algal nutrients, shows no
c improvement. In the case of phosphate, there is evidence
5 that the improvement observed in 1969 has been lost, and
7 that further increases in phosphate concentration have
occurred in 1970. Furthermore, it may at least be conjec-
9 tured that concentrations of phosphate in the relatively
10 shallow waters of Lake Michigan from which water supplies
11 are drawn are tending toward an equilibrium concentration
12 which is well above the threshold concentration for
nuisance algal growth.
The city of Chicago has always taken an aggressive
15 position in abating pollution of the southern end of Lake
16 Michigan and in maintaining the best possible quality of
17 water supplied to the consuming public. An early step in
lg this direction was the establishment in 188& of what is
19 now known as the Metropolitan Sanitary District of Greater
20 Chicago for the purpose of taking Chicago's sewage out of
21 Lake Michigan. This has been accomplished. Again in 1924
22 "the Water Purification Division was established to keep
23 tight control over water quality. (Since 1923 there has
24 not been a single death from typhoid fever in Chicago that
25 is attributable to its water supply.) Regular surveys of
-------
837
1 J. C. Vaughn
2 the southern end of Lake Michigan and its tributaries have
3 been carried out since 1926. Chicago's reports on water
4 quality have been the basis of many conferences and enforce-
5 ment acts.
6 The city recently passed an ordinance banning the
7 use of phosphates in detergents sold in the city after June
g 30, 1972. The Mayor of Chicago, the Honorable Richard J.
9 Daley, said in a TV interview on March 11, 1971: "The use
10 of treatment chemicals in Chicago's water supply has been
11 substantially reduced during the past year (1970). However,
12 this doesn't mean the lake has been saved, but the trend is
13 in the right direction."
14 However, Chicago will continue its policy of
15 intensive surveillance over the quality of water in its
16 southern end of Lake Michigan.
17 Thank you, Mr. Chairman.
lg MR. STEIN: Thank you.
19 By the way, even though the hour is late, I am
20 just going to take a minute, because I want to state my
21 candid opinion. I know you are all involved in the thermal
22 questions. But I think this is possibly as significant a
23 report as we have had in this conference. This is
24 what I want to point out, and I know Mr. Vaughn calls
25
-------
838
1 J. C. Vaughn
2 them as he sees them, and sometimes he has come in here,
3 as you may know, with very dismal reports. He says, in
4 general, the story is one of continuing improvement in
5 water quality, but he points out some --
6 MR. MAYO: Excuse me, Mr. Chairman, the reporter
7 is having difficulty because of the conversation.
8 (Whereupon, Mr. Stein sounded the gavel.)
9 MR. STEIN: — he has pointed out some very
10 specifics we have to get at, but I think his essential point
11 is the most encouraging one.
12 When we started this program, we all had our
13 fingers crossed and we were not sure we could turn the
14 tide and we could make this go» I remember at one of
15 our progress meetings, Mr. Vaughn came and it was at the
16 time we had one of the popular Broadway plays "The
17 Impossible Dream," and we didn't know whether we had an
1$ impossible dream or not.
19 But Mr. Vaughn, I think, with your painstaking
20 report — I think while we certainly are going to have to
21 do a lot better because you pointed out where we are not
22 catching np — at least in the main it looks like we are
23 on the right track, and we are improving the lake,
24 This is encouraging indeed. This is something I want
25 to thank all of you people here for. This is really —
-------
839
,
MR. VAUGHN: One little facet of the thing which
~ is not specific, on a recent trip to the crib in September,
, my assistant reported he was able to see to a depth of 15
e feet for the first time in 30 years.
x
H
n
TC
30
22
23
24
25
J. C. Vaughn
Thank you
.
MR. MILLER: Mr. Chairman, I would like to take
this opportunity to thank Mr. Vaughn and commend him for
these reports. As he knows, and many of the others here
also know, the work of the Chicago Water Department was
pretty much the foundation of the Technical Committee's
report from the 196$ conference, and the basis for the
standards that were proposed by the Technical Committee,
And it certainly is indeed gratifying to know that much
of the work that has been done is now producing results
and sho\*ing improvement at the South District filtration
plant intake, and I certainly commend him for these
reports.
I look at the tables in the back and it is most
interesting to me to compare these, and while I realize
these are from the Water Quality Surveillance Section and
not from the Chicago Water Department, I believe — is this
correct?
MR. VAUGHN* The Water Quality Surveillance
Section is a part of our Department.
-------
840
, J. C. Vaughn
2 MR. MILLER: This is a part of yours0 That the
3 phosphates and the nitrogen and ammonia nitrogen and the
• coliforms, when you compare them up and down the lake, would
r indicate that even some of those that are quite a ways north
5 compared as far as Waukegan are as high or higher than those
7 in some of the southern part of the lake, so that I think
3 while we have done a job in the southern part of the lake
o that there still remains much to be done, and that certainly
10 these results are indicative that we have a problem in the
11 lake as a whole.
12 MR0 STEIN: Thank you, again.
,~ I want to join with that, because if it weren't
!• for the Chicago Water Department surveys and the data that
15 they had, we never could have mounted this program or had
16 this cleanup in Lake Michigan. I know that while we
17 said this again and again, I have never seen in the litera-
lg ture and the press or anywhere else that you people have
19 gotten the recognition that you should have gotten, because
20 we have found no such data, no such followup, and no such
2i dedicated public servants checking on the water to see the
22 results of what we have done anywhere in the country as
23 we have in Chicago. Tou are indeed to be commended,
24 and if I could give an award for citizens dedicated to
25 clean water and being unsung heroes, you people in the
-------
841
, J. Co Vaughn
the Chicago Water Department would get it.
Thank you very much, Mr. Vaughn,
5
MR. VAUGHN: Thank you.
MR. CURR.LE: I would like to second that, Mr.
x Chairman,, I think that Mr. Vaughn1G reports have been of
7 inestimable value to the Conference 3nd we are happy to
H have him here.
MRo STEIN: Thank you.
, ~ Are there any other citizens whom we iiave to hear
-,-, from, having reports, or outside groups other than these
, 2 technical committees who have been waiting?
,- MR0 FRANCOS: Mr. Chairman, I have a statement
from the city of Racine I would like to have entered into
,(. the record.
MR. STEIN: Without objection, this will be done.
,„ (The above referred to statement follows in its
entirety.)
19
20
21
22
23
24
25
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842
city of RACINE...racine, Wisconsin
•x-
DEPARTMENT OF HEAITH G. P. Ferrazzano, M.D.
March 18, 1971
City of Racine Statement to the Lake Michigan Enforcement Conference
March 23 S 24, 1971. Sherman House, Chicago, Illinois.
The City of Racine is concerned and interested in all discharges
that enter Lake Michigan. The public awareness of mounting environmental
problems in the United States, and specifically the deteriorating effect
of waste entering Great Lakes directly, affects the people in the City of
Racine. The efforts of individual citizen and citizen groups to combat
the growing problems of water pollution has the City of Racine's support,
for this public awareness is most welcome and much needed. Public con-
cern, however, is not enough to overcome pollution problems. It must be
followed by action programs in both public and private sectors. The City
of Racine has been active in proceeding with pollution abatement programs
that follow in the lines of criteria that have been established by the
state and federal governments. We shall, in the future, enter into pollu-
tion abatement programs that will comply with the latest environmental
standards that will be adopted by the state and federal governments. To
date our concern and dedication to environmental protection is shown by the
following:
I. Wastewater Treatment
A. Plant
As per the attached orders from the State of Wisconsin, Department
of Natural Resources, the City of Racine, Wisconsin is to place in
operation by December 31, 1972, facilities to adequately treat all
waters tributary to the sanitary sewer system. Such treatment shall
provide for a minimum of 85 per cent removal of the total phosphorus
tributary to the wastewater treatment plant.
730 Washington Avenue, 53403 City Hall 414-634-7111
-------
843
-2-
In complying with the above order, the City of Racine has taken the
following steps:
1. On March 16, 1970, the City of Racine signed a contract with a con-
sulting engineering firm to prepare a report on the expansion of the
city's wastewater treatment plant.
2. On November 17, 1970, the Common Council of the City of Racine
approved said report and directed the consulting engineers to begin
the preparation of the plans and specifications for the expansion of
the wastewater treatment plant. (See attached Resolution)
3. The proposed enlarged wastewater treatment plant for the City of
Racine is expected to remove in excess of 90 per cent of the sus-
pended solids and 5-day biochemical oxygen demand and 85 per cent of
the phosphorus present in the raw wastewater. The estimated con-
struction cost is $6,400,000.00.
4. It is anticipated that construction will begin in the fall of 1971
with a completion date of December, 1972.
B. Industrial Waste:
As per Federal regulations in regard to Industrial Waste, the City of
Racine has taken the following steps:
1. On May 6, 1969, the Common Council of the City of Racine adopted a
Wastewater Control Ordinance which establishes what type of dis-
charges can or cannot be directed to the wastewater treatment plant.
This ordinance was adopted to prevent any detrimental waste from
entering the plant and thus assuring the proper and efficient operation
of the wastewater treatment plant.
A copy of this ordinance is attached to this report.
2. The latest Federal Regulations also state that where industrial
wastes are to be treated by a proposed project, an equitable system
of cost recovery shall be in force. During the past year, the City
of Racine has established a committee for the prupose of establish-
ing a sewer service charge. It is anticipated that a sewer service
charge will go into effect on January 1, 1972.
II. Sewer Separation
1. Prior to 1935 the City, like most other cities in Wisconsin, relied
on a combined sewer system to carry its sanitary sewage and storm
water to the Waste Water Treatment Plant or Lake.
2. As a result of a sewer separation construction program begun in 1935
only 17% of the City is not served by separate sewer systems at the
present time. With the completion of the 1969 H.U.D. Program involv-
ing the construction of 1.5 million dollars worth of sanitary and
storm sewers, all but 13% of the area in the City will be served by
separate siewer systems.
-------
844
-3-
3. At present a Federally subsidized FWQA Demonstration Program is
underway. This 1.395 Million dollar project will determine the
feasibility of serving the remaining 13% of the area by the use of
screening and air flotation treatment of combined sewer overflows.
4. During the time period when combined sewers were used in the City, it
was required that roof downspouts be connected to the sewer. As the
combined areas are separated, the individual property owners are re-
quired to disconnect their downspouts and direct the water onto the
surface and thus into the storm sewer system.
5. The City of Racine will meet the requirements of the Department of
Natural Resources order dated April 17, 1970, requiring separation
by July 19, 1977, This will be accomplished by separation or by
installation of combined overflow treatment units, provided that
State and Federal Grants are continued at the present level of fund-
ing.
-------
845
Department of natural Resources
Box 450
Madison, Wisconsin 53?Q1
February 27, 1970
BOOT RIVER DRAINAGE AREA
In accordance v;ith the requirements of the June 11, 1963 order, you
were required to submit a preliminary report and schedule for the construction
of adequate facilities in keeping with the State Water Quality Standards and
the recommendations of the Lake Michigan Enforcement Conference. Since that
date, the conference has reconvened and clarified its recommendations.
As a result of the conference, the Department has agreed to amend
the requirements as follows:
1. All effluent discharges to the surface waters of the La:cc
Michigan Basin must have secondary bio-mechanical treatment or equivalent
by December, 1972.
2. All municipalities or industries with a population equivalent
of more than 2,500 persons (C,750 pounds of total phosphorus per year)
shall remove 55 percent of the total phosphorus on an annual basis.
3. Year-round disinfection of all effluents containing pathogens
or their indicator organisms must be provided.
4. A program for separation or control of pollution from combined
sewers and those receiving excessive amounts of clear water must be developed
and completion of the project control facilities must be attained by July,
1977.
While the Department does not order phosphorus removal for cosraunities
under 2,500 population, it does not discourage them from doing so. This
guideline does not preclude the Department from ordering phosphorus removal
where such discharges are causing or may cause over-fertilization of surface
waters.
The attached order properly reflects the modified requirements of the
conference as well as the implementation schedule applicable to your specific
case.
Very truly yours,
Division of Environmental Protection
Thomas G. Frangos
Administrator
Attach.
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846
Department of Natural Resources
Box U50
Madison, Wisconsin 53701
Racine, City of
Findings of Fact
THE DEPARTMENT FINDS:
1. That the City of Racine was issued an order on June 11, 1968 which
required submission of a report and schedule for the separation of regaining
combined sewers and exclusion of clear water fron sanitary severs, and for the
construction of improvements to the treatment facilities including 80 percent
removal of the total phosphorus content of the effluent.
2. That the City has submitted a schedule for sewer separation, plant
Improvements and phosphorus removal.
Conclusions of Law
1. That this Department, having reviewed the matter, has authority
tinder lW-,025 (2) (d), Wisconsin Statutes, to issue an amended order directing
particular owners to secure such operating results toward the control of
pollution of the waters of the state as the Department prescribes, within a
specified time.
2. That the order hereinafter made for separation of combined sewers,-
exclusion of clear water from the sanitary sewers, and construction of improve-
ments to the treatment facilities by the City of Racine is reasonable, p-oper
and necessary for the protection of public rights in Lake Michigan.
Order
XT IS, THEREFORE, ORDERED
1. That the City of Racine complete its combined sewer separation
program by December 1, 1972.
2. That the City of Racine place in operation by December 31 j 1972
facilities to adequately treat all wastes and waters tributary to' the sanitary
sewer system. Such treatment shall provide a minimum of 85 percent, annual
average removal of the total phosphorus tributary to the sewage treatment plant.
3. That the City of Racine subrr.it annual reports to the'Department
beginning Kovec&er 1, 1970 demonstrating progress towards compliance with
provisions 1 and 2 of this order.
Dated at Madison, Wisconsin, this 27th day of February, 1970.
STATE OF WISCONSIN
DEPARTMENT OF NATURAL RESOURCES
For the Secretary
Thomas G. Frangos, Administrate
Division of Environmental Protection
-------
847
f'-
Stale of Wisconsin \ DEPARTMENT 'OF NATURAL RESOURCES
L. P. Vo,,
April 17, 1970
»0< (SO
M,,OISCN, WISCCSSI-i 53701
Kr. George W. Benson
City CUr'x.
R.iclne, V.'lsconsln 53403
Dear Mr. Benson:
Enclosed is a copy of Order No. AB-68-4-21AA which has been amended
to correct a typographical error in the compliance date for completion
of Racine's coabinad se;;er separation program. The incorrect compliance
date of Daceraber 1, 1972 has been changed to July, 1977 to inset the
requirements of the La!;e Michigan Enforcement Conference reconr.-.2r.dations,
Very truly yours,
Divisio£"o>f Environmental Protection
G. Pran303
Administrator
-------
Department of llacural Resources 848
Box 450
Madison, Wisconsin 53701
4B-68-4-21AA
Racine, City pj
Findings of Fact
THE DEPARTMENT FINDS:
1. That the City of Racine was issued an order on June 11, 1968 which
required submission of a report and schedule for the separation of remaining
combined severs and exclusion of clear water from sanitary severs, and for the
eonotructioa of improvements to the treatment facilities including 80 percent
of eh* total phosphorus content of the effluent.
2. That the City has submitted a schedule for sever separation, plant
5 crvJ phoaphorujj removal.
Conclusions of Law
1. That this Department, having reviewed the matter,' has authority
vr.lcr Iii.025 (2) (d) , Wisconsin Statutes, to issue en amended order directins
particular ovncrs to secure such op3ratin3 results toward the control of
pollution of the vatera of the state ao the Department prescribes, within a
tine.
2. That the order hereinafter made for separation of combined severs,
exclusion of clear water from the sanitary severs, and construction of improvo-
tcnta to the treatment facilities by the City of Racine is reasonable, proper
«r.<5 ncceseary for the protection of public rights j.n j,nvc Michigan.
Order
IT IS, THEREFORE, ORDERED:
1. That the City of Racins complete its combined sewer separation
^ ty juij»t 1977.
?. 7h.it tiic City of Racine place in operation by December 31, 1972
f»::Ilttf3 to adequately treat all wastes and waters r tributary to the sanitary
«ev-r i/jtcin. Such treatment shall provide a minimum of 85 percent annual
• T.'J^S rcrovol of the total phosphorus tributary to the sewage treatment plant.
3. That ths City of Racine subnit annual reports to the Department
S<£tr.r.inj J.'ovor.bcr 1, 1970 demonstrating progress towards ccr.?liance vit.h
yr.n-lslcna 1 cr.J 2 of this order.
ct Hidicoa, WioconDin, this 17th day of April, 1970.
STATE 0? WISCONSIN
DEPARTJ-.'iiNT 0? 1LMURAL RESOURCES
For tho Secretary
. .
omas G. Frar.jos, Adr.iinistrt-.tOi- //
ivision of Environmental Protect'i
-------
849
RESOLUTION NO. 305
RESOLVED, that the engineering report submitted by
Consoer, Townsend and Associates on Waste Water Treatment
Facilities be approved and said report be submitted to the
Southed- tern Wisconsin Regional Planning Commission and the
Slate of Wisconsin for approval for State and Federal Aid.
FURTHER R£Sui,VED, that Consoer, Townsend and Associates
.are hereby authorized and instructed to proceed with the prepa-
ration of plans and specifications for the additional Waste
Water Treatment Facilities recommended in the aforementioned
report.
STATE OF WISCONSIN)
)3S
COUNTY OF RACINE )
I, Albert A. Reid, City Clerk for the City of Racine,
Racine County, Wisconsin, DO HLREBY CtJITIFY that the foregoing
is a true and correct co} y of a resolution which was adopted by
the Common Council of the City of Racine under Item 39 of the
meeting lie Id November 17, 19T"U.
Dated this 2nd day of December, 1970,
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850
WASTEWAToSR CONTROL ORDINANCE
and
OPERATING STANDARDS FOR WASTEWATER DISCHARGES INTO
PUBLIC SEWERS, NATURAL OUTLETS or WATERCOURSES
of the
City of Racine, Wisconsin
Water Pollution Control Division
Gary K. Coates, P. E.
Engineer-Manager
2101 S. Main Street
Racine, Wisconsin 53U03
U1U - 633-7709
-------
851
ORDINANCE NO. 11-6?
To create Chapter 12 of the Municipal Code of the City of Racine
relating to the Control of Sewage and Wastewater Discharged into the
Wastewater System of the City of Racine.
The Common Council of the City of Racine do ordain as follows:
Part 1.
Chapter 12 of the Municipal Code of the City of Racine is hereby
created to read as follows:
"CHAPTER 12"
WASTEWATER CONTROL
12.01 Scope. The Wastewater System of the City of Racine includes
all of the sanitary sewers and the Wastewater Treatment Plant and appurten-
ances operated for the treatment and disposal of sewage and wastewater
within the entire area served thereby.
12.02 Purpose. It is hereby determined and declared to be neces-
sary and conducive for the protection of the health, safety and welfare
of the public, to prevent abuse or break down of the wastewater control
system, to obtain the maximum practical reduction of wastes entering the
system, and to protect the receiving waters from pollution and to regulate
the use of all sewers and drains connected to the sanitary sewer system and
the wastewater treatment plant of the City of Racine.
12.03 Policy as to Industrial Waste. It is hereby declared to be
the policy of the City of Racine that industrial wastes shall be accepted
into the sanitary sewers and Wastewater Treatment Plant of the City of
Racine under the following conditions:
(a) Treatment by the City is at less cost than by
the industry.
(b) The wastes are amenable to treatment by the City
either directly or with pretreatment.
(c) Controls are provided so there is no damage to
sewers or treatment plant and wastes can be measured.
