PROCEEDINGS
ILLINOIS
Third Session
{Reconvened!)
March 24, 2S,
Chicago, Illinoi
Volume 1
INDIANA
CONFERENCE
In the Matter of Pollution off Lake
ichigan 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 I
Grand Ballroom
Sherman House
Chicago, Illinois
March 23, 1971
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CONTENTS
Opening Statement - Murray Stein
Francis T. Mayo
Hon. Abner J. Mikva (Read by David Cleverdon)
Hon. Adlai E. Stevenson, III (Read by Francis Mayo)
Mrs. Samuel Rome
Leonard B. Young
Enrico Conti
Robert P. Hartley
Dale S. Bryson
Hon. Richard B. Ogilvie (Read by Murray Stein)
Mrs. Helen Hoock (Read by Murray Stein)
Donald I. Mount
Bruce A. Tichenor
Mrs. Harry Janis
Mrs. Jack Troy
Mrs. L. W. Bieker
Edwin Neimeyer
Henry G. Zander, III
Hon. Patrick J. Lucey (Read by Thomas Frangos)
Mrs. Ruth Collins
Ted Falls
Arthur Pancoe
Mrs. Grace Knapp
Page
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CONTENTS (continued)
Mrs. Lee Botts
Robert Cramer
Mrs. Harriet Sherman
Dr. Peter Bertoncini
225
231
244
260
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1 Reconvening of the Third Session of the
2 Conference in the Matter of Pollution of Lake Michigan and
3 Its Tributary Basin, in the States of Wisconsin, Illinois,
4 Indiana, and Michigan, held in the Grand Ballroom of the
5 Sherman House, Chicago, Illinois, on Tuesday, March 23,
6 1971, at 9:30 a.m.
7
8 PRESIDING:
Murray Stein, Assistant Commissioner for
Enforcement and Standards Compliance, Water
11 Quality Office, U.S. Environmental Protection
12 Agency, Washington, D.C.
13
CONFEREES:
15 ,
CARLOS FETTEROLF, Water Quality Standards
16
Appraisal, Michigan Water Resources Commission,
17
Lansing, Michigan.
18
RALPH W. PURDY, Executive Secretary, Michigan
Water Resources Commission, Lansing, Michigan.
21 PERRY A. MILLER, Technical Secretary, Stream
22 Pollution Control Board, Indiana State Board
23 of Health, Indianapolis, Indiana.
24
25
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1 CONFEREES (continued)
2 FRANCIS T. MAYO, Regional Director, Water
Quality Office, U.S. Environmental Protection
Agency, Region V, Chicago, Illinois.
5
WILLIAM L. BLASER, Director, Illinois Environ-
6
mental Protection Agency, Springfield, Illinois,
7
DAVID P. CURRIE, Chairman, Illinois Pollution
Control Board, Chicago, Illinois.
9
10
15
16
THOMAS G. FRANCOS, Administrator, Division of
Environmental Protection, Wisconsin Department
of Natural Resources, Madison, Wisconsin.
13
ALTERNATE CONFEREES:
ORAL H. HERT, Director, Division of Water
Pollution Control, Indianapolis, Indiana.
17
' ROBERT P. HARTLEY, Regional Water Quality
Standards Coordinator, Water Quality Office,
19
U.S. Environmental Protection Agency, Region V,
20
Chicago, Illinois.
21
DALE S. BRYSON, Deputy Director, Office of
22
Regulatory Programs, Water Quality Office,
23
U.S. Environmental Protection Agency, Region V,
24
Chicago, Illinois.
25
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1 ALTERNATE CONFEREES (continued)
2 DONALD J. MACKIE, Assistant Secretary, Division
3 of Environmental Protection, Wisconsin
* Department of Natural Resources, Madison, Wisconsii
5
JACOB D. DUMELLE, Member, Illinois Pollution
6
Control Board, Chicago, Illinois.
7
3
PARTICIPANTS:
9 " '•
Hon. Abner J. Mikva, U.S. House of
10
Representatives, Washington, D.C.
11
David Cleverdon> Executive Assistant to Congress-
12
man Mikva, Second Congressional District, Washington, D.C.
13
Hon. Adlai E. Stevenson, III, United States
14
Senate, Committee on Banking, Housing and Urban Affairs,
15
Washington, D.C.
16
Mrs. Samuel Rome, Member, President's Water
17
Pollution Control Advisory Board; and League of Women
Voters, Chicago, Illinois.
19
Leonard B. Young, Regional Engineer, Federal Power
20
Commission, Chicago, Illinois.
21
Enrico Conti, Assistant to the Manager for
22
Environmental Activities, Chicago Operations Office, Atomic
23
Energy Commission, Argonne, Illinois.
24
Hon. Richard B. Ogilvie, Governor of Illinois,
25
Springfield, Illinois.
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6
7
PARTICIPANTS (continued)
Mrs. Helen Hoock, Chairman, Community Action to
Reserve Pollution (CARP), Gary, Indiana.
Dr. Donald I. Mount, Ph.D., Director, National
Water Quality Laboratory, Duluth, Minnesota.
Bruce A. Tichenor, Ph.D., Chief, Hydrographic
Branch, National Thermal Pollution Research Program,
Corvallis, Oregon.
Mrs. Harry Janis, Chairman, Lake Michigan Inter-
9
League Group, League of Women Voters, Chicago, Illinois
10
Mrs. Jack Troy, President, Save the Dunes Council
11
Munster, Indiana.
12
Mrs. L. W. Bieker, Division Board, American
13
Association of University Women (AAUW) , Indiana State
14
Division, Munster, Indiana,
15
Edwin Neimeyer, President, Lake County Council of
16
Conservation Clubs and Affiliates, Inc., Gary, Indiana.
17
Henry G. Zaner, III, President, Evans ton -North
Shore Board of Realtors, Chicago, Illinois.
19
Hon. Patrick J. Lucey, Governor, State of
20
Wisconsin, Madison, Wisconsin.
21
Mrs. R. Collins, International Representative,
22
Department of Conservation, United Auto Workers, Detroit,
23
Michigan.
24
Ted Falls, President, Porter County Chapter,
25
Izaac Walton League of America, Wheeler, Indiana.
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viii
1 j PARTICIPANTS (continued)
2 Arthur Pancoe, Scientific Director of Society
Against Violence to the Environment and Campaign Against
Pollution, Glencoe, Illinois.
5
, Mrs. Grace Knapp, Milwaukee Audobon Society,
o
Milwaukee, Wisconsin.
d Mrs. Lee Botts, Executive Secretary, Lake
8
Michigan Federation, Chicago, Illinois.
Robert Cramer, Campaign Against Pollution, Chicago,
Illinois.
.. Mrs. Harriet Sherman, Citizen, Chicago, Illinois.
,, Dr. Peter Bertoncini, The Committee for
15
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IS
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20
21
22
23
24
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Ecological Action, Bellwood, Illinois.
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IX
Mrs. Mervin S. Abrams
League of Women Voters
1162 Terrace Ct.
Glencoe, 111. 60022
Anne M. Alberts
Campaign Against Pollution
600 W. Fullerton
Chicago, Illinois
Dr. S.R. Aldrich
HI. Pollution Control Board
N - Ml Turner Hall, U. of I.
Urbana, ni. 6l801
Donald B. Arps
Supervisor of Environmental Control
Combined Paper Mills, Inc.
Combined Locks, Vis.
Charles A. Bane
Commonwealth Edison
Lawrence P. Beer
Manager, Environmental Sciences
Industrial Bio - Test Lab.
l8lO Irontaze Rd.
Northbrook, 111. 60062
Irving Bernstein
Chemical Engineer
EPA, WQO, REGION V
33 E. Congress Parkway
Chicago, .HI. 60605
Dr. Peter J. Bertoncini
Water Pollution Chairman
Committee for Ecological Action
5^30 W. Monroe St.
Chicago, 111. 6o6kk
J.G. Asbury
Physicist, Argone Nat'l Lab.
9700 S. Cass
Argone, 111.
Micheal Bialas
Chicago Area Council of Liberal Churches
11030 S. Wallace
Chicago, 111. 60628
A.F. Aschoff
Head Environmental Division
Sargent & Lundy
IkO S. Dearborn
Chicago, HI.
J0hn H. Bickley Jr.
Chief, Environmental Control
Attorney General Of HI.
160 N. LaSalle
Chicago, HI.
Mrs. Dean Asselin
Grand Mere Association
U.F.S. Benton Harbor
2826 S. Lake Shore Dr.
Chicago, 111.
Burton H. Atwood
Field Representative
U.S. Dept. of Interior
2510 Dempster St.
Des Plaines, 111. 60016
John C. Ayers
University of Michigan
Ann Arbor, Michigan
Mrs. L.W. Bieker
Indiana Div. AAUW
115> Ridge Rd.
Monster, Indiana
Harry V. Bierma
Chairman, Clear Streams Committee
Illinois Audubon Society
6te5 W. 32nd St.
Berwyn, 111. 60^02
R.M. Billings
Director of Environmental Control
Kimberly Clark Corporation
862 E. Cecil St.
Neenah, Wisconsin
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Irs. James Blake
Action Chairman - League of Women Voters
281 Linden Ave.
Glencoe, 111. 60022
William L. Blaser
Acting Director
Illinois Environmental Protection Agency
2200 Churchill
Springfield, 111. 62706
Edward H. Bryan
Manager Environmental Projects
Ecology Division, Rex Chainbelt
P.O. Box 2022
Milwaukee, Wisconson 53201
Mrs. Janice M. Burgos
Gads Hill Action Group
1919 W. Cullerton St.
Chicago, 111.
Carl T. Blomgren
Environmental Control Engineer
Illinois Environmental Protection Agency
1919 W. Taylor St.
Chicago, 111. 60612
Mrs. Lee Botts
Executive Secretary
Lake Michigan Federation
53 W. Jackson
Chicago, 111.
Jeanne Bonynge
Lake Michigan Inter-league Group
1120 Chestnut
Wilmette, 111. 60091
Gloria Brady
President
Committee for Ecological Action
24l Bohland Ave.
Bellwood, 111.
John R. Brough
Director, Air & Water Control
Inland Steel Co.
3210 Watling St.
East Chicago, Indiana U6312
Amos H.C. Brown
Clean Environment Comm.
Mid-North Association
2339 Commonwealth Aye.
Chicago, in. 6o6ll*
Mrs. Delores A. Burkee
Chemist, Kenosha Water Utility
100 - 51st Place
Kenosha, WI
John Burnett
Loyola University
820 N. Michigan
Chicago, HI.
Sol Burstein
Senior Vice President
Wisconsin Electric Power Co.
231 W. Michigan St.
Milwaukee, Wisconsin 53201
John T. Case
Treasurer
Izaak Walton League of America
1326 Waukegan Rd.
Glenview, m. 60025
Evelyn Cheslow
Glencoe L.W.V.
n5^ Carol Lane
Glencoe, HI. 60022
Ralph G. Christensen
Physical Scientist
EPA, WQO, Region V
33 East Congress Parkway
Chicago, 111. 60605
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Gary K. Coates
Engineer - Manager,
Water Pollution Control Division
City of Racine
2101 S. Main St.
Racine, Wisconsin 53^03
Mrs. Phyllis Cohodes
League of Women Voters
37 Turribull Woods
Highland Park, 111.
Mrs. Miriam G. Dahl
State Div. Chairman,
Water Committee, IWLA
5832 N. Lake Dr.
Milvauke Wisconsin 53217
D.M. Dailey
Vice President,
Citizens of Greater Chicago
5726 Stony Island Ave.
Chicago, HI. 60637
Ruth Collins
Int. - Rep. Dept. Conservation
United Auto Workers
5132 W. Harrison St.
Chicago, HI.
David Dinsmore Comey
Director of Environmental Research
Businessmen for the Public Interest
109 N. Dearborn, Suite 1001
Chicago, 111. 60602
James M. Conlon
Radiation Office, EPA
433 West Van Buren
Chicago, 111. 60607
Mark Coup
Park Forest, m. 60^66
Eleanor Coup
Secretary - Treasurer
South Suburban Water Committee
League of Women Voters
359 Wilshire
Park Forest, 111. 6oU66
Robert Creamer
Campaign Against Pollution
600 W. Fuller-ton
Chicago, 111.
Mrs. Frederic A. dePeyster
696 Prospect
Winneska, 111. 60093
Fred P. Dobbins
Sanitary Inspector
State of 111., EPA
1919 W. Taylor
Chicago, m. 60612
Charles G. Doehrer
Editor
Free Chicago Graphic
P.O. Box 1832
Chicago, HI. 60690
Mrs. Cory Domanovski
Gads Hill Action Group
1919 W. Cullerton
Chicago, HI. 60608
A. Joseph Doud
Assistant Chief Counsel
American Electric Power
New York, New York
Rev. Leonard Dubi
Co -Chairman, CAP
600 W. Fullerton Ave.
Chicago, 111.
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xii
J.J. Dwyer
Engineer Environmental Control
Chesapeake & Ohio Railway Co.
P.O. Box 907
Huntington, W. Virginia 25712
Carlos Fetterolf
Supervisor, Water Quality Appraisal
Michigan Water Resources Commission
Mason Building
Lansing, Michigan
John R. Eyer
Environmental Relations
Consumers Power
Jackson, Michigan
Dr. D.N. Edgington
Associate Chemist
Argonne National lab
Argonne, 111.
Mrs. Mildred Erhardt
Chairman, Environmental Quality
League of Women Voters
338 Forest
River Forest, 111. 60305
Mrs. Robert G. Erickson
No. Centra Audubon Council
3328 N. Main St.
Racine, Wisconsin 53402
William J.D. Escher
Founding Associate
Escher Technology Associates
P.O. Box 189
506 S. Clinton Ave.
St. Johns, Michigan 48879
Ted Falls
Porter County Chapter
Izaak Walton L.
Wheeler, Indiana 46393
A. William Finke
Attorney
Wisconsin Electric Power Co.
231 W. Michigan St.
Milwauke, Wisconsin
Edward G. Fochtman
Mgr. Water Research Center
IIT Research Institute
10 W. 35th Street
Chicago, 111. 60616
Sam Foust
Pollution Control Coordinator
Union Carbide
P.O. Box 750
Whiting Ind. 46394
James A. Fowler
Atlantic Richfield Co.
3500 Indianapolis Blvd.
East Chicago, Indiana
Arthur A. Frigo
Assistant Mechanical Engineer
Argonne National Laboratory
Center for Environmental Studies
9700 So. Cass
Argonne, IL 60439
Larry Gattin
5757 S. University Ave.
Chicago, 111. 6o637
G.P. Ferrazzano, M.D.
Commissioner of Health
City of Racine
730 Washington Ave.
Racine, Wisconsin 53403
Paul Goodman
Committee on Lake Michigan Pollution
Box 583
Wilmette, HI. 60091
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xiii
Lowell Gomes
Senior Associate
T.S. Leviton & Associates
208 S. LaSalle
Chicago, 111.
Phyllis Ann Gregory
John K. Langum (Business Economics)
209 S. LaSalle
Chicago, 111.
Mr. L. Griffin
5755 S. Bishop
Chicago, HI. 60636
John E. Gunnon
Limnologist
Center for Great Lakes Studies
University of Wisconsin-Milwaukee
Milwaukee, Wisconsin
Marilyn Hall
Marilyn Hall Associates
Court and Convention Reporting
1372 Thurell Road
Columbus, Ohio 1*3229
Jill Hallahan
John K. Langum, Business Economics
209 S. LaSalle St.
Chicago, HI.
Joan Harper
League of Women Voters
Box 52 Rt. 3
Cretz, 111. 6oiH7
Dan Hartman
Supt. of Utilities
National Steel Corp
Mid-West Steel Div.
John Hedrick
Application Engineer
The Marley Co.
Ill W. Washington
Chicago, ni. 60602
James B. Henry
Vice President & Gen. Counsel
American Electric Power Service .Corp.
2 Broadway
New York, New York 1000^
Mrs. Constance Herman
Illinois Wildlife Federation
3735 Morton Ave.
Brookfield, Hi. 60513
Judy Heyman
3296 Brook Rd.
Highland Park, 111.
K.W. Hamming
Sr. Partner
Sargent & Lundy
Ik0 S. Dearborn St.
Chicago, 111.
Frank Ho
Assitant Engineer
Pioneer Service & Eng. Co.
1*00 W. Madison
Chicago, 111.
Dr. R.V. Harmsworth
Limnetics Inc.
6132 W. Fond Du Lac Ave.
Milwaukee, Wisconsin 53218
Lester 0. Hoganson
City Engineer
City Hall
Racine, Wisconsin 53^03
John D. Harper
Director, n&BO
Box 83 Rt. 1
Elgin, 111. 60120
Dorothy J. Howell
Microbiplogist
MSD of Greater Chicago
5901 W. Pershing
Cicero, HI. 60650
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xiv
Jack L. Hupke
Environmental Control Chemist
122 W. Washington
Madison, Wisconsin
Connie Hurlent
Commonwealth Ed.
1st National
Evan W. James
Sr. V.P. - Power Gen. & Engr.
Wis. Public Service Corp.
600 N. Adams St.
Green Bay,Wisconsin
Mrs. Harry Janis
Chairman
Lake Michigan Inter-League Group
League of Women Voters
Rt. 1
Williamsburg, Michigan 1*9690
James W. Jardine
Commissioner Water & Sewers
City of Chicago
Room 1*03, City Han
Chicago, 111. 60602
M.A. Jaroch
Enviornmental Specialist
UWM Engineering Dept.
Milwaukee, Wisconsin 53201
B.G. Johnson
Tech. Mgr. -Environmental Sciences Div.
Industrial Bio-Test Labs, Inc.
1810 Frontage Rd.
Northbrook, 111.
Eileen L. Johnston
505 Maple Ave.
Wilmette, 111. 60091
Mrs. J. Barton Kalish
21*19 St. Johns
Highland Park, in.
Renee S. Kane
League of Women Voters
R.E. Kary
Swanson Environmental Consultants
105 W. Madison
Chicago, ELL. 60602
Steven E. Keane
Attorney
Wis. Pub. Service Corp.
735 N. Water St.
Milwaukee, Wisconsin 53202
David Kee
D-linois Ponution Control Board
189 W. Madison
Chicago, HI.
Frank N. Kemmer
Market Mgr., Ponution Contol Dept.
Nalco Chemical Company
180 N. Michigan Ave.
Chicago, m. 60601
Charles W. Kern
Environmental Technologist
Northern Indiana Public Service Co.
5265 Hohman Ave.
Hammond, Indiana
Paul Keshishian
Director of Power Production
Wisconsin Power & Light Co.
Richard Kissel
minois Pollution Control Board
189 W. Madison St.
Chicago, in.
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XV
Mrs. Sidney C. Kleinman
Glencoe League of Women Voters
178 Maple Hill
Glencoe, 111.
S.T. Lawton,Jr.
HI. Pollution Control Board
189 W. Madison
Chicago, 111.
Mrs. David Koch
League of Women Voters
3lB Marshman
Highland Park, 111.
G. Fred Lee
Professor of Water Chemistry
U. of Wisconsin
Madison, Wisconsin 53706
Rdbert M. Kopper
Executive Vice President
Indiana & Michgian Electric Co.
2101 Spy Rum Ave.
Fort Wayne, Indiana
Dr. A.R. LeFeurre
Environmental Quality Coordinator
Canada Centre for Inland Waters
Box 5050
Burlington, Ontario Canada
Edward A. Krenzke
City of Racine
City Hall
Racine, Wisconsin
Bennet C. Kwan
Chemist
Indiana Bio-Test Lab., Inc.
1510 Frontage Road
Northbrook, IL
Mel Lamble
Biologist
Bio-Test
Northbrook, 111.
John Langum
President
Business Economics
209 S. LaSalle
Chicago, 111.
Fred H. Larson
Commissioner of Public Works
City of Racine
730 Washington Ave.
Racine, Wisconsin
Kenneth Leaner.
Supt. of Chemical Services
Wisconsin Electric Pover Co.
231 W. Michigan St.
Milwaukee, Wisconsin
George Leposky
5046 S. Woodlawn Ave.
Chicago, 111. 60615
Alvin Liebling
Asst. Attorney General
George R. Louthan
706 Locust St.
Sterling, 111.
Mrs. Louise T. Lunak
Mid-North Clean Environment Comm.
1922 N. Sedgwick St.
Chicago, 111.