(d) The industry pay for the additional actual cost
of treatment.
- 3 -
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852
ORDINANCE NO. 11-69
12.0U Definitions. The following definitions shall apply in the
interpretation and enforcement of this ordinance.
(a) "Biochemical Oxygen Demand" shall mean the quantity
of oxygen utilized in the biochemical oxidation of organic
matter under standard laboratory procedure in five (5) days at
20 degrees Centigrade expressed in milligrams per liter.
(b) "Combined Sewer" shall mean a sewer which receives
storm water, surface runoff, industrial cooling water and
serfage.
(c) "Domestic Sewage" shall mean sewage discharging from
the sanitary conveniences of dwellings (including apartment
houses and hotels), office buildings, factories, commercial
establishments, institutions, and free from storm surface water,
cooling water and industrial wastes.
(d) "Garbage" shall mean solid wastes from the domestic
and commercial preparation, cooking, and dispensing of food,
and from the handling, storage, and sale of produce.
(e) "Industrial Wastes" shall mean any liquid substance
rejected or escaping from any industrial, manufacturing,
trade or business process as distinct from domestic sewage.
(f) "Natural Outlet" shall mean any outlet into water-
course, pond, ditch, lake or other body of surface or ground
water.
(g) "Person" shall mean any individual, firm, company,
association, society, corporation, or group.
(h) "pH" shall mean the logarithm of the reciprocal of
the hydrogen concentration.
(i) "Properly Shredded Garbage" shall mean garbage which
has been sliredded to such a degree that all particles will be
carried freely under the flow conditions normally prevailing
in public sewers with no particle greater than one-half inch
in any dimension.
(j) "Public Sewers" shall nean a sewer in which all owners
of abutting properties have equal rights and is controlled by
the City.
(k) "Receiving Waters" shall mean any public water into
which effluent from any wastewater treatment plant or any
public or private sewer is discharged.
- k -
-------
853
ORDINANCE NO. 11-69
(cont'd)
(1) "Sanitary Sewers" shall mean a sewer which carries
domestic sewage and industrial wastes, and to which storm,
surface, ground and unpolluted cooling or process waters are
not intentionally admitted.
(m) "Sewage and Wastewater" shall mean any combination
of water-carried wastes from residences, buildings, industrial
establishments, institutions, manufacturing plants, processing
plants, commercial establishments, or other places in which
such wastes are produced, together with such ground, surface,
storm or other water as may be present.
(n) "Sewer" shall mean a pipe or conduit for earring
sewage.
(o) "Shall" is mandatory; "May" is permissive.
(p) "Storm Sewer or Storm Drain" shall mean a sewer which
carries storm water, surface water, drainage and unpolluted industrial
water discharges, such as cooling and air conditioning water,
but excludes sewage.
(q) "Suspended Solids" shall mean the dry weight of solids
which are physically suspended or floating in a flow of sewage,
industrial waste, or water which are measureable by laboratory
filtering.
(r) "Wastewater Treatment Plant" shall mean any devices
and/or structures used for the treating of sewage.
(s) "Wastewater Works" shall :aean all facilities for col-
lecting, pumping, transporting, treating and drying of sewage.
(t) "Watercourse" shall mean a channel in which a flow of
water occurs, either continuously or intermittently.
(u) "itogineer-Manager" shall mean the authorized depart-
ment head of the Water Pollution Control Division of the City
of Racine, having supervision of maintenance and operation of
the sewerage system and wastewater treatment facilities of the
City, or his authorized deputy, agent or representative.
12.0$ Unpolluted Waters Prohibited.
(a) No person shall discharge or cause to be discharged,
any storm water, surface water, ground water, roof runoff, sub-
surface drainage which is not contaminated, unpolluted cooling
water or unpolluted industrial process waters to any sanitary
aewer, provided that a storm drain into which such waters and
drainage can be discharged is available at reasonable cost,
and provided further that separation of existing internal com-
-------
854
ORDINANCE NO. 11-69
(cont'd)
bined sewers in any source of industrial waste shall not be
required, except in the case of system replacement or renewal
initiated by the owner of such source.
(b) Storm water and all uncontaminated drainage shall be
discharged to such sewers as are specifically designated as
storm sewers, combined sewers, or to a natural outlet or water-
course approved by the ciigineer-Manager . Industrial cooling
water or unpolluted process waters may be discharged, upon
approval of the itogineer-Manager, to a storm sewer, combined
sewer, natural outlet, or watercourse.
12.06 Prohibited jfaste Discharges . No person shall discharge
or cause to be discharged any of the following described waters or
wastes to any public sewers, natural outlet or watercourse:
(a) Any explosive or flammable solid, liquid or gas,
including but not limited to gasoline, kerosene, benzene,
naphtha, fuel oil.
(b) Any waters or wastes causing a pH lower than 5.0 or
higher than 10.0 at any point in the public sewer or receiving
water .
(c) Any solid or viscous substances in quantities or of
such size capable or causing obstruction to the flow in sewers,
or other interferences with the proper operation of the waste-
water works, including, but not limited to, ashes, cinders,
sand, mud, straw, shavings, metal, glass, rags, feathers, tar,
plastics, wood, underground garbage, lime slurries, chemical
residue, paint residues, etc.
(d) Any waters or wastes containing toxic solids, li
or gasas in sufficient quantity acting either singly or by inter-
action with other wastes to injure or interfere with any waste-
watsr treatment process, constitute a hazard to humans, animals,
or aquatic life, or create a public nuisance.
(e) Any solid, liquid or gas creating a hazard or public
nuisance in the receiving water.
12.07 Conditionally Prohibited Discharges.
(a) No person shall discharge or cause to be discharged into
the sanitary sewers any wastewaters having physical properties and
concentrations of chemical constituents or such other physical and
chemical properties which exceed the standards and limitations es-
tablished by the Board of Standards under Section 12.09 hereof and
adopted by the Common Council..
- 6 -
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855
ORDINANCE MO. 11-69
(cont'd)
(b) Shou.11 any sawage have the characteristics set out in (a)
abov 2, the City may, nevertheless, accept such sewags subject to indi-
vidual agreements which specify pretreatment or controls on rates and
quantities of discharges which, in the opinion of the Engineer-Manager
will protect the wastswater works and wastewater treatment process, or
The City may agree to accept such sewage subject to the payment of
charges for the actual additional costs to the City resulting fro/a the
treatment of such sewage by the City. In making such agreements the
Engineer-Manager shall give consideration to such factors as the quanti-
ties of such wastes in relation to the capacity, flow and velocities in
tne receiving sewers, degree of treatability of the sewage and require-
ments of the public authorities having jurisdiction over discharges f .-can
the City wastewater works. If the Engineer-Manager permits the pretreat-
ment or equalization of sewage flows, the design and installation of tne
plants and equipment for such pretreatment or equalization shall be sub-
ject to review and approval of the Engineer-Manager, and subject t?
the requirements of all applicable ordinances, laws and regulations.
(c) Where preliminary treatment or flow-equalizing
facilities are provided for any sewage, they shall be main-
tained continuously in satisfactory and effective operation
by the owner at his expense.
(d) When required by the Engineer-Manager, the owner of any pro-
perty serviced by the building sewer carrying industrial wastes int> a
public sanitary or public combined sewer shall install a suitable Con-
trol manhole together with s\ich necessary maters and other appurtenances
in the building sewer to facilitate observation, sampling and measure-
ments of the wastes. Such manhole, when required, shall be accessi-bly
and safely located and shall be constructed in accordance with plans
approved by the Engineer-Manager. The manhole shall be installsd by
the owner at his expense, and shall be maintained by him so as ta be
safe and accessible at all times.
(3) All measurements, tests, and analyses of sewage to wnlih
reference is made in this ordinance shall be in accordance with th-.^
latest edition of "Standard Methods for the Examination of Wat-jr and
tfastewater" published by the American Public Health Association.
Measurements shall be made and samples taken at the control manhole
provided. In the event that no special manhole has besn required,
the control manhole shall be considered to be the nearest downstre.-ua
manhole in the public sewer to the point at which the building sawsr
is connected. Sampling shall b
-------
856
ORDINANCE NO. 11 -69
(cont'd)
(f) The Board of Standards shall hear and decide all appeals
by persons affected by any decision of the Engineer-Manager to
accept or reject sewage under the provisions of Section 12.07 of this
ordinance and shall, in the appropriate cases authorize the accep-
tance of sewage under conditions and safeguards in harmony wi th the
t;en
-------
857
ORDINANCE NO. 11-69
(cont'd)
Ui.; inili'd Board for a term expiring on th-a 1st Tuesday in Kay,
r->70; one at-large member for a term expiring on the 1st Tuesday
in May, 1970; one at-lar^e member for a term expiring on the 1st
'''in'sday in May, 1971 5 and one at-large member for a term expirlnr
«:• '.he 1st Tuesday in May, 1972. All subsequent appointments of
to-large members shall be made on the 1st Tuesday in May and shall
be for a term of three (3) years. The term of the Alderman member
shall oe one (1) year} he shall be appointed on the 1st Tuesday in
May; and he shall be a member of the Board only as long as lie con-
tinues to hold his office as Alderman. The Engineer-Manager shall
he a member of the Board so long as he continues to hold his posi-
tion as ^ig:Lneer-Manager . Board members shall receive no corrq:i
-------
858
ORDINANCE NO. 11-69
(cont'd)
(e) Powers and Duties. The Board shall have the following
powers and duties:
(1 ) To adopt guidelines on physical and chemical properties
and characteristics of wastewaters under Sections 12.06 and 12.07 in
relation to ths policies stated in Sections 12.02 and 12.03 of this
ordinance .
(2) To establish standards and limits for the concentration
of chemical constituents and for such other physical and cbflmir.al
properties as may be required for wastewaters discharged into pub] ir
sewers or accepted at the wastewater treatment plant. In setting such
Limits the Board shall take into consideration the purpose and dec] are<:
policy of this ordinance as well as the requirements of public sutho:-ii.\
having jurisdiction over quality of discharges frori city wastewater works,
(3) Approval by Council . The guidelines established, by
the Board under paragraphM~and the standards and limits established
under paragi'aph 2 above shall not become effective until they have been
submitted to the Common Council of the City of Racine and approved by it.
Such guidelines, standards and limits shall, upon approval of the Coranon
Council, be filed in thej Office of the City Clerk of the City of Racir.e
and shall become effective upon such filing.
(U) Appeals . To hear and decide appeals where it is
alleged there is error in any order, requirement, decision or dfitemi na-
tion by the Engineer-Manager in the administration of this ordinance,
the Engineer -Manager shall be disqualified fror> sitting a.s a member '•>*'
the Board in any appeal under this paragraph.
Decision of Board. In exercising its powers under tb: s
ordinance the Board may, in conformity with the provisions of this
ordirance, reverse, or affirm, wholly or partly or may modify the ord-c-r,
requirements, decision or determination appealed from, and make such
order, requirement, decision or determination as ought to be made, mid
to that end shall, have all of the powers of the aigir^er-Manager.
12.10 Penalties.
(a) Notice. Any person foiind to be violating any provision of
this Ordinance shall be served, by the City with written notice statii't/
the nature of the violation and rvoviding a reasonable time limii. for
the satisfactory correction thereof .
(b) Any person who shall continue any violation beyond the
limit provided for in paragraph (a) shall be subject to the penal tirtfi
provided by Section 1 .0? of the Municipal Code of the City of Racine.
(c) Damages . In addition to any penalty provided hereir, an}.'
person violating the provisions of this Ordinance shall becone liab.!-
to the City for any expense, loss or damage sustain**! by tbp City by
reason of such violation.
- 10 -
-------
859
ORDINANCE NO. 11-69
(cont'd)
Part 2.
This Ordinance shalll take effect upon passage and publication.
Passed by the Common Council May 6, 1969
Approved May 8, 1969
Kenneth L. Huck
Mayor
Attest:
George H. Benson
City Clerk
- 11 -
-------
860
OPERATING STANDARDS
FOR
WASTiiMTSR DISCHARGES INTO
PUBLIC S&JriKS, NATURAL OUTLETS
ADOPTED BY BOARD OF STANDARDS
SECTION I. Authority.
The Board of Standards created by Chapter 12 of the Mur.icipal Code
of the City of Racine, in accordance wilb the authority granted by Secti< n
12.09 (e) of that Code, hereby establishes the following guidelines arid
standards for control]ing the characteristics of wastewater which dis-
charges into the public sewers, natural outlets or watercourses of the
City of rtacine.
11. Intent.
In order to obtain and insure the continnod satisfactory operation
cf the Wastewater Treatment Plant at its optimum efficiency consistent
with the purpose and policy of Chapter 12 of said Code, it is necessary to
insure that strong materials not be admitted to the system in sufficient
or slug quantities that would reduce or eliminate the effective operation
cf the system. Strong materials are those which cause the waste to be
prohibited by Section 12.06 of the Code, or which exceed the guidelines,
standards or limitations contained herein or those which in sufficient
quantity or in combinations will, in the opinion of the Engineer-Manager
cause this reduced effectiveness.
ACTION 13]. Prohibited. Waste _Di_p charees.
As prescribed by Section 12.06 of the Municipal Code, no person snail
discharge or cause to be discharged any of the following described waters
or wastes to any public sewers, natural outlet or watercourse:
(a) Any explosive or flammable solid, liquid, or
gas, including but not limited to gasoline,
kerosene, benaene, naphtha, fuel oil.
(b) Any waters or wastes causiiv; a pH lower than
5.0 or higher than 10.0 at any point in the public
sewer or receiving water.
(c) Any solid or viscous substances in quantities
or of such size capable of causing obstruction to
the Dow in sewers, or other interferences with
the proper operation of the wastewater works, in-
cluding, but not limited to, ashes, cinders, sand,
mud, straw, shavings, metal, glass, rags, feathers,
-------
861
OPERATING STANDARDS
(cont'ci)
tar, plastics wood, un ground garbage, lime slurries,
oh optical residue, paint residues, etc.
(i.i) Any wai err, or wastes containing toxin so] ids,
liquids, or gases in sufficient quantity acting
ei i~.'r. =sr singly or by interaction with other wa-u.,:r.
to injure or interfere with any wastewater tr&al-
rvyi! process, constitute a hmard to hunans, animal r.,
or iquatic life, or create a public md francs.
(<>) Any solid, liquid or gas cr^atinp: a na:ar>i c.r
pu' "•]•' nuisance in the receiving water.
o >7riiW .:'/. GtiidelJnes.
The following arc guidelines to be used by t; e iii^Jrorj-'-ji^rweier ar
after the point of discaarg,;.
H. Iny water or wastes containing substances vnich r:wy soliflify
or become viscous and Cfause obsti'uct.icm to tbs flow in sewers
at temperatures between 32° F and l£o° F.
C. Air/ water or wastes coniainint* fats, grease, oj.lf; or waxes,
whether emulsified or not, in excess of 100 mg/1 .
D. Any waters or wastes contaiiiir.R cadmium, chrori'ivn, copper,
lead, nickel, zinc, .and other heavy metal loir substance's
lotalilinf, more than 15 mc/1.
S. rjTjr wastes exerting excessive or unusual chlrrim-
o:--;rj;n demand, biochemical o^/fren dempjul or .-?'ie.n-; ,-".] o:-.7*r,!n
doin^nd iji such quantities as to constitute n si gni i i ••:ui;i
load on the "i7a.stewat.er Treatment Plant or receiving WM/'TP.
i1 . Any radioactive wastes or isotopes of sucn nalt'-li i « rr
concentration as may exceed lir-its establisr.^f) bv ;".t,?t£ or
federal iegul f tions .
o. Any water or waster, containing excessive amni«it.? t>f risos: h&r.^us
so as to constitute a significant load at, /jmt.'.-iwntor Treat-mori
Plant or receiving waters.
n. An,;/ waters or wastes containijig phenols, chirri rated hydro-
carbons, mercaptans, or other taste or odor produ;:inr sub-
stances to such degree that such material received in the
composite sewage at the Wasr.ewater Treatn mi PJ nnt oxcocas
a connntration such that the plant, effluent wi 1 1 i
- 2 -
-------
862
OPIATING STANDARDS
(cont'd)
unpalatable flavor to food fish, or result in noticeable
offensive odors in the vicinity of the plant or receiving
water or otherwise interfere with the legitimate use of the
water.
I. Any water or wastes containing excessive color or color agents
which cannot be removed to allowable levels in the Wastewater
Treatment Process.
J. Any water or wastes containing unusual concentrations of
suspended solids and/or dissolved solids.
X. Any waters or wastes containing substances, whether they be
solids, liquids, or gases which are not amenable to treatment
or reduction by the Wastewater Treatment Process employed, or
are amenable to treatment only to such degree that the Waste-
water Treatment Plant effluent cannot meet the requirements of
State and Federal agencies having jurisdiction over discharge
to the receiving waters, or create a public nuisance.
The iingineer-Manager with the approval of the Board of Standards may in
specific cases enforce stricter limitations than ar--; shown in the guide-
lines if the needs or capacity of the system requires these limitations,
or the Engineer-Manager may accept sewage with characteristics that excocd
the guidelines subject to written agreements under the conditions des-
cribed in Section 12.07 (b) of the Code.
The Board of Standards shall from time to time recommend to the Common
Council such changes in the guidelines as are necessary to best indicate
the current level of each restriction the Board finds necessary to enforce
in the majority of cases, in order to obtain satisfactory operation of
the system.
SJflCTIOIl V. Information Required.
The Engineer-Manager may require any person, firm, organization or
corporation manufacturing, using or storing strong materials as descrit.?.
-------
863
OPERATING STANDARDS
(cont'd)
StjCTION VII. Changes or Additions.
It shall be necessary to obtain approval of the Engineer-Manager
prior to making changes or additions to facilities which would material}y
affect the acceptability of wastes into the Wastewater System.
SJCTION mi. Inspection.
The Engineer-Manager may inspect all control facilities periodically
=md report to the Board of Standards on the maintenance of such controls.
SECTION IX. Accidental Discharge.
If in spite of the above, an accidental discharge of strong materials
occurs, the person, firm, organization or corporation having the accident
shall inform the Racine City Wastewater Treatment Plant Engineer-Manager
or operator immediately by telephone of such accidental discharge and al]
pertinent facts available at the time in order to enable the Engineer-
Manager to take corrective action where possible.
SECTION X. Testing Procedures.
In forming an opinion on the acceptability of solutions or compounds
into the sewage system and in analyzing the operations of the plant or
system the Engineer-Manager and Board of Standards will be permitted to
use the American Society for Testing Materials, Latest Edition and
other recognized testing procedures in addition to the "Standard Methods"
as spelled out in the Ordinance.
Adopted by the Common Council June 16, 1970
Item 35 (2)
-------
864
eifcy of ft£iliiliiJC...racinel Wisconsin
OFriCS OF THc CITY ATTORNEY ----- Jack Harvey
March 23, 1971
City of Racine Statement to the Lake Michigan Enforcement Conference
March 23 & 24, 1971. Sherman House, Chicago, Illinois
In an earlier statement Dr. G. P. Ferrazzano presented to
this Commission the statement of one community along the shores of
Lake Michigan that is carrying out - according to plans initiated
within this Commission - an effective pollution abatement program.
While this program is expensive, it is the City of Racine's
belief that it is effective and consistent with the objectives and
timetables established within the framev;ork of this Commission.
There is no question that there are an unknown number of
communities along the shores of Lake Michigan that have been
"hedging" on taking steps necessary to save Lake Michigan. But
these communities are not confined to the State of Wisconsin.
Recently Attorney General William J. Scott of Illinois
singled out a half dozen municipalities of Wisconsin and now seeks
to bring them into the U.S. Supreme Court to abate alleged pollu-
tion practices. This is not the time or place to argue the merits
of that litigation - nor is this the time and place to ask the ques-
tion: "Look, who's calling the kettle black."
730 Washington Avenue, 53/103 Cify Hall 414-634-7111
-------
865
The point to be made is that action of this type is
working at cross purposes of this Conference. It would appear
that the appropriate approach at overcoming the overall problem
is for the four States to work together within the framework of
the Conference. It would appear that the time has come for this
Conference to become hard-nosed and to take a more firm position
against those States, municipalities and individuals and firms
who have been reluctant to proceed with programs needed to over-
come the pollution problem.
Certainly, if the Commission doesn't take measures to
pursue the objectives of this Commission, our meeting here is a
waste of time and money.
The City of Racine, therefore, urges upon this Commission
that it immediately embark upon a program of stricter enforcement
of its agreed upon program.
Edward A. Krenzke
Deputy City Attorney
EAK:lj
-------
866
D. I. Mount
MR0 STEINi If nothing more, may we go on to the
Pesticide Committee Report? We are still lucky enough to
have Dr. Mount,
5
6 | STATEMENT OF DONALD I. MOUNT, Ph.D.,
7 CHAIRMAN, LAKE MICHIGAN INTERSTATE
PESTICIDE COMMITTEE, NATIONAL WATER QUALITY
LABORATORY, ENVIRONMENTAL PROTECTION AGENCY,
10 DULUTH, MINNESOTA
11
12 DR. MOUNT: I would like to start out, Mr*
Chairman, by saying that parts of this report from the
States and from the other agencies didn't reach me until
Monday of this week and while the various participating
members did see partial drafts of this report, none of
them have seen the entire report, and so where subjective
interpretation or summaries are involved, I will take
responsibility for their errors if there are any.
2Q A program for monitoring pesticide levels in
streams tributary to the Upper Great Lakes was funded in
22 October 1969 by the FWQA on a two-for-one matching basis
23 with approximately $40,000 of Federal funds granted to
2JL Illinois, Indiana, Michigan, Minnesota, and Wisconsin.
25 The principal project objectives are: 1) to identify the
-------
867
T ii D, I. Mount
I ,1
2 levels of pesticides in tributary streams to the Great
i
-2 Lakes; 2) to identify the sources so they may be con-
, iS trolled; and 3) to establish backgrounds against which to
c ij judge the success of control programs. This funding has
6
11
12
,., tiated a statewide pesticide monitoring program. Activities
i
i of the first year of the program included the establishment
i
f. n of personnel and adequate laboratory facilities, the
16
19
20
22
23
25
allowed the States in the Lake Michigan Interstate Pesti-
„ cide Committee — Illinois, Indiana, Michigan, and
Wisconsin —- to staff and equip laboratories to determine
existing pesticide levels in major and minor tributaries
and water intakes of Lake Michigan.
Michigan
Upon receipt of the FWQA grant, Michigan ini-
collection and analysis of composite water samples from
29 major tributaries, the use of freshwater clams to monitor
pesticide levels in 54 tributaries, and the analysis of
water from 47 Great Lakes municipal water intakes, (Clams
were used to reduce the work involved in sampling smaller
tributaries.)
Clams proved to be good indicators of pesticides
contained in streams. Streams draining the Thumb Area to
Lake Huron, tributaries to lower Lake Michigan, and streams
in the Grand Traverse Bay area showed the highest
-------
868
1 D. I. Mount
I
2 concentrations of DDT in clam tissues. In streams from
which both clams and water were analyzed, the average
4 concentration factor by the clams was approximately $00
5 \ times,
6 Wisconsin
7 | The State of Wisconsin analyzed resident inverte-
brate organisms and clams at selected sites near the mouth
9 of rivers tributary to both Lake Michigan and Lake Superior
10 to determine pesticide levels present. Nearly 50 percent
11 of all invertebrate analysis fell below 10 parts per billion
12 which for this study is considered background level. Sites
13 where concentrations exceeded 10 p.p.b, but were less than
14 100 p,p,b, may be significantly contaminated and further
15 investigations are recommended. Where concentrations in
16 invertebrates exceeded 100 p,p,b,, intensive efforts are
17 required to locate and eliminate the sources of pesticides.
1# Counties with four or more analyses over 100 p.p.b, included
19 Door, Kenosha, Milwaukee, Ozaukee, and Racine. The contam-
20 ination in Door County may be due to runoff from the numer-
21 ous orchards. Kenosha, Milwaukee, Ozaukee, and Racine
22 Counties are relatively populous and industrialized.
23 Counties in the Lake Superior drainage basin with low pes-
24 ticide concentrations are sparsely populated with little
25 agriculture or industry.
-------
869
D. I. Mount
2 Over $0 percent of all samples had dieldrin con-
3 centrations less than 10 p.p.b. Many samples were less
than 2 p.p.b. Counties with four or more analyses greater
than 10 p.p.b. were Kenosha, Milwaukee, Ozaukee, and Racine.
Sites with concentrations between 2 and 10 p.p.b. should be
investigated further. Where concentrations exceed 10 p.p0b.,
comprehensive studies are necessary to locate dieldrin
sources.
Kenosha, Milwaukee, Ozaukee, and Racine Counties
again had the highest concentrations of DDT and dieldrin in
12 fish. The fish analyzed from Shawano County also had high
13 DDT concentrations. Most high concentrations were found
in the southeastern counties of Wisconsin.
In several instances, pesticide or apparent
pesticide contamination has been traced to point sources
17 where necessary corrective action has been taken. In far
more situations, additional sampling is necessary to locate
and eliminate point sources of pesticide contamination.
20 Areas with an indication on one column analysis of high
concentrations of chlorinated hydrocarbons other than the
22 DDT complex and dieldrin also need further investigation.
23 The probability of analytically interfering compounds in
24 these areas is significant.
25 Illinois
-------
870
II D. I. Mount
|
2 Ij The State of Illinois has not yet acquired the
3
4
5
6
7
a
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
necessary facilities and personnel to perform pesticide
analyses in their own laboratory but has collected samples
of Lake Michigan water, sewage plant effluents to Lake
Michigan, and flow-in tributaries to Lake Michigan. They
then sent these samples to the Anderson Laboratories, Inc.,
Urbana, Illinois, for analysis. Sampling was conducted in
the fall of 1970 and analyses were made for dieldrin,
heptachlor epoxide, and DDT. Future sampling will be done
to identify lindane, aldrin, endrin, and methoxychlor.
Water samples were collected at two tributary
streams, seven sewage treatment plants, six water treatment
plants, and three open lake stations.
Indiana
Indiana has sampled water, sediments, clams and
invertebrates beginning in June 1970. No major sources of
pesticide were found. Low water conditions produced the
highest concentrations of DDT. Based on usage surveys,
present DDT levels appear to be from past usage. Indiana
feels that the use of clams was unsuccessful and should be
discontinued.
EPA Lake Michigan Basin Office
Results of analyses by the Lake Michigan Basin
Office in Chicago on open lake samples indicate that dieldri:i
-------
871
l li D. I. Mount
**• 1 1
2
10
11
12
13
16
19
20
22
23
24
was not detectable in more than one-half of the samples.
A weekly sampling of the Chicago Filtration Plant from
April 1970 to August 1970 shows highly variable concentra-
tions of DDT — but low ones — that are generally higher
than the open lake samples but without a seasonally-related
trend. The purpose of this sampling site was to identify
trends in the pesticide levels in Lake Michigan and to date
none are apparent.
Michigan
Great Lakes Fishery Laboratory t BSJFW, Ann Arbor ,
During 1970, The Bureau of Sport Fisheries and
Wildlife Laboratory in Ann Arbor sampled several species
of fish from different parts of Lake Michigan and analyzed
them for insecticide residues.
Lake trout were collected from the South Haven-
Saugatuck area of Lake Michigan in May, June, and July
1970. Total DDT concentrations in nineteen of these fish,
averaging from 22 to 26 inches in length, ranged from 11
to 2B p. p.m. with an average concentration of 19 p. p.m.
Dieldrin concentrations ranged from 0.14 to 0.45 p. p.m.
with an average of 0C27 p.p.m. Smaller lake trout have
substantially lower concentrations of both DDT and dieldrin,
Thirty chubs collected off Saugatuck, Michigan,
contained an average DDT concentration of 10.2 p. p.m. and
-------
872
D. I. Mount
2 dieldrin concentrations averaged 0.19 p.p.m.
o Coho salmon (average length IB inches) from the
• 1968 year class collected off Waukegan, Illinois, in early
c May contained an average DDT concentration of 2.S p.p.m.
and an average dieldrin concentration of 0.0? p.p.m. Coho
collected off Ludington, Michigan, in late August (average
length of 26 inches) contained DDT concentration averaging
14.1 p.p.m. and dieldrin concentrations averaging 0.12
10 p.p.m.
-,-, A comparison of DDT and dieldrin concentrations
between fish collected in 1970 and those collected in 1969
indicates there has been no appreciable change in the
concentrations of these insecticides. Fish from southern
TC Lake Michigan have higher concentrations than those from
farther north.
17 WARF Institute, Inc.
WARF Institute, Inc. has cooperated with the
Committee and completed a survey during 1969 on the lakes.
2Q Their results generally are similar to data reported above.
Their report specifically points out the interferences from
22 chlorinated compounds formed from disinfections of sewage
23 and of probable high PCB interference.
24 Problems
25 The analytical difficulty of measuring part per
-------
873
1
D. I. Mount
trillion levels of DDT and dieldrin in water are staggering.
To put a part per trillion in more understandable terms,
. that concentration in Lake Michigan equals only 11,000
c pounds in the entire lake. In other terms, one 10-pound
coho salmon containing 20 p.p.m. would have as much as
70 acres of water, 1 foot deep and a concentration of 1
Pop.t.
To determine the accuracy of our analyses, we
began a ten-laboratory comparison to check the comparability
-,-, of data. The results are very disheartening because on the
same sample there was as much as a 20-fold difference in the
TO results. In comparing the analyses on 10 different water
-,, samples, there were six key laboratories reporting; three
ic were consistently finding values about 5 times higher than
the other three. Since most of the analysts did not report
recovery efficiencies, there is no way to identify the
erroneous results. Because these differences are so large,
I have deleted all values for water data from this progress
20 report. The best I feel we can say at present is that the
DDT concentrations are less than 1 p.p.t. Only one
22 laboratory found other hard pesticides in lake water.
23 Tissue analyses are much less variable. Results
of an eight-lab comparison on samples of lake trout and
coho salmon tissue distributed by the BSFW lab at Ann
-------
874
D. I. Mount
2 Arbor, gave an interlab variation of only two or three
times. Therefore, I have included tissue data in this
report.
A critical analysis of three water samples was
completed by the BSFW lab at Columbia, Missouri. Mass
spectrographic confirmation was employed to confirm quali-
tative identification. These samples contained 50-75 p.p.t.
9 | of PCB's, 45-600 p.p.t. of di-n-butyl phthalate, and 34-300
10 j P.p.t0 of di-2-ethyl-hexyl phthalate. Any of these can
seriously interfere or mask pesticide analyses. These
analytical problems must be resolved before the water
monitoring program can proceed. Perhaps the choice of
concentrations in fish tissues as the primary measuring
point is a very wise one.
I
16
The Committee's activity to examine the PCS
problem in Lake Michigan is beginning to move, but it, too,
is hampered by even more severe analytical problems than
20 f°r pesticides. The average laboratory cannot do defini-
tive PCB quanitification at this time. We have developed
22 a grant agreement with Dr» Veith at the University of
23 Wisconsin, and last week I received assurances from EPA,
24 WQO, Research and Development Office in Washington that
25 this work was expected to receive funding in mid-April.
-------
875
D. I. Mount
2 ! This study will identify the important isomers of PCB's
(Kf |
o ! found in Lake Michigan and we hope such information will
lead to identification of important sources.
The States agreed to conduct an industrial waste
5 I survey to locate users of PCB's. Of the two States having
i
n \ most of the watershed of the lake, the State of Michigan
has not completed their survey and Wisconsin's was not very
o j informative. A. prime problem is that PCB's are not used
10 j alone but rather occur in many products and users of these
!|
11 I products are not aware that PCB's are contained in them.
12 j The National Water Quality Laboratory and the
13 j Bureau of Sport Fisheries and Wildlife Pesticide Laboratory
in Columbia, Missouri, are both conducting tests to
determine the toxicity and uptake of PCB's in aquatic
organisms. The PCB's with intermediate chlorine contents
17 appear most toxic and preliminary evidence shows very large
concentration factors from water into tissue. While I
did not have time to poll the Committee's opinion, I
20 believe PCB's are probably significant pollutants in Lake
Michigan,, The conferees may be interested to know that an
22 action level of 5 p0p.m. for fish flesh has been selected
23 by FDA.
24 Phthalates
25 Earlier I mentioned the occurrence of these in
-------
876
|T
2 |! D. I. Mount
ji
9 {' several water samples examined by the BSFW in Columbia.
*~ I.
., | The phthalates formed have a relatively low mammalian
i !
|
i i toxicity and very scant data for fish shows moderate con-
ji
c |; centrations, approximately 1-5 p.p«nu, are lethal to fish,
However, evidence obtained by the Columbia lab shows
7 ! teratogenic effects at lower concentrations. These
chemicals are widely used in plastics and warrant watching,
Summary
' : '
1, Highest DDT concentrations occur in more
populous areas.
2, No outstandingly large discharges have been
found.
U
-, />
im
20
22
25
Perhaps I should qualify this statement now
after having seen Wisconsin's tributary data in which in
the previous years they did find some relatively high con-
cenfcrations up as high as a tenth of a part per million of
DDT, as I recall, as well as some others, and those were
found in the 196&-1969 period, and I understand from Mr.
Frangos that these have for the most part been corrected*
Perhaps he would want to comment on that later,
3» Present sources may be from past usage,
4o No trends up or down are shown by concentra-
tions in fish flesh.
5» Fish in southern Lake Michigan have more DDT
-------
877
, ,• D. I. Mount
i,
0 || and dieldrin than those in the northern part.
6. Many of the chubs and larger coho and lake
. ;! trout have DDT concentrations higher than 5 Pop.m., the
h
c -I FDA action level.
/• | 7. Larger fish are approaching the 0.3 p.p<,m.
I j
7 i| action level for dieldrin.
a #. Analytical problems have made all water
Q J analyses questionable.
,„ 9. PCB's are probably a significant contaminate
in Lake Michigan.
10. Phthalates are occurring in the samples and
~~ I
-, o i determination of their importance should receive priority.
, , 11. The Committee expects to publish a more
,c ij complete progress report by June 1971.
,/• j 12. A meeting is scheduled on April 13 and 14,
1971, to attempt to resolve analytical problems.
MR. STEIN: Thank you, Dr. Mount,
Are there any comments or questions?
MR. CURRIE: Yes. Dr. Mount, what are phthalates
DR. MOUNT: I am not able to give you a chemical
22 definition of them, but they are plasticizers which are used
2-3 j extensively in the plastics industry and I believe are the
i
biggest group of plasticizers in use.
25 MR. CURRIE: Are they organic?
-------
878
1 J1 D. I. Mount
ji
2 II DR0 MOUNT: Yes.
•^ : MR0 CURRIE: What teterogenic effects are you
i ! referring to?
5 I DR0 MOUNT: These are on fish, and they cause
!
£ i premature hatching of eggs, abortion, deformities of the
|
n | skeletal system, and this sort of thingo
' i
i
$ j| MR. CURRIE: It seems to me, Mr. Chairman, this
is an excellent, very informative, and important report.
And once again, as with most things in this Conference, it
seems unfortunate that we didn't get it in time to study
it, evaluate it, understand it, and comment on it intelli-
TO gently. It seems to me that is a recurring problem with
these Conferences despite our repeated requests to the
-, c ! Administrator to see that important papers are distributed
in advance.
DR. MOUNT: I might point out, Mr. Chairman,
that the holdup was the four States and I got the report in
only 2 weeks ago.
20 MR. CURRIE: Then, perhaps it should be presented
at a session after we have had a chance to evaluate it. I
22 i think that the, paper raises some serious problems. For
23 one thing, it seems to be saying that we have some inedible
fish in the lake, which is a rather serious problem, and I
25 wonder what the Conference proposes to do about it?
-------
879
IT
11
•J.J D. I, Mount
l
« I MR. STEIN: The question I had — and maybe this is
f; \
\
3 a more general one — perhaps, Dr. Mount, you can give us an
4 ' indication of what action items you would propose that the
|l
5 || Conference take in this area. I know that you are going to
5 have another more complete report by June this year.
7 Hopefully, you are going to resolve that analytical problem,
which is always a very difficult one. But I am not sure,
in listening to your report — and I think this is an
10 i excellent one — that you are proposing that the conferees
11 take any action on any pesticide item at the present time,
12 Is that correct?
DR. MOUNT: Well, I guess that is essentially
correct.
First of all, I think that Wisconsin has taken
16 action on sources that they have found, and I would assume
17 that if and when Michigan is sure of theirs they will do
the same certainly,
The PCB program, I think, is finally moving and
20 I have got assurances that it will be funded. I would sug-
21 gest that one of the actions that perhaps need be taken
22 is attention directed to this phthalate section to see if
23 it is in fact a problem.
24 MR. STEIN: Well
25 MR. MAYO: Do you have any suggestions, Dr.
-------
880
.
D. I. Mount
2 Mount, for the route that we take for directing attention
o to that problem?
DR. MOUNT: Well, I am very much afraid that it
is going to involve essentially what the PCB's are. First
of all, this terrifically difficult problem of analysis,
which may not be quite so bad with the phthalates to find
out what is there, and obviously then we have to follow up
n with where they are coming from, and connected with that
10 there will have to be some research work to determine what
levels are significant.
12 MR. MAYO: How quickly do you think the committee
could put together a proposal for some specific action? I
certainly would not hesitate to attempt to include in the
15 work plans for Region V of EPA a significant effort, start--
ing fiscal year 1972 if we could have a strongly stated
purpose for that kind of an effort and an identification of
the resources that would be required.
19 DR. MOUNT: Well, there are two clear things
20 that have to come, as I say: 1) a determination of what
level is significant; and then 2) a monitoring or some
22 measurements to find out what is there; and I think that
23 we can spell these out as good as we are going to be able to
24 spell them out within, say, 2 months.
25 MR. STEIN: Yes, but I think what probably Mr.
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881
i
I
-, [| D. I. Mount
ii
2 I Mayo was talking about — and I think possibly Mr. Currie
, I was getting at the same thing — I know, Dr<> Mount, I have
. been in a lot of these programs where you have been in the
c forefront and at first we come to these things which you say
£ bear watching and you point with alarm as much as your
7 scientific tentativeness can permit you that kind of luxury,
/
i
d But then what I think they are asking is: Is there
anything on an administrative or action program which
10 we should be doing to accelerate coming to grips with the
pesticide problems in the lake?
12 MR. PURDY: Mr. Stein.
MR. STEIN: Yes.
1 i MR. PURDY: It seems to me that this Conference
did make a recommendation with respect to the pesticides,
although I am not clear on that. But what do the conferees
intend to do to respond to Mr. Currie1s question with
respect to DDT?