Erling H. Lunde
Volunteer Administrator
Citizens of Greater Chicago
18 S. Michigan Ave.
Chicago, 111. 60603
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xvi
Ted MacDonald
Luningston Hills Associattion
La layette, Indiana
Kenneth A. Manaster
Assistant Attorney General,
State of Illinois
188 West Randolph St., Suite 2300
Chicago, HI. 60601
Donald W. Marshall
Sanitary Engineer Director
EHS/EPA - Region V
toW. Van Buren
Chicago, HI. 6o602
Miss Edith M. McKee
Chief Geologist
Leviton & Associates
208 S. LaSalle
Chicago, HI.
Jerry McKersie
Chief Water Qaulity Evaluation
Wisconsin Dept. Natural Resources
P.O. Box U50
Madison, Wisconsin
M.A. McWhinnie, Professor
DePaul University
1036 Belden Ave.
Chicago, HI. 6o6lk
Helen Meier
15810 South Park
South Holland, HI.
60^73
Hildegarde Melzer, Chief
Clean Environment Committee
Mid - North Assoc.
bk2 Belden Ave.
Chicago, HI.
Mrs. Alice Mikals
CAP
51^6 S. Nagle
Chicago, IL
Renee Mikals
CAP
51U6 S. Nagle
Chicago, IL
Priscilla Zlatoff - Mirsky
2599 S. Johns Ave.
Highland Park, HI. 60035
T.A. Miskimem
Sr. Engineer
Indiana & Michigan Electric Co.
2 Broadvay
New York, N.Y. 1000^
Robert G. Mowers
Technical Assistant
Standard Oil Company (ind)
910 S. Michigan
Chicago, 111. 60605
Bruce Muench
Pish Biologist
Bio-Test Ind.
Northbrook, 111.
Mrs. James Mulqueeny
CAP
56*4-2 S. Merrimac
Chicago, HI. 60638
Rose Marie Naputano
CAP
2913 N. Elston
Chicago, HI. 60618
Abigail Natenshon
Exec. Secretary
HI. Planning & Conservation League
Kenneth D. Mendelson
1826 Rosemary Rd.
Highland Park, HI. 60035
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xvii
Win. R. Nelson
Dir. R & D
Green Bay Packaging, Inc.
Green Bay, Wisconsin 5^-305
David R. O'Donnell
Hydraulic Engineer
Pioneer Service & Engineer Co.
2 N. Plaza
Chicago, 111.
Dr^M.J. Oestmann
Associate Chemist
Argonne Nat. Lab.
9700 S. Cass Ave.
Argonne, HI.
Richard A. Ott
Illinois State Medical Society
360 N. Michigan
Chicago, 111. 60601
Richard A. Pavia
Deputy Commissioner of Water & Severs
Chicago Dept. Water & Sewers
Room U03 City Hall
Chicago, HI.
Mrs. Nisson Pearl
966 Garvell' Lane
Highland Park, HI.
Bill Pell
Joseph A. Pelletier
Northern Indiana Public Service Co.
5265 Hohman Ave.
Hammond, Ind.
Ed Perkins
Staff Writer, Tribune
So. Bend, Ind.
Mrs. Louis H. Palmer, Jr.
Chairman, Environmental Quality Comm.
Racine League of Women Voters
1715 College
Racine, WI
Gunnar A. Peterson
Executive Director,
Open Lands Project
53 W. Jackson Blvd.
Chicago, HI. 6o6ol«.
Arthur Pancoe
Scientific Dir. of SAVE & CAP
Box Qk
Glencoe, HI. 60022
Paul Partak
Water Pollution Chairman
111. Wildlife Fed.
Cook Co. Council
5508 W. 23rd St.
Chicago, 111.
R.W. Patterson
Sargent & Lundy
1^0 S. Dearborn St.
Chicago, HI. 60603
O.K. Peterson
Attorney
Consumers Power Co.
212 W. Michigan Ave.
Jackson, Michigan 1*9201
Wesley 0. Pipes
Professor of Civil Engineering
Northwestern University
Evanston, 111. 60201
Dr. Anthony J. Policastro
Assistant Engineer
Argonne National Laboratory
9700 S. Cass Ave.
Argonne, 111.
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xviii
H.W. Poston
City of Chicago
320 N. Clark
Chicago, 111. 60610
Walter Romanek
111. Pollution Control Board
189 W. Madison St.
Chicago, 111.
Ralph E. .Purdy .
Executive Secretary
Water Resources Comm.
Mason Building
Lansing, Michigan U8923
Catherine T. Quigg
Pollution & Enviornmental Problems
838 Harriet
Barrington, HI.
Robert R. Raisanen
Manager of Environmental Quality
Upper Peninsula Power Co.
6l6 Shelden Ave.
Houghton, Michigan
John Reynolds
Environmental Planner
Consumers Power Co.
Jackson, Mich. 1*9201
Charles P. Riefstahl
Mrs. Alan Rosenwald
Glencoe League of Women Voter
Glencoe, 111. 60022
Phillip Rothenberg
Sr. Assistant Atty.
MSD of Greater Chicago
100 E. Erie
Chicago, HI.
Mrs. Sarah B. Schaar
Save-The-Dunes-Council
Chesterton, Ind.
Bernard E. Schaar
Save !Rie Dunes Council
1360 Lake Shore Dr.
Chicago, 111. 60610
Robert A. Schacht
Supervisor, Lake Michigan Basin Unit
Surveillance Section
710 Hillside
Elmhurst, IL 60126
Francine Rissman
290 Briar Lane
Highland Park, 111.
Voanne D. Rocker
Environmental Chairman
League of Women Voters
10^12 Jennings
Crown Point, Indiana 46307
Stephen Roffler , Graduate Assistant
University of Wisconsin
925 University Ave.
Madison, Wisconsin
Mrs. Richard H. Schnadig
Glencoe League of Women Voters
379 Jackson Ave.
Glencoe, HI. 60022
Harriet Sherman
7119 S. Crondon Ave.
Chicago, 111.
Anne Socha
CAP
5^30 S. Narragarselt
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XIX
W.K. Specht
Dir. of Plant Engr.
J.I. Case Co.
TOO State St.
Racine, Wisconsin
Mrs. Jack Troy
President
Save the Dunes Council
1512 Park Dr.
Munster, Ind.
Dr. W. Brevster Snow
Associate, Quirk, Lawler
& Matusky Engineers
505 Fifth Avenue
New York, NY 10017
Steven A. Spigarelli
Ecologist
Argonne National Lab.
Argonne, 111.
Matthew J. Stahl
Sanitary Engineer
U.S. Naval Base
Great Lakes, 111.
Raynor F. Sturgis
Consultant-Pollution Abatement
Room 1002 300 N. State St.
Chicago, 111.
Fred 0. Sullivan
Sanitary Engineer
Corps of Engineers
219 S. Dearborn St.
Chicago, 111. 6060U
A.W. Tuemler
Ass't to Works Chief Engineer
U.S. Steel Corp.
Stan Twardy
P.R. Coordinator
Air & Water Conservation
Standard Oil Co.
810 S. Michigan Ave.
Chicago, 111.
James C. Vaughn
Dept. of Water & Sewers
1000 E. Ohio St.
Chicago, 111. 60611
Frank I. Vilen
Kenosha Water Utility
100 51st Place
Kenosha, Wisconsin
Mark fc. Virstibo
Attorney
Commonwealth Edison
Chicago, in. 60620
Jon R. Swanson Joseph F. Voita
Director, Swanson Environmental Consultants 229 N. Taylor Ave.
105 W. Madison, Suite 9<& Oak Park, 111.
Chicago, 111.
Robert Terrell
Marine Studies Center
Univ. of Wisconsin
Madison, Wisconsin 53706
F.E. Thompson
Sen. Proj. Engr.
Union Carbide Corp.
Box 750
Whiting, Ind.
Mrs. J. F. Voita
Open Lands
229 N. Taylor Ave.
Oak Park, 111. 60302
Gilbert Vosswinker
Civil Engr. V
City of Milwaukee
3^1 N. Broadway Rm. 8l2
Milwaukee, Wisconsin 53202
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Ralph Weaver
Pioneer Service & Engineering Co.
2 N. Riverside Plaza
Chicago, 111.
Roy A. Wells
Executive Director,
Environmental Activities
Consumers Power Co.
212 W. Michigan Ave.
Jackson, Michigan
B.F. Willey »
Director, Water Purification Laboratory
Bureau of Water
1000 E. Ohio St.
Chicago, 111. 60611
David H. Williams Jr.
Assistant Vice President
American Electric Power Service
2 Broadway
New York, New York
Wm. Walker
Reporter
CBS News
New York, New York
Ruth Wander
League of Women Voters
2023 Linden Ave.
Highland Park, 111. 60035
Mrs. Isabel B. Wasson
League of Women Voters
606 Thatcher Ave.
River Forest, Illinois
David P. Welch
Sanitary Engineer
US EPA WQO
33 E. Congress Parkway
Chicago, 111. 60605
Corp.
T.A. Winkel
Superintendent Steamships
Chesapeake & Ohio Railway Co.
Ludington, Michigan
Gery Witt
12U3 Glencoe Ave.
Highland Park, 111.
60035
Richard Frederick Wood
Attorney
320 Circle Ave.
Forest Park, 111. 60130
Jess A. Wood
Chief Chemist
Cities Service Oil Co.
1*900 Cline Ave.
East Chicago, Indiana 46312
Steve Yates, Attorney
Illinois Planning & Conservation League
122 S. Michigan
Chicago, HI.
Board of Realtors
Henry G. Zander III
President
Evanston - North Shore
3009 Central Street
Evanston, 111.
D.H. Brandt
Consumers Power Co.
19^5 Parnall Rd.
Jackson, Michigan
Anne Alberts, CAP
600 W. Fullerton
Chicago, HI.
Robert J. Baker, Technical Director
Wallace & Tiernan Div., Pennwalt Corp.
25 Main St.
Belleville, New Jersey 07109
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Harriette Bowman
CAP
5837 S. Muhhigan Ave.
Chicago, IL
Charles A. Bane
Partner, Isham, Lincoln, Beale
Commonwealth Edison Company
One 1st National Bank Bldg,
Chicago, IL
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Opening Statement - ibtrray Stein
OPENING STATEMENT
MURRAY STEIN
MR. STEIN: The conference is open*
This reconvening of the Third Session of the Con-
f erence in the Matter of Pollution of Lake Michigan and its
Tributary Basin in the States of Wisconsin, Illinois,
Indiana, and Michigan is being held under the provisions
of section 10 of the Federal Water Pollution Control Act,
*
as amended* The Third Session, which this is, first met
on March 31 and April 1 of 1970* The conference reconvened
on May 7* 1970, and workshop sessions were held on
September 2# through October 2, 1970* An Executive Session
f~ "
was held on October 31, 1970* Under the provisions of the
Act, the Administrator of the Environmental Protection
Agency, is authorized to call a conference of this type
when requested to do so by a Governor of a State, and when,
on the basis of reports, surveys, or studies, he has reason
to believe that pollution subject to abatement under the
Federal Act is occurring*
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Opening Statement - Hurray Stein
As specified in section 10 of the Act, the
Administrator of EPA has notified the official State water
pollution control agencies of this conference* These
agencies are the Wisconsin Department of Hatural Resources,
the Illinois Environmental Protection .Agency, the Indiana
Stream Pollution Control Board, and the Michigan Water
Resources Commission.
We have had many conferences on Lake Michigan*
Many of you people have attended these conferences before*
As you know, the purpose of the conference is to bring
together State water pollution control agencies, repre-
sentatives of the Environmental Protection Agency and
other interested parties to review the existing situation,
the progress which has been made, and lay a basis for
future action by all parties concerned and to give the
States, localities, and industries an opportunity to take
any indicated action under State and local law*
We have developed an extensive abatement program
for Lake Michigan under the auspices of this conference
dealing with a wide variety of municipal and industrial
waste sources* Requirements have been set for these
municipalities and industries, time schedules have been
set, and we think the conferees of the States and the Federal
Government have taken care to see that these time schedules
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1 Opening Statement - Hurray Stein
2 were met and we hare taken action when slippage appeared
3 from tine to time*
4. X think we hare had a considerable measure of
5 success in the abatement program so far, and I dare say
6 that the municipal-industrial water pollution control
7 abatement program for Lake Michigan is probably as actire
g and as extensive as any program in the United States*
9 We did know when we started this program that we
10 were dealing with a very, very complex situation* There
11 is not too much known about all the answers to the Great
12 Lakes, although we certainly know a lot more than when we
13 started*
14 The Great Lakes, their origin, the reason the
15 waters remain fresh, the fate of pollutants in the lake,
16 in large measure remains a mystery to this day* What we
17 are trying to do is use the best modern techniques to pre-
1$ serve these lakes, because I have said again and again, but
19 it bears repeating, that the Great Lakes are the greatest
20 single freshwater source in the free world and we must
21 preserve them*
22 The problems that we are dealing with now are
23 problems concerning thermal pollution or heat discharges
24 to the lake* This is a relatively new subject, and the
25 reason for the many previous sessions and workshop
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1 Opening Statement * Murray Stein
2 sessions of the Third Session of the conferenoe has been
3 due to the fact that we were grappling with a new very
4 prickly problem on which there are clearly many, many
5 divergent points of view*
6 These points of view were expressed with consid-
7 erable clarity and force at previous sessions and workshop
$ sessions of the conference* I am sure that the States, the
9 citizens groups and industry has carefully considered all
10 of the points of view and have come up with conclusions
11 possibly in their own mind of suggestions to make^which
12 hopefully are a little more developed and a little more
13 mature on all sides than we may have had previously, because
14 now we have had the advantage of hearing all the opposing
15 points of view, hearing them analyzed, hearing them
16 criticized and attacked, and hearing these points of view
17 defended*
13 The primary purpose of this session of the con-
19 ferenee today, as announced in the agenda, will be to
20 consider the question of heat discharges in thermal
21 pollution* We do recognise that there are other problems
22 that some of the people want to take up, and some of the
23 State agencies want to bring up, and that we want to bring
24 up, and these are certainly of vital importance*
25 One of these problems will be the question of
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Opening Statement - Murray Stein
phosphates, and whether we have adequately considered the
impact of the runoff from farmland in phosphates. In light
of our experience and present knowledge to protect the lake
we also have the problem of whether our phosphates program
we adopted at the last conference is sufficient. We said
that the States would have to embark on the program, which
they have, to cut the municipal loading of phosphates
^0 percent on a Statewide basis.
Another question which has come up several times
and we have not considered in the Lake Michigan conference
but considered in other parts of the country is the
question of discharge of chlorides to the lake. Obviously,
this is an important matter in dealing with a freshwater
lake and trying to maintain it as a freshwater lake.
We will also be open to other pertinent issues
which any of the citizens, the industries, the municipali-
ties, or the States feel appropriate.
However, for the purpose of the record, I would
suggest that we stick to the thermal presentations today.
In other words, anyone who is going to speak on these other
topics will probably not be called today.
We are going to have a Federal presentation firstj,
and since this is a session of a conference in the usual
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1 Opening Statement - Murray Stein
sense of the term and not a workshop session, we are going
to refer to our usual practice in letting the States manage
their own time. After the Federal presentation is con-
eluded, we will call on the States in series — the States
can make their own presentation or use their time to call
on a representative from that State to make the statement,
and then we will call on the next State.
I think you all have to recognize that with all
the people wanting to make presentations, we have to have
some sort of order and not everyone can go first. We will
try to make this as equitable as possible. I am sure we
will have a break or a recess after the Federal presenta-
tion.
,c At that time, if you have any special problem
with the time you feel you might appear, see your State
agency. It will call you, and it will manage the time for
you and have an appropriate time to appear if it is
possible.
I ask you to cooperate with us on this. Again,
one of the most difficult things in preparing a case is the
mechanics of running that case. Many of the lawyers in the
audience and on the panel know that is when you can
bring a witness to the stand. And the problem with that
is, 1) you don't know how long someone is going to talk
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Opening Statement - Murray Stein
when he gets on the stand, 2) you don't know how long the
questioning is going to take. You are dealing with these
unknowns and therefore you have to be patient and try to
work your way through.
Now, just as an aside, the last time we were here
in a workshop — and I know a lot of people were restless
— I tried to get the cards in order, so that people who
said they would speak for only one minute were put on
first, in order to get them out of the way. Many who were
repeats in the audience know what happened. The concept
of 1 minute on the clock and that of the people who got up
to speak for 1 minute was not exactly the same.
So I would ask that you try to be patient and
that you try to work out with your State representative
when you are going to appear. If there is any acute
problem that can't be resolved on that basis, you and the
State representative may come to me and we will try to work
it out.
Now, with that I would like to again ask that
the usual rules apply. Except the conferees, everyone should
come to the lectern to make his statement, identify himself
for the purpose of the record, and as usual we will
have questioning by the conferees. Everyone in the
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Opening Statement - Murray Stein
2 audience, however, will be allowed to make a full statement*
3 As this is not a workshop, hopefully we will get through
much more rapidly than we hare in the past*
I would like to ask the people at the panel
table to identify themselves. Could we start right to my
left, please?
MR. MACKIEi Donald Maekie of the Wisconsin
9 Department of Matural Resources,
10 ME* FRANCOS: Thomas Frangos, Wisconsin Department
11 of natural Resources*
12 MR* DUMELLE; Jacob Dumelle, Member of the
Illinois Pollution Control Board*
14 MR* CURRIE: David Currie, Chairman of the
15 Illinois Pollution Control Board* \
16 MR* BLASSRt William Blaser, Director of the
17 Illinois Environmental Protection Agency,
18 MR. BRTSONt Bale Bryson, Federal Environmental
19 Protection Agency*
20 MR* MAIOs Francis T* Mayo, Regional Director,
2i Region V of the Water Quality Office of the Environmental
22 Protection Agency, and the Federal conferee*
23 MR* HARTLEY* Robert Hartley, Environmental
24 Protection Agency, Region T*
25 MR* HERTs Oral Hert, Director, Division of Water
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Opening Statement - Murray Stein
Pollution Control, Indiana*
MR. MILLER i Perry Miller, Technical Secretary,
the Indiana Stream Pollution Control Board, and the conferee
for Indiana*
ME. PURDY: Ralph Purdy, Executive Secretary,
Michigan Water Resources Commission, Michigan conferee*
MR* FETTEROLFt Carlos Fetterolf, Supervisor of
Water Quality Appraisal for the Michigan Water Resources
Commission in the Bureau of Water Management*
MR* STEIM: And I am Murray Stein from the
Environmental Protection Agency, Washington, D*C*, and a
representative of Administrator Ruekelshaus*
Before we start, I would like to again call your
attention to the fact that we are making —
«•• Cries of "Can't hear you" •••
MR* STEIN: Before we start or continue, I would
like to make an announcement that we are making a verbatim
transcript of the statements made here of the entire pro-
eeedings* This transcript is made by Mrs* Hall, who is an
independent contractor* If you should require or feel you
want any portion of the transcript or the entire transcript
prior to the time that it appears, you should make your
own arrangements with Mrs* Hall* Usually we will not get
the transcript printed for about 3 or 4 months, then we will
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F* T. Mayo
make it available to the State agencies represented here,
and it is available to all*
Let's continue with the Federal presentation now,
Mr* Mayo*
6
7 STATEMENT OF FRANCIS T, MAYO, REGIONAL
DIRECTOR, REGION Y, WATER QUALITY OFFICE,
ENVIRONMENTAL PROTECTION AGENCY, CHICAGO,
10 ILLINOIS
11
12 NR« MAYOs Mr* Chairman, fellow conferees, ladies
and gentlemen* Administrator Ruckelshaus has directed to
each of the conferees a letter expressing the concern and
the position of the Environmental Protection Agency with
respect to the need for thermal discharge controls on
Lake Michigan* Identical letters have gone to each of the
conferees*
I am going to read for the record that letters
20 "The Lake Michigan Enforcement Conference will
reconvene today* The major subject of the Conference will
22 be the need to protect Lake Michigan from the threat of
23 damage by large volume discharges of heated water* I am
24 anxious at this time to express my personal concern for
25 this problem I urge the Conference to adopt strong
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F. T. Mayo
standards to protect these valuable and vital waters.