The sale of DDT has been banned in Michigan for
20 quite sometime. From the standpoint of PCBfs, Dr. Mount
mentioned that we had not furnished certain information
22 to him, and that does not mean that we do not intend to
23 furnish it to him. We recognize the importance of this
24 problem, and it is being assembled at the present time. In
25 fact, quite sometime ago, we asked Commissioner Dominick
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882
D. !• Mount
2 to initiate research in this matter of PCB's and separately
o we contacted our major — what we thought to be our major
. industrial users of PCS, and cautioned them against the
c possible long-range toxic effects of the substances and
asked them to look into it. And there has been a great
reduction in the use of the PCB's in Michigan.
I think, too, as an outgrowth of this program
now that has been initiated at both State and Federal -level,
that Monsanto Chemical Company has withdrawn certain com-
pounds from the market. They have also made arrangements
to take, say, the end products, or the wastes, back to
their factories for disposal. So there is quite a little
under way, to ray knowledge*
MR. STEIN: Again, if I read Dr. Mount's testimony
correctly, the plea for funding for research and development
of PCB's has been fairly fruitful and apparently is forth-
coming. So that is settled.
Now, the question, again, I have to raise: What
20 are we going to do, just wait for the June report before we
do anything? Or is there anything that is determined that
22 the conferees might do at this session of the Conference in
23 a recommendation to the Administrator on this problem or
in this area, I should say?
25 MR. MAIO: May I make an observation, Mr,
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883
1 ! D. I. Mount
i
2 ! Chairman?
3 MR. STEIN: Yes.
4 MR. MAYO: One of the burdens that the conferees,
5 the State agencies and us on the Federal side operate
6 under continuously, and that is responsibility to apply what
7 resources are necessary to these problems as they occur,
£ And I think most frequently the conferees find themselves
9 in the position of wanting to respond positively to the
10 findings of the Technical Committee, but yet being out of
11 phase with them in terms of the availability of resources,
12 If we have an opportunity here for the Pesticide
13 Committee to make some specific recommendations as early
14 as possible, so that we can generate them into — include
15 them into the generation of budgets and work plans for
16 fiscal 1972, I certainly make the plea to do that.
17 DR. MOUNT: Well, we can certainly do that.
18 MR. STEIN: All right. Are there any other
19 specifics on this?
20 MR. CURRIE: Yes, Dr. Mount, does your future
21 study program include the identification of sources of these
22 contaminants? It seems to me that must be the special step
23 after monitoring of the levels of the lake and the fish.
24 DR. MOUNT: Yes, it does, and it has already been
25 under way, I know, at least in Wisconsin, and perhaps in the
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884
j. __ _
I
1 Ij D. I. Mount
2 | other States, too, and this more detailed report that I
ji
3 I! mentioned will not — I don't think substantially — change
4 j anything I said here but will provide the blow-by-blow
5 account of where they have been found, and whether or not
6 anything has been done about them*
7 MR. FRANCOS: Let me respond to your comments on
$ what our experience has been. We, of course, have banned
9 the use of DDT, and we have gone to a Pesticide Review Board
10 whereby the several State agencies have responsibilities.
11 Uses of the other pesticides are being restricted.
12 The other obvious thing to do, of course, is to
13 see whether there are any point sourcesf In at least
14 two of the instances that you are referring to, Dr. Mount,
I
15 we were able to trace this thing back, and what we found
16 was, in both instances, a moth-proofing operation which
17 was washing out into the sewage system and getting into
lg the stream. Those two have since stopped using dieldrin
19 as a moth-proofing agent.
20 But, again, interestingly enough — and one of
21 these operations, which was a dying of wool yarn — even
22 when they stopped the use of the product, we were able to,
23 we think, get within the limitations of the analytical
24 capabilities, as it were.
25 On the virgin wool that was coming in, there were
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885
-j j| D, I, Mount
2 ' traces of dieldrin that we think may have gone all of the
li
•2 j way back to sheep-dippingo It is this kind of a problem
• that we have goto Now, some of the other high readings that
i
c we have gotten in water or the fish come from, I think,
general agricultural type application,
DR. MOUNT: Perhaps one of the things that could
be done by the Conference is to bring every pressure or every
effort to bear that you can to ensure that the State program
receive any support that they can that we can give them to
continue on, because one of the worst things that could
happen right now would be for this monitoring to die. We
are just now beginning to get the fruit of it,
MR. MILLER: Mr. Chairman, I was going to say
ic i that we certainly hope and expect that we will receive the
grant to continue the pesticide program in Indiana, And
while we have not banned pesticides, we have done a detailed
study, and we have a very small drainage area to Lake Michigan^
j_o, and we donft find any major source or major use of DDT in
20 this area.
And I think one of the things that Mr, Frangos
22 touched upon is very important, because one of the minor
23 sources that we have found were the dry cleaning establish-
24 raents, and the solutions that they do use for dry cleaning
25 often contained DDT for moth-proofing, and these end up
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886
;!
I J! D. I. Mount
j;
~ ! — and even new clothing that are dyed and dry cleaned
* 1!
ji
•2 i where they are not using DDT in them. So that, in our
• ji modern society, we are using DDT in a lot of places that
ji
c we hadn't anticipated and this may be some of the source
z of the dye rather than insecticides and pesticides that
are used.
DR0 MOUNT: It might well be that some increased
effort on looking at sewage treatment plant discharges for
these pesticides might be in order in that it certainly
appears that the problems are not at all unique to the
agricultural areas, that they are in the industrialized or
TO urbanized areas.
MR. STEIN: Right. I don't want to look for any
,c problems where we don't have one.
MR. PURDI: Mr. Chairman, I would like to speak
to a point that Dr. Mount made with respect to the contin-
•i g uation of these programs. I think even more than the
•jo continuation, that we need to expand them into the PCB's,
on metallic acid or metallic salts.
We did file for a continuation of this pesticide
22 grant. We were turned down,. We followed this up with a
23 letter to Administrator Ruckelshaus, and we received a
letter last week from Commissioner Dominick indicating
25 that the funding situation had improved and that we should
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887
1 D. I. Mount
2 resubrait our application for a grant. I think it might
3 be worthwhile for the conferees — I don't know whether the
4 Federal conferee can join in — but from the standpoint of
5 the States, that we strongly support the work of this
6 committee and ask that they expand it into the areas of
7 PCB's more than they have in the past, and to metallic salts,
g and that we attempt to finance this from all possible sources,
9 MR. MAYO: Mr. Purdy, I don't have very much luck
10 getting grants for myself, but I surely wouldn't hesitate
11 at all to endorse the State efforts in that direction.
12 MR. STEIN: Do we find that the conferees agree
13 with that?
I/,, If they do, we will include that as a recommenda-
15 tion by the conferees.
16 MR. CURRIE: Mr. Chairman, could we make the
17 recommendation more specific? It seems to me that the
lg report we now have establishes a very substantial suspicion
19 that pollution is occurring. Therefore it seems to me our
20 recommendation should say that, first of all, monitoring
21 should continue; secondly, that sources of these pollutants
22 should be identified; and, third, that the committee recom-
23 mend specific action to be taken by this conference, signi-
24 ficantly in advance of the next meeting.
25 MR. STEIN: Are there any comments on that? If
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1 |; G. Pratt
li
2 || that is agreeable, that is fine,
i!
03 || Thank you very much, Dr, Mount,
11
4 H We go to Status of Compliance with Conference
5 Recommendations. We want to go through that, but I would
I
6 I ask that vie summarize this, if possible,
7 May we call on the Federal conferee?
il
$ || MR. MAYO: The presentation on the Status of
! j
9 I Compliance will be made by Mr0 Pratt of the Region V
10 office, and, Mr0 Pratt, I would make the suggestion that
you start perhaps somewhere down near the bottom of the
12 || second page.
!
13
|l
14 || STATEMENT OF GLENN PRATT, SANITARY ENGINEER,
15 OFFICE OF REGULATORY PROGRAMS, WATER QUALITY OFFICE,
16 i EPA, REGION V, CHICAGO, ILLINOIS
17
lg MR. PRATT: I was going to, and I would like
i
19 i the paper to appear as if read in the transcript and I
20 will start at the bottom of the second page.
21 (The above referred to report follows in its
22 entirety.)
23
24
25
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889
LAKE MICHIGAN ENFORCEMENT CONFERENCE
SUMMARY STATEMENT AS OF MARCH 1,1971
STATUS OF COMPLIANCE WITH ABATEMENT'SCHEDULES
MUNICIPALITIES AND INDUSTRIES
On the basis of a written request to the Secretary of the
Interior from the Honorable Otto Kerner, Governor of Illinois, dated
November 22, 1967, as well as on the basis of reports, surveys, or
studies, the Secretary of the Interior on December 16, 1967, called
a conference in the matter of pollution of Lake Michigan and its
tributary basin (Wisconsin-Illinois-Indiana-Michigan) under the
provisions of Section 10 of the Federal Water Pollution Control Act,
as amended (33 U.S.C. 466 et seq.J. The conference was held on
January 31, February 1-2, February 5-7, March 7-8, and March 12, 1968,
in Chicago, Illinois.
The following recommendations dealt with the treatment of
direct discharge of municipal and industrial wastes:
1. Waste treatment is to be provided by all municipalities to
achieve at least 80% reduction of total phosphorus and to
produce an effluent that will not result in degradation of
Lake Michigan's water quality. Such treatment will provide
compliance with the water quality standards for Lake
Michigan as approved by the Secretary of the Interior and
the appropriate State water pollution control agency of
Illinois, Indiana, Michigan or Wisconsin. This action
is to be substantially accomplished by December 1972.
2. Industries not connected to municipal sewer systems are
to provide treatment so as not to result in the degradation
of Lake Michigan's water quality and to meet the water
quality standards for Lake Michigan as approved by the
Secretary of the Interior and the appropriate State water
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-2-
890
pollution control agency of Illinois, Indiana, Michigan
or Wisconsin. This action is to be substantially accom-
plished by December 1972.
3, Within six months each State water pollution control agency
shall list the municipalities and industries discharging
wastewater to the Lake Michigan Basin. The United States
Department of the Interior will provide a comparable list
of Federal installations. Each source so listed will
indicate whether it discharges pollutants, including
nutrients, having a deleterious effect on the Lake Michigan
water quality. Detailed action plans for treatment of all
waste having deleterious effect on the water quality of
Lake Michigan are to be developed. Such plans shall identify
the principal characteristics of the waste material now being
discharged, the quantities, the proposed program for con-
struction or modification of remedial facilities and a
timetable for accomplishment, giving target dates in detail.
This list shall be presented to the conferees for their
review and consideration. Pollution sources shall be added
to or removed from the list by formal action of the conferees.
4. Continuous disinfection is to be provided throughout the
year for all municipal waste treatment plant effluents.
This action is to be accomplished as soon as possible and
not later than May 1969.
9. Continuous disinfection is to be provided for industrial
effluents containing pathogenic organisms, or organisms
which indicate the presence of such pathogens, which may
have a deleterious effect on persons coming into contact
with Lake Michigan waters.
At the February 25, 1969, and May 7, 1970, reconvened sessions of
the conference the State and Federal conferees submitted detailed action
plans for treatment of municipal and industrial discharges having a
deleterious effect on the water quality of Lake Michigan. Since these
sessions the conferees have proceeded to issue necessary orders to all
dischargers and work has commenced on designing and constructing necessary
facilities. A summary, by state, of those dischargers which are on
schedule, those less then one year behind schedule, and those over one
year behind schedule follows:
-------
STATE
111i no i s
Indiana
Michigan
Wisconsin
TOTAL
7
25
88
61
-3-
MUNICIPALITIES*
891
SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
7
19
55
37
2
33
10
4
14
STATE
Illinois
Indiana
Michigan
Wisconsin
INDUSTRIES
TOTAL ON SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
5
27
5
41
3
23
5
26
2
15
2
2
TOTAL
FEDERAL INSTALLATIONS
TOTAL ON SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
18
277
18
193
62**
22
*Does not include schedules for Storm & Combined Sewer or Non-Point Discharges.
**40 of these are three months or less behind schedule of interim dates.
Of the 277 dischargers required to construct treatment facilities
193 are presently on schedule, 5^ have not met interim dates, and 26 have
not met final dates. Of those not in compliance, 63 are municipalities
and 21 are industries. Also, of those not now in compliance, 45 are
three months or less behind schedule, 1? are between three months and
one year behind schedule, and 22 are over one year behind schedule.
Following is a detailed listing of all dischargers behind schedule:
-------
INDIANA
-4-
MUNICIPALITIES
892
TOTAL
ON SCHEDULE
LESS THAN 1 YR. BEHIND
MORE THAN 1 YR. BEHIND
25
19
(2) Hammond (CS) 12-31'-70
Whiting (CS) 12-31-70
(4) Ashley (Dis) FT2-31-69
Ligonier(Dis) Fl2-31-69
South Benc{Dis)F12-31-6C
Elkhart (Sec) Fl 2-31-69
INDUSTRIES
TOTAL
ON SCHEDULE
LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
27 23 (2) Cities Service
F 12-31-70
Penn-Central Trans.
F 6-1-69
CS - Combined Sewers (Final Date)
F - Complete Construction (Final Date)
Dis - Install or Operate Disinfection (Final Date)
ILLINOIS
(2) American Motors
F 12-31-69
U.S. Steel (Gary)
F 12-31-69
MUNICIPALITIES
TOTAL
NSSD
(7 Plants
& 2 Bypasses)
ON SCHEDULE
LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
TOTAL
5
INDUSTRIES
ON SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
3 — (2) U.S. Steel - Waukegan
F 12-31-68
U.S. Steel - South Works
F 12-31-68
F - Complete Construction ( Final Date)
FEDERAL INSTALLATIONS
TOTAL ON SCHEDULE . LESS^HAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
18 18
-------
893
MICHIGAN
MUNICIPALITIES
ON SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
55 (33) Albion D 9-70
Allegan D 1-71
Eaton Rapids D 3-1-71
Battle Creek D 2-71
Big Rapids D 12-70
Boyne City D 9-70
Cadillac D 9-70
Chikaming Twp. F 12-70
Delhi Twp. D 1-71
East Lansing C 9-70
Fremont D 9-70
Gladstone D 12-70
Grandville D 9-70
Harbor Point Assoc. D 12-70
Hillsdale D 9-70
Iron Mountain-Kingsford D 3-1-71
Ionia D 12-70
Iron River D 1-71
Mason D 12-70
Menominee D 9-70
New Buffalo D 10-70
New Buffalo Twp. F 12-70
Norway D 2-71
Otsego D 9-70
Paw Paw D 9-70
Portland D 12-70
South Haven D 12-70
Vicksburg D 9-70
Lansing D 3-1.-71
Whitehall D 9-70
Wyoming D 1 -71
Zeeland D 12-70
Ludington D 3-1-71
INDUSTRIES
TOTAL ON SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
D - Detailed Plans (Interim Date)
F - Complete Construction (Final Date)
-------
-6-
WISCONSIN
894
TOTAL
ON SCHEDULE
37
MUNICIPALITIES
LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
(10) Appleton D 1-71 (14)
Cedarburg SC 1-71
Fond du Lac D 1-71
Green Bay MSD D 1-71
Manitowoc D 1-71
So.Shore Plt.-MMSCD 1-70
Racine D 1-71
Sheboygan B 8-70
Two Rivers D 6-69
Waupaca D 1-71
Clintonville (Dis) F 5-6!?
Franklin SD (Dis) F 5-6!}
Germantown(Exp) F 12-68
Kimberly (Dis) F 5-69
Kiel (Dis) F 5-69
Little Chute (Dis) F 5-159
Jones Is.Plt.-MMSC (Dis)!F5-69
Neenah-Menasha (Dis)F5-6!9
Oak Creek Sub.#3 (Dis)F!5-69
Oconto (D1SJF5-69
Oshkosh(Dis)F5-69 (Partial)
Portage (Dis) F5-69
Racine Co.Hwy.&Ofc.Bldg.
(Dis) F 5-69
Thiensville (Dis) F 5-69
INDUSTRIES
ON SCHEDULE LESS THAN 1 YR. BEHIND MORE THAN 1 YR. BEHIND
26
(15) American Can D 1-71
Badger Paper Mills D 1-71
Bergstrom Paper Co.D 1-71
Charmin Paper Prod.D 1-71
Combined Paper Mills D 1-71
Consolidated Papers D 1-71
Geo.A. Whiting Paper D 1-71
John Strange Paper D 1-71
Kimberly-Clark (Badger Globe Mill)D 1-71
11 " (Kimberly Mill) D 1-71
11 " (Lakeview Mill) D 1-71
" " (Neenah Division) D 1-71
Riverside Paper Corp D 1-71
Scott Paper Co D 1-71
Thilmany Pulp & Paper D 1-71
SC - Start Construction (Interim Date)
" - Detailed Plans (Interim Date)
D. - Install or operate Disinfection (Final Date)
-------
-7-
895
It is anticipated that a number of dischargers which have missed
interim checkpoints will still complete construction by their scheduled
compliance date. However, several other dischargers such as the North
Shore Sanitary District, Abbott Laboratories, and Fort Sheridan, which
have met interim dates are not expected to complete construction on
schedule.
After reviewing anticipated progress, the following estimate
was made of the percent of required facilities which will be completed
by the required conference date, up to one year beyond the conference
date, and over one year beyond the conference date:
ESTIMATED COMPLETION OF REQUIRED FACILITIES (%)
Illinois
Indiana
Michigan
Wisconsin
Federal
Inst.
On Schedule
34
40
50
30
82
1 Year Behind
33
40
35
30
12
Over 1 Year
33
20
15
40
6
Behind
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896
G. Pratt
MR. PRATT: At the February 25, 1969, and May 7,
1970, reconvened sessions of the Conference, the State and
4 Federal conferees submitted detailed action plans for
5 treatment of municipal and industrial discharges having a
6 i deleterious effect on the water quality of Lake Michigan.
7 Since these sessions, the conferees have proceeded to issue
necessary orders to all dischargers and work has commenced
9 on designing and constructing necessary facilities. A
10 summary, by State, of those dischargers which are on
i
i
11 schedule, those less than 1 year behind schedule, and
12 I those over 1 year behind schedule follows. And I don't
know if the conferees want me to go down the list.
14 MR. STEIN: Unless you have any specifics you
want to point out.
16 MR. PRATT: No, I think that this appears for
17 the record.
Of the 277 dischargers required to construct
19 treatment facilities 193 are presently on schedule, 3$ have
20 not met interim dates, and 26 have not met final dates. Of
21 those not in compliance, 63 are municipalities and 21 are
22 industries. Also, of those not now in compliance, 45 are
23 3 months or less behind schedule, 17 are between 3 months
24 and 1 year behind schedule, and 22 are over 1 year behind
25 schedule. Following is a detailed listing of all discharger^
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897 _
i
I
1 !! G. Pratt
behind schedule. It is anticipated that a number of
dischargers which have missed interim check points will
still complete construction by their scheduled compliance
j
5 date. However, several other dischargers such as the
ij
6 ij North Shore Sanitary District, Abbott Laboratories, and
7 Fort Sheridan, which have met interim dates, are not
expected to complete construction on schedule. And I
9 think I will end with that,
10 MR. STEIN: Any comment?
11 MR. CURRIE: Yes, indeed.
12 We have now come, after we are all too tired to
be able to consider it, to the essential business of this
Conference which is seeing to it whether or not people are
living up to the earlier Conference recommendations. We
can't possibly be expected to make any sense whatever of
17 this presentation which we have just this minute received,
which tells us in cryptic and cipher form about the status
19 of several hundred dischargers, and I wonder what it is
20 contemplated that we can possibly do with this presentation
2i at this time, and I wonder whether the Conference ever
22 intends to get down to the business of seeing to it that
23 people are complying with its recommendations.