"A considerable and growing body of evidence
indicates that serious ecological damage will be caused by
the increasing use of Lake Michigan waters to dissipate
waste heat. The intake and discharge of waters used for
cooling purposes, particularly by the electric power
industry, is already large and is rapidly increasing in
response to growing needs for electric power. At the present
time 26 generating facilities are using Lake Michigan waters,
all using once-through cooling. Plants planned or uader
construction will almost double present capacity within a
few years. It is anticipated that a great many additional
power-plants will be located on the shores of Lake Michigan
by the year 2000. The prospective waste heat load from
these plants poses a serious threat. Although other heat
sources to the lake, such as industrial and municipal waste
discharges, are minor in comparison to that of the power
industry, they, too, are a source of concern.
"Thermal effects from unrestricted waste heat
discharges may cause profound impacts on water quality and
thus on other legitimate water uses. These effects are most
serious in the shallow waters near the shore. The possible
risks to Lake Michigan were described in a report prepared
by the United States Department of the Interior in
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1 F. T. Mayo
2 September 1970 entitled /'Physical and Ecological Effects
3 of Waste Heat on Lake Michigan'. This report pointed out
4 that 'fhe inshore zone is in many respects the most important
5 portion of Lake Michigan. It is the most used by man and is
6 the most biologically productive,' . The report also stated:
7 'At times very large percentages,..of the waste heat
& discharged to the lake are diffused into the beach water
9 zone; and studies of model plumes indicate that the influenc
10 of the heated water from a single discharge can cover many
11 areal miles of the lake. '
12 "Plumes of heated water have been shown to alter
13 the habits of fish by excluding them from areas of such heat
14 water near shorelines, and by producing stress and possible
15 mortality in the event of rapid cooling. Such plumes create
16 broad areas of thermal influence in inshore waters
17 influencing critical life history stages of certain fish and
13 other aquatic organisms in the vicinities of such discharges
19 "During the warmer seasons, waste heat accelerate;s
20 the process of emtrophication within, and probably outside,
21 the discharge area. Research indicates that added heat
22 alters the usual population composition of algal species
23 and heightens conditions favorable to the development of
2^- Clostridium botulinum type E bacteria during warmer seasons.
25 The rate of emtrophication is controlled primarily by
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F. T. Mayo
nutrient supply and water temperature, either of which may
limit productivity. Nutrient levels in certain areas of
Lake Michigan are now approaching critical levels, and a
widespread, shallow water warming influence would contribute
to accelerating eutrophication.
"Several major programs of resource management ar«
also affected. The ultimate success of the United States-
Canadian sea lamprey control program, the State and Federal
lake trout program, alewife control, and various sport fisher
ies programs are all dependent upon the preservation of
high quality lake waters,
"Those risks from waste heat discharges can be
avoided. Alternatives to the use of once-through cooling
are known and increasingly in use. Evaporative or dry coolirg
towers, cooling towers, cooling ponds or spray cooling canals
can be employed in closed cycle cooling systems. The chemicsl
and petrochemical industries in this country have used
cooling towers as part of standard practice. In England
nearly 300 cooling towers are in operation serving over
BO electric generating stations. Such alternative cooling
systems are now both technologically and economically
feasible for large powerplantsv In this regard, I commend
the northern Indiana Public Service Company for their
decisions to employ cooling tower facilities at the Baily
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1 F. T. Mayo
2 Plant and Consumers Power Company for their recent agreement
3 to backfit the Palisades Plant with cooling towers.
4 MI recognize that certain environmental effects
5 may possibly result from employment of alternative cooling
6 systems* Such effects, however, appear clearly less serious
7 than those posed by once-through cooling. To a large extent
B they may be avoided or minimized by proper design of the
9 system or location of the plant.
10 "The Great Lakes are an irreplaceable national
11 asset. One of these lakes, Lake Erie, has already suffered
12 serious harm. The quality of Lake Michigan waters, though
13 still high, has begun a steady and measurable decline, with
14 associated damage to its biological systems. Although
15 several other sources of ecological damage to the lake
16 exist, thermal discharges are increasingly important and
17 may well accelerate the harm caused by other pollutants.
13 It is my conviction that if there are feasible methods to
19 avoid this serious risk of harm posed by thermal discharges,
20 those methods must be adopted.
21 "We must recognize that many unknowns exist in
22 the problem we now confront. Much research is required before
we can fully understand the nature and extent of effects
from thermal discharges. More must be knowa also about
25 the specific water quality conditions of Lake Michigan.
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F. T. Mayo
In the face of such unknowns, however, we must choose the
course of caution. For far too long precautions against
environmental damage have awaited a full understanding of
the threat. The march of progress has aggravated
environmental damage while proposed safeguards were under
consideration or studies were being performed.
"In the case of Lake Michigan, we cannot afford
further delay. Stringent standards must be established to
prevent damage from thermal discharges. In particular, I
believe that limitations should be placed on large volume
heated water discharges by requiring closed cycle cooling
systems using cooling towers or alternative cooling systems ;
. bn all new powerplants and addi'tion of such cooling
facilities to plants now under construction. (Applause)
"In addition to the development of stringent
thermal standards for Lake Michigan, I would like to direct
your attention to the need for setting implementation
schedules for plants now under construction or in operation
such that their discharges will be brought into compliance
as soon as possible.
"I urge your consideration and adoption of
clearly defined temperature standards and look forward to
your submission of the Conferees' recommendations to me in
the near future."
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2 There is a need to emphasize that the recommeada-
3 tion of Mr. Ruckelshaus, that large volume heated
water discharges be required to impose closed cycle cooling
systems or alternative cooling systems to all new powerplanta
and additions of such cooling facilities to plants now under
7 construction was not lightly taken*
3 There was * most serious consideration of the
significance of that proposal* It was made in the light
10 of the Agency's considered opinion that the importance of
11 Lake Michigan is of such consequence that this is the most
12 reasonable approach that the Federal Government can propose
at this point in time*
We will be offering for the conferees this morning
15 proposed Lake Michigan thermal discharge regulations which
will speak to specific receiving water criteria that could
17 be accepted by the States and enacted by the States into
their Water Quality Standards*
We feel that the proposed regulations are reason-
20 able, and when applied to existing discharges and the
limited discharges from powerplants not yet in operation
22 from which there would be the release of waters only from
23 blowdown purposes can constitute a basis for reasonable
24 protection of the waters of Lake Michigan from thermal
25 waste discharges* We are anxious that the States take these
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Fo T. Mayo
recommendations, hare private discussions, and employ them
with the respective State water quality standards* We are
anxious also that the States join with the Environmental
Protection Agency in our proposal in the recommendations
of Administrator Ruckelshaus that for the powerplants not
yet in operation that there be concurrence in a requirement
that they go to other than once-through cooling*
I should like to make it clear, however, that
the position of the Environmental Protection Agency to work
as cooperatively and as constructively as possible with the
States on that point, but that we are prepared to employ
the full extent of the administrative and the legislatively
defined processes that are available to the Environmental
Protection Agency to achieve that end*
As we proceed this morning, the next presentation
will be that of the recommendations of the Lake Michigan
Enforcement Conference Technical Committee on Thermal
Discharges* That presentation will be made by Mr* Robert
Hartley* Following that, we will have a presentation of
the proposed Lake Michigan thermal discharge regulations*
That presentation will be made by Mr* Dale Bryson* Follow-
ing Mr* Bryson, there will be a presentation by Dr. Donald
Mount concerning thermal requirements for Lake Michigan
and speaking to the proposed thermal standards for Lake
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1 Hon* A* J* Mikra *~
2 Michigan as they will be presented by Mr« Bryson*
3 Mr* Chairman, I suggest that, at this point, we
4 proceed with the presentation by Mr* Hartley*
5 MR. STEINj I wonder if you could come here*
6 You have a few additional requests; you may want to look
7 at these*
g MR* MAYO: I think, Mr* Chairman, it would be
9 appropriate, at this time, to have the statement from Mr*
10 David Cleverdon, the Executive Assistant to Congressman
11 Mikva.
12
13 STATEMENT OF THE HONORABLE ABNER J.
14 MIKVA, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D. C.
15 (READ BY DAVID CLEVERDON)
16
17 MR« CLEVERDONt Thank you, Mr* Mayo*
13 Congressman Mikva regrets that ho could not be
19 here today* As you know, there is important business in
20 Washington dealing with the 13-year old that he had to be
2i at the Capitol for*
22 However, he did write a formal statement which I
23 would like to read to you* It responds to the Technical
24 Committee Report and not to Mr* Mayo*s letter* I am sure
25 were Mr* Mikva here he would second Mr* Mayo's remarks,
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Hon. A, J* Mikva
particularly that in the face of such unknowns we must choose
the course of caution*
The Congressman's statement beginss
"Mr0 Chairman, thank you for the opportunity to
appear before you this morning to respond to the recommen-
dations of the Lake Michigan Enforcement Conference Tech-
nical Committee on Thermal Discharges to Lake Michigan*
"When I appeared before you last October, I
testified that the mission and the public responsibility
of this body must be to set a thermal standard and that
standard should be based on the proposition that no sig-
nificant thermal discharges into Lake Michigan should be
allowed unless the polluters can prore beyond a reasonable
doubt that no damage will be done to the lake*
"It has been my understanding that in the interim
a Technical Committee was to be formed to work out a com-
promise thermal standard proposed by the Federal Office of
Water Quality using B*t*u**s instead of temperature. This
Conference, I further understood, was to more forward and
meet in February to reriew that implementation plan* But,
Mr* Chairman, that Technical Committee Report does not
more the work of this enforcement forward if it is adopted;
it mores it back* It raises again the question of whether
or not this Conference should set a thermal standard at all*
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1 HOB. A. J. Mikya
2 It is an effective bit of sabotage*
3 "In a momentous failure of nerve, the Technical
'
4 Committee concluded that inadequate studies prevented them
5 from fulfilling their responsibility of recommending a
6 thermal standard* On that basis, no standards concerning
7 water pollution should be set since every facet of water
g pollution suffers from inadequate research* This decision
9 not to decide was justified by the Technical Committee Report
10 because the existing research, although admittedly inade-
11 quate, demonstrated no damage to Lake Michigan from thermal
12 pollution discharges* I hare a hard time understanding how
13 inadequate research can demonstrate anything*
14 "If the Enforcement Conference follows the
15 recommendation of the Technical Committee not to set a
16 standard, not to set a deadline for the use of thermal
17 pollution abatement systems and, by default, to allow thermal
lg pollution to eontinue under the guise of studying the prob-
19 lorn, then it is not fulfilling its public responsibility
20 &ad trust* It is not, in short, carrying out a fundamental
2i pledge to set a thermal standard which I thought had been
22 made a long time ago*
23 "It is unfortunate that the Technical Committee
24 has forced us to talk again at this stage about whether or
25 *et this Conference would set a thermal standard* I urge
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Hon. A* J* Mikra
this Conference t© reject their report and more forward to
the establishment of a thermal standard which will protect
Lake Michigan as our region* s greatest natural resource*
"If we care about keeping Lake Michigan from
becoming an industrial sink, then we cannot afford, as a
matter of public policy, to net set thermal pollution stan-
dards in the face of inadequate information* It is pre-
cisely because our information is inadequate that a
thermal standard is necessary* If we must err, then let's
err on the side of the public and set a rigid standard*
"Gentlemen, you must exercise your public trust*
The lake will not wait* By rejecting the Technical
Committee Report and establishing a tough thermal standard
you will go a long way towards maintaining the public *s
faith in the capacity of its government to solve our
environmental problems*1*
Mr* Chairman, thank you for this opportunity to
read Congressman Mikva's statement* (Applause)
MR. STEIIs Thank you for your participation*
Mr* Mayo*
MR. MATOi Mr* Chairman, we have a letter
addressed to you from Senator Stevenson that I will read
into the record.
"March 18, 1971
"Dear Mr* Steins
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"I an deeply concerned about the dangers of
thermal pollution in Lake Michigan0 While I am well aware
of the urgent need for increased electric power, I do not
believe we can take chances with one of Illinois' greatest
natural resources by allowing the indiscriminate installa-
tion of nuclear powerplants along its shores*
"Until sufficient data, proving beyond all doubt
that heated discharges are not the cause of significant
ecological harm, can be gathered from those few plants
presently under construction, further construction of the
many facilities currently in the planning stage should not
be permitted*
"Clearly, the most immediate need is the setting
of a lakewide standard that can be enforced* It is my
hope that the Lake Michigan Enforcement Conference, meeting
on March 23-24, will provide such a standard and that it
will at least encompass the following provisions of the
Illinois Pollution Control Board's tentative minimum
requirement s t
"Neither the bottom nor the shore shall be
affected by a new heated discharge of significant propor-
tions*
"No new heated discharge of significant propor-
tions shall be located so as to affect spawning grounds
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A* Stevenson
or migration routes*
"Discharge structures shall be so designed as to
maximize short-term mixing and thus to reduce the area
significantly raised in temperature.
"No new heated discharge of significant proper-
tions shall interact with any other heated discharge of
significant proportions*
"lackfitting of alternative cooling devices will
be required if at any time it can be shown that damage
has resulted from existing or future heated discharges*
"All reasonable steps shall be taken to reduce
the number of organisms drawn into or against the intakes*
"Much testing and further data are obviously
i
needed to prove the feasibility of these guidelines and
determine ways of improving discharge structure design and
the interrelationship of locations* Above all, it is my
strong conviction that future construction of nuclear plants
without a tested lakewide standard derived from and applied
to those plants presently under construction would be a
grave mistake endangering the future of the lake and the
lives of these millions who depend upon it for their well-
being
.
"Looking forward to working with you on our common
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goal of preserving Lake Michigan, I am sincerely, Adlai
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2 Stevenson*"
3 We have requests for making a statement from Mrs*
4 Samuel Rome representing the President's Water Pollution
5 Control Advisory Board*
6 Mrs* Rome.
7
g STATEMENT OF MRS. SAMUEL ROME, MEMBER,
9 PRESIDENT'S WATER POLLUTION CONTROL
10 ADVISORY BOARD, CHICAGO, ILLINOIS
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12 MRS* ROME: I am representing the President's
13 Water Pollution Control Advisory Board*
14 The following resolution, introduced by Mr* Louis
15 S, Clapper of the National Wildlife Federation, was maani-
16 mously adopted by members of the Water Pollution Control
17 Advisory Board at a meeting in Washington, B.C* on February
Id 9, 1971.
19 Whereas, the Technical Committee on Thermal
20 Discharges to Lake Michigan has made confusing recommenda-
21 tions to the Four-State Enforcement Conference on Pollution
22 •? Lafc* Michigan with respect to nuclear power generating
23 plants and the requirement that closed circuit cooling
24 facilities be installed} and
25 Whereas, the Technical Committee has recommended
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7 VJMffiiMiaj these studies should determine basic
physical and biological effects of heated discharges from
thermal electric power generating facilities which would
Mrs. S« Rome
that in-depth field and laboratory studies to determine the
effects of heat upon the ecology of the lake be conducted
under the guidance of a technically competent steering
committee appointed by the Lake Michigan Enforcement Con-
ference; and
apply to many bodies of water in addition to Lake Michigan;
Now, thereforg^J^BLJJLXMiJjtftl that the Water
Pollution Control Advisory Board, in regular session assemble)*
February 9, 1971* hereby recommends to the Administrator of
the Environmental Protection Agency and to the Four-State
Enforcement Conference that closed circuit cooling facilities
be required; and
Board recommend in
the strongest possible manner that the steering committee
conducting the in-depth studies include representation of
the general public and that the committee be urged to conduct
public hearings in which all opinions can be expressed prior
to the development of any final recommendations*
Members of the President*s Water Pollution Control
Advisory Board are as followst
Dr, Melbourne Ro Carriker, Director of the
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Systematics-Ecology Program at Woods Hole Marine Biological
Laboratory,
Mr* Louis S* Clapper, Conservation Director of
the National Wildlife Federation, Washington, D.G,
Mr* William D, Farr, President of Farr Farms
Company, Greenley, Colorado,
Mr, Ray W, Ferguson, Commissioner, California
Water Commission, Ontario, California,
Dr. Wallace W* Harvey, Jr., who is a physician
from Manfeeo, North Carolina,
Mr, Ralph W, Kittle, who is Vice-President of the
International Paper Company, New York, New York,
Mr, Stuart M, Long, Editor of the Long News
Service, of Austin, Texas*
Florida,
Mr* Parker E« Miller of North Reddington Beach,
And Mrs* Samuel Rome, representing the League of
Women Yoters of Illinois, and speaking here on behalf of
the Water Pollution Control Advisory Board*
I am sure the Board Members will be more than
pleased with the letter from Mr* Ruckelshaus which was read
this morning* Thank you very much. (Applause)
MR, ST1IN: Thank you, Mrs* Rome* If you have an
extra copy, would you give one to the reporter first?
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STATEMENT OF LEONARD i* YOUNG, REGIONAL
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Mr. Mayo*
MR0 MAYO: We hare another request for a statement
on the Federal side, Mr* Chairman, from Mr« Leonard B*
Young, Regional Engineer for the Federal Power Commission*
Is Mr* Young available at this point?
ENGINEER, FEDERAL POWER COMMISSION,
CHICAGO, ILLINOIS
MR. YOUNG: For the record, I am Leonard B*
Young, Regional Engineer, Chicago Regional Office of the
Federal Power Commission.
I appear here to make a statement on behalf of
the Federal Power Commission. I will read the statement.
The Federal Power Commission notes the reconven-
ing of the Lake Michigan Enforcement Conference as a sequel
to the Federal-State Conference of September 2$, 1970, and
subsequent meetings of the conferees and their technical
representatives. Because of its continuing interest in the
environmental questions and the related aspects of electric
energy supply for the region, the Commission wishes to
present further comments herewith to the Conference. In
doing so, the recommendations of the Lake Michigan
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Enforcement Conference Technical Committee on Thermal
Discharges dated January 1971 have been received and have
been studied with care*
With reference to the general question of
determining appropriate standards to apply to cooling water
discharges of powerplants existing on Lake Michigan and to
be constructed in the period between now and 1990, we must
again emphasize and confirm the data and estimates of
future plant construction contained in the statement pre-
sented on behalf of the Federal Power Commission to the
Conference on September 28, 1970, by Frederick H. Warren,
the Commission's Advisor on Environmental Quality* These
power needs continue to require the same thoughtful con-
sideration by the State and Federal conferees in determin-
ing the best balance achievable in providing needed pro-
tection of biological systems of the lake while assuring
adequate and reliable supplies of electric energy for the
health and economic welfare of the region surrounding the
lake*
We note from the report of the Technical Committee
a number of pertinent conclusions which underlie the
situation which the conferees now facet
1* After evaluating numerous studies conducted
at Lake Michigan and elsewhere, the Committee statess "It
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2 is obvious that further field studies are warranted and
3 necessary to determine ecological impact on Lake Michigan**
4 2* It was the consensus of the State represen-
5 tatives that "their laws require controls to be set on the
6 basis of demonstrated damage or potential damage to water
7 uses*1* Andt further, "»•» since there has been no demon-
g strated significant damage at existing Lake Michigan thermal
9 plume sites from artificial heat inputs, the assignment of
10 numerical effluent values or other engineering design
11 requirements at this time would be arbitrary and not
12 defensible*1*
13 3» Further, "Unlike many other waste problems,
14 there is limited concern about persistence or buildup in
15 the water environment or other biological magnification
16 (such as with toxic substances) or about a direct effect
17 upon the health or safety of man* The amount of waste heat
18 in a body of water is always in equilibrium with the atmos**
19 phere and cessation in input will result in an almost
20 immediate return to the natural temperature regime." Thus,
21 "The Committee believes that the above characteristics of
22 *&* waste heat program in Lake Michigan are such that they
23 do allow a period of time for the establishment of sensible
24 controls,"
25 Having stated the foregoing conclusions, which
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2 appear to the Coauaission to be wholly consistent with the
3 technical information so far brought forward on this complex
4 subject, it is difficult to find a basis for the Technical
5 Committee's further conclusion that "«•• unless these effects
6 are shown definitely not to be ecologically damaging, such
7 damage must be assumed and controls instituted accordingly*"
g The Committee then moves from the foregoing assumption,
9 which it acknowledges is not supported by technical data,
10 to recommend that "»,, all thermal electric power generating
Xi facilities using or planning to use Lake Michigan water for
12 the dissipation of artificial waste heat be required to
13 hare closed cycle cooling systems, or such other techniques
14 as may be approved by the Lake Michigan Enforcement Con-
15 ference, under construction by a date considered reasonable
16 and appropriate by the conferees, unless it has been con-
17 clusively demonstrated to the Lake Michigan Enforcement
lg Conference that ecological damage does not or will not occur
19 from onee-through cooling*M
20 With regard to the above far-reaching recommenda-
21 tion, we must make a number of comments:
22 !• Xt is apparent that it would be impossible
23 for anyone to conclusively demonstrate that ecological
24 damage will not occur, since the statement is so written
25 that any level of damage whatever, regardless of the extent
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of damage and the amount of offsetting benefits, could be
considered "damage,1* Furthermore, the biological factors
will probably provide only a basis for reasonable judgment,
which is short of conclusive demonstration*
2* We note also that the conferees have not given
any significant study to the environmental consequences to
the affected regions around Lake Michigan which would result
from complete switchover from once-through cooling systems
to the use of evaporative cooling towers or cooling ponds*
These environmental consequences, of course, include not
only local air quality effects but also water consumption,
the use of substantial land areas, and esthetic impact
wheresoever large structures are involved* It appears to
us that this is an important consideration in achieving a
fully balanced approach to the optimum solution for
environmental protection and the provision of needed energy
supplies*
3* It appears wholly logical for a committee of
the conferees to continue to be responsible for the prose-
cution of further studies and the determination of appropriatjs
criteria to be applied to future discharges in the lake and
the evaluation of plans to meet these criteria* nevertheless
we urge that such a committee, in keeping with the stated
intent of the National Environmental Policy Act of 1969,
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should be concerned with the achievement of balanced results
for the protection of the "human environment,11 Thus we
believe that such a Conference should include appropriate
representation from State, regional or Federal agencies
representing the user functions whose services are necessary
to serve the human and industrial needs of the region*
To be more specific, it would seem essential for the
achievement of balanced determinations that representation
on the technical committees or the Conference should be
extended to appropriate agencies such as State public
utility commissions concerned with electric power supply,
or other officials responsible for economic development and
land use planning*
HR* STEIHi May I interrupt for the purpose of
clarifying the record? The representation of the Conference
is set by Federal law* We don't do that*
HE. TOHIG: All right, Mr* Chairman*
MR* STEXKs les*
ME* 10916s I believe that they refer here to a
committee which would oversee the prosecution: of further
study and ttee determination of appropriate criteria that
would be applied to future dischargers in the lake*
ME* STIIIs I understand what you are saying, but
the statements are the representation of the Technical
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L« B. Young
Committee or the Conference* Now, we are bound by the
Federal law, just the way your agency is, and the represen-
tation of the Conference is set by Federal Iaw0
5 MR. TOUHGj I will so advise the Commissioner*
6 MR. STEIN) Right.
7 MR, YOUNG: 4. We note that the Committee,
following its recommendation, suggests three alternative
methods for once-through cooling which might be "designed
10 t® avoid" any significant ecological damage. It appears to
11 us that these three alternatives are reasonable and con-
12 structive ideas toward minimizing but not avoiding completely
ecological damage. In this connection we should like to
I/,. observe that according to our estimates, the total use of
15 cooling water by the present powerplants on Lake Michigan
16 amounts to about 10 billion gallons per day at full load,
17 and the estimated volume which would be required by the
lg plants constructed in the next 10 years would be approxi-
19 mately an additional 10 billion gallons per day without
20 auxiliary cooling. These daily quantities constitute about
2i 0*04 percent of the volume of the inshore portion of the
22 lake, indicating a dilution factor of about 2,500 to 1 each
23 day
24 -In the light of the foregoing factors, we propose
25 that the conferees consider in lieu of the recommendation
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of the Technical Committee a program such as the following:
1« All powerplants scheduled to come into
operation between now and July 1, 1976, shall be giren
conditional authorization to proceed with currently designed
cooling systems —
FROH THE FLOOR: Point of information, Mr* Stein.
Boos this gentleman work for the gorernment or for the
power companies*
MR, ami Yes, he does*
I am sorry* If we are going to do this, we are
not going to be able to finish* low* I suggest you will
all be giren an opportunity to make your statement in
order, and please giro him erery courtesy that I am sure
we are going to giro you*
This is part of the Federal presentation, and as
introduced, and I guess you all know, he is a representatire
of the Federal Power Commission*
Would you continue, sir?
MR* YOUHG: I will begin with the first recommen-
dation again*
1* All powerplants scheduled to come into
operation between now and July 1, 1976, shall be given
conditional authorization to proceed with currently designed
05
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2 systems, providing such systems are designed to minimize
3 ecological damage by techniques including such as
4 described in points 6.(a), (b), and (c) of the Technical
5 Committee Report; with the further provision that if such
6 plants as a result of prescribed pre- and post-operational
7 monitoring show evidence of distinct ecological damage
$ (as against certain prescribed biological population and
9 diversity standards related to the particular location),
10 they shall in the event of such ecological damage irame-
XI diately institute measures to alter or improve the thermal
12 discharge condition to achieve a modified biological
13 effects standard agreed upon by the responsible environ-
14 mental protection agency* A maximum of 3 years shall be
1^ allowed the operator for the completion of the required
16 corrective measures, from the date of official notice from
17 the responsible environmental protective agency*
1$ 2« Future powerplants scheduled for commencement
19 of operations after July 1, 1976, may be designed according
20 t® t&e applicant's concept of the optimum means of meet-ing
21 the prescribed tolerable ecological conditions specified
22 in paragraph 1* above, but must be planned to make pro-
23 vision for modification in the cooling water facilities if
24 as a result of further studios and operating experience
25 between now and July 1, 1976, it becomes apparent that
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2 such modified designs will be necessary to meet the
3 required environmental standards*
4 3* All existing power-plants will be reqmired to
5 hare in effect biological monitoring programs adequate to
6 determine the relative lerel of biological damage, if any,
7 attributable to thermal discharges, and if such damage is
g found to occur and to exceed substantially the biological
9 effects standards developed as in paragraph 1 above, there
10 shall be determined on a case-by-case basis (by joint
11 consultation between the company and the responsible
12 environmental protection agency) a program of the most
13 appropriate corrective measures to be taken* Such measures
14 may include:
15 (a) Continued operation with present design
16 where the remaining life of the plant, the average annual
17 usage, and the probable scheduling of plant operation are
1$ such that the potential costs of supplementary or modified
19 cooling facilities would not be warranted as an offset to
20 the limited and recoverable biological effects consequences
21 that may be experienced*
22 (b) Installation of supplementary cooling
23 facilities or modified once-through discharge facilities
24 where warranted by the continuing life, and usefulness of
25 the powerplant and the relative biological damage
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consequences,
Thank you*
MR0 STEIN: Thank you*
I should have asked with the previous speakers,
but I will do this now: Are there any comments or questions?
I just have a few clarifying ones, and I think
Mrs* Rome made this point, that we should try to get as clear
as possible*
As I understand your view, that what you would
suggest on each plant is that we determine whether the poten-
tial costs of cooling facilities would be warranted as an
offset to biological effects that these effects are bad*
In other words, in each case, there will be a
balance between biological degradation and what the cost
will be*
sir?
Is that what you are saying in your proposal,
MR, YQ&NGt Tes, sir, of course, it would hare to
judgment*
MR* STEIMt Yes, I understand that*
Vow, there is one other point that I hare, and I
jwst do this as a point of clarification* You say in point
/*-, it appears to us that these ideas are reasonable toward
minimizing, but not avoiding completely ecological damage*
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2 In other words, as I read what you are saying, if we adopt
your proposal, we should be ready to accept or not avoid
completely the ecological damage, and consider that may be
something we just have to put up with. Is that correct?
MR. YOUNG: Maybe that is correct, yes, sir.
MR. STEIN: Now, you say, if we are going to
make anyone put in anything, we have to show evidence of dis
tinct ecological damage as against certain prescribed
biological population and diversity standards related to
the particular location. In other words, what you are
saying is that we can possibly stand a little ecological
damage, but for each location we have to get the numbers
and the variety of the organisms limited there, and beyond
. _ that we will make a judgment that perhaps cooling has to
_, be put in if the potential costs are not offset by these
limited damages. Is that it?
MR. YOUNG: Yes, sir.
MR. STEIN: All right. Thank you.
__ Any other comments or questions?
Thank you very much, sir.
22 Mr. Mayo.
2_ MR. MAYO: Mr. Chairman, it would be appropriate
_, at this point to proceed with the Technical Committee
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Report* Mr* Hartley will make the presentation,
MR. HARTLEY: Thank you, Mr* Mayo.
MR* STEIN: I checked the time, and I think this
is about halfway through the morning, Mr* Hartley* Let's
take a 10-minute recess* And all of the people who want
to talk, please make arrangements with your State represen-
tative*
(Short recess*)
MR* MAYO: We have a request from Mr« Henry Conti
Assistant to the Manager for Environmental Activities,
Chicago Operations Office of the United States Atomic
Energy Commission, to make a statement* We will ask Mr*
Conti to come forward and make his statement before we
hear the Technical Committee Report by Mr* Hartley*
MR. STEIN: Please identify yourself for the
purpose of the record* I know you weren't here when that
announcement was made, Mr* Conti*
19
STATEMENT OF ENRICO CONTI, ASSISTANT TO
THE MANAGER FOR ENVIRONMENTAL ACTIVITIES,
CHICAGO OPERATIONS OFFICE, ATOMIC ENERGY
COMMISSION, ARGONNE, ILLINOIS
MR* CONTIt My name is Enrico Conti* I am
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1 E. Conti
2 Assistant to the Manager of the AEG Chicago Operations Office
3 at Argonne, Illinois. I am presenting a statement that has
4 been prepared for the AEG.
5 During the past year, the Atomic Energy Commission,
6 in connection with its developmental responsibility, has
7 followed with considerable interest the combined efforts f
& the Environmental Protection Agency, the four states
9 surrounding Lake Michigan, the utility industry, universities*
10 and consulting engineers and scientists in the development
11 of temperature standards for Lake Michigan and an under-
12 standing of the effects and control of thermal powerplant
13 effluents on the lake. In connection with the reconvening
14 of the third session of the Lake Michigan Enforcement
15 Conference, on March 23 and 24, 1971, in Chicago, Illinois,
16 the AEC would like to submit the following statement for
17 consideration by the conferees at this session.
18 The AEC has had a long-standing interest in the
19 effects of heat upon the aquatic environment and has funded
20 a significant portion of the Federal effort to date on
21 thermal effects research and development. Because of our
22 mutual interests with EPA in this area, we have endeavored
23 to coordinate AEC efforts with various EPA programs around
2/t- the country. Im this regard, the extensive research
25 program on the Columbia River has been expanded in the past
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2 two years in the cooperative studies with EPA and the
3 Bureau of Sport Fisheries and Wildlife. More recently, the
4 Argonne National Laboratory has initiated field and laboratory
5 research studies to examine the effects of heated water
6 discharges on the physical and biological systems in Lake
7 Michigan. These studies are being carried out in concert
& with the Chicago Regional Office of EPA, several universities
9 in the area, and the utilities. In addition, similar
10 cooperative studies are now under way in the vicinity of
11 Biscayne Bay in Florida.
12 In line with our studies, we have reviewed the
13 report of the Conference Technical Committee on Thermal
14 Discharges to Lake Michigan dated January 29, 1971* Based
15 upon our own experience and research efforts in the field
16 of thermal effects, we can endorse much of the assessment.
17 We agree with the Committee's conclusions that "there has
IB been no demonstrated significant damage at Lake Michigan
19 plume sites from artificial heat inputs," and that "the
20 studies which have been conducted at these plume sites are
21 inadequate to thoroughly assess the possible effects."
22 However, in our opinion, there is considerable
23 question as to the adequacy of the technical basis to support
24- the Committee's Recommendation 4 that: "All thermal electric
2^ power generating facilities using and planning to use Lake
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Michigan water for the dissipation of artificial waste heat
be required to have closed cycle cooling systems — unless
it has been conclusively demonstrated that ecological damage
does not or will not occur from once-through cooling."
While this recommendation appears to effectively eliminate
once-through cooling schemes and require alternate cooling
methods, Recommendation 6 suggests that once-through cooling
systems might be acceptable under certain circumstances.
10 In our view both cooling towers and once-through cooling
11 systems need careful examination for each individual situation
12 From information provided the conferees, there are
13 indications that properly designed intake and discharge
1^ i structures for condenser cooling water have the potential
15 to eliminate significant harmful effects of'thermal releases
1° to the receiving water body and its ecological environment.
1? In accord with the Committee recommendations that "further
i A
field studies are warranted and necessary to determine
^ ecological impact on Lake Michigan," we would strongly
20 propose that comprehensive, in-depth field and laboratory
21 studies be carried out during the next 5 years to verify the
22
design of these effluent control facilities and also to
23
determine the effects on the surrounding lake ecology.
24
These in-depth field studies should be carried
25
out prior to the commitment of hundreds of millions of
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2 dollars for closed cycle coolings systems. There is
3 increasing concern around the country by knowledgeable indi--
4 viduals that alternative cooling means may cause unacceptable
5 air quality conditions or other undesirable environmental
6 effects. At certain powerplant sites, wet cooling towers
7 may have the potential of causing fogging and icing problems
in the surrounding area. The design and operation of dry
9 cooling towers has yet to be demonstrated as a practical
10 system for large steam-electric generating plants at any
11 site either in this country or in the world. Large cooling
12 towers (400-500 feet high) are not attractive aestheti-
13 cally along the lake front and may cause potential safety
14 hazards to normal air transport operations. The significantly
15 large consumption of cooling water through the use of wet
16 cooling towers or spray canals as opposed to once-through
systems should be considered.
While it may be extremely difficult, or impossibl^,
to "conclusively demonstrate" that ecological damage does
20 no"t °r will not occur from once-through cooling, we strongly
endorse the Committee recommendation that comprehensive,
22 in-depth field studies be carried out to determine the effects
23 of thermal releases on the surrounding lake ecology.
24 It may be of interest to this conference pro-
25 ceedings, that a recently published Argonne report which
analyzed the impact of man-made thermal discharges into
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2 Lake Michigan from artificial heat loads (nuclear and fossi!
3 fueled power generating facilities — both existing and
proposed — and steel plants) has concluded that increase
5 in lake temperature and water loss due to evaporation as a
6 result of these heated discharges are "negligible and will
7 continue to be so for the rest of this century." The daily
addition from existing and proposed nuclear plants to the
o lake's heat input represents about 0.1 percent of the
10 average natural daily warming from the sun. The report
concludes, however, that while the average lake-wide effect
12 of man's thermal effluents may be small, it does not auto-
matically follow that local thermal effects, and the short
and long term meteorlogical effects will also be negligible
More detailed information is needed on these local effects,
lake circulation patterns and details of heat transfer
between air and water, all areas that would be included in
•tA the in-depth field studies which have been recommended by
•jo the Lake Michigan Technical Committee.
2Q In summary, the AEG endorses the Lake Michigan
Conference conferees' objectives of establishing meaningful
22 temperature standards for the lake and its recommendation
for comprehensive, in-depth field studies to determine the
effects of thermal releases on the surrounding lake ecology
We suggest a broader-based participation in the development
and guidance of these studies than just the EPA,, the
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Bureau of Sport Fisheries and Wildlife, and the surrounding
States. Experience which has been obtained in the on-going
cooperative study of the Chesapeake Bay during the past yea
would be of value in the planning and conduct of the Lake
Michigan study. EPA, the Federal conferee in the Enforcement
Conference is participating in the Chesapeake Bay Study.
The opportunity to share these thoughts on the
Technical Committee's report is appreciated, and we hope
to continue to actively participate with EPA and the
surrounding Lake Michigan States in developing the necessar
technical data as a basis for establishment of reasonable
water quality standards for Lake Michigan.
MR. STEIN: Thank you, Mr..JBonti.
Are there any questions or comments? I wonder
if you would clarify one point for me? I didn't quite see
it in your paper, although I was looking for the answer to
this if possible.
You talk in terms of in-depth studies, and I thinlj:
that is what a lot of people have recommended. The
question I think that is going to face these conferees
is whether when we have existing or proposed plants, we
permit these plants to go in with once-through cooling
while we have these proposed studies.
Do you care to comment? What is your view on thatl?
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MR« CONTI: Was your question whether the pres-
_ ently proposed plants should be allowed to go in while the
, study is being performed?
MR. STEIN: That is correct.
MR. CONTI: Yes.
MR. STEIN: Right, that is the view — with onoe-
through cooling?
MR. CONTI: Yes, the answer is yes,
MR. STEIN: Righto Thank you.
Any other questions or comments? Thank you very
,_ much, Mr. Conti.
MR. MAYO: Mr.o Chairman, we will proceed, at this
point, with the presentation of the Technical Committee
Report by Mr. Hartley.
MR. STEIN: We have had the criticism of the
,„ report before it came up. I guess this puts you in a
peculiar position, Mr. Hartley
19 MR. HARTLEY: Yes, it does.
20 MR. STEIN: — but go ahead.
21 MR. HARTLEY: Thank you, Mr, Mayo.
22
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.1 R. P. Hartley
2 STATEMENT OF ROBERT P. HARTLEY, DIRECTOR ,
3 OFFICE OF ENFORCEMENT AND COOPERATIVE PROGRAMS,
4 FEDERAL WATER QUALITY ADMINISTRATION, DEPARTMENT OF THE
5 INTERIOR, CHICAGO, ILLINOIS
6
MR. HARTLEY: Mr<> Chairman, conferees, my name
7
is Robert Hartley, I am with the Environmental Protection
8
Agency and Chairman of the Enforcement Conference Thermal
9
Technical Committee,
10
At the October 29, 1970, Executive Session of the
11
Four-State Enforcement Conference on Pollution of Lake
12
Michigan, held at Grand Rapids, Michigan, several proposals
13
were brought forth for the consideration of the Conferees,
14
The Department of Interior had earlier proposed
15
to the Conference as a policy recommendation the following:
16
"The minimum possible waste heat shall be added
17
to the waters of Lake Michigan. In no event will heat
IB
discharges be permitted to exceed a 1° F. rise over ambient
19
at the point of discharge. This will preclude the need for
20
mixing zones."
21
The Illinois Conferee proposed the following:
22
"There shall be no heat from man-made sources
23 "
permitted to enter directly or indirectly into Lake Michigan
24
or its tributaries in any discharges having a rate greater
25
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R. P. Hartley
than 50 gallons per minute. This rate relates primarily
to cooling water from watercraft."
The Michigan Conferee indicated that Michigan would
"... support a moratorium for five years for
further construction of thermal powe/plants on Lake Michigan
pending findings from intensive before and after studies
at the Palisades and Cook plants under outstanding (Michigan
Water Resources) Commission orders; such studies to include
investigations of effects on fish larvae on their passage
through plants in the cooling waters; that this position
does not change the present Order provisions that at any
time injury from thermal discharge is detected, existing
Orders will be reviewed and modified as necessary to prevent
such injury; and that this position will guide Executive
Secretary Ralph Purdy in Lake Michigan enforcement conference
deliberations..."
The Federal Conferee offered the following proposal
1. "Establish a level of thermal input in B.t.u./
hr. from individual man-made sources below which there would
be no concern for adverse impact on the lake environment
or established beneficial uses of lake waters, recognizing
that in special circumstances some control may be necessary
because of unique factors at the site of the discharge.
2. "Establish above this level a range of thermal
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2 input in B.t.u»/hr. within which there is concern for possibl
3 impact on the lake environment or established beneficial uses
4 of lake waters unless control is exercised over the manner
5 in which the discharge takes place. Such controls may be
6 in the form of a prohibition of shoreline discharges and
7 requirement for outlet works that will discharge at a
8 minimum distance from shore and in a minimum depth of water
9 (whichever is the lesser) keeping the heated water off the
10 lake bottom and designed to restrict the temperature of the
11 discharge to a range of temperature rise above the natural
12 temperature of the receiving waters.
13 3. "The upper level of this range to represent
14 a level of thermal input that could not be exceeded for any
15 given man-made installation.
16 4» "Apply this upper level as the maximum thermal
17 input limit that would be permitted for any given reach of
1# shoreline (perhaps 5 miles) from all sources, recognizing
19 that natural heat input from tributary streams may exceed
20 this limit at times.
21 5. "Consider the applicability of these limits on
22 man-made thermal discharges to the lower reaches of tributary
23 streams.
24 6. "Consider the justification for applying the
25 proposed limitations to thermal discharges from municipal
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2 treatment plants."