24 i MR. STEIN: Well, Mr. Currie, it seems to me that
25 if you are hearing for the first time the Illinois
-------
1
2
3
4
5
6
7
a
9
10
11
12
13
14
15
16
17
ia
19
20
21
22
23
24
25
898
G. Pratt
[ communities that are more than a year behind or 2 years
behind, and this is cryptic and news to you, I think that
is quite a revelation.
I was going to ask the same question. We have
62 less than a year behind; 22 more than a year behind; we
have other avenues for direct court action, and I don't
know — maybe these are being reviewed for the direct court
action. I know that is what we are doing in the Federal
Government, and I am not too tired to look at this. As a
matter of fact, my ears perk up when I see this, and see
ho w many are behind and how many are not meeting the
schedule, and I think as public servants we can't afford
to be too tired to look at this. I am not*
MR. PURDY: Mr. Stein — have you completed?
MR. STEIN: Yes.
MR. PURDY: Possibly Mr. Currie wants to follow thi|s
up before I start.
MR. STEIN: Go ahead.
MR. CURRIE; Go ahead, Mr. Purdy.
MR. PURDY: Mr. Stein, I have noted on the final
table on the estimated completion of required facilities
that the total for Michigan there adds up to, I believe,
100; and on page 3» the municipalities, we have S&, and
industries 5, which I believe totals to 93. I don't know,
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899
r
I
1 G. Pratt
2 at this point which one is right, and where the error lies,
3 MR. PRATT: The table is in percentages.
4 MR. PURDY: It is in percentages?
5 MR. PRATT: Yes. They all add to 100.
6 MR. PURDY: Okay.
7 That just emphasizes Mr. Currie's statement that
g we are all tired, I think, but ~
9 MR. STEIN: I guess you are tired.
10 Let me ask Mr. Mayo a question. For those that
11 are behind, do you contemplate recommending remedial action
12 on the Federal level, Mr. Mayo?
13 MR. MAYO: Well, the instructions that I have
14 from Commissioner Dominick are to keep his office advised
15 of the dischargers that are behind schedule, at least
16 those that have passed the final completion date,
17 and to provide his office with questionnaires
lg stating the facts with respect to each of those delinquen-
19 cies, and the relationship of those dischargers to viola—
20 tions of Water Quality Standards or other Federal statutes,
21 as a means for a judgment being made on whether or not there
22 should be a Federal action under the terms of either the
23 Federal Water Quality Act, or the 1S99 Refuse Act. We have
24 proceeded in that manner.
25 MR. PURDY: Mr. Stein, I might say, on behalf of
-------
$00
G. Pratt
Michigan, that we are ready and will furnish Mr, Mayo with
the detailed information on each of those that are behind
so that he will have all the data at his disposal to reach
a decision on the sort of recommendation that he should
make.
Most of these, the Water Resources Commission has
not extended the time for their compliance, so that they
remain in a strong position to start enforcement action as
10 they deem it necessary in the courts.
I should point out that Grand Haven now should
12 De added to the list of those that are not on schedule.
13 They would have to be added to the "less than one year
behind." Grand Haven proceeded, had their final plans
15 approved. They took construction bids. They had let the
contracts subject to the sale of their bonds. Unfortunately
17 they were taken to court by the citizens in the area that
protested the location of the plant. A preliminary
injunction was obtained. Grand Haven had that dismissed.
2Q This was appealed to a higher court. This delayed the
sale of bonds until the contractor would no longer hold
22 his bids, and so that plant has now fallen behind due not
23 to an unwillingness on the part of Grand Haven to proceed,
24 but due to the fact that they could not proceed in view of
25 the legal problems facing them.
-------
G. Pratt
2 MR, STEIN: I want to make it clear to all of the
o conferees that right now — and I think Mr, Purdy's
description of Grand Haven points up the problem as well
as any — right now we are going through all the schedules
for Lake Michigan as well as the other Conferences. If any
are behind date, certainly if they miss a final date, or
are significantly behind in interim date, it looks to us
like they can't get a final date, we are carefully reviewr-
10 ing whether we are going to propose court action to get
11 rapid compliance, .
12 However, we recognize precisely what Mr, Purdy
has said — that there is no point in spending a lot of time
and energy in a court action when you are not going to
really push the completion date forward. If you have a
situation like that, where something has been tied up in
17 a local suit or things are moving as fast as they possibly
03n, even if you filed the court suit, given the limited
resources that we all have, it might be more productive to
20 put our efforts somewhere else.
So I think it isn't just as simple as we have all
22 found out in going down the list and seeing who is behind,
23 That is the first step,
24 The second step, we have to determine, is why
25 they are behind.
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902
1
2
3
4
5
6
7
a
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
G. Pratt
And the third and most important thing is if we
file that case that we really are going to do any good and
hurry things up because there are no dearth of cases, there
are plenty of cases that we have to file through this* And
I do think that all of the States can expect us to be with
them and be analyzing anyone who shows up as a laggard on
these lists very, very carefully in detail, case by case.
And as soon as we get a recommendation from Mr. Mayo, I
can assure you we are going to forward that as rapidly as
possible and take appropriate action where it is indicated,
MR. MILLER: Mr. Chairman.
MR. FRANGOS: Mr, Chairman.
MR. MILLES: Go ahead, Tom.
MR. FRANGOS: I couldn't agree more with the
statements that you have just made. Of course, we have
got, I suspect, the largest burden at least in terms of
numbers here, but I think at least the statistics need
some comment on my part. If you look at those that are less
than a year behind, for the most part they relate to the
submission of plans by January of this year by industries,
and a number of municipalities in the southern part of the
Fox River tributary to Green Bay; and that situation we
have been working with the Fox Valley Council of Governments
to determine a regional — if we can't come up with a
-------
903
Go Pratt
regional system for that area. And, therefore, a large
number of those have not come forward with individual plans
4 pending the outcome of a regional system,
5 But the time is running out there quite obviously
5 and we are going to have to make a decision very soon there,
7 On those that are more than a year behind —
g again, this is just a general observation — for the most
o, part they do relate to disinfection, I think the Confer-
10 ence has been through that discussion previously, but I
11 believe, in the main, most of those have either — are now
12 either providing disinfection or are in the process of
13 constructing facilities that will secure the disinfection,
14 One further comment that I would have: I think
15 that I can understand Mr, Curriefs concern for getting
16 this kind of information, I donft think it has been forth-
17 coming, I don't think that anyone is necessarily to blame
lg for not providing this; I just think our system hasn't
19 been very goodo
20 I would say to him, because I have sensed his
21 concern about his wanting to know what we are doing in
22 Wisconsin —• and if he has got any question about any
23 entity at any time — that our records are always open to
24 him, and that beyond that we can provide him and other
25 conferees any information they would like on this.
-------
904
1 G. Pratt
2 MR. STEIN: Any other comments or questions?
3 MR. MILLER: Mr. Chairman, I would like to comment
4 that we do have a report that we prepared updating the
5 status of all of the municipalities and industries in
6 Indiana. But I would say that on those that are listed as
7 being behind, either one or two years, that either they are
now under construction or the Board has held hearings with
9 them with the exception of Cities Service, and we have some
10 question whether it belongs on this list, in that we have
11 carried them as complying with the conference requirements
12 and what they are now doing is advanced waste treatment over
13 and above conference requirements, so that I think that the
14 Indiana Stream Pollution Control Board is following through
15 on these, and we expect to do that in the future.
(The above-referred to report follows in its
17 || entirety.)
19
20
21
22
23
24
25
-------
905
PROGRESS REPORT
FOR
CONFERENCE
ON
POLLUTION OF LAKE MICHIGAN AND ITS TRIBUTARY BASIN
(ILLINOIS - INDIANA - MICHIGAN - WISCONSIN)
RECONVENED MARCH 23, 1971
CHICAGO, ILLINIOS
ON BEHALF OF
THE
INDIANA STREAM POLLUTION CONTROL BOARD
AND
THE STATE OF INDIANA
MARCH, 1971
-------
906
INTRODUCTION
The January, 1968, reports to the Conferees for the Conference on
Pollution of Lake Michigan and its Tributary Basin provided a description
of the Indiana portion of the Basin, a summary of water uses, and excerpts
from the Implementation Plans of the Water Quality Standards for the Lake
Michigan and the St. Joseph River Basins. The March, 1970, report to the
Conferees updated the listing of municipalities and industries and pro-
vided details on the status of wastewater treatment facilities. A
supplemental report dated May k, 1970, provided a timetable for completion
of additional facilities required to meet Water Quality Standards and/or
recommendations of the Conferees.
The following report provides current information on the status of
municipal and industrial wastewater treatment and control measures in
the Indiana drainage area tributary to Lake Michigan.
-1-
-------
907
MUNICIPAL SEWAGE TREATMENT
Portage, Elkhart, and Ligonier have sewage works projects under
construction which include phosphorus removal and effluent chlorination.
Lagrange has completed construction of effluent chlorination facilities.
Construction is anticipated in the near future for connection of the East
Gary sewage to the Gary Sanitary District sewers for treatment at the
District's main plant. Treatment for sewage from East Gary is now provided
by the District's Miller plant which needs extensive improvements in order
to continue to provide effective treatment.
Construction of sewage works improvements including phosphorus removal
and effluent chlorination should be undertaken in the near future at South
Bend. This project has recently been certified for Federal and State grant
funds. Early construction is also anticipated by the Town of Middlebury
which will also provide wastewater treatment for the Middlebury Cooperative
Creamery. In addition, final plans and specifications for plant improvements
including phosphorus removal have been submitted by Goshen, Kendallville,
and Valparaiso. The municipalities of Gary, East Chicago, and Hobart have
submitted preliminary engineering reports and Chesterton, Crown Point,
Michigan City, Angola, Lagrange, and Nappanee have authorized engineers to
undertake studies relative to phosphorus removal.
Michigan City has made substantial progress towards separation of
combined sewers in major areas of the City. Consideration is being given
to utilization of deflatable tanks at other overflow points serving
isolated areas. Mishawaka and South Bend have provided combined sewer
separation in some areas and East Chicago is completing a demonstration
project to provide control of pollution from combined sewers serving
-2-
-------
908
approximately 1/3 of the City. East Chicago also has separate storm
sewers under construction in other areas of the City. East Gary is pro-
posing separate storm sewers for a portion of its drainage area and the
Gary Sanitary District has submitted a master plan for sewer improvement .
Enforcement hearings have been held with the City of Whiting and the
City of Hammond relative to projects for control of combined sewer over-
flows and disinfection of storm water discharges to Lake Michigan. An
order issued to the City of Hammond provided for its project to be completed
by December 31> 1970. The order also required completion of plant improve-
ments by December 31> 1972. Final plans have been approved, financing
procedures started, and construction bids are to be received April 22,
1971, Hammond plans to finance the storm water project and the sewage
plant improvement project with one bond issue. The City of Whiting entered
objections to the Board's order which provided for completion of the
Whiting project by May 1, 1971. The City has submitted a preliminary
engineering report which proposed a new sewage treatment plant to treat
all flow from existing combined sewers with effluent discharge to Lake
Michigan. The Board has not found this proposal satisfactory because it
believes that the sewage from Whiting should continue to discharge to the
Hammond sewer system for treatment. The effluent from the Hammond plant
normally discharges to the Illinois Waterway.
Other enforcement actions have been held with the municipalities of
Angola, Ashley, Kendallville, Ligonier and Valparaiso relative to construc-
tion of required sewage works improvements.
-3-
-------
909
Federal grant applications filed by Cromwell, East nary, Gary, Goshen,
Hammond, Independence Hill Conservancy District, Kendallvilie, Ligonier,
Valparaiso, and Topeka request over $12 million in Federal and $6 million
in State grant funds to help finance construction of projects estimated
to cost approximately $29 million.
Projects now under construction by Elkhart, Portage, and Wolcottville
and projects proposed for early construction at South Bend and Middlebury
cost approximately $21 million including $6.6 million in Federal and $3-2
million in State grant funds.
On the basis of plans that have been submitted and those now underway,
it is indicated that, if adequate State and Federal funds are available,
practically all of the Indiana municipalities could have projects for
phosphorus removal facilities completed by the end of 1972. The Sanitary
District of Gary, which plans major plant improvements in addition to
phosphorus removal facilities and the Cities of East Chicago and Mishawaka
will not meet this date unless progress towards completion of final plans
and start of construction is accelerated. The status of municipal waste-
water treatment facilities is shown in Appendix I.
Surveillance of wastewater treatment plant operations and the require-
ment for submission of meaningful monthly reports has continued. In general,
this activity, plus the requirement for certification of operators in charge
of wastewater treatment plants, has improved the operation and maintenance
of these facilities. However, the control of pollution from combined sewer
overflows and storm sewer discharges is required to meet water quality
standards during wet weather periods. Emphasis has been continued on the
-U-
-------
910
requirement for serai-public installations to connect with area-wide sewerage
facilities where practicable and for improved operation and maintenance
of existing plants.
-5-
-------
911
INDUSTRIAL WASTE TREATMENT
Continued progress has been made on construction of waste treatment
facilities at Indiana industries. A total of 8 projects at 7 industries
have "been completed since the Third Session of the Conference on March 31,
1970. A total of 36 projects have been completed since the First Session
of the Conference on January 31, 1968.
Three projects were completed at the steel mills during the second
and third quarter of 1970. These were the blast furnace treatment system
and north lagoon system at Youngstovm Sheet & Tube Company and the terminal
treatment plant at Inland Steel Company.
On May 26, 1970, an enforcement hearing was held with U. S. Steel
Corporation, Gary Works, Gary, concerning pollution of the Grand Calumet
River, Indiana Harbor Ship Canal and Lake Michigan. As a result of the
hearing an order to abate pollution was issued to the Corporation on
December 1, 1970, over the objections of U. S. Steel Corporation. The
order provides for submission of plans for pollution control facilities
by July 1, 3-971, and completion of construction of control facilities by
December 31, 1972. The Corporation has filed for judicial review of the
Board's action in Lake County Superior Court. The matter is pending.
The Corporation reports that plans for additional waste control facilities
are being developed.
American Oil Company, Whiting and Atlantic Richfield Company, East
Chicago, completed advanced waste treatment facilities during December
1970. These systems are in the process of start up and evaluation.
Advanced waste treatment facilities are under construction at Cities
Service Oil Company, East Chicago, which are scheduled for completion in
-6-
-------
912
June, 1971• U.S. Gypsum Company, East Chicago, completed process changes
during late 1970 and has eliminated all waste discharge to the Indiana Karbor
Ship Canal. The Ameridan Maize Products Company, Hammond, is developing
plans for advanced waste treatment facilities for completion by December 1,
1972. The preliminary plans are due by March 1, 1971. E. I. du Pont de
Nemours & Company, Inc., East Chicago, is also developing plans for additional
waste treatment facilities and upgrading of present facilities. These
improvements will be completed by December 31, 1972.
Three industries in the St. Joseph River Basin do not have adequate
wastewater treatment or control facilities. Enforcement action has been
initiated against General Products Division, American Motors Corporation,
South Bend; Centner Packing Company, South Bend; and Pennsylvania New
York Central Transportation Company, Elkhart, in order to acquire firm
commitments for construction of waste treatment facilities.
Waste treatment facilities were completed at Middlebury Cooperative
Creamery Company, Middlebury, and Angola Reduction Company, Angola, in
December, 1970. Waste treatment facilities are under construction at the
Pennsylvania New York Central Transportation Company, Elkhart; Centner
Packing Company, South Bend; and General Products Division, American Motors
Corporation, South Bend. Completion of these projects will occur during 1971.
The Continental Can Company, Elkhart, ceased operations on February 27, 1971.
The Lehman Veal and Poultry Packers, Wakarusa, closed during late 1970.
A listing of industrial plants appears in Appendix II. The listing of
industrial projects completed since March, 1970, and the timetables for
construction of industrial wastewater treatment facilities appear in
-7-
-------
913
Appendix III. The status of completion of interim actions leading to
construction of required municipal and industrial wastewater treatment
facilities appears in Appendix IV.
SUMMARY
Review of water quality monitor data and operating reports from
municipalities and industries disclose a continuing improvement in water
quality. Recent reports of the Department of Water and Sewers, City of
Chicago, confirm that the quality of raw lake water continues to improve.
Efforts will be continued to insure the completion of projects now
underway or in planning stages for sewage works improvements, including
phosphorus removal, not later than the end of 1972. Completion of these
municipal projects plus effective operation of industrial waste treatment
facilities recently completed will provide further improvement in water
quality. The control of pollution from combined sewer overflows, storm
water discharges, and surface water runoff from municipal and industrial
areas will be required in order to meet and maintain water quality
standards.
-8-
-------
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935
1
2
3
4
5
6
7
9
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11
12
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l«j
16
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19
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2i
22
23
24
25
G. Pratt
MR. STEIN: Well, let me try to put this together,
because I think what we have heard from the States and from
Mr. Currie represent both sides of the problem, and we just
have to meet this.
Sometimes when we go on the rare dates of the
conferences — for example, when we hear explanations from
Perry Miller or Ralph Purdy on a particular case, you can
get an answer about what a figure means. Or when we heard
the analysis from Tom Frangos, you get the answer to what
the figure means.
However, there is a lot of impatience, as Mr.
Currie points out, with dates apparently being slipped as
set up at the conference. I think there are several points
we have to make on this. For these dates which certainly
have not been revised and set at the beginning of the con-
ference, we went on the assumption that if everyone began
to work immediately they could complete the work in accord-
ance with these dates.
We do know that many of these plants did not
meet immediately. Also, as Mr. Frangos said, perhaps the
reporting has not been the kind that gives us the explana-
tion. But I think there is a problem that we are facing
today. Right now, we have a special group in Lake Erie
-------
936
1 G. Pratt
2 checking on Lake Erie violators, case by case, and if there
3 is an explanation, there is an explanation. But, as Mr.
4 Currie points out, people are not going to wait for it.
5 And we are, on the average, inspecting and evaluating one
6 industry a day on Lake Erie. We are going to get through
7 with that pretty soon, because, as you indicate here, the
# kind of violators you got, dealing with 62 that are behind
9 schedule, are within reasonable limits, you can get them
10 off.
11 As soon as we finish there, if the Region is not
12 going to do it with its own resources, I suspect we are going
13 to come up here. But I think the States can expect that
14 we are going to have to send in Federal forces to examine
15 every industry and municipality. When I say "examine" —
16 I don't mean necessarily examine them — every industry and
17 municipality that is behind the conference schedule, and if
18 there isn't a bona fide reason for their being behind, or
19 if pollution can be moved forward by filing a court action
20 or a ISO-day -notice against them, I am sure Mr. Mayo will
21 make that recommendation. If he makes that recommendation,
22 I want to guarantee you that I am going to act on it, and
23 these cases are going to be moved forward in that
24 manner.
25 MR. PTJRDI: Mr. Stein, we have no objection to
-------
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3
5
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7
10
11
12
15
15
20
22
23
24
25
937
G. Pratt
that sort of procedure. And, again, I am not asking for
more frequent sessions of this conference, but this con-
ference has never met in a full reconvened session in
Michigan yet. We have one of the largest tributary basins
to Lake Michigan — from the total listings of municipali-
ties and industries, I think we have about as many as anyone
there. And so far this Federal involvement is a long ways
away from our people, and we have had to carry this message
back to our people as well as we could. In many instances
an appearance before the Water Resources Commission has
served to spur on action. I think if the requirements of
this conference could be brought closer to some of our
recalcitrants that it might have a beneficial effect.