3 The Conferees agreed that the proposal presented
4 by the Federal Conferee offered a reasonable conceptual approach
and was worthy of an attempt to use it as a basis for
6 control regulations. As a result the Conferees authorized
7 the formation of a technical committee to specifically
review that proposal and if possible to recommend suitable
9 numerical limits to be included in the proposal. The
10 technical committee was to be comprised of representatives
11 designated by the States of Illinois, Indiana, Michigan and
12 Wisconsin, the U.S. Environmental Protection Agency and the
13 U.S. Bureau of Sport Fisheries and Wildlife. Members of
ji
14 the technical committee are:
15 Robert P. Hartley, U.S. Environmental Protection
16 Agency, Chairman.
17 Howard Zar, U.S. Environmental Protection Agency,
13 Alternate.
19 Yates Barber, U.S. Bureau of Sport Fisheries and
20 Wildlife.
21 Thomas Edsall, U.S. Bureau of Sport Fisheries and
22 Wildlife, Alternate.
23 Carl T. Blomgren, Illinois Environmental Protectioji
24 Agency.
25 !| James C. Paccione, Illinois Environmental Protection
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R. P. Hartley
Agency, Alternate.
Oral H, Hert, Indiana State Board of Health.
Carlos Fetterolf , Michigan Water Resources
Commission.
Alternate.
Resources.
F. B. Frost, Michigan Water Resources Commission,
Jerome McKersie, Wisconsin Department of Natural
The committee met in Chicago November 10,
November 24» December 7-&t December 16, and December 22,
1970, and January 12, 1971.
The committee assumed that most of the information
available as a design basis for thermal regulations had been
presented at the Enforcement Conference workshop September
2B through October 2, 1970. Unfortunately the information
presented at the workshop consisted primarily of conflicting
opinions by many experts as to the effects of thermal discharges
but contained little conclusive data. The committee evaluated
numerous studies conducted at power generating stations at
locations other than Lake Michigan and determined that this
information is not sufficiently thorough or applicable to
Lake Michigan conditions. It is obvious that further field
studies are warranted and necessary to determine ecological
impact on Lake Michigan.
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2 The technical committee, after careful considera-
3 tion of the Federal Conferee's proposal and several variation
4 of the concepts therein, agreed that, although the concepts
5 have merit, a lack of specific data and an abundance of general
6 contradictory information on the effects of thermal inputs
7 prevents assignment of specific numerical input limits at
# this time. It was the consensus of the State representatives
9 that it would be their responsibility to enforce such limits
10 and their laws require controls to be set on the basis of
11 demonstrated damage or potential damage to water uses.
12 The committee recognizes the value of receiving water tempera
13 ture standards but, since there has been no demonstrated
14 significant damage at existing Lake Michigan thermal plume
15 sites from artificial heat inputs, the assignment of numerical
16 effluent values or other engineering design requirements at
17 this time would be arbitrary and not defensible. The same
13 reasoning applies, of course, not only to the proposal of
19 the Federal Conferee but also to the proposals of the Illinoi
20 and Michigan. Conferees and the earlier proposal by the
21 Department of Interior. However the committee unanimously
22 expressed concern that as yet undemonstrated damage to the
23 ecology of Lake Michigan may be occurring or might occur with
24 increasing inputs of waste heat. The committee thus felt
25 an obligation to consider other approaches to thermal input
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2 regulation.
3 The committee examined several remedies for ecologji
4 cal damage including closed cycle cooling, and ideas about
5 multi-port, high speed discharges. . Because of the sparsity
6 of information available to it, the committee considered it
7 inadvisable to recommend the imposition of specific
B engineering requirements for cooling or discharge systems
9 which would possibly appear inadequate or damaging in them-
10 selves in a few short years.
11 Unlike many other waste problems, there is limited
12 concern about persistence or buildup in the water environment
13 or other biological magnification (such as with toxic
14 substances) or about a direct effect upon the health or safetjy
15 of man. The amount of waste heat in a body of water is
16 always in equilibrium with the atmosphere and cessation
17 in input will result in an almost immediate return to the
l£ natural temperature regime. The behavior of waste heat in
19 Lake Michigan is also significantly different than it is
20 within the predictable confinement of a flowing stream.
21 The committee believes that the above characteris-
22 tics of the waste heat problem in Lake Michigan are such that
23 they do allow a period of time for the establishment of
24 sensible controls. During that time however the committee
25 urges that the selection and development of new sites for
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2 facilities utilizing Lake Michigan waters for waste heat
3 dissipation be held in abeyance pending completion of adequatje
4 field studies of thermal effects. In fact the committee
5 seriously considered several proposals, such as stopping heat
6 input at the presently existing level or at the level existing
7 or now under construction with limitations as to maximum
8 allowable input from a single source. Each of the proposals
9 was tied to a time required to complete studies. The
10 moratorium proposal has the disadvantage of not being likely
11 to lead to controls on existing discharges.
12 The committee believes that the most important
13 effects of waste heat are local, lying mainly at or very near
14 the heat source. The most obvious effects will be to
15 organisms caught up in tremendous volumes of water passing
16 through cooling facilities and immediately subjected to large
17 temperature rises and other physical stress. Of almost equal
13 importance would be the fate of additional organisms entrained
19 within the plume in the immediate area of the discharge.
20 Only limited information is available on the numbers of organ1-
21 isms which are affected and whether they are in the critical
22 region long enough for the effects to be significant. It
23 appears to the committee that, unless these effects are showr
24 definitely not to be ecologically damaging, such damage
25 must be assumed and controls instituted accordingly. One
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1 R. P. Hartley
2 alternative to prevent damage is to greatly reduce the volume
3 of lake water used.
4 The committee is particularly concerned also about
5 the behavior of waste heat inputs in winter, on which infor-
6 mation for Lake Michigan is virtually absent. Bottom layer-
7 ing of warm water might occur over relatively large areas,
having its chief effects on bottom fauna and the disruption
9 of fish reproduction. If such occurs, the reasonable control
10 course is again to reduce greatly the amount of waste heat
11 input.
12 The committee has taken the approach in the followj-
13 ing recommendations that ecological damage must be assumed
14 until it is shown otherwise. It has also taken an approach
15 that it hopes will tend to force adequate field and
laboratory research into an area where rhetoric is profuse
17 but information for judgement is either sorely lacking or
strikingly contradictory.
19 Conclusions and Recommendations
20 i9 Tke committee recognizes that existing water
21 pollution control laws in the Four Lake Michigan States permi
22 the use of Lake Michigan for domestic and industrial water
supplies, for the propagation of wildlife, fish and aquatic
life and for domestic, agricultural, industrial, recreationaj
25 and other legitimate uses including their use in the final
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1 R. P. Hartley
2 distribution of the watergprne wastes of our economy.
3 The committee further recognizes that all Four States can
4 order the abatement of demonstrated pollution resulting from
5 thermal discharges as well as other sources. The existing
6 laws also permit action to prevent pollution should there
7 be reasonable assurances that such pollution will occur.
The committee has agreed that there has been no demonstrated
9 significant damage on Lake Michigan plume sites from artifici*
10 waste heat inputs, however, it is the consensus that the
11 studies which have been conducted at these plume sites are
12 inadequate to thoroughly assess the possible affects.
13 2. The committee has determined from knowledge
14 of (a) thermal and biological principles, (b) field and
15 laboratory studies of Great Lakes fish and other organisms,
and (c) field and laboratory studies on other areas, that
17 the use of Lake Michigan waters for the dissipation of waste
heat may be damaging to the ecology .of the lake. Of particul
19 concern is the damage that may be occurring to phytoplankton,
20 zooplankton, benthos and to egg, larval, and juvenile life
stages of important fish species. The committee believes
22 that local adverse effects that may occur can be corrected
by the reduction of the use of Lake Michigan waters for
waste heat dissipation.
25 3. In reviewing the waste heat burden to Lake
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1 R. P. Hartley
2 Michigan the committee has concluded that discharges of waste
3 heat from controllable sources other than thermal electric
4 power generating facilities are at present a relatively
5 small part of the total waste heat discharged to the lake.
6 Therefore, in the judgement of the committee, control of
7 heat from such lesser sources as vessels, water treatment
8 plants, municipal sewage treatment plants and industrial
9 installations does not require waste heat control measures
10 at this time.
11 4. The committee therefore recommends that all
12 thermal electric power generating facilities using or plannin
13 to use Lake Michigan water for the dissipation of artifical
14 waste heat be required to have closed cycle cooling systems,
15 or such other techniques as may be approved by the Lake
16 Michigan Enforcement Conference, under construction by a
17 date considered reasonable and appropriate by the Conferees,
13 unless it has been conclusively demonstrated to the Lake
19 Michigan Enforcement Conference that ecological damage does
20 not or will not occur from once-through cooling.
21 5. The committee further recommends that in-depth
22 field and laboratory studies to determine the effects on
23 the ecology be conducted under the guidance of a technically
24 competent steering committee appointed by the Lake Michigan
25 Enforcement Conference. The studies should determine the
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1 R. P. Hartley
2 physical and biological effects on Lake Michigan of heated
3 discharges from thermal electric power generating facilities
4 and the affects on organisms in the cooling water passing
5 through these facilities.
6 6. The committee recognizes that facilities with
7 once-through cooling may possibly be designed to avoid
& ecological damge by:
9 (a) Discharging far enough offshore to prevent
10 the thermal plume from reaching the shoreline.
11 (b) Designing the discharge structure to prevent
12 the thermal plume from reaching the lake bottom.
13 (c) Designing plant piping and pumping systems to
14 minimize physical damage to entrained aquatic organisms.
15 7. The committee recommends that geographic
16 areas affected by thermal plumes from artifical waste heat
17 discharges not overlap or intersect.
lg 8. The committee recognizes the possible
19 detrimental effect on various aquatic organisms resulting frcm
20 the use of chlorine or other chemicals in the cooling water,
21 The committee recommends that all new power facilities using
22 Lake Michigan water be required to incorporate mechanical
23 cleaning rather than chemical into plant design. All
24 existing facilities should be required to install mechanical
25 cleaning devices on condensers as improvements or modifications
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2 are made to equipment.
3 9. The committee has limited evidence that there
4 may be physical damage to phytoplankton, zooplankton and fish
5 at intake structures and during the pass through the cooling
6 system. The committee anticipates that studies will
7 demonstrate damage to the above organisms and therefore
recommends that future intake structures be designed and
9 located to minimize entrainment and thus avoid possible
10 destruction of these organisms.
10. The committee has concerned itself with the
12 loss of benthos, phytoplankton, zooplankton, and fish
13 through the intakes of various industrial and municipal
14 water supplies. The committee suggests that each State
15 conduct studies under the guidance of the technical steering
16 committee of the passage of organisms into these facilities
17 to determine if there is a significant loss.
18 11. The committee recommends that all thermal
19 generating facilities be required to record intake and
20 discharge flows and temperatures continuously and to make
21 these records available to the regulatory agency upon
22 request.
23
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1 R. P. Hartley
2 MR. STEIN: Thank you, Mr* Hartley.
3 Are there any comments or questions?
4 Mr. Purdy.
5 MR. PURDY: Mr. Hartley, on the matter of mech-
6 anical cooling devices -~ the cleaning devices — is this
7 limited to the once-through system or does that also apply
g to the closed cycle system, and if so are there mechanical
9 cleaning devices for, say, slime control, and so forth, on
10 the cooling towers?
11 MR. HARTLEY: It is my understanding that it
12 applies to all condenser cooling facilities, cleaning
13 within the condenser. That would include closed cycle
14 cooling.
15 MR. PURDY: But there would still need to be,
16 say» sonie sort °f •— or very probably need to be some sort
17 of control for growths on the surfaces of the cooling
18 towers. Would this not be correct?
19 MR. HARTLEY: That is quite possible.
20 MR. PURDY: But if you have to use chemicals
21 there, what is the purpose of limiting the use of chemicals
22 within the condensers?
23 MR. HARTLEY: You have a very good question.
24 (Laughter)
25 MR. MAYO: Mr. Purdy, I think we are obliged here,
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to the extent that we have confidence that mechanical
cooling means are practical for the condensers^ to use those
take whatever opportunities are available to us technolog-
ically to achieve the cleaning requirement, but at the same
time minimize those additives which in themselves present
potential problems*
MR« PURDY: I understand this, Mr. Mayo, for the
once-through system. But for the closed cycle system where
a great portion of water will be recirculated, it seems to
m« that the detention time and continued exposure of any-
thing entrained in this recirculated flow to elevated heat
levels will damage the entrained organisms to the point
of where it doesn't make any difference whether you use
a chemical additive or a mechanical cleaning device on the
closed— cycle system. Plus the fact that when you get out
into the cooling tower and the recirculation there, it is
my understanding from cooling tower use now that additives
have to be used for slime control there. And that, as such,
I am wondering what the purpose is of the mechanical
cleaning on the closed- cycle system*
MR, MAYO: Let me make this point.
MR0 STEIS: Why don't we let Mr. Hartley answer?
Mr. Hartley, I don't know whether you want to
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1 R. P. Hartley
2 answer the question or not, but do you want to respond to
3 this for yourself or the Technical Committee?
4 MR. HARTLEY: Well, I think Mr. Purely has made a
5 yery good point, and I think it was the thought of the
6 Technical Committee, at the time — and I think they were
7 thinking particularly of once-through cooling, and perhaps
g had not considered closed *ycle cooling in this respect*
9 MR. STEINt Mr* Mayo.
10 ME* MAYO: By observation, it would seem to me, Mr,
11 Purdy, that cooling towers, of course, are not the only
12 alternative to once-through cooling* Wet cy.de recycling
13 would be accomplished by means other than cooling towers*
14 And under those circumstances where there would not need to
15 be any additives for antifouling purposes,thflrt certainly the
16 use of mechanical devices in the condensers would seem most
17 appropriate* However, I think there would be a need to be
l£ alert to the fact that if antifouling additives are needed
19 in taking care of this kind of a problem where a cooling
20 tower might be employed, then certainly we need to be
21 attentive to the opportunity for that additive to take care
22 of the condenser problem as well, and not make the
23 requirement any more burdensome than it would have to be*
24 MR. P9RBY* Well, again, it seems that on the
25 closed cycle, that the repeated long detention times and
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o,
10
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15
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25
continued exposure to elevated heat levels on the closed
cycle makes the damage to the organism somewhat a moot
question.
MR0 STEIN: Is this a — are we in agreement on
that or not?
Let me pose the question this way: I assume the
addition of chlorine or another material as an anti-
foulant is considered undesirable because of its effect on
the zooplankton, phytoplankton, and the small fishes going
through the system, not because of its effect on the dis-
charge to the lake. Is that correct?
MR. MAYO: Well, depending upon the character of
the additives, Mr<> Chairman.
MR. STEIN: That is right.
MR0 MAYO: They may, in fact, represent a water
quality problem in the receiving water.
MR. STEIN: Well, if there is a water quality in
the receiving water that is one question. But I think what
Mr. Purdy was saying: If the purpose of this is to prevent
the demise of these organisms going through the plant, and
if you have a closed system and you are going to create some
lethal pressures anyway, you can only be killed once. What1^
the point in restricting this?
MR. MAYO: Mr. Purdy*s comment was directed toward
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2 the reasonableness of requiring mechanical cleaning in the
condenser versus using additives in an instance where these
additives are required for other antifouling purposes and,
5 at the same time, take care of the antifouling requirements
6 in the condenser* I think he asked the question, aside
7 from the point of whether or not the additives, as such,
would be of consequence to the organisms that are going
9 through the plant.
10 I interpreted Mr* Purdy's remark to be related
11 to the general character of the water that would be re-
12 cycled and the general character of the blowdown that would
13 come as a consequence of using the antifouling materials*
MR* STEIN: Well, I am trying to see if there is
15 agreement or disagreement between you* The issue here iss
16 Let us suppose we have a closed- cycle tower system* Let
17 us suppose that a chemical has to be used for an anti-
foulant to keep those cooling towers working* Would you
19 then say that for the condensers you had to use mechanical
20 cleaning?
21 MR* MAYOi Probably not as long as we had the
22 opportunity to control the character of the water that was
23 discharged later on*
24 MR. STEIIi . All right*
25 Mr* Purdy, do you care to comment further?
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2 Mr* Dumelle0
3 MR0 DUMELLE: Mr* Hartley, I just wanted to ask
4 you: Since the Committee report was done in January and
5 it has been about 2 months since that time, has any new
6 information come to your notice other than what we have had
7 presented to us at the hearings, as to significant damage,
g or will Dro Mount be speaking to this?
9 MR0 HARTLEY} Specifically none to me. I think
10 that Dr» Mount will cover this quite adequately particularly
11 with respect to fish*
12 MR. DUMELLE: All right* Thank you very much*
13 MR0 STEIN: Mr* Frangos.
14 MR. FRANGOS: Yes*
15 Mr* Hartley, I am wondering if you could review
16 for me the principal concern in the requirement that there
17 not be a physical intersection of plumes*
l£ MR. HARTLEY: If I understand the question cor-
19 rectly, you are asking what is our concern for intersection
20 of plumes?
21 MR. FRANGOS: Yes.
22 MR. HARTLEY: Well, I think there are several
23 reasons. If plumes do intersect, then that means that a
24 far greater area — a continuous area is affected by heated
25 water* This essentially limits the area from which
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2 organisms in the near shore area can escape the heated water0
3 I think the idea here is that if they do overlap,
4 then we are getting to a point where we are approaching
5 continuous, let's say, excess temperature in the near shore
6 zone* Does that give you any idea of what we are talking
7 about?
g MR. FRANCOS: Yes, but I think, wouldn't the con-
9 cern depend upon the character of the plume, the location,
10 how the intersection is made? For example, you might have
11 something in the area of, let's say, a tenth of a million
12 B*t*u*/hour, and let's assume you had two of those* You
13 might very well treat those as — again, depending upon the
14 configuration and the physical characteristics — as a single
15 source*
16 MR* HARTLEYS You are saying if you have two small
17 discharges which intersect, would that be of concern?
lg I suspect not, if they are very small* The
19 Technical Committte, I think, recognize the fact that there
20 are small heat discharges which do not require regulation,
2i and I suspect that this would fall under this category. If
22 they are very small and adjacent, I suspect you could assume
23 that they are one for all practical purposes*
24 MR* FRANCOS: Okay, Thank you*
25 Mr* Chairman, I would just like to perhaps, at this
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time, commend the Technical Committee on the work that they
have done on their report, and if indeed the results and
the recommendations may not be totally responsive to some
people, and perhaps there may be some inadequacies in the
technical report, I think that this reflects the fundamental
problems and difficulties that we have been faced with at
this Conference, grappling with this thermal question,
And I think we ought to understand — at least I understood
•— that the conferees viewed this as a Technical Committee,
and their charge was to review the voluminous data that was
presented to the Conference over a span of some 5 days*
Again, I think it just restates the two funda-
mental problems as we see them: 1) the lack of technical
certainty in either way, whether there is damage or there
is not, and 2) I think some rather serious questions in
terms of the legal authority and scope of this Conference
or outside of the Conference when you are dealing with,
I think, subtle ecological problems of this nature,,
So 1 would think that they have indeed made a
contribution to the Conference, that they have been very
helpful* I don't think that their mission or their charge
was to determine public policy; rather they were to review
the technical data, submit it to the conferees, and I
believe that our principal charge is to come up with
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2 some recommendations that do determine public policy*
3 MR, MAYOj I am glad to have Mr* Frangos' com-
4 ments, Mr, Chairman, The assignment to the Technical
5 Committee was certainly a burdensome one and an onerous one
6 in terms of the subject matter and the magnitude of the
7 material that they had a responsibility to address in making
g their appraisal, and in terms of the sensitivity of the
9 subject matter and the sensitivity of the relationship
10 between the State and the Federal Governments in attempting
11 to put together a report that represented some form of a
12 consensus of the technical people involved*
13 To that extent, 1 think the Committee is entitled
14 to recognition for the very sincere and very serious effort
15 that they put forth* This is in spite of the fact that
16 there has been a fair amount of criticism directed at the
17 report and, as a consequence, I suppose by inference at the
18 Committee members themselves*
19 MR, STEIN: I don't think so* As a matter of
20 fact, I think the record today speaks for itself on the
21 Committee report* I think the Committee did a commendable
22 job in getting this material together under its deadline*
23 But the criticism ~ we had the report today* No one agreed
24 with it* Some people thought it was too lenient; some
25 people thought it didn't go far enough; and other people
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thought it was too strict.
Now, I might say that as far as I can see this
has served an immensely useful purpose in clearing out a
lot of the underbrush in getting at the problem. But I
don 't see that this report that the Committee put forth is
in any different shape than say a proposal that was put
forth at Grand Rapids, or proposals put forth at previous
conferences or at the workshops, by industry, conservation-
ists, governmental groups. They were all received with
the same kind of reception that this Technical Committee
Report was. Practically no one agreed with what anyone put
forward .
There were only two kinds of judgments — one "
group of people said it was too strict, and the other said
it was too lenient.
Now, if we are going to criticize this Committee
for getting the same kind of reception everyone else has
had with this proposal, I don't think that is a criticism.
I think they have done a good job. (Applause)
Are there any other comments or questions? If
not, thank you very much, Mr. Hartley.
Mr. Mayo.
MR. MAYO: Mr. Chairman, in keeping with the
recommendations contained in Mr. Ruckelshaus' letter, we
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wish to offer for the consideration of the conferees at
this time some proposed Lake Michigan thermal discharge
regulations. The proposal will be presented by Mr. Dale'
5 Bryson.
6
7 STATEMENT OF DALE S. BRYSON, DEPUTY DIRECTOR,
OFFICE OF REGULATORY PROGRAMS, WATER QUALITY OFFICE, EPA,
9 REGION V, CHICAGO, ILLINOIS
10
11
12 MR. BRYSON: The proposed Lake Michigan Thermal
Discharge Regulations are in two parts, part A and part B:
A. Applicable to all waste heat discharges to
^ Lake Michigan except those occurring from municipal waste
treatment, water treatment plants, and vessels.
1. At any time, and at a maximum distance of
i j»
1,000 feet from a fixed point adjacent to the discharge,
° the receiving water temperature shall not be more than 3
20
F. above the existing natural temperature nor shall the
21
maximum temperature exceed those listed below, whichever
22 . .
is lower:
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January
February
March
April
May
June
July
August
September
October
November
December
Determination of
shall be made by the State
June 30, 1971.
2, Water intake
* Bryson
Surface 3 feet
45°
45°
45°
55°
60°
70°
SO0
80°
80°
65°
60°
50°
compliance with the above limits
regulatory agencies and EPA by
shall be designed and located to
minimize entrainment and damage to desirable aquatic
organisms. Requirements may vary depending upon local
situations but, in general,
intake should 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
devices shall also be at a
screens and other exclusion
minimum.
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2 3» Discharge shall be such that geographic areas
3 affected by thermal plumes do not overlap or intersect and
shall not affect spawning or nursery areas of important
fishes*
4o Fouling problems shall be solved by the use of
inert mechanical devices* In exceptions where antifoul
chemicals must be used to supplement mechanical devices
9 as an interim measure, the concentrations at the point of
10 discharge shall not exceed the 96-hour TL^ concentration
11 for fishes and important fish food organisms*
12 5* Investigations shall be carried out by the
13 discharger at each intake and discharge site for those
14 facilities discharging more than a daily average of 2 billion
15 B*t,u*/hour, Such investigations should place emphasis on
16 the determination of direct effects of intake and discharge
17 upon the fishery resource of Lake Michigan, All investiga-
tions shall be conducted with frequent review and guidance
19 from the State regulatory agencies and EPA,
20 6, Should information at any time become avail-
21 able from these studies or other sources which indicates to
22 the regulatory agencies that any cooling water use has cause<.
23 or may reasonably be expected to cause ecological damage or
24 violate item 1 above, immediate necessary steps will be
25 taken to restrict this use.
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7. In order to provide for timely construction
of auxiliary cooling systems, in the event they become
necessary, each facility discharging more than a daily
average of 0.5 billion B.t,u,/hour will begin immediately
to prepare plans for alternative methods of waste heat
disposal, including closed cycle cooling* Preliminary plans
shall be completed by December 31f 1971, for facilities now
in operation* More than one plan may be appropriate,
3, All facilities discharging more than a daily
average of 0*5 billion B,t»m,/hour of waste heat shall
continuously record intake and discharge temperature and
flow and make those records available to regulatory agen-
cies upon requesto
B, Applicable to all new waste heat discharges
exceeding a daily average of 1/2 billion B,t,u,/hour,
except those occurring from municipal waste treatment
plants, and vessels, which have not begun operation as of
March 1, 1971, and which plan to use Lake Michigan waters
for coolings
1* Discharges and water use shall be limited to
that amount essential for makeup and blowdown in the
operation of a wet, closed cycle cooling facility*
2* New applications for powerplant construction
permits must be submitted in the context of a regional
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2 power expansion plan and must provide evidence of partici-
3 pation in site planning by the State and Federal regulatory
/,, agencies. Public notice of proposed sites should be given
5 at least 5 years in advance of construction*
6 MR. STEIN: Are there any questions or comments?
7 MR. PURDY: Mr* Stein, from the standpoint of
g the monthly temperature recommendations now, under A, 1.,
9 can we of the States now assume that this is a fixed and
10 final recommendation? And the reason that I ask this is
11 that roughly about 1 year ago, I think on March 16 of .
12 1970, we held public hearings to adopt monthly maximum
13 temperature restrictions on Lake Michigan, based upon
14 recommendations that had been made to Mr, Poston by Dr,
15 Mount, and although they are somewhat different than these
16 presented today, they were very close, and yet we went a
17 long ways away from that in the intervening 12 months and
^ are now back, and I would hope that this now represents
19 a fixed and final recommendation that we can act on,
20 MR. STEIN: Do you want to comment on that?
2i MR, BRYSON: These specific numbers will be
22 addressed to by Dr, Mount in his presentation shortly, Mr,
23 Purdy. So I feel that these are the numbers that EPA
24 feels are values that should be associated with Lake
25 Michigan.
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2 MR. PURDY: All right.
3 MR. STEINj Maybe you want to defer that, Mr.
4 Purdy. We do have a committee established now, because
5 in administrating this, I do believe we have a need for
6 some fixed numbers not only here but throughout the country.
7 We have Dr* Mount, who is in charge of our fresh-
g water standards in Duluth, Dr. Tarzwell in charge of salt
9 water standards for fishes and other aquatic organisms in
10 Narragansett, and they are on the committee as well as
11 Mr. Yates Barber in the Department of Interior, Fish and
12 Wildlife Service, and Mr. Frank Rainwater, Engineer
13 of our Gorvallis lab, who specialized in the engineering
14 aspects of cooling.
15 Now, I think when Dr. Mount and these others come
16 up to do this, as I understand it, this is the composite
17 view of this committee agreed to by the committee? and as
lg far as I am concerned, we are pretty stable on this, and
19 we have established these numbers after consulting with our
20 experts on a nationwide basis.
21 Are there any other comments or questions?
22 MR. MAYO: Yes, Mr* Chairman, with respect to
23 item 7 on page 2.
24 The item addressed itself to a requirement that
25 preliminary plans be completed by December 31> 1971, for
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facilities now in operation. In the context of being
prepared to address each installation to the possibility
for some remedial action to take place, I think it would
be most appropriate for the conferees to address themselves
also to a date by which any necessary remedial action would
have to be accomplished. We have done this in a variety of
other circumstances in connection with the Conference
activities, and it would be appropriate here for the con-
ferees to also address themselves to a date certain for
the accomplishment of the needed remedial action.
MR. STEIN: Is that agreeable?
-,* I think that probably is essential because I
,, noted that too. I think the point is that if your
. g. proposal is to close the circuit on that and have a closed
-/• loop system, you have a proposal for plants that are not
already in operation. But I think we should consider a
timetable for putting in remedial facilities for plants
which are now operating, which you would consider by
_ whatever data you did — if December 31, 1971 is the data
— to need facilities. We should have a timetable on
22
2, Mr. Purdy.
MR. PURDY: Mr. Stein, I guess now — or Mr.
Mayo, the question of how A. 7. fits in with A. 1., and
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2 does this mean that you would move forward on the closed
3 cycle cooling for any existing facility that exceeds a
4 half billion B»t<,u0/hour even though it met the standard
5 adopted of 1,000 feet with a Delta-T of not greater than
6 3° Fo?
7 MRo MAYO: No, I think perhaps you have missed
g the relationship between those two points, Mr« Purdy*
9 Item 7 directs itself to the timely construction
10 of auxiliary cooling systems in the event they become
11 necessary in terms of not being able to meet A, 1, and it
i
12 speaks in terms of the development of preliminary plans by
13 December 31, 1971, for each facility discharging more than
14 a daily average of a half a billion B«««u«/hour»
15 So what it says is that the discharger, whose
16 average daily discharge is more than a half a billion
17 B«t.u«/hour, it would be an automatic requirement for them
lg to develop preliminary plahs for any auxiliary cooling
19 facilities should it be found that they are not in com-
20 pliance with A* 1,
21 MR, MILLER: Mr0 Chairman, I have a question of
22 how you relate item 5t which has a daily average of 2
23 billion B.t,u,/hour, where you are going to make investi-
24 gations of a discharger at the intake of the discharge,
25 and then you require it if it is over 1/2 billion B.t»u»/houz[«
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2 Should 5 be a half of a billion B,t0u0/hour?
3 MR. MAYO: No, the distinction between 7 and 5
4 is one that relates to the magnitude of the discharge,
5 and the considered judgment that when you are in the range
6 of 2 billion B*t*u,/hour, that there be investigations of
7 some substance with regard to those discharges0
8 MR. MILLER: Yet, we apply it to all those that
9 are over a half*
10 MR. MAYO: In item A» 1., that concluding sentence:
11 Determination of compliance with the above limits shall be
12 made by the State regulatory agencies and EPA by June 30,
13 1971.
14 For all dischargers whose heat discharge is half
15 a billion B»t*u*/hour, we would say, because of the pros-
16 pects for not being able to meet A, 1,, we think it would
17 be reasonable for all of those dischargers to develop
18 preliminary plans by December 31, 1971, should it be found
19 that auxiliary cooling systems would be necessary*
20 But for those discharges in excess of 2 billion
21 B*t.u,/hour that there be special investigations carried
22 out. Such investigation should place emphasis on the
23 determination of direct effects of the intake and discharge
24 upon fishery resources of Lake Michigan* So we are dis-
25 tinguishing in terms of magnitude with respect to the
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D. S. Bryson
intensity of investigation, but taking all of those over a
half a billion B.t.u./hour and requiring them to develop
at least preliminary plans. So that, should it be deter-
rained that they are not in compliance with A. I., that the
preliminary planning element would already have been
accomplished by December 31 » 1971.
MR. CURRIE: Mr. Chairman, at what date is it
contemplated under paragraph B that facilities now under
construction will have closed cycle cooling?
MR. STEIN: By the way, Mr. Currie, I think that
is a pertinent question and really one we have to answer.
As far as I am concerned, we are going to pursue that and
pursue it hard.
We have two questions here: 1) whether plants
under construction or not started, yet have to have this
closed cycle system before they begin operation; 2) where
you determine that existing plants need cooling facilities,
how long we are going to give it. I think these are the
essentials of the time schedule that have to be met.
Now, do you want to take a crack at what Mr.
Purdy asked for?
MR. BRYSON: Our intent at this is to look at
each one of these facilities on a case-by-case basis with
25
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- amount of time in which it is going to require to either
, backfit these facilities or construct the necessary
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our technical experts to find out what is a reasonable
facilities for ones that are, not under construction right
now* So it will be on a case-by-case basis that we would
look to the facilities*
MR0 CURRIEt Is it contemplated that you may want
to keep some of them closed down until they have installed
10 these facilities?
MR0 BRYSON: I think that is a judgment we are
going to have to make when we look at the individual plant,
and the circumstances around that individual plant*
MR. MAIO: I wouldn't rule that out on the basis
of a case-by-case appraisal*
MR, STEIN: Let me get back to Mr, Currie's
question on this* In other words, what you are saying is
that for a plant under construction, you are not proposing
necessarily that we have a date that they are going to
comply, nor are you saying you won't permit them to go
unscreened without having these facilities in. You are
saying you are going to review that on a case-by-case basis,
and you are going to come up with two judgments on a case-
by-case basis: For a plant that is under construction or
which hasn't started yet, that they are going to have a
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2 closed cycle or its equivalent, but you are not going to
3 say when they are going to have to have it finished* Nor
^ are you going to say whether a plant can open without it
5 being finished or not. except on a case-by-case basis0
5 Is that what you proposed?
7 ME. BRYSON: I think the conferees could establish
3 an outside date if necessary* The thing is that these
o, plants have various complexities due to their size, due to
10 the physical location of the facility, or planned location,
11 and I think to generalize for this broad range of possi-
12 bilities is impossible,
13 MR0 STEIN: Have we generalized for the steel
I/,, mills and the oil companies up here on completion dates of
15 not? I think they were fairly complex operations*
16 MR. MAYO: I think your point is well taken,
17 Mr. Chairman, in terms of seeking to establish an outside
1$ date for the achievement of compliance with this closed
19 cycle cooling requirement, I think your point is well
20 taken,
21 MR, STEIN: Maybe we can think of that, but let's
22 get back to Mr, Currie's point which I think is an
23 essential point, too,
24 That is, whether with a plant under construction
25 that we are going to contemplate, if we have this outside
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plant, letting that plant open without having the facilities
in place and in operation. Is that contemplated in your
proposal?
MR, MAYO: We would see the possibility for a plant
that is essentially ready to go into operation and for which
the whole question of backfitting needs not to be addressed,,
that it might not be unreasonable for that circumstance to
permit operation for a specific limited period of time.
We are faced with the possible parallel of the situation
that exists at Palisades*where in substance there has been
an agreement between the power company and the intervenors
in the context of the AEC technical committee requirements^
whereby the plant could go in operation and that within
32 months, in terms of that agreement, the discharger would
be required to be on line with backfitted cooling facilities.
To the extent that we might have a close parallel
to that situation, which may not be unreasonable, it may
not be unreasonable to use the same solution,
MR. STEIN: Well, we can simplify this if you are
talking in terms of your outside date or your date in each
one, whether you stated 2 months, 3 years or 2 years.
2' I just pose this question. If you can say that with
plants under construction that these plants will be or will
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1 not be permitted to go into operation as long as they meet
2 — let's assume you are making judgments that they meet
3 to go in operation — as long as they meet the State require
ments, then your limited time takes care of itself because
5 you have already set the limits.
6 Now, I think this is a very significant question
7 that Mr. Currie asked. I base this not on a question
of ours — of one against the other — but if you have a
question of getting sufficient power in the area and if a
10 plant doesn't come on line when someone figures it should
11 come on line, I think the conferees have to consider that
12 question very, very carefully.
MR. MAYO: I think we should set a date certain
for the accomplishment of the corrective backfitting
operations that would be required under item B; and the
period of somewhere between 32 months and 3 years, if
17 this is reasonable in terms of our understanding of the
problems of design and construction, might be certainly
•jo worth very specific discussion on the part of the conferees
20 MR. STEIN: Well, why don't you think about that
possibly during lunch. Again, let me go back. I
22 think in dealing with Mr. Currie's point, assuming you
accept this — and I am making no assumption now; I am
just pursuing this and trying to see that there is a
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I D. S. Bryson
2 reasonable and viable regulatory plan for both. That is all
3 that we are doing at the present stage, and I want this
^ understoodi there is no judgment made now.
5 But I think the question that you are going to
6 have to get if you are coming up with a notion, say, on
7 a 3-year basis, for all new powerplants to put in essentially
g a closed system, that for plants that aren't built in the
9 3 years away you may have no problem. Or for all plants,
10 in going back to those old plants, you are going to go back
11 to the old plants, permit them to operate and put in their
12 treatment facilities as I understand your proposal, within
13 a reasonable time, the same way as we go to any city, any
14 industry and ask them to do it within a reasonable time*
15 The real hard, unique situation you have in the
16 power situation is when a plant is under operation — let's
17 suppose for sake of argument we have given everyone 3 years,
1$ One plant is due to open in 1 year; one plant is due to open
19 in 2 years. Do we allow those plants to open provided they
20 have agreed to put in what may be the regulatory agencies
21 considered are needed facilities, or do we hold them back
22 and don't let them throw that switch to open until they
23 have the facilities? What do we do? (Applause)
24 MR, CURRIE: 1 have another question, Mr, Chairman,
25 What is the likelihood that provision A, 1, of the Federal
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2 recommendation will require backfitting of existing
3 facilities?
MR. STEIN: Well, I think an engineer or possibly
5 a biologist would have to answer that*
5 Can you answer that?
7 I will give you a supplement to that, if I may,
Mr. Currie* Do you know of any existing facilities that
o, don't meet A. 1, now?
10 MRo CURRIE: That, I think, is my question.
11 MR. STEIN: Yes. I don't like to fumble around
12 this close to lunch.
13 MRo MAYO: By way of observation, Mr. Gurrie,
for the limited analysis —-. the analysis that we have
made, it appears to us that most or perhaps all of the
16 existing plants would be able to meet the requirements of
17 A. 1. by going to improved discharge structures,as dis—
tinguished from the possibility for having to go to a closed
19 cycle cooling system.
20 MR. CURRIE: And how big a job is it to rebuild
21 the intake and discharge structures on existing plants?
22 MR. MAYO: Well, I think it is going to depend
23 on what is already there in the way of facilities, and
24 what physical local considerations need to be taken into
25 account in order to meet the requirements of 1. A«
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Each one of these dischargers, at the present
time, is a separate individual discharge and to try to
collectively generalize on what it would require, I don't
think we can do it meaningfully at this time.
MR. STEIN: Wait a minute. Are we getting into
the same kind of discussion we had before? Should any of
these take more than 3 years, for example?
MR. MAYO: Oh, no.
MR. STEIN: Then, we can generalize.
MR« MAYO: I got the impression Mr. Currie was
asking what would be required, not what period of time
would be required.
MRo CURRIE: My present question has to do with
the impact of section A. and particularly Section A. 1.
on existing facilities in terms of cost and feasibility of
compliance
.
MR. STEIN: How many of the plants in existence
would be required to put in extensive modifications to
meet 1, do you know?
MR. BRYSON: I don't have the numbers at my finger--
MR. STEIN: May I suggest, then, I think this is
very important. Would it be possible to have that, —
MR. BRYSON: Yes.
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1 D. S« Bryson
2 MR. STEIN: — after lunch?
3 MRo BRYSONs Yes.
4 MR. STEIN: All right.
5 Are there any other questions or comments?
6 Mr. Purely.
7 MR. PURDY: Mr. Stein, the wording under A* 1* is
$ somewhat interesting. This maximum distance of 1,000 feet
9 from a fixed point adjacent to the discharge •—• it doesn't
• i
10 say'a,000 feet from the discharge point," it Says"a point
11 adjacenf'to it. And I am wondering how this is to be in-
12 terpreted and what really is meant by this"point adjacent
13 to the discharge?"
14 MR. BRYSON: Our thinking on that, Mr, Purdy,
15 wast A lot of information was presented at the workshops
16 concerning the flexibility that can be achieved with a dis-
17 charge structure, that it can be made pretty adaptable to
13 any configuration of a discharge plume that you wanted.
19 Now, we were trying to provide some flexibility
20 to the dischargers by making this 1,000 feet from the point
21 adjacent to the effluent pipe*
22 Let me give you an example of that. That might
23 clear it up easier. If you have a discharge plume coming
24 out of the pipe, that is 2,000 feet long, the area — and
25 a very few feet wide, say — the area — the restrictive
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nature of that — that is no more restrictive than if you
set a point 1,000 feet out from that discharge and make
that your point of monitoring. So you are measuring 1,000
feet from that point back to the discharge and 1,000 feet
further out* So that the area covered by the plume is no
greater than a straight 1,000 feet from the discharge*
I obviously left you totally in the dark now*
(Laughter) Well, let's try it again*
The whole purpose is to provide some degree of
flexibility to the discharger.
MR* PURDY: I am with you up to there*
MR0 BRYSON: Okay* You are with me up to there.
Very good*
MR, CURRIE: Are you saying, Mr. Bryson, that we
should interpret 1,000 as meaning 2,000 or however much we
choose to depending on how far out we start measuring,
say a mile?
MRo BRYSON: No, the purpose is to allow flexi-
bility in the discharge structure itself* Now, we are
trying to minimize the impact of the area of the discharge
plume.
Everybody there so far? All right, now, it may
be equally as nonoffensive to make the point 1,000 feet from
that discharge pipe as to make the point at the discharge
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pipei due to the configuration of a discharge plume*
If we had some of —
MR, STEIN: Mr. Bryson, may I suggest —
5 MR. BRYSON: Tes0
6 MR« STEIN: — that if it takes this explanation,
7 we also better think of fixing up this language a little
so we can understand it, because it doesn't seem to me just
o, on the basis of this discussion that we really have a fruit<-
10 ful basis for understanding the regulation, particularly on
11 as vital a point as this one.