MR. STEIN: Thanks. That is a very nice invi-
tation. I ask the conferees to consider that. I know I
and possibly Mr. Mayo and maybe his predecessor, Mr. Poston,
when we have been in Michigan on various cases spent some
very entertaining times there in Detroit and Grand Rapids.
I am glad to hear we are still welcome in the
State. I appreciate those remarks very much.
MR. CURRIE: Mr. Chairman, it seems to me to be
appropriate to suggest at this point, after the statement
of Mr. Purdy and others, that it would be desirable for each
-------
938
G, Pratt
conferee to prepare a full report on the statement of com-
pliance of particular industries for submission to the
conferees and, after those reports are in hand, to schedule
5 an additional Conference session which, so far as I am
5 concerned, should be in Michigan, and to determine at that
7 time which polluters we should recommend be prosecuted* I
think it is long overdue• I think in addition we ought to
meet to reassess the adequacy of the recommendations which
10 have so far been made, particularly in light of the recom-
11 mendations of the Technical Committee on the Calumet Con-
12 ference, which has suggested that the existing recommenda-
tions for that part of Lake Michigan are, in fact, insuffi-
cient to achieve the desired water quality,
MR. STEIN: I think those points are well taken.
However, I just have certain authority and perhaps Mr,
17 Mayo doesf I thoroughly agree with your last two or
three points* Michigan looking at the requirements,
checking Lake Calumet, meeting in Michigan,
2Q
2i But, as far as the first one, I think Mr. Mayo
22 and I have been overtaken either by events or executive
23 directors. While we can meet and we would like to ask
24 for your reports and meet again, I think we are under a
25 directive ourselves to get these reports in for possible
-------
939
2
o,
10
12
16
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2Q
22
23
24
25
G« Pratt
court action, and I don't know that we are in the position
o where that can be modified while we wait for the State to
report to us.
MR. MAYO: I feel an obligation in terms of the
directions I have received to go forward and respond to the
directions from Commissioner Dominick. However, I do think
that it would be appropriate for the conferees to get
together in the near future to review for one another
their respective enforcement programs. We could take the
opportunity to review the enforcement actions that we have
taken in the basin and lay out the full scope of what each
of us is doing and how they are or may not be compatible.
MR. STEIN: How soon do you think you could have
that report in, if you want to do that?
MR. PURDY: Mr. Stein, I just passed out a
report to the conferees. It may not be in sufficient detail
to meet all of the needs but —
MR. STEIN: In other words, you think you have
this already.
MR. PURDY: No, there would be certainly addi-
tional information that is necessary. I often wonder how
— we overcommit ourselves in many ways. Certainly we
will try to have it in, say, 4 week's time.
MR. STEIN: All right. Let's see if we can get
-------
940
1 I G. Pratt
'i
2 j a report.
i
3 By the way, I think this is a very good suggestion
4 ! of Mr. Purdy's, because if we can get it from the States in
i
5 | 4 week's time, I think we are going to save time in the long
i
6 run, because we will all be proceeding at least on the same
7 data and I find that the way we can get delays is if you
$ have data that is erroneous.
o Now, let's see if that completes the Federal
10 presentation.
11 Do we have one from Illinois, Mr. Currie?
12 MR. CURRIE: On the compliance schedules?
13 MRo STEIN: Yes.
14 MR. CURRIE: No.
15 MR. STEIN: Indiana?
16 MR. MILLER: We passed out one that we prepared on
17 the compliance schedules and the status of the industrial
18 plants and the municipalities in Indiana, and I don't think
19 we would care to read it at this time.
20 MR. STEIN: Well, I would like to put it in the
21 record as if read. Is that agreeable?
22 MR. MILLER: That would be fine.
23 (The above—referred to report may be found at
24 PP. 749-77S.)
25 MR. STEIN: Right. Are there any comments on
-------
941
Go Pratt
Indiana?
Michigan, do you have any comments, Mr, Purdy,
4 i on yours?
5 MR. PURDI: No. We had an opportunity to review
6 | the report made by the Federal conferee and I think in
i
i
7 general we are in agreement with the figures that have been
presented.
9 MR. STEIN: How about Wisconsin?
10 ll MR0 FRANCOS: Well, I think, in general, short of
11 some updating, that the report is accurate.
12 MR. STEIN: All right.
13 Have you submitted a report here, or do you think
14 the Federal report is pretty accurate?
15 MR. FRANCOS: Well, we had some working documents
16 which we assumed were going to be submitted by the EPA
17 which I assume were summarized in this report, and we par-
1# ticipated in that.
19 MR0 STEIN: Mr. Pratt, are the working documents
20 which were submitted by Wisconsin incorporated in your
21 report?
22 MR0 PRATT: Yes.
23 MR. CURRIE: And Illinois is in the same position,
24 Mr. Chairman,
25 MR. PRATT: All of the States submitted
-------
942
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19
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23
24
25
Discussion on Phosphorus
corrections to our document,
MR. MAYO: Excuse me. A point that may not be
clear, Mr. Chairman and Mr. Pratt: What was submitted for
the record was the summary report, is that correct?
MR. PRATT: Yes.
MR. MAYO: I think it might be appropriate to
submit for the record as exhibits the backup material, and
then make copies of that material to the extent that they
may not already be available for the conferees.
MR. STEIN: Do you have that?
MR. PRATT: Yes.
MR. STEIN: All right. Let's take that as an
exhibit without objection. That concludes that,
(The above-mentioned exhibit will be on file at
Headquarters EPA in Washington, D.C. and Region V office of
the Environmental Protection Agency, Chicago, Illinois.)
MR. STEIN: Now, I think we have been over this.
I would like to split the next item in two parts because I
think while they are put together they are just put together
for literary convenience, and I think we have quite dif-
ferent problems.
One, the discussion of the phosphorus problem.
Let me state this as I have heard the problem. The prob-
lem is this: We have come up with a plan for 80 percent
-------
943
Discussion on Phosphorus
2 i reduction in municipal and industrial phosphate discharges,
j BQ percent to be computed on a Statewide basis, into the
4 j Lake Michigan Basin, This program is going forward. There
5 is some concern that we did not take into full account the
6 phosphates coming from the land or from storm runoff and
7 we may not have a tight enough phosphate control program,
$ Now, I think if — I think if we have to change
9 direction on this program, we should consider this, and I
10 welcome comments from the conferees,
11 MR. MILLER: Mr. Chairman, of course, working
12 from some of the information that Mr. Dumelle submitted on
13 this problem, I think that we in Indiana have several years
14 of data where we have been sampling the mouth of the tribu-
15 taries, which would get the phosphates both from runoff and
16 from municipal water treatment plants.
17 And contrary to the data that he had or has
1& included in his letter — not his data — we would find
19 that the data that we have would be about one-fifth of
20 the values that were used at arriving at the 80 percent
21 reduction. So wherein I believe he said that they were
22 low by a factor of 7» we would find that our values are
23 beneath him by a factor of 35.
24 So that we do not find that in a very small per-
25 centage of the basin we have — which is roughly 5 percent
-------
944
Discussion on Phosphorus
that the phorphorus problem, if it were uniformly divided
and I am sure it is not — throughout the entire basin, is
such that it would be as much as was used in the figures
for predicating the treatment that we based the needs upon,
MR. STEIN: Any other comments?
MR. DUMELLE: Mr. Stein and Mr. Miller, you will
recall that in October I presented a kind of paper and
pencil study comparing Lake Erie with Lake Michigan, and
there were some factors of 12 times as much, and so forth,
and to omit a lot of stuff in between, Michael Schmidt has
come in with a paper based on Federal data and shows 15
million pounds of phosphates going into Lake Michigan. I
11 don't have all of his backup sheets; I don't have the St.
Joseph River sheet. I know the Federal people have looked
at it because they have had it for 2 months, and really all
I am asking is the thing that you said, Mr. Chairman, in
October—that this would be referred to the Technical
Committee for study. I am not prepared to say which is
20 the correct number, but I think we have tributary monitor-
ing around the basin, and we can do as Mike Schmidt did and
22 take the 1970 data now and put them together and come up
23 with a report for the next session of the Conference and
24 see what the facts are.
25 MR. STEIN: Well, I think, Mr. Dumelle, at least
-------
945
1 Discussion on Phosphorus
2 I agree with what you said.
3 Let me check this out. Do we have an appropriate
4 technical committee to handle that?
5 MR. MAYO: To my knowledge, there has not been
6 one established.
7 MR. STEIN: Here is what I think. I think, Mr.
g Dumelle, you have raised what I think are some very inter-
9 esting points and certainly pointed at a problem that has
10 to be looked at,
11 On the same point, I think we have to consider
12 with care the kind of comments we got from Mr. Miller on
13 what the situation is in Indiana, as an example.
I/,, Now, if the conferees think this warrants it,
15 if we have not mounted a phosphate program on this municipal
16 and industrial waste reduction program that is going to
17 handle the phosphate program —— and I think Mr. Dumelle*s
lg initial analysis in the case there may be some significant
19 doubts about this — we had better examine this and come
20 up with certain specifics.
21 Again, like all of these programs that emerge,
22 vou Set a general identification, but unless we have real
23 specifics, we can't deal with it.
24 Now, do you think it would be worthwhile for us
25
-------
94&
Discussion on Phosphorus
2 to establish a group to deal with the question of phosphates
!
3 We ought to keep open, however, as we proceed with our dis-
cussion this afternoon, the desirability of that same group
5 looking at a chlorides question. And, as I recalled some
6 of the comments that Mr. Vaughn made this morning — I am
7 trying to find out where it is covered in his report — he
$ spoke to the concentrations of dissolved solids increasing
o, at a rate faster than had been projected. So it may be
10 that what we have here is an appropriate package of
11 parameters that a technical committee could address itself
12 to and make advantageous use of their time in looking at
13 phosphates, chlorides, and total dissolved solids. I
14 just offer that as an observation as we proceed. Certainly
15 they could at least address themselves to the phosphorus
16 issue.
17 MR. MILLER: Mr. Chairman.
18 MR. STEIN: les.
19 MR. MILLER: I have a little problem in this
20 area in that I don't know what data is available from
21 the various States,, As I indicated, we in Indiana, I
22 think, on the phosphorus problem and I think also pretty
23 much on the chloride problem, can give you the loadings
24 from Indiana.
25 Now, it would seem that if this can be done by
-------
5
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7
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20
22
23
24
25
947
Discussion on Chlorides
all of the States of the Lake Michigan Basin, the first thing
that we should have should be an assessment of these data,
and a compilation of them, so that the conferees could
review it. It would seem that this is almost fundamental
if we are going to have a technical committee work on it.
MR. STEIN: Right. But I don't know whether you
want to do this with a technical committee or assign the job.
You are saying, before the technical committee works, they
are g°inS to have to get some data from the States pulled
together and presented to them. Is that what you are
saying?
MR. MILLER: I am saying I think — correct —
MR. STEIN: By the way, this same situation may
be the case with chlorides, too. I don't know. Do we have
this disparity in data, or do we pretty much know the point
sources we expect in chlorides? Don't we? Or do we?
MR. DUMELLE: I would say, in general, yes.
MR. STEIN: In other words, you know where to
look, Mr. Dumelle, for the chlorides in more particularity
than the phosphates.
MR. DUMELLE: Yes. I think — and I don't know
how many of you have had time to look at it — but Dr.
Ayers put out a recent report called "The Lake Michigan
Environmental Survey," which we got about a month ago, and
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948
1 Discussion on Chlorides
2 in whe back he has his loading data which I have never seen
3 before updated for the lake. But curiously enough he shows
4 that the flow out through the Straits is cleaning out the
5 lake, which shows really, you know, that the input data is
6 probably too low, and he makes the point that there are no
7 data for direct dischargers, and many others,
# So I think this committee that we are talking
9 about could eventually go perhaps through all these loads,
10 but I would say phosphate would be the most important first
11 and whatever else the conferees would want,
12 MR, STEIN: Let me raise a question with you, and
13 I don't want to divert too much,
14 But if we made certain requirements, or proposed
15 certain requirements, at least on the new plants, I think
16 this was unanimous,
17 I understand the addition of heat to the lake, which
13 we all admit is transient and we are going to leave it there
19 for awhile, but when you have a freshwater lake, what is the
20 problem in just saying they can't put in chlorides above
21 certain concentrations?
22 I find it difficult to believe that in tackling a
23 big thing with powerplants that the government seems to be
24 afraid to tackle something like chlorides, or why we have
25 to go through this.
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949
1 Discussion on Chlorides
2 Is there a limitation that the conferees can eon-
3 sider pretty soon on what limitations we should require,
4 just as in good housekeeping for a clean lake like Lake
5 Michigan, and say that, darn it, no industry, no city is
6 going to put more chlorides in or dump them in the lake?
7 Now, what — do we need a committee to examine
$ where it comes from? You know my Business is evidence,
9 and chlorides are the easiest thing for us to trace. If I
10 have to send a crew out to find anything — maybe there is
11 one easier thing, radioactivity or these dyes — but other
12 than that, salts, chlorides are like rolling off a log; you
13 j know where they come from.
14 MR. CURRIE: Exactly right, Mr. Chairman, and
15 I think what we need in the case of chlorides is not the
16 kind of study to determine the sources and the loadings that
17 we need in the phosphate situation, but a specific recommen-
lS dation as to what deadlines and what requirements this con-
19 ference should impose.
20 MR. PURDY: Mr. Stein, may I read a statement
21 with respect to the status of the chloride reduction program
22 in "the Lake Michigan Basin?
23 MR. STEIN: Yes.
24 MR. PURDY: The Michigan salt and brine industries
25 has been estimated by the staff of the Water Resources
-------
950
Discussion on Chlorides
Commission to contribute $0 to 60 percent of the average
daily chloride contribution to surface waters in the total
Lake Michigan Basin, and this estimation, of course, had to
be made in the absence of specific information from the
other three States.
The Commission has notified the five companies
involved that discharge of concentrated chloride solutions
cannot be continued and that appropriate corrective programs
must be developed,
11 At its January 21, 1971, meeting, the Commission
12 held conferences with the Manistee area salt brine indus—
tries, Hardy Salt Company, Morton Salt Company, Morton
Chemical Company, and Standard Lime and Refractories
Company, at which time the industries indicated that pro-
grams have been initiated that would affect chloride ion
17 reductions of 75 to &Q percent,
lg Stipulations formalizing the programs have been
19 entered into with Hardy Salt Company, Morton Salt Company,
20 and the Morton Chemical Company, Staff have recently
reviewed program proposals from Standard Lime and Refrac-
22 tories Company and the Dow Chemical Company Ludington
23 plant. These are presently under review by staff. And
24 I would be most happy to make the details of this avail-
25 able to all of the conferees.
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951
1
10
11
12
13
14
15
16
17
IB
19
20
21
22
23
24
25
Discussion on Chlorides
2 What is more, I am abundantly aware of the
I
o permit program required under the Refuse Act, and at such
• time as we are required to certify under 21 (b) the
c i permit applications of these industries, we intend to include
as a condition in that certification the requirements that
the Commission had established and the time schedules that
they have established for this reduction.
MRo STEIN: Do these reductions meet the stan-
dards? Do we have a standard for these chlorides?
MR. PURDY: Well, from the standpoint of, say, an
effluent standard, we, of course — of course, effluent
standards have not been established as a part of the stan-
dards program. From the standpoint of an injury to fish
and aquatic life, I do not believe that the present dis-
charges are causing an injury to fish and aquatic life.
I do not believe that the chloride discharges are
injuriously affecting water supplies or public health in
the concentrations that we find them in the receiving
waters and the purposes for which those receiving waters
are used.
Now, as stated either yesterday or the day
before, the Michigan Water Resources Commission does not
believe that this represents a wise use of the resource ~
either the salt brine or the freshwaters, and that action
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5
6
7
9
10
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18
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952
Discussion on Chlorides
was necessary to bring about an early reduction, and we are
3 j| on that sort of a program.
4 MR. STEIN: Well, do you know what the reaction of
the other States to the program are, Mr. Purdy? Well, to
the kind of reduction — now, let me cut this — go off the
record right here.
(Discussion off the record.)
MR. STEIN: I think that we are probably closer
to a solution or a proposal for consideration of the con-
ferees on the chloride problem than we are possibly to a
12 |l solution of the phosphate problem,
Now, I think what we have to do is get to the
conferees, if we can — and we have this from Michigan
15 j| now •— identifiable chloride sources that you believe are
significant; that we will exchange this information with
all of the States, and if anyone believes that the States
are not proceeding with a reasonable program, we should
bring this up. And also if we were going to have the next
session of the Conference, we should be able to come up
with a proposal for control of chlorides, which should
be applicable to all sources going into Lake
Michigan.
Is this reasonable, without setting up a real
data-gathering operation? I think we should be prepared
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3
4
6
7
a sources of chloride* to Lake Michigan,
10
11
12
13
14
15
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17
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25
953
Discussion on Chlorides
to do that.
MR. CURRIE: I agree, Mr. Chairman,,
MR. PURDI: Mr. Stein, I can't help but point out
from the standpoint of chlorides as a whole into Lake Michi-
gan, and the input into Lake Michigan, that for those in-
stances where we use a ferric chloride salt for the removal
of phosphates, that we are in fact going to be adding new
MR. STEIN: That may be true.
By the way, as I pointed out, I think that is a
problem, dealing with phosphates . Dealing with the
chlorides and the salts associated with phosphates is
probably going to be a more difficult problem to get at.
Let us put it this way: I think — is it fair
to say that the point sources of salts we are all talking
about are in Michigan? Do you have any in Wisconsin?
MR. FRANCOS: No.
MR. STEIN: They are all in Michigan.
MR. MAYO: That is from industrial discharges.
MR. STEIN: Yes, that is what we are really
talking in terms of, and that is the crucial point, and
from the citizens testimony, these are the sources we
are talking about.
MR. PURDY: Do we not have some large chloride
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1
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3
4
5
6
7
9
10
12
13
14
•ic
19
20
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2/.
25
954
Discussion on Chlorides
sources from steel mills, where they use hydrochloric acid
for pickling purposes?
MR. STEIN: Yes, you do.
MR. PURDI: Well, is that not a chloride?
MR. STEIN: Sure is.
Now, I am suggesting, sir, that since we deal
with this, you get your program to the Federal people, and
at the next session Michigan present its program. Hope-
fully this will dovetail with the Federal recommendations.
So we can deal with the chloride program, the Federal people
will come up with a recommendation on chlorides that will
deal with these industrial sources, steel mills, and muni-
cipal sources as well if you feel it is significant.
In other words, let me repeat, it will be the
Federal responsibility to come up with a recommendation
on chloride control.
It should make a careful analysis of the Michigan
program, and consult with the other States relating to
controls of chlorides. Really, gentlemen, I don't think
this should be a very difficult task.
MR. MAYO: Just by way of information, Mr.
Chairman, I think it would be appropriate to put in the
record, at this time, some observations on the differences
-------
955
1 ; Discussion on Chlorides
2
3 | in the Water Quality Standards relating to chlorides in Lake
^ i
4 Michigan. And I think it would be appropriate in this
5 interim period for the States to address themselves or at
6 least be aware of those differences and to keep in mind the
7 thought that it might be desirable for a considerable
g amount of more uniformity than we have at the present time.
9 The Illinois and Indiana standards — just to
10 summarize it — provide for an annual average not to
11 exceed a graduated scale which went from & milligrams per
12 liter in 1965 to 12 milligrams per liter in the year 2000.
13 The Michigan standard is a monthly average not
14 more than 50 milligrams per liter with 10 milligrams per
15 liter as desirable.
16 Wisconsin doesn't have a specific criterion
17 for chlorides and the existing water quality in Lake
18 Michigan — on a quick summary of the data that is avail-
19 I able — is on an average £.5 milligrams per liter, with a
20 maximum, at some points in the lake, in the range of 11
21 milligrams per liter.
22 So we have a fair range in difference in terms
23 of the maximum permitted, and two sets of standards that
24 provide for a programmed increase.-in chlorides with time.
25 So as we proceed with this, I think we will draw this
-------
956
1 Discussion on Chlorides
2 l matter to the attention of the States,
3 |i MR. FRANCOS: Mr. Mayo, I was just wondering, as
long as we are making observations here, would you want to
5 make an observation of how that came about?
6 MR. MAYO: I would have to say these standards
7 were approved, and I think we need to collectively address
ourselves to it.
9 In fact, I think it would be a good idea for
10 the Regional Office of EPA to provide you with a working
11 draft of a resume of Water Quality Standards by parameter,
12 ^7 State, with some relationship to average and maximum
water quality conditions in the lake.
14 We will get this out to you. I think it would be
I
15 very informative.
16 MR. PURDY: Mr. Stein.
17 MR. STEIN: Yes.
13 MR. PURDY: I really don't interpret our standards
19 with that much leeway, and I think the only way one can
20 interpret it in that fashion is to disregard the antidegra-
21 dation statements, and it was my understanding that the
22 antidegradation statement was to serve this very purpose.
23 And I consider this to be a real statement, and therefore
24 as such it does not mean that it provides for increasing
25 amounts to go into Lake Michigan from Michigan sources.
-------
957
1 Discussion on Chlorides
2 MR. STEIN: Well, I appreciate that. I know you
3 people were not at St. Louis at our meetings on the tempera-
4 ture standards of the Mississippi River States, I know for a
5 very pressing reason. But we had precisely the same problem,
6 You know, Mr. Frangos, this may be a little unfair to ask
7 Mr. Mayo, the Regional Director, because one of the responsi-
bilities I also have now are these standards. The way they
a are developed on a State-by-State basis without getting the
10 States together, we find that in many areas you have dis-
11 parities such as we have found here.
12 From the chlorides we have heard and the standards,
13 for example, and the explanation given by Mr. Purdy, I suspect
that the standards while expressed differently, in fact are
15 not that much different and can be brought together. In the
entire Mississippi River, I think we just had from top to
17 bottom a spread of a difference maybe of less than 5° on
these maximums. Of course, they were very vexing to put
together once you got set.
2Q But I think we are in the ballpark, and I would
ask the Federal conferee to try to get together and see if
22 we can't come up with a recommendation that we can all go
23 forward with on chlorides.
24
25
-------
958
1 Discussion on Phosphorus
2 Now, on phosphates, I think maybe we can have an
3 alternate of the same procedure, I suspect what Mr. Miller
4 said is probably entirely correct — that before any group
5 can get together you should be able to get the data and
6 evaluate the material that each State has and how it considers
7 its problem on phosphates.
g Then, once that is assembled, as I understand the
9 proposal, it would be productive for the Federal Government
10 to get in contact with the States, and set up a group, and
11 make a determination whether v/e have an effective phosphate
12 program in existence or have to revise it.
13 If we have to revise it, there are two things,
14 1) either we are going to know enough to make the recommen-
15 dations for revision, or 2) we are going to have to do some
1$ further work or some data-gathering before we can come up
17 with the answers. By the next conference we should turn
lg in the recommendations.
19 MR. MAIO: Well, I would have to know what you
20 are thinking of in terms of the estimated date of the next
21 conference, Mr. Chairman, because as you know our resources
22 aren't limitless either.
23 MR. STEIN: No. We haven't set the date, but I
24 think we should start working on the project.
25 MR. MAIO: Yes.
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959
^
i | Discussion on Phosphorus
i
i
? [ MR. STEIN: Now, even though you don't have the
"* I
3 next Conference date — and Mr. Purdy has invited us to
i
^ J Michigan; that is lovely in the summer — the fact is we
i
5 j are going to have to do this one way or the other. I
think we just have to get started on it to evaluate this
7 situation.
MR. FRANCOS: Now —
MR. STEIN: les.
,0 MR. FRANCOS: — I would view the phosphorus
TI question as one that is of high priority for a couple of
12 reasons. I think that indeed if Mr. Dumelle's figures are
i -5 anywhere near correct that we do have a lot more to do,
•ii but beyond that — and I would say that our estimates are
considerably lower than his, but they do ran se another
question.
I think if indeed his figures are anywhere near
what is really happening, then I think it also raises a
question about phosphorus removal at sewage treatment
plants- Because if the ratio of input is not indeed what
2T we estimate it to be between municipal and agricultural
22 sources, and if we are talking about taking phosphorus
23 out of the box, then I think we have got to look very
closely at these requirements before providing phosphorus
25 removal because of what we are getting for our dollar that
-------
960
1 Discussion on Phosphorus
2 | we are investing, I raise that question because that
I
3 i question is being asked of me by our communities.
i
4 ! MR. STEIN: I think that was implicit, and it
5 j seems to me — in what Mr. Dumelle raised — that he
6 raised some very vital and pertinent questions. But what
7 I am saying is this: I think you have made the same kind
of rejoinder as Mr. Miller. If we are operating on the
9 basis of some figures made by Mr. Dumelle, and then we have
10 great variances on these assumptions made by Indiana, and
perhaps we have heard from Wisconsin now, what I think we
12 have to do is get the Federal people together and pull this
together with Mr. Dumelle and all of the States, and if
14 those assumptions or figures still stand up we know we have
a problem. If the estimates are way too high — no one has
16 any way of knowing this — and you can scale this down,
17 maybe we don't have a high priority problem.
What I am suggesting is with all of the work we
19 have to do before we go into high gear, and even to make
20 this a meaningful study, even if we do go into high gear,
21 we are going to have to assemble the facts and get the
22 assumptions correct first, That is what I think we should
23 do and send a man around to the States and send them pretty
24 quickly to get this and feed this back to all of the States
25 so we know where we are.
-------
961
Discussion on Phosphorus
MR0 PURDY: Mr. Stein, again, I think we may
possibly know where we are a little bit more than might
have been indicated, and I certainly would not like to
give the, say, roughly 33 Michigan communities, that are
less than 1 year behind schedule any comfort, I think we
need to press forward on this phosphorus removal program
at point sources as quickly as possible, because I do
think they represent a significant contribution — contri-
bution of readily available phosphorus to the lake.
Michigan State University has a rather detailed
12 study on the Grand River, a large tributary to the Lake
Michigan Basin, I think this detailed study, yet in
unpublished form, will show the dangers of trying to gener-
alize where you can go into small tributaries on the basin
and find that a large percentage of that small tributary
17 might be from land runoff j that from the basin as a whole
the figures indicated that some 55 percent of the total
19 phosphorus input into Lake Michigan is from point sources
20 i and roughly 45 percent from land runoff.
2i MR. STEIN: By the way, I don't think that has
22 been disputed, and I think that that was the basis of our
i
23 setting up the phosphate program in the first place.
24 MR. MILLER: That is right.
25 MR. STEIN: I don't think this was lightly
-------
962
T Discussion on Phosphorus
S
2 '] undertaken when we put this requirement on our major
i
i
3 ! cities. It is costing a lot of money, and the reason that
the States decided to go with this program and we did is
5 that we were all convinced that it would work, and nothing
6 has — as far as I can see that has come up — has changed
7 our thinking on that.
The point is this though — the question is maybe
9 we have not gone far enough, and there may be additional
10 things that we have to do if we are going to lick the
phosphate problem in the lake.
12 MR. PURDY: In that context, I agree.
13 MR. STEIN: Okay. So let us start with that.
This about completes the agenda.
15 Does anyone have anything else?
16 MR. MAYO: Just the observation, Mr. Chairman,
17 that when we reach the point where the number of the people
at the head table equals or exceeds the number of the
19 people in the audience, itfs a sign.
20 MR» STEIN: I know it's a sign* I learned some-
21 thing from you again, Mr. Mayo, at this one. There is one
22 phrase you used, boy, I am going to cherish for awhile.
23 For a big merchandising part of the country — you see that
24 is where we make the money — and when you said that we were
25 going to send the States a "package of parameters," I figured!
-------
963
1 ij Discussion on Phosphorus
i
2 we had something.
3 !i MR. MILLER: Mr. Chairman, I might just raise a
i
4 question. In the findings that were passed out, they do
!
5 I not include those that were made by Mr. Purdy. Will there
i
6 be a supplement to these?
7 MR. STEIN: Was that just an oversight?
g MR. MAYO: Yes.
9 MR. STEIN: That was just an oversight. It will
10 be corrected.
11 MR. PURDY: Thank you.
12 MR0 STEIN: Are there any questions?
13 You know by the time we got to the end of the New
14 Testament they kind of forgot to produce the old one.
15 FROM THE FLOOR: Amen.
16 MR. STEIN: Are we ready to stand adjourned?
17 Does anyone have anything to say?
lg By the way, I think this has been exhausting,
19 but it has been productive, and I think we are on our way,
20 and let me make one last observation — and I ask you to
21 bear with me.
22 I* is very easy, in a sense, in a conceptual
23 sense, to hit the gross municipal and industrial pollution
24 that we hit at the beginning of these cases and the begin-
25 ning of the Conferences, and when you start a cleanup. But
-------
964
Discussion on Phosphorus
2 once you get beyond tht,t, and you come to these more
o subtle effects and the things that we don't know too much
about and are not as obvious, I think there is no substi-
tute to, in a sense, what we have gone through here, to try
to work our way toward conclusions and determinations when
we have such a divergence of opinion — that, and maintain-
ing our democracy, and maintaining our sanity, and main-
taining due process means taking up a lot of time.
Thank you for staying with us, and we stand
adjournedo
(Whereupon, the Conference adjourned at 5:25 p»m,)|
13
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965
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MRS. WENDELL ALEXANDER
,
VY\ AjLC-'k \ °l - I J 7 f
4700 JAMES AVENUE, RACINE, WISCONSIN 53402
O£JIL
Li
^-. , ^
-Ur-M
-------
966
Statement for the Four State Enforcement Conference on Lake Michigan
March 23, 1971, Chicago Illinois
', ibmitted "by Mrs. Wendell Alexander, 4700 James Ave. ,Racine, Wis. 534o2
Every one agrees that Lake Michigan is one of the greatest assets
f this area. It means much to many people. My husband and I have
med Lake Michigan property for over 20 years, and we live within
sight and earshot of the lake. We love it, and we are worried about
its future. You don't have to be a scientist to observe the changes
in the lake during the last two decades. They are dramatic. However,
the preponderance of evidence from biologists and ecologists in-
dicates that unless we reverse the present trend, Lake Michigan will
suffer irreparable damage. Then, why don't we reverse this trend?
I followed with great dismay the arguments given by industry at
the conference September 28 - October 2, 1970. Such as: discharges
of heat are not necessarily detrimental to the ecology; if proven
to be so, measures could then be taken to rectify the situation.
Such statements are reminiscent of the arguments used by the tobacco
industry concerning lung cancer, years ago. And they are just about
as valid. By the time industry admits to enviremental damage, it
will be too late.We cannot afford to wait and see. The longer we
wait, the more damage done, and the more difficult and expensive the
cure. We must do ALL we can now. I urge you to adopt the one degree
standard on thermal pollution.
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967
STATE OF ILLINOIS
189 WEST MADISON STREET SUITE 9OO
DAVID P. CURRIE,CHAIRMAN CH ICAGO, I LLI NOI S 6O6O2 TELEPHONE
SAMUEL R.ALDRICH 312-793-3620
JACOB D. DUMELLE
RICHARD J. KISSEL
SAMUEL T. LAWTON, JR. April 7 > 1971
Mr. Murray Stein
Assistant Commissioner
Environmental Protection Agency
Water Quality Office
Washington, D.C. 202^2
Dear Mr. Stein:
In response to your invitation to keep the record of the
Lake Michigan Enforcement Conference open for two weeks, I ask
that this explanation of my position as Illinois Conferee with
respect to thermal standards be transcribed in the record of
Thursday, March 25-
Illinois has conducted extensive hearings on this subject
and forwarded detailed fact findings, together with a position
statement, to the other Conferees in advance of the March 22
session. Virtually all of our findings were adopted by the
Conference, yet our position on the merits was not adopted.
This statement will further explain our position.
I disagree with' the proposal of the Technical Committee
because what the Committee proposed was a non-decision: to,,*
put off the decision whether or not to require alternatives to
once-through cooling until a date to be set by the Conference.
I think such a proposal is based upon the vain hope that with
a little more research we will be able to quantify the harm to
the Lake from once-through cooling. I think it quite likely
that five years from now we shall have a good many more studies
but not much better an idea about the harm to be expected from
once-through cooling. I think we know enough to draw a firm
line today, and I think we should settle the controversy now
for the benefit of everybody concerned.
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968
Mr. Murray Stein
Page two
April 7, 1971
I agree with the latest federal proposal in what I consider
its most important aspect: that no new power plants beyond those
now under construction shall utilize Lake Michigan water for
once-through cooling. I agree_, as Dr. Mount said, and as ;the original
federal white paper established, that the proliferation of
power plants poses a serious threat to the Lake. Moreover, I
agree with Dr. Mount's argument that we will never know just
which power plant it is—whether the twentieth or the fiftieth—
that pushes the lake beyond the danger point. I agree that if
we wait until we can prove that a proposed power plant will do
more harm than good before forbidding once-through cooling we
may very well make up without a lake to save one of these fine
days. It therefore seems to me the only safe course of action
is to tell the power companies today that they should look
elsewhere for free cooling water and not clutter the shores
of Lake Michigan, which have other important uses, with any
additional power plants.
I therefore applaud the federal government for its firm
stand in principle against proliferation of power plants on
the Lake, and I support that part of the federal position
heartily. Illinois intends to outlaw proliferation; I hope
the apparent acquiescence of the other states in the new federal
proposal indicates that they will do so as well.
But I disagree with the federal proposal to require cooling
towers on plants now under construction. The cost of doing
so is quite considerable; Dr. Tichenor estimated it at from
twenty to forty million dollars for the Zion plant alone. It
is possible to make this figure sound insignificant by calling
it twenty-five cents, ©r ten cents, per residential customer
per month; I would cheerfully impose such a cost on the consumer
if I thought there would be a benefit from doing so that is
somewhere in the same ballpark. But twenty million dollars is
a lot of money to spend even if it is collected from a great
number of people, and it should not be spent without justification.
I have seen no evidence that a single plant such as Zion will
cause such a degree of damage to the Lake as to justify the
expenditure of that kind of money. Dr. Mount emphasized the
other day that what we are all worried about is the effects of
a number of power plants, not of one. The nine days of evidence
I have heard convince me, as I said in my letters of February
2 and March 3 to Mr. Stein, that the damage we are confronting
is the exclusion of fish from a handful of acres at the point of
discharge and the killing of a number of microorganisms drawn
through the condensers. I should of course prefer not to have
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969
Mr. Murray Stein
Page three
April 7, 1971
this damage occur. But I believe that the effects of one plant
will be both local and minor. Moreover, I do not believe it de-
sirable to foster the construction of large and unsightly
cooling towers on the lakefront. Lakefront property ought to
be kept for recreational uses. And there are blowdown problems
with cooling towers that risk the discharge of pollutants other
than heat to the Lake. I am unconfortable when I read, in
the statement by the Porter County Izaak Walton League, that
"evaporative cooling towers will prove to be extremely objection-
able and will have to be abandoned within a few years of first
operation." I think this overstates the problem; but- I do
think it not entirely clear that cooling towers on the lake
are much better for the environment, under the present circum-
stances, than once-through cooling. When all these things are
considered, I do not think we should require today the back-
fitting of cooling towers or other devices on plants now under
construction. But I do believe the situation should be care-
fully watched and corrective action taken if at any time
significant harm to the lake is shown.
I think the best argument in favor of backfitting is
the one I have used above in justifying an absolute ban on
once-through cooling in future plants, namely, that the line
must be firmly drawn at the outset. But I see no reason why
we must draw the line in such a way as to impose the added
costs of backfitting, especially if the federal proposal is
to be read as requiring that the operation of plants must be
delayed while cooling towers are installed. Let us draw the
line today to avoid the excessive costs of backfitting and to
end the threat of proliferation.
I have serious doubts about the water quality standard
proposed for existing plants in paragraph A of the federal
proposal. I believe it is likely to require expensive modifications
to old plants that in my opinion cannot be shown to have sufficient
adverse effect on the lake to justify the cost. I question whether
a mixing zone should be defined in terms of the greatest linear
dimension, since this makes the legality of a discharge depend
on winds and currents rather than on the area of the lake affected.
I am disturbed by the ambiguity in the definition of the mixing
zone, as to the location of the "fixed point" from which the
1000' measurement is to be made. I should like to know more about
the impact of the monthly maxima on existing plants, specifically
whether we must require cooling towers as well as intake and dis-
charge modifications to plants like Waukegan.
In short I think there remain technical difficulties with
the present federal proposal, as well as important questions of
policy. I think too much money will have to be spent under that
-------
970
Mr. Murray Stein
Page four
April 7, 1971
proposal to deal with what I believe is an insignificant
problem. What we are all worried about is proliferation.
Let us deal with proliferation. Let's forget about the few
existing plants until someone shows they're doing more harm
than we now suspect they are. On the present record I think
they're not worth the cost.
Finally I should like to say that I think overall the federal
proposal is a substantial step forward; it does give us substantial
protection against proliferation, and that is to me more important
than the question of what happens to existing plants and to those
under construction. I wish, however, that the federal government
and this Conference would give half so much attention and half
such agressive energy to the solution of other pollution problems
which I believe to be far more important, such as the continuing
discharge of phosphates, oil, cyanides, ammonia, and inadequately
treated sewage. We have been diverted from these critical
questions for over a year while we fiddle about thermal pollution.
I think the federal government exhibits an extraordinary system
of priorities in insisting on backfitting thermal sources in
Lake Michigan to avoid speculative harm while backing down on
the rudiments of decent sewage treatment on the Mississippi
River and while doing nothing about enormous chloride discharges
to the- Lake.
Please make this letter a part of the record.
Sincerely,
David P. Currie
Chairman
DPC:jc
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971
N THE WING
MILWAUKEE AUDVBON SOCIETY
Branch of the National Audubon Society
Policy Statement, I.Iarch 17,1971
1.7e wish to make clear our stand on the discharging of heated
water into the lakes and rivers by power plants.
It is a well-known fact the demand for more and more electrical
power lies been increasing. To supply that demand , greater power
sources are needed. This has lead to the building of more power
plants, including the nuclear power complexes.
We are not opposed to power plants as such — nuclear or other-
wise. We AHE opposed to the discharge of superheated water into our
lakes and rivers, because we are not satisfied that sufficient evidence
of the ecological impact of such action has been obtained. We are con-
vinced that it is foolhardy to gamble with the long-range welfare of man
and his environment for the sake of an immediate and perhaps only too
short lived gain.
We therefore stand firmly beside those who urge further honest,
diligent study IT OS, so that when we go on to build , our progress may
be truly beneficial.