12 MR. BRYSON: You know, Murray, you have often said
13 in the past that an engineer can't talk without a black-
ly board. That is just about the case here.
15 MR0 STEIN: Well, I don't think we have a black-
16 board. We have this language, and I think the engineers
17 developed the language* We also have an engineer from
lg Michigan down there. I can understand him when he talks
19 about 1,000 feet from the discharge. I know what that
20 means. Or if you want to set one point for each plant and
21 give them 1,000 feet to fool with, from any reasonable point
22 from their plant, that is another thing that I can under-
23 stand. But I think we have to resolve that in — I am sure
24 you know what you mean there. I am not —
25 MR. BRYSON: True.
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MR. STEIN: But I don't think it is put down here
in a kind of language that communicates to the people here.
Maybe you want a little more time to think possibly of how
this language can be clarified. We are going to
have to adjust this language.
MR. PURDY: Mr* Stein.
MR. STEIN: Mr. Purdy.
MR0 PURDY: Mr. Bryson, I am wondering if you
are saying that if you have a high velocity discharge
that this point adjacent to the discharge might be where
the — say the initial velocity of this discharge is lost
and now approaches natural lake currents, and then the
1,000 feet is measured from this point of where the
velocity is lost? Does that, say, approach the thinking?
MR. BRYSON: It does in one possibility. Again,
there is such a wide flexibility in these discharge
structures that, yes, that is one example. But there are
other situations that are comparable to that.
MR. PURDY: I think this makes it difficult to
write into a standard.
MR. STEIN: So do I.
Why would you say, at a maximum distance of 1,000
feet from a fixed discharge point from each plant, from a
single fixed discharge point?
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1 D. S. Bryson
2 In other words, you pick one place in a lake — if this is
3 what you mean — and there you kind of pick a place certain
4 and then you have 1,000 feet to fool around with within
5 that space* How about that?
6 MR. BRYSON: Yes, around that point*
7 MRo STEIN: I think this is largely a drafting
3 problem* Perhaps you can find a lawyer or two during lunch
9 and we will try to work it out* (Laughter)
10 MR* BRYSON: Do you want to keep these regulations
11 short or make them long?
12 MR, STEIN: They can't be any longer and more
13 opaque than what I hare been reading here*
14 Are there any other comments or questions?
15 MR. FRANCOS: Yes, Mr* Chairman.
16 MR* STEIN: By the way, I don't want to lose
17 that point, but you have a 96-hour TLm without an explana-
1$ tion of what TLm is in your proposal, and I would like to
19 know how many people in the room know what TLm is?
20 Mr* Frangos*
21 MR. FRANGOS: Yes, I was wondering if Mr. Bryson
22 has determined how or what the mechanics are for reaching
23 an evaluation by June 30, 1971» on whether we meet those
2^ temperature requirements* Are we talking about modeling,
2' or have you been out on the lake doing -some work?
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2 MR<> BRYSON: I think it could be a combination,
3 Mr, Frangos, of both. With the expertise that is available
4 at the State and Federal level, with what should be expected
5 from the various types of existing discharges, and with
5 appropriate sampling in the field, I think this can be
7 determined rather quickly*
3 MRo FRANGOS: For a large measure, I assume it
9 would be empirical because how do we — I mean do you have
10 information, for example, on what is happening in December?
11 How will we know that in June';- I am just trying to get a
12 feel for this.
13 MR0 BRISON: In order to implement it for the
14 months that obviously we don't have between now and then
l^ it would be somewhat empirical based upon the best technical
16 judgment of the experts in the country.
17 MR. FRANGOS: And these experts would be available
18 by the EPA between now and the first of June to make that
19 evaluation. Again, we have got a real problem in terms of
20 resources of putting this information together, getting out
21 of the lake what we have to get out of the lake, and to make
22 an evaluation*
23 MR, STEIN: I think that is one question we can
24 get an answer to. Is that feasible, Dr. Mount?
25 DR. MOUNT: I am sorry, What is the question?
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1 D. S. Bryson
2 MR. STEIN: The question is whether we can supply
o the experts to the States to give them an evaluation of the
figures that we have in 1. A. by June 30, recognizing that
they will not have experienced July, August, September,
October, November, and December, by June 30, and will not
be able to set out a junior clerk with a thermometer in
his grubby hands. Will we be able to assist them to come
up with this judgment by June?
DR. MOUNT: I think Mr. Mayo should answer that.
MR. MAYO: In terms of the resources and in keepirjg
iwth a number of dischargers that are involved, and I would
TO hope the availability of some photogrametric techniques, I
•, i think that there is the opportunity to meet that date or on«
•ic very close to it. In the matter of dollar resources, Mr.
,x Chairman, we are speaking in terms of June 30, 1971, in
,7 anticipating the availability of resources.
,g MR. STEIN: I don't know, Mr. Mayo whether I speaP
, Q for the conferees, but let me pose this question. If
2Q we are going to ask the conferees to accept this schedule
__ as Mr. Frangos has pointed out, it is going to be very
22 difficult for the State to come up with this result by June
30, 1971, by its own resources, and it is going to take 6
months' projection of information which we might not have,
25
.nd
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they don't have that expertise nor can they afford it,
3 I think before we can ask them to accept that
date, we have to give them a yes or no answer whether we
are going to help supply one . Riphtv
MR. MAYO: Certainly, there is a commitment to
help, Mr* Chairman*
MR. STEINi Or supply it*
MR. MAYO: To do the whole job?
MR. STEIN: No, to help them so they can come up
with this answer by June 30, 1971.
If we have the commitment to help them and make
the resources available, I think that is Mr, Frangos*
question*
MR. MAYO: Well, I would have to say, Mr* Chair-
man, this would be the most optimistic date that we could
make* If at this point in time there is a reservation on
the part of the States in terms of their ability to commit
resources and to participate —• and we do want this to be
a cooperative effort — then I think we are required to addr4ss
ourselves jointly to the reasonableness of this date in
terms of the States' ability to participate, and I think
in terms also of their consideration of the reasonableness
of making those kinds of projections in this period of
time*
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1 D. S. Bryson
2 At this point, I think that the date is open to
3 discussion and subject to a response from the States in
^ terms of their ability to respond with resources and
5 commitment to participate and to reasonableness of the date
6 in terms of making these estimates.
7 MR. STEIN: I think we have outlined the question.
g May I suggest that this can be more easily
Q resolved by deferring now, asking you and the States to
10 get together with informal caucuses on this question.
11 I know you will get together on this and others before we
n ' _.'
1t conclude and see what kind of date we can come up with.
13 Are there any other questions?
MR. CURRIE: Yes, Mr. Chairman, paragraph A. k.
15 of the Federal proposal speaks of backfitting inert
16 mechanical devices for fouling problems.
I wonder if we have any information about the
lg practicability as to cost of doing that,
MR. BRYSON: I think for that question, let's
20 call on Dr* Tichenor from our Corvallis Laboratory to
2i respond
22 Dr. Bruce Tichenor.
23 DR. TICHENOR: My name is Bruce Tichenor. I work
24 for the Environmental Protection Agency with the National
25 Thermal Pollution Research Program in Corvallis, Oregon.
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1 . Do S. Bryson
2 The question had to do with the practicability
3 and cost of backfitting condensers with mechanical devices*
4 I have to admit I am not an expert in this par-
5 ticular area. I do know that the Tennessee Valley Authority
6 has had some experience in backfitting these devices, so
7 in terms of its feasibility, it is feasible* I really
B can't give you any good information on the cost; I just
9 don't have this available to me right now*
10 MR0 STEIN: Let's go over your question again*
11 I know we have been on this particularly with
12 the Tennessee Valley and other southern companies* You
13 say it is technically feasible*
14 DR. TICHENOR: Yes*
15 MR0 STEIN: But do you have any idea the time it
16 takes, Bruce?
17 DR* TIGHENOR: I really don't. I think this is
1^ a similar question to backfitting cooling devices. I mean
19 we can make general statements about its technical feasi-
20 bility, and I think everybody will agree that it is tech-
21 nically feasible, but I think when you get to any one
22 specific case you would have to look at that case and look
23 at the design limitations which are there right now and
24 then make a decision.
25 MR. CURRIE: Finally, I would like to ask whether
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1 Hon. R. B. Ogilvie
2 the ensuing Federal witnesses will address themselves to
3 the question why the Federal Government has decided to
4 depart from the recommendations of the Technical Committee.
5 We have before us a detailed Federal proposal. I think we
6 are entitled to some reasons.
7 MR. STEIN: By the way, I am not sure you are going
$ to have any ensuing Federal witnesses other than technical
9 witnesses. I think we can — do you want to handle that,
10 Mr. Mayo?
11 MR. MAIOt Yes. I think what I would like to do
12 would be to proceed with the presentation by Dr. Mount and
13 then following that, for whatever it can contribute to
14 answering your question, through this further witness.
15 MR. STEIN: Are there any other questions?
16 If not, I have two telegrams here. One from
17 Governor Ogilvie designating David P. Currie, Chairman of
lg the Illinois Pollution Control Board as the official
19 conferee for Illinois at this Conference. It says primar-
20 ily> actions at this Conference will relate to adoption of
21 standards. This telegram without objection will be put in
22 the record.
23 (The telegram from Governor Ogilvie follows in
24 its entirety.)
25 "Pursuant to Illinois Environmental Protection
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n Hon. Ro B. Ogilvie - Mrs. H. Hoock
2 Act section 5 (c) the Illinois Pollution Control Board has
3 'the authority to act for the State in regard to the
4 adoption of standards for submission to the United States,1
5 Therefore, I am designating Mr. David P<> Currie, Chairman,
6 Illinois Pollution Control Board as the official conferee
7 for Illinois for this Conference since the primary actions
g taken at this Conference will relate to adoption of stan-
9 dards. The Environmental Protection Agency of Illinois is
10 charged under our statute with implementing and enforcing
11 such standards and will continue to provide personnel for
12 the technical committees of the Conference."
13 MR. STEIN: And also a telegram from Mrs, Helen
14 Hoock, and this telegram asks that we meet our responsi-
15 bility; no thermal discharge; standard must be adopted and
16 enforced immediately,
17 Without objection this telegram will be put into
lg the record as if read*
19 (The telegram from Mrs, Hoock follows in its
20 entirety.)
2i "CARP, Community Action to Reverse Pollution,
22 demands Conference meet responsibility. No thermal dis-
23 charge. Standard must be adopted and enforced immediately."
24 MR. STEIN: Let us recess for lunch until 2:00
25 o'clock,)
(Noon recess,)
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D. I. Mount
2
3 AFTERNOON SESSION
4
5 MR. STEIN: Let's reconvene. The Conference is
6 reconvened.
7 Mr. Mayo — I guess Mr. Mayo isn't here on time
8 this afternoon, Is Mr, Bryson here to answer Mr. Currie's
9 questions? If not, let's call on Dr. Mount.
10 Dr. Mount, will you come up?
11
12 STATEMENT OF DONALD I. MOUNT, Ph.D.,
13 DIRECTOR, NATIONAL WATER QUALITY LABORATORY, ENVIRON-
14 MENTAL PROTECTION AGENCY, DULUTH, MINNESOTA
15
16
17 DR. MOUNT: There are copies of my presentation
lg available for the conferees. Does anyone here have them?
My name is Donald Mount, and I am Director of the
20 National Water Quality Laboratory, Environmental Protection
21 Agency, at Duluth, Minnesota.
22 Mr, Chairman, I would like to make a few prelimi-
23 nary comments about my role in this, in that it is my
24 responsibility, as I understand it, to attempt to make an
25 objective appraisal of the data available and not necessarily
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1 D. I. Movint
2 to support or refute any particular decision that might
o be made by the conferees, but rather to try to attempt to
relate to them — to you what I believe is the best evidence
available as to the effects of thermal discharges or par-
ticular temperatures in Lake Michigan.
In doing so, we look at two questions: 1) what
are the requirements for the organisms that are there, and
the organisms that are to be protected, and, 2) of course,
we have to look at how this relates to the existing condi-
11 tions*
12 I would like also to mention that in my prepared
comments that I hope will be passed out to you shortly, I
have deleted references to the supporting data that goes
15 into this simply for the sake of making it more readable
16 and shorter*
17 We do have these references from the literature*
We have been combing the literature as well as our own
19 research now for 2 years and what I bring to you is clearly
20 not something which I conjured up but rather a summary of
2i many, many people's work including some who have appeared
22 before this Conference before*
23 I want to emphasize that the lack of references
24 in this does not mean that we are claiming credit for all
25 of the information*
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1 D. Io Mount
2 In the summary — does anyone here yet have copies
3 of this?
4 MR0 STEIN: Yes, I have a copy.
5 DR. MOUNT: Has it been distributed?
6 MR0 STEIN: I must have Mr. Mayo's cppy0 Maybe
7 it is a good thing he didn't show.
8 DR. MOUNT: Well, I will proceed, Mr. Chairman,
9 then, without these copies, because they are apparently not
10 available right now.
11 MR0 FETTEROLF: Who has them?
12 DR<> MOUNT: Mr. Pratt, I think, has them.
13 In the summer of 1969, the National Water Quality
14 Laboratory provided recommendations for temperature stan-
15 dards on Lake Michigan. We have now been asked to discuss
16 our recommendations. Our views have changed only slightly
17 since 1969 and these changes are due to more evidence
lg gleaned from the literature, as well as new research that
19 we have completed, but by and large, our present recommenda-
20 tions are not significantly changed. My discussion today
21 is based on an assumption that I believe is now well
22 accepted by informed people, that the lake as a whole will
23 not be warmed, except in localized areas, by powerplants.
24 As has been said many times before, the effects of tempera-
25 ture on Lake Michigan will show first in the aquatic biota
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103
D. I. Mount
rather than on other water uses such as for swimming and
for drinking water supplies. Therefore my discussion will
center around aquatic life criteria.
In spite of all the words that have been said
regarding temperatures in Lake Michigan and the effects of
powerplant discharges, there are a number of principles
and concepts that need to be clarified. By way of
introduction, I would emphasize that unlike pollutants such
as DDT or lead we are not striving for a zero concentration,
but rather for the range of temperatures which is best for
the well-being of the aquatic biota of the lake, and we
further recognize that the temperature range is clearly
different in various seasons.
MRo PURDY: Mr. Chairman, I would like to have
a copy of this statement so I could follow and know what
is going on.
MR. STEIN: Mr. Mayo, is it possible for us to
get copies of the statement for the conferees?
MR. MAYO: There should be statements here, Mr.
21 Chairman.
0 STEIN: We said we were going to reconvene
at 2:00 o'clock, Mr. Mayo.
MR. PURDY: I don't understand how the press
can have the statements and we don't have it here.
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1 D. I.,Mount
2 MR. STEIN: Can you explajn that? I guess they
3 can. Dr. Mount, to whom did you give copies of the
statement?
DR. MOUNT: The original copies, Mr. Chairman,
were sent to Mr. Bryson in Minneapolis on Saturday
morning.
MR. STEIN: Thank you.
(Whereupon, Dale Bryson entered the room and
distributed copies of Dr. Mount's statement to the
conferees.)
DR. MOUNT: I will pick up again now in the
middle of page 1.
•* • In spite of all the words that have been said
regarding temperatures in Lake Michigan and the effects of
powerplant discharges, there are a number of principles
,« and concepts that need to be clarified. By way of
introduction, I would emphasize that unlike pollutants such
•jo as DDT or lead we are not striving for a zero concentration
2Q but rather for the range of temperatures which is best for
2, the well-being of the aquatic biota of the lake, and we
22
23
24
25
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D. I. Mount
further recognize that the temperature range is clearly
different in various seasons. While toxicity levels may
vary some, on the whole there is little difference in safe
concentrations of DDT or lead as the seasons change. This
is not so with the temperature requirements and so a single
value is not enough to specify necessary temperature condi-*
tions. The problems of establishing acceptable temperature
limits are further complicated because within some limits
the aquatic biota has the capability of shifting critical
seasons such as spawning, to coincide with a faster or
slower warming rate of the water, either from natural or
artificial causes. On the other hand, since many of the
important species require rather specific foods, particularly
when they first hatch from the eggs, there is a danger of
upsetting the timing of food supply of the right type with
the various life stages of the desirable fishes in the lake.
One of the significant points, often not recog-
nized, is the different temperature requirements for various
species of fish in the lake. Lake Michigan must be
considered as a 2 -story lake in the summertime; that is,
warmwater fish in the surface waters and coldwater fish
near the bottom. There should not be significant changes
in the relative volumes of the epilimnion and hypolimnion.
The cold, deep waters must be preserved for salmonids, in
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106
1 D. I. Mount
2 : particular, if they are to survive during the summer months
3 While we mention here only maximum temperatures, it is
4 important to remember that maximum temperatures are intended
5 j to be maximum temperatures and not sustained for long periods
6 of time. It would be far better to use both mean and
7 | maximum temperatures in our standards; in this way more
flexibility could be permitted and still assure adequate
9 conditions for the biota. Regulatory agencies, however,
10 resist the use of mean temperatures in standards and, to
accommodate them, we have recommended only maximums that
12 are protective. Repeating again, it is ultra-important
that maximum temperature standards not be used as safe valu<
for prolonged periods of time.
15 • There are relationships that emerge as we examine
in detail the available literature and research on temperat
effects. Several measures of effect fit together to provid
supplemental information regarding acceptable temperatures
for various species. We have found that temperatures that
20 fish select in their natural environment are the same
temperatures at which food is most efficiently converted to
22 fish flesh and at which the growth rate is best. Usually
23 each is a good estimator of the temperature requirements
for a particular fish. Sometimes information on each of
25 these is not available, but having established this
relationship, any one of the three can be used to estimate
re
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107
1 D, I. Mount
2 requirements for other species. Particularly in the
3 summer months lethal temperatures are not much higher than
4 the temperatures at which best growth occurs. Therefore,
5 the control of temperature to within a few degrees is truly
6 necessary if we are to avoid adverse conditions and yet
7 take maximum advantage of the heat that is there. We strongljy
support the many observations showing that fish do congregate
9 in warmwater discharges, particularly in the cooler months
10 Caution during the cooler months is necessary, however,
11 because change in wind, currents, or plant operations that
12 shift or dissipate the plume can and have resulted in fish
13 kills due to the drop to ambient temperature. This effect
in part determines the maximum temperatures permissible
15 in the winter months and is the basis for establishing
the maximum values for those months. It is equally true
17 that in the summer months when temperatures become too
1° warm, fishes will move away from these plumes and will not
19 be killed as long as there is a suitable place to go.
Lethal temperatures have meaning only when related to the
length of time at which that temperature occurs. There is
relatively little difference between lethal temperatures
3 for a 24-hour period and those for a longer period. There-
* fore, we usually use temperatures that are lethal in
2*5
approximately 24 hours as representative of lethal
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108
1 D. I, Mount
2 temperatures for the species. Obviously, for short period
3 of time, temperatures may go higher without demonstrable
4 damage. It is not survival though that we are protecting,
5 but rather growth and reproduction, events which almost
6 always require significantly lower temperatures than
7 lethal ones,
3 The following, then, are key points of concern
9 regarding temperature standards on Lake Michigan;
10 1. Safe temperatures vary with season and
11 species,
12 2. Heat is not persistent,
13 3. Timing of food and fish hatching is
14 precarious,
15 4, In the summer, Lake Michigan is Ma lake over
16 a lake," the top one is much warmer than the bottom one,
17 5, Maximum temperatures are not safe for long
1& periods— the lethal temperatures must be related to time,
19 6, Mean temperatures must be lower than the
20 maximums for growth and reproduction,
21 7. Fish kill hazards are greatest in winter.
22 If we could now turn to the transparencies, in
23 Figure 1 we are showing the maximum temperatures of record
2^ for each month at various locations around Lake Michigan,
2* This is Figure 1 in your handout, by the way, (See p, 109<>)
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D. I. Mount
The numbers at the top show the number of locations
represented. These include swimming beaches and water intakes
from many parts of the lake, and the temperatures have been
measured at the surface and at depths up to 50 or 60 feet.
The period of record varies from station to station; in some
cases a period of many years in included and in other cases
it is limited to a relatively short period of time. It is
o surprizing to me to see the limited range of maximum values
•J_Q for such widely separated locations. The spread in tempera-
tures for the summer months using data from swimming beachej
does not materially change the distribution of maximum
recorded temperatures from deeper water intakes. The spread
in maximum recorded temperatures is greatest during the
spring and fall when the lake is warming or cooling.
, /•
did not occur in the same year. One cannot draw a line
through these points and say that it represents the annual
curve for the maximum temperatures in Lake Michigan. It
2Q is certain that the maximum values recorded in September
1 c
The maximum temperatures for successive months
... of a particular year occurred in a different year than
22 the maximum values for the same location in April. The
annual pattern as shown by this graph never occurred in
2L any one year* Even though the picture portrayed by this
is somewhat artificial, it nevertheless gives a
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Ill
1 D. I. Mount
2 reasonable picture of the variation in temperatures in
3 surface water with respect to location and season,
4 Figure 2 (See p. 112) is the same base graph
5 as used in Figure 1 with an overlay showing the lethal
6 temperatures for various species of fish that are important
7 in the lake.
These are shown by the open circles. I failed
9 to mention, by the way, that the lines — the horizontal
10 lines in Figure 1 are drawn at the temperatures for the
11 recommended temperatures as listed in the proposal read
12 this morning. And, secondly, that the red dotted line is
13 an approximation of the temperature of the hypolimnion at
14 various times of the year. This is only an approximation
15 and was not done by exact plotting as was the case for the
16 maximum temperatures at the surface. So we should be
17 thinking of two temperatures in the lake all of the time
as somewhat representing the conditions. The dots
19 representing lethal temperatures were not derived from
20 existing temperatures in Lake Michigan — and here I am
referring to the open circles — but from many sources
22 both in the literature and from recent research, and are
based on the requirements of the biota.
There is no real justification, in our opinion,
for the often-made statement that field and laboratory
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112
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D. I. Mount
data do not agree, or that the work of different
experimenters shows completely different results. People
who say this are unable to interpret and understand the
conditions upon which experiments were performed* When one
corrects for acclimation temperatures and other variables
that might not be evident, he sees that there is good
agreement between both field data and laboratory data,
and among various experimenters* Dr. James Gammon,
Associate Professor of Zoology at DePauw University, in
a report covering study from 196? to 1969 on work financed
by a power company of Indiana and consisting solely of
field surveys, collections and observations, states in his
Summary, point number 5» "Generally good correspondence
was found between laboratory determinations of temperature
preferenda of some resident species and their abundance
in different thermal zones of the river although a few
laboratory studies of the species found in this river have
been made." I want to emphasize this study just quoted
from was a field study financed by the power industry*
Individuals reviewing the information on thermal effects
on aquatic life on both sides of the issue have used data
in a biased manner to meet their own needs.
You will notice in Figure 2 that the lethal
temperatures for a given species such as the channel
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114
1 D. I. Mount
2 catfish are different in successive months. As pointed
3 out by the arrow, you see the lethal temperatures are
4 increasing as we approach summer and decreasing as we
5 approach winter. Fish during the winter months are
6 acclimated to a lower temperature and their upper lethal
7 temperature is therefore considerably lower than it would
& be for the same species in the summertime when the fish
9 are living at much warmer ambient temperatures0 Lethal
10 temperatures for the spring and fall months when the lake
11 temperature is changing, are difficult to position on the
12 graph because their temperature of acclimation is changing
13 with that of the lake. The lethal values for winter months
j
14 are based on an acceptable drop to ambient temperatures.
15 I think it is a very significant point, that these lethal
16 temperatures in the winter are based on the drop rather
17 than the highest value they can tolerate. We see that
13 pike and channel catfish have lower lethal temperatures in
19 the wintertime than rainbow trout or herring. This may
20 seem inconsistent at first glance, but it gives a true
21 reflection of the ability of these species to accept a
22 temperature drop from a warmer temperature to a colder one.
23 It makes sense when we remember that they are cold-water
24 fish and a drop in temperature means a change toward a
25 more desirable temperature for them. On the other hand,
-------
1 D. I. Mount
2 in the summer months, salmonids must have much cooler
3 water and their lethal temperatures are therefore much
4 lower during the summer months than are those of warmwater
5 fish.
6 Figure 3 (See p. 116) is Figure 1 -- the same
7 base map again — with an overlay showing the growth
requirements of important fishes oif the lake. Growth
9 requirements are more properly relatable to mean temperature
10 than to maximum temperatures and so we have plotted for
11 maximum growth requirements those temperatures which are
12 approaching the maximum values at which acceptable growth
13 occurs. Considerably cooler mean temperatures are
14 required for best growth. If maximum temperatures exceed
15 these values for short periods of time on any one day, it
16 does not mean that there would be a fish kill, but simply
17 that the temperatures would be too high for good growth,
reducing it for that period — not a catastrophic effect,
but certainly biologically significant,
20 Since these temperatures are for growth, they
are plotted for only the growing season. Here we must
22 make the distinction of the 2^-story lake, the warmer water
fish are in the upper layers and the colder water salmonids
are in the lower, cooler water. All the fish will find
their preferred temperature and remain there for much of
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2 the time. I think,again, that is a rather significant
3 point to emphasize, that these species shown, for example,
4 around 60° as having optimum growth requirement — let
5 me check here — these would be such fish as the rainbow
6 and herring, the lake trout, and so on.
7 You will see we have growth requirements that
g are considerably lower than on the surface — than the
9 maximum temperatures either occurring or those which are
10 recommended. This is what I mean when I say these fish
11 will seek the temperature they can do best at, and
12 they will find it somewhere between the hypolimnion and
13 the surface water, and this is where they will remain.
14 So that I am fully aware that these growth requirements
15 are below these maximum temperatures, but notice that
16 they are above the hypolimnionic temperatures, and so
17 they select the place where they can do well.
IS The standards should be specified for surface
19 waters and hypolimnionic waters to define the requirements
20 for all the species. Some species such as rainbow and coho
21 salmon feed in surface waters, at times so that surface
22 waters should be as low in temperature as is feasible for
23 feeding. This makes such species, as the coho and the
24 rainbow, more accessible to the sport fisherman. We do
25 recognize that fish will move into deeper waters when
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2 necessary to avoid unacceptably warm surface water,
3 Figure 4 (See p. 119) is an overlay again on
4 Figure 1, portraying spawning and maturation requirements
5 for various species. There is less information in regard
6 to requirements for the reproductive period than for
7 other life stages. It is difficult to locate the tempera-
8 tures for spawning for the proper months because some
9 species will shift their spawning period depending on the
10 temperature. There are other species that apparently do
11 not shift their spawning seasons; spawning is controlled
12 by photoperiod,, for example. For these, matching photo-
13 period with temperature is very important. I have shown
14 spawning periods for the months in which others and we
15 have determined spawning normally occurs in Lake Michigan,
16 We feel no change in annual cycle should be permitted until
17 more is known about such changes,
lg We have precise information on chill require-
19 ments — that is, the need for a cold period in the winter-
20 time to initiate egg production — for only one species of
21 fish, the yellow perch. Perch have been intensively
22 studied in the last couple of years at the National Water
23 Quality Laboratory, and the work has shown rather
2/»- conclusively that perch must be at or below 45 F. for a
25 period of more than three months if they are to reproduce
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1 D, I. Mount
2 successfully. It is certain that other species require
3 a chill period and some, such as the rainbow trout, do not.
4 Several species are known to live at constant temperatures
5 in springs and are still able to reproduce normally. The
6 chill requirement is peculiar to certain species and one
7 can make no generalization.
# A number of important species spawn in the fall
9 months so temperatures at this time of the year are critical
10 as well as in the spring. Studies have shown that on the
11 Columbia River a lag in cooling during the fall months
12 preceding spawning, damages eggs in the female and
13 successful reproduction does not occur. For this reason,
14 although fish such as the coho may be able to shift their
15 spawning season, it is essential that the annual pattern
16 of the lake be maintained. It is true that one can find
17 ripe coho salmon in tributaries where temperatures are
warmer than have been shown to be safe. This does not
19 mean that the temperature is acceptable. After the run
20 begins, higher temperatures do occur and they will have
21 adverse effects.
22 Returning now to the base chart, Figure 1
23 and the existing temperatures of the lake, I have drawn
• lines that represent recommended monthly maximum tempera-
tures for each month. These limits are based upon the
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requirements of the fish and not upon the existing
temperatures of the lake. Now, compare the maximum
temperatures of record with the recommended maximum
values and you will see that the critical period is in
April and May — a time when the salmonid fry are in
shallow water and are likely to experience these maximum
temperatures.
Reports given before this conference and in the
literature suggest that areas of the lake are now warmer
than is acceptable for some of the species with low
temperature requirements. This would be in local situations
of course. Our data show also that temperatures are a
bit high during certain months and that there should not
be additional temperature increases at those times. We
should not find it disturbing nor think it unusual that
existing conditions, even though natural, are unacceptable
at times and indeed these data show that to be the case.
The acceptable temperatures in the winter, summer
and fall months appears to pose little problem. One
cannot reason, however, that because there is an apparent
concern in only two or three months of the year that
nothing need be done. Indeed, these months are among
the most important of. the entire year and any special
precautions or treatment devices needed to protect the
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1 D. I. Mount
2 biota for these months are just as necessary as though
3 such devices were needed for every month,
4 Leaving now the maximum values that have been
5 recommended, any discussion of powerplant discharges would
6 be incomplete without some comment in regard to other effect
7 Certainly the location of the intake structure may be as
& important in reducing the effects on the biota as is
9 meeting the permissible temperatures. Many of the fish
10 larvae and fry are very poor swimmers at a time when they
11 are found in the inshore waters and it is for this reason
12 that current velocities and location of intakes away from
13 nursery grounds is very important if substantial numbers
14 of fish fry are to be kept from entering the plant. Equally
15 important, several species in Lake Michigan fish are
16 likely to congregate in a current and feed on organisms
17 being carried by it. While most swim upcurrent, they do
move back and forth and can easily be swept into the plant.
19 For this reason we recommend low velocities in the intakes.
20 The intake should not be on the bottom in our judgement,
21 where a number of important species dwell, nor should it be
22 at the surface, particularly because surface water is
likely to contain high concentrations of desirable plankter
and numerous fish fry. Even bottom-dwelling fish must
25 spend a time at the surface while they fill the air
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! D. I. Mount
2 bladder. Because many fish species are attracted to warm
3 water, particularly during the cool months, warm water from
4 the discharge should not be permitted near the intake.
5 Keeping the discharge from nursery areas and off
6 the bottom are obvious requirements and need little comment,
7 Important bottom-dwelling food organisms such as Mysis are
8 killed by temperatures of 61 F.
9 Chlorine and chloramines, formed when chlorine
10 is added to lake water, are highly toxic to many organisms.
11 We have shown, for example, that less than a part per
12 billion of chloramines is lethal to Daphnia in 96 hours.
13 Generally, the lethal concentrations of chloramines to
14 many desirable forms of aquatic life are below «5 ppm.
1$ Such toxicity leads to the recommendation that the 96-hour
16 TLm be met at the point of discharge and mechanical
17 antifoulants be used when possible.
lg Finally, in regard to assessing damage from
19 individual discharges in Lake Michigan, it is extremely
20 difficult to measure effects of one discharge in a lake
21 as large as Lake Michigan. This perhaps is analagous to
22 trying to measure the effect of 1,000 automobiles on the
23 air pollution conditions in Chicago. It is nearly
24 impossible to do, and yet all of the cars together do
25 contaminate the air over this city. In the same way,
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1 D. I. Mount
2 while the effects from one powerplant discharge may not
3 be discernible, this is not to say that there will not be
4 a combined effect from many powerplants. While before and
5 after operational studies certainly are highly desirable
6 to identify gross changes, it is not possible with the
7 present state of the art, to assess the impact of damage
$ in localized areas on a big lake.
9 For this reason I certainly would not be
10 completely satisfied if postoperational studies showed
11 that there was little damage at a given point in a lake
12 powerplant. One could not construe from that that there
13 will be no damage to the lake as a whole. Unless we
14 adopt the position that harming any number of organimss
15 is significant damage, we will ultimately face the
16 question of determining whether or not the number of
17 organisms that are damaged is significant.
18 There is not a biologist at the present time
19 who could tell you whether a thousand or five hundred
20 thousand yellow perch fry is a significant number and
21 would affect the lake, or even the local area. Counts on
22 zooplankton, while they may show that the organisms are
23 not able to tolerate passage through the plant, cannot be
24 extrapolated directly to lake damage. For this reason
25 it will be a long time before studies on individual
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1 D. I. Mount
2 powerplant discharges can be used to significant
3 advantage in assessing impact on Lake Michigan. In the
meantime, we must rely on the literature and the research
5 work currently under way and completed to give us the
6 best answers until the technology of population estimation
7 in large lakes is developed. Certainly in the coming
years we must develop methods by which we can measure the
9 impact of man's activities on populations of aquatic
10 animals with enough sensitivity to provide leadtiitne to
11 take corrective action before damage is irreparable.
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MR. STEIN: Thank you, Dr. Mount.
Any comments or questions?
Mr. Currie.
MR. CURRIE: Dr. Mount, are you presenting us with
any facts that were not known to the Technical Committee?
DR. MOUNT: I would say that for the most part
I probably am not. I think the only thing that is different
from the original in this presentation, if anything, is an
attempt to actually plot these requirements on a graph so
that they can be compared to the existing temperatures.
I hope to provide you with some idea of how close
conditions are to — how close they are to the temperatures
which we believe are important and necessary for the aquatic
life.
MR. CURRIE: Would it be fair to characterize your
statement by saying that you are concerned over the combined
effect on the lake of many powerplants, as you say, at the
bottom of page 12?
DR. MOUNT: Yes, I think that is close. The
main point that I am trying to make is that, in our judg-
ment, there are many, many subtle effects of these discharges
which are going unmeasured in present site studies.
For example, it was not really until relatively
recently — well, I am not saying no one knew this; I am
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D. I, Mount
sure somebody did — but it was not until relatively
recently that I think many of us realized that the bottom-
dwelling fish such as lake herring, for example, must come
to the surface for a period of some days while they are
filling their air bladders. These are effects which are
not measured in a typical powerplant survey, and I am identi-
fying these as being subtle effects which we had not measured
to date. And, furthermore, if we killed X-number of organisms i
per minute, we don't really know how to use that information
yet in assessing the damage to a big body of water like this,
MR, CURRIE: Thank you,
MR, STEIN: Are there any other questions or
comments?
MR, MAYO: I gather, Dr, Mount, that one of the
cautions you are offering the conferees is that the less
water that is involved, in terms of intake into the plants
and subsequent discharge, the less water that is heated as
a consequence of industrial and power generation operations,
the more nearly we are going to be able to maintain the
environment in Lake Michigan that is compatible with the
fishes that are there now,
BR, MOUNT: Yes, I think that is a .fair analysis,
and I would like to expand on it to this extents to say
that it is a principle of ecology which all of us who have
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1 D, I<> Mount
2 had courses in ecology learns probably the first day we take
the course, and that is that every plant or animal modifies
4 the environment in which it lives, and for too long we have
5 been trying to say that man isn't a part of this environment*
5 I think we are now beginning to realize that he
7 really is quite a part of it, and certainly his activities
are going to modify the environment the same as any other
plant or animal. The fact that people live in the drainage
10 basin changes Lake Michigan to some extent and we, I feel,
from the standpoint of ecological point of view, have to
12 give up this idea that we can live anywhere and not have
an impact on the environment*
14 And the question, as you phrased it, or the point
that you raised is that we want to have the minimum impact*
I might also add the point which I wanted to make when I
17 began, when I stated I wanted to present an objective
evaluation of the data* First of all, when you do that
19 you are unpopular because sometimes you are not strict
20 enough and sometimes you are too strict* I guess you can't
2i win.
22 But there are many places where this does become
23 a matter of subjective evaluation* There just are no
24 clearcut cases when we begin to deal with the amount of
25 damage, and in these cases we are really dealing with
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D. I. Mount
probabilities, not all or none, and I have tried to make
judgments that are middle-of-the-road* I am sure that I
have failed in some cases*
MRo STUN: Mr. Purdy.
MR, PERDY: First of all, Mr. Chairman, I would
like to thank Dr. Mount and his staff workers for the very
enlightening statement. It is something that we have come
..
to expect from Dr. Mount in many other ^conferences that he
has presented statements on. I wish we had had it many
months ago.
You mention the — you say — relative impact of
say an instantaneous heated load to say an organism as
compared to an extended period of time. From the stand-
itf^'ltl—
point of the table that was presented this morning with
maximum temperatures, I am wondering how these are to be
interpreted, or is this to be interpreted as an instantan-
eous maximum, daily average, or just how is it looked at?
DR. MOUNT: Well, Mr. Purdy, it would be my
judgment — I guess this is a decision which you people
in part have to make, and it is my job to help you. It
would be my judgment that in a lake the size of Lake Michi-
gan that the instantaneous values for any minute or hour
are not going to be drastically different than they are
for a period of several hours. We are not dealing with a
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D# I* Mount
small stream where the temperature can change drastically.
Now, this, of course, is accepting upwellings which none
of us are going to stop anyway* But it would seem to me
that there would be little difference*
Now, perhaps some of the people who have worked
more clearly with Lake Michigan can answer that better
than X can as to whether these values would be greatly dif-
ferent* I would tend to doubt that they are*
MR. PURDI: Well, as we have attempted to arrive
at some temperature restrictions on a monthly basis for
Lake Michigan, we have looked at a number of individual
measurements^ The fact is, I think it is about 50,000
measurements now. From the standpoint of the monthly
jr'-' „
temperatures that you have recommended, as it relates now to
the natural temperatures in the lake, I would say on the
open waters we are in pretty close agreement* But as we
move into the inshore waters, and in particular for those
waters along western Michigan where you have the prevailing
westerly winds that push the warm surface lake waters up
along the Michigan shoreline.makes it valuable from the
standpoint of recreational swimming. I believe that we do
have natural temperatures that may extend out into 20-foot
water depths or more that exceed by several degrees the
maximums that you have proposed, and in particular as you
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2 move into October, that these waters stay warmer than the
3 65° maximum that you have proposed there quite frequently.
4 DR. MOUNT: I certainly recognize the validity of
5 what you are saying. There are two points that I would make
6 in regard to this. First of all, I looked at the data that
7 I had, which I believe Mr. Fetterolf prepared, on the
g swimming beach temperatures . As I indicated in my
9 comments before, I was really amazed that there wasn't a
10 greater difference between these and the intake temperatures
11 from the water intakes on the Michigan shore. I believe
12 Indiana had provided swimming beach temperatures, and possibljr
13 Wisconsin, too. I am not sure. I looked at an awful pile
14 of data to sort these numbers out, so that I would suggest
15 that perhaps this — first of all, that this difference in
16 the shore water areas is not maybe as great as one would
17 think that it would be just on the surface of it.
lg Now, you may have other temperature data to show
19 differently, I don*t know. But I am sure there will be
20 cases where this is a problem.
2i My second point would be, as I said again in
22 the paper, I think we are obviously going to face a number
/
23 of situations where temperatures — maximum temperatures
24 occurring as the result of apparently natural effects do
25 exceed these recommended values/^ While I recognize, I
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1 D» I, Mount
2 think, the regulatory problems involved, I also must
recognize the biological principle involved. That is
that no matter what made the water warm, it may be that it
will be harmful if it gets too warm, and perhaps these are
situations which have to be dealt with on a judgment basis
when they occur*
Certainly if the whole eastern shore of Lake
Michigan is running warm, that is obviously not due to a
10 single discharge somewhere . This has to be taken into
11 consideration much in the same way that any other limit whicl
12 we place on water may be exceeded from causes beyond con-
13 trol and have to be ignored at that time.
I think this is an enforcement problem which I
am not capable of dealing with myself. That doesn't solve
15 it. But, on the other hand, I also know that if we estab-
17 lish standards which are so high, or maybe I should say so
low ~ maximum temperatures — that natural conditions
19 never exceed these, I don't think we will have much either.
20 MR. PURDY; I don't disagree with you, and I
21 appreciate your comments because at some point in time
22 when somebody measures it and then asks the enforcement
23 agency to take action to stop this, it is nice to be able
24 to turn back to the record and show that it was recognized
25 that at certain times natural conditions will exceed the
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D. I. Mount
recommendations*
DR. MOUNT: I had hoped to have a draft to try to
explain the way we view these maximum temperatures, and I
failed to have time to make it*
But if you can envision