Sister Prances Wagner
^
Secretary, Milwaukee Audu^on Society
-------
972
(The following statement was prepared for
presentation to this Session of the Lake
Michigan Enforcement Conference but because
of time limitations was not read:)
POLLUTION FROM AGRICULTURE
AND OTHER LAND-USE ACTIVITIES
By
Will C. LaVeille
U. S. Environmental Protection Agency
Water Quality Office, Region V
Chicago, Illinois
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973
POLLUTION FROM AGRICULTURE AND OTHER LAND-USE ACTIVITIES
Pollution from land-use activities is a serious problem in the Lake
Michigan basin, leading to over-enrichment and possible ultimate death of
the lake itself and of the tributaries to it. Livestock operations con-
sisting mainly of dairy farms and small beef cattle and hog raising units
predominate in the region; poultry and sheep are also raised, but in smaller
numbers. Changes in the cost of operation and in general farming technology,
however, are making larger livestock operations more profitable and are
causing an increase in the number of large beef cattle feedlots. The
accumulated animal wastes from these operations are causing a new environ-
mental problem, although one which can be controlled relatively easily
because of the approximately point-source origin of these materials.
The change in agricultural technology, e.g., the raising of mono-crops
and the switch to high-yield plant varieties, has also resulted in a greater
dependence upon chemicals. Heavy applications of pesticides in fruit orchards
and on certain field crops throughout the basin presents a high potential
for pollution from runoff. Similarly, fertilizers and nutrient materials
can reach the waterways through the erosion process and can cause eutro-
phication of the waters. Indeed, the over-shadowing problem regarding pollu-
tion from agricultural and other land-use operations seems to be soil
erosion, which of itself causes siltation, a serious problem related to all
land-use activities.
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974
By controlling soil erosion it seems probable that upwards of 90%
of the agriculturally related pollutants could be prevented from reaching
the surface waters. Animal wastes could be confined to the land by the
same techniques used to keep out soil particles. Pesticides and fertili-
zers could similarly be prevented access to the waters by erosion control
measures. And the polluting nature of soil particles themselves could be
prevented by proper land management techniques.
The existing soil erosion abatement programs of the U.S. Department
of Agriculture are not effective enough. It has been estimated that the
total soil erosion is 25% less than it would be without these measures,
but in general, and definitely in localized areas, the problem continues
to be very serious. Educational programs carried out by the Extension
Service (ES) and the Soil Conservation Service (SCS) have only been slightly
effective in reducing pollution. The newly approved pollution abatement
practices of the Agricultural Stabilization and Conservation Service (ASCS)
are only a halting step toward an effective program. In general, the U.S.
Department of Agriculture has not made pollution reduction a major concern
and therefore agricultural pollution continues for the most part, unchecked.
Additionally, State plans for pollution abatement are in general poor and do
not properly address the problem.
In the area of on-going control programs, pesticide regulations of one
form or another seem to exist in all States; specific details of the four
Lake Michigan States are as follows:
-------
975
ILLINOIS:
The State of Illinois has a Customs Spray Law effective since January 1,
1965. To obtain a license, the applicant by examination, shows that he
possesses adequate knowledge concerning proper use and application of
pesticides, the dangers involved, and the precautions to be taken in connec-
tion with their application.
All pesticides sold in Illinois must be registered with the Illinois
Department of Agriculture before they can be legally sold in the State.
The use of DDT was prohibited on January 1, 1970, except where a per-
mit is obtained from the Director, Illinois Department of Agriculture.
INDIANA:
Indiana has had a Herbicide Law since January 1, 1961. It places re-
strictions on the sale and use of herbicides by requiring registration with
the State.
It has no general pesticide law at the present time, but expects
to have one passed this spring by the legislature.
MICHIGAN:
Michigan has had an Economic Poison Law since 1949, amended in 1961
and 1964. It regulates the sale and use of pesticides by requiring regis-
tration with the State Department of Agriculture.
The Michigan Department of Agriculture sent a Notice to Manufacturers,
Distributors, and Registrants of Economic Poisons on April 28, 1969, that
it was concelling the registration of DDT, 60 days from the receipt of that
notice.
-------
976
Another notice was sent on June 30, 1970, that all arsenicals for the
purpose of debarking trees and as an aquatic herbicide were to be denied
registration effective November 1, 1970.
WISCONSIN:
Wisconsin has a Pesticide Law regulating the sale and use of pesti-
cides by requiring registration with the Wisconsin Department of Agricul-
ture.
On July 25, 1970, the distribution and sale of DDT was prohibited.
On November 1, 1970, new rules adopted by the Wisconsin Department
of Agriculture on pesticide use and control went into effect. It prohibits
the registration, possession, sale or use except for research and experi-
mental purposes, or emergency use under permit, three pesticides:
DDT
ODD (TDE)
Endrin
It restricts the registration, sale and use only for purposes speci-
fied, the following pesticides:
Aldrin Heptachlor
Benzene Hexachloride Lindane
Dieldrin Alkyl Mercury Products
Most of the State Economic Poison Laws are modeled after the Federal
Insecticide, Fungicide, and Rodenticide Act, which the Pesticides Regula-
tion Division, EPA, currently enforces. The Economic Poison Laws regulate
the sale and use of pesticides by requiring registration. In order to
register a pesticide, the applicant must furnish efficacy and toxicity data
for the active ingredients in the pesticide. The label must also have
adequate warnings and directions for use to protect the environment.
-------
977
In the past, the applications were reviewed by the Departments of Agri-
culture, Interior and Health, Education and Welfare.
As indicated above, the States do not have mutually uniform re-
strictions and regulations. It is suggested that this be achieved by
empowering the existing five-State Governor's Interdisciplinary Pesticide
Committee (Illinois, Indiana, Michigan, Minnesota, and Wisconsin) to draw
up measures for unifying the lists of permitted, restricted, and prohibited
materials. As an additional step in the control of these agricultural
chemicals, it is suggested that the States adopt a program of accounting
whereby the pesticide user must sign for each quantity of pesticide and
specify the area it is to be applied on. Thus application rates over the
recommended level or at the wrong time of the year (rainy season) could be
detected and controlled.
The handling of animal waste problems is not governed, at the present
time, by administrative codes, regulations, or water pollution control
guidelines by any of the four Lake Michigan States. However, Illinois and
Wisconsin have initiated the drawing up of such documents. The Illinois
Environmental Protection Agency has (in its second or third draft now)
proposed a registration program, coupled with suggested design parameters,
for the reduction of pollution from animal wastes. Similarly, the Wisconsin
Department of Natural Resources has formed an ad hoc committee to suggest
an administrative code for the management of animal wastes. Both of these
States felt it advisable to formulate such a program to regulate the
development of new livestock operations, the enlargement of existing opera-
tions, and the control of pollution from improperly managed existing dairy,
-------
978
beef, swine, sheep, or poultry facilities, it is strongly suggested that
Indiana and Michigan also take this first step toward regulating these
essentially point-sources of agricultural pollution.
Basic to the solving of the entire problem of pollution from land-use
activities is control of soil erosion. Soil particles carry phosphates and
pesticides from the land to the waterways; animal wastes are also transported
to the lakes and streams by the same erosion mechanisms; and vast quantities
of soil are lost from the land by improperly managed urban and suburban land
development operations. Proper application of soil and water conservation
techniques would abate these pollution sources. None of the Lake Michigan
States now has a workable program to halt this form of pollution. Ideas
for proposed legislation are being considered in Indiana for sediment
control on all lands, rural and urban, and a state-wide sediment control
conference was recently held in Michigan to exchange information and sugges-
tions in that State. But unless legislative measures are adopted, control of
pollution from industrial and municipal point sources will have only limited
effect on overall water quality improvement. It is suggested that mandatory
sediment control policies be promulgated by cooperating officials from soil
conservation districts, county governments, and municipal and State agencies.
In conjunction with such action, zoning boards should be instructed
to adopt regulations prohibiting waste-producing agricultural operations
from unprotected land of high slope in the proximity of waterways, from
fertilizer and pesticide application in flood plains, and prohibiting urban
land developers from construction in erosion prone areas and flood plains.
-------
979
Another zoning requirement should be the establishment of permanent "green
belt" areas surrounding urban communities. Such permanently set aside
parkland or other recreational reservations would serve to separate odor
and dust producing agricultural operations such as concentrations of live-
stock, manure spreading operations, and plowing and harvesting actitivies.
Indeed, physical separation of urban and rural areas would serve to minimize
many irritations occurring along the fringe of rapidly expanding communities.
It is recognized, despite the evidence indicating the significant
effect of agriculture and other land-use activities on the lowering of water
quality, that there may be areas of concern in which there are insufficient
data to support the suggested need for legislation or other action programs.
To assemble such information, it is therefore recommended that a Task Force
be established, with the aim of gathering adequate facts to form the basis
of recommendations to a reconvened session of this Lake Michigan Enforcement
Conference.
In summary then, it is suggested that work proceed leading to the
ultimate adoption of the following measures to abate pollution from agricul-
tural and other land-use activities:
1. Uniform regulation of pesticide use including licensing
of applicators, use permits, and accounting procedures
to record all purchases and applications.
2. Animal waste regulations to prevent transport of manures
to surface and ground waters; they should include guide-
lines for approved disposal of the waste material by
techniques of irrigation, lagooning, and land spreading.
3. Mandatory soil erosion control measures to include both
rural and urban areas.
4. Modifications in zoning codes to prohibit waste producing
activities from erosion susceptible land and to create a
"buffer zone" between expanding urban communities and agri-
cultural land.
-------
980
V\Jl&con&in (Lcolopical Society
P.O. Box 514
Green Bay, Wis. 54305
Or. Douglas LaFollette
Wisconsin Ecological Society
1004 College Avenue March23, 1971
Racine, Wisconsin 53403 FOR IMMEDIATE RELEASE
"Dangerous and often illegal levels of DDT and Dieldrin in Lake Michigan trout,
salmon, chubs, and other fishes raise a number of important questions, which no one
seems willing to answer," challenged Douglas LaFollette, speaking as a fioard Member
of the Wisconsin Ecological Society. "We have waited for some word from the Depart-
ment of Natural Resources, since the conference on commercial fishing held in Green
Bay on January 23, 1971." He said that they felt the citizens of Wisconsin should
be told the facts and allowed to have the honest reasons behind the silence about
the very high pesticides levels in both commercial and sport fish.
The Wisconsin Ecological Society feels that there are "strong indications that failure
to publicize these dangerous levels of DDT is but another example of the built-in
conflict of interest which plagues the DiMR."
The same State agency which is charged with preserving Wisconsin's resources and
protecting it's citizen's health from pollution is also concerned with selling
fishing licenses, stocking streams with fish, and developing and encouraging the
growth of sport fishing and the tourist trade.
LaFollette, a Professor of Chemistry, cited a recent survey by Ronald Poff and
Paul Degurse of pesticide residues in Great Lake Fish which showed that "most trout
and salmon from Lake Michigan exhibited DDT residue levels in excess of 5.0 ppm, the
established limit of the Food and Drug Administration". (Management Report No, 34,1V) '70)
He added that, although the study was done by the Bureau of Fish Management of the
Department of Natural Resources, the Division of Environmental Protection must
certainly be aware of the results. "Some of the fish samples were in exebss of 14.0
-------
- 2 - 381
ppm DDT and over 0.3 ppm Dieldrin and many ranged from 5 'u 11 ppm DDT ,.nd from
0.2 to 0.3 ppm Dieldrin," The FDA has concluded that 0.3 parts per million of
Dieldrin in the edible portions of fish warrants legal action.
These facts raise the question of whether the Department of Health, Department of
Agriculture or ONR itself should prevent people from eating contaminated fish.
LaFollette pointed out that because of the high cost of sport fishing (as much as
$20 per day) it is likely that sport fishing is predicated on sport and trophy
rather than food. "however," he added, "the State agency is still responsible for
widely publicizing these dangerous pesticide levels. It is appalling that the DNR
could ignore the implications of their own report for so long."
In the area of commercial fishing the DNR seems equally able to ignore the fact that
a very large part of the Lake Michigan fish catch exceeds FDA health limits. LaFollette
said that, according to a naper presented by Don Uinter and Lloyd Lueschow of DNR
at the AfiAfe meeting in Chicago on December 2-), 1970, "approximately 80 percent of
the Lake Michigan commercial catch is nonmarketable in interstate commerce,"
Here again we think a conflict of responsibility is possible. The DNR, which
regulated commercial fishing makes no mention of these pesticide levels when talking
about commercial fishing. They discuss low fish populations due to lamprey eels and
say "lake trout populations have not built up to the point where it would sustain
commercial harvest." (Quote from Russell I. Daly, DNR Lake Michigan coordinator at
the January 23, 1970 conference in Green Bay.)
Fishermen want an Bnd to restrictions on net fishing, to be paid 30 cent per pound
for lake trout, and for an increase of trout planting in the lake. They say this
will stimulate the economy of Wisconsin and keep commercial fishing alive. LaFollette
stressed that trout had the highest DDT levels of any fish, according to DNR'S own
Report No. 34.
"The question is; why DNR does not forcefully make these points to the commercial
fishermen and to the public?" The Uisconsin Ecological Society does not believe
that fish unfit for interstate sale should be sold in Wisconsin or that tax dollars
should be used to promote commercial or sport industry when the dangers of DDT and
other pesticides are well established.
-------
UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
982
REGION V
WATER QUALITY OFFICE
33 EAST CONGRESS PARiCWAY ROOM
CHICAGO, ILLINOIS 60605
March 29, 1971
Mrs. Kathleen Nixon, Secretary
Mason County Anti Pollution Action Council
P.O. Box 6lk
Ludington, Michigan ^9^31
Dear Mrs. Nixon:
I am sorry that you were unable to attend the recent Lake Michigan
Enforcement Conference held here in Chicago on March 23-25, 1971.
Your statement was received in time for presentation and Mrs. Lee
Botts of the Open Lands Project, read it to the Conferees the first
afternoon.
The Michigan Conferee reported to the conferees on progress they are
making in abating point source discharges of chlorides to Lake Michi-
gan Basin Office. The conferees expressed their desire that Michigan
continue their program to "bring these dischargers under control at
the earliest possible date.
The conferees will shortly be preparing detailed reports on the status
of compliance with measures underway to abate the discharge of pollu-
tants to Lake Michigan. It is expected that the Conference vill be
reconvening in about two months to consider these reports. At the
request of the Michigan Conferee, this next meeting will be within
the Michigan portion of the Lake Michigan watershed.
Again, thank you for your concern in abating the discharge of pollu-
tants and in preserving Lake Michigan's high water quality.
Sincerely yours,
X/><-- /A^/Y
'
Glenn D. Pratt
P.S. Your presentation will appear in the transcript as read, but I
am returning your original to you for any further use you may have for it.
Attachment: !Pranscript
Copies to: R. Purdy vM. Stein
L. Townsend
-------
983
Statement of the
MASON COUNTY ANTI POLLUTIon ACTION COUNCIL (MACAPAC)
REGARDING THE
CHLORIDE CONTAMINATION OP
LAKE MICHIGAN AND RECOMMENDATIONS
Presented to:
LAKE MICHIGAN ENFORCEMENT CONFERENCE
March 23-4, 1971
Sherman House
Chicago, Illinois
-------
984
This report Is similar in content to one which we
attempted to present in a public meeting held by the Michigan
Water Resources Commission in Manistee, January 21, 1971.
Our organization, the Mason County Anti Pollution
Action Council, known as MACAPAC, was formed in September
of last year to study and act upon the pollution problems
of our area. We now have information on a number of different
pollution problems there.
¥e will limit ourselves in this paper to only one
problem. That is, chloride discharges into Lake Michigan
from a pipeline between Ludington and Manistee. In our
paper we will draw from data from the Water Resources
Commission Industrial Wastewater Survey Reports and from
the minutes of the Michigan Water Resources Commission meeting
of January 21, 1971. V/e will use these data because they
are the most reliable and authoritative we have.
The Industrial Wastewater Survey Report is that of the
Dow Chemical Company of Ludington, Michigan for November 3-5
of 1969. This report is approximately 16 months old at this
time.
Dow Chemical Company processes brine, It discharges
effluent containing concentrations of chloride into Pere
Marquette River. In addition, Dow discharges effluent
containing high concentrations of chlorides into Lake
Michigan by way of a 14 inch diameter pipeline which runs
-------
-2-
985
from the plant in Ludington to a point approximately 9,000
feet north of Point Sable and 500 feet from shore in about
15 feet of water. This pipeline has been in existence since
1943. In the meeting of January 21, 1971 the WRC admitted
that 5 point sources supply at least one half of all chlorides
into Lake Michigan. Three are in Manistee and two in
Ludinston. The two in Ludington were named as The Dow
Chemical Company and the Harbison-Walker Company.
We would like to draw your attention to some figures
for the discharge of this pipeline. For the first survey
period from the third to the fourth of November, the total
solids discharged were 3,190,000 Ibs/day. The total chlorides
discharged was 1,693,000 Ibs/day. The concentration of
chlorides was 145,000 mg/1. For the second survey period,
from the fourth to the fifth of November, the total solids
discharged were 1,448,000 Ibs/day. The total chlorides
discharged was 794,000 Ibs/day. The concentration of chlorides
was 68,000 mg/1. We understand that Dow is participating in
a voluntary program to restrict and control the polluting
content of their waste discharges. We have requested
information on the subject from Dow but have not yet received
any.
Note that we are talking about millions of pounds of
chlorides and concentrations in the thousands of parts per
million. The quantities of discharge over a long period of
time have amounted to astronomic proportions. The concentrations
of chlorides as they come from the pipe are vastly greater
-------
-3-
986
than any acceptable standard which we know of.
¥e understand that the discharge of these heavy concentra-
tions of chlorides have been permitted with the concept that
there is a mixing zone where these chlorides are mixed and
diluted with the fresh waters of Lake Michigan. We submit
that, in practice, the definition of a mixing zone is that
quantity of water required to dilute an unacceptable effluent
to an acceptable level. By this logic it might be reasoned
that no discharge would be unacceptable until the entire
lake failed to meet the standards for discharge waters.
We also understand that, at present, one must prosre
injury before action ean be taken to abate a particular
pollution problem. In practice, injury has been Interpreted
to mean obituary and regulation impossible till the damage
is done.
The primary fault is not with Dow. Dow has 400 employees
in Ludlngton. The community depends on their presence. It
would be pointless to act against Dow and not against other
firms which may do the same thing, perhaps in other states.
What Dow has done Is neither illegal nor unreasonable under
the circumstances. The fault is in the circumstances.
What Is needed is (1) regulation of industrial waste
discharges with uniform standards based on ecologic principles;
(2) that the regulations be enforceable; (3) that there be
sufficient personnel and funds to enforce them; and (4) that
there be additional technical and scientific personnel and
funds to find solutions, if possible, for problems for which
there are presently no solutions.
-------
-4-
987
We are concerned about the pollution problems of our
lake and elsewhere. Our ability to effect these problems is
limited. Representatives here have the power to effect
these problems if they will act. The primary.fault is,
therefore, inaction.
-------
988
EM*
EPA WSH
TLXA027 (32)DEA030
DE THA003 GC PDF TERRE HAUTE IND QO IQUAEST
WILLIAM RUCKELSHOUSE
ENVIRONMENTAL PROTECTION AGENCY
1129 20TH ST NORTHWEST WASHDC
POLLUTION IN LAKE MICHIGAN CRITICAL. THERMAL DISCHARGE STANDARD
NECESSARY TO AVERT STOP FURTHER DEGRADATION
JACK R MUNSEE 34 SOUTH FAWN.
836A EST.
EPA WSH
* U. S. GOVERNMENT PRINTING OFFICE : 1971 O - 441-076
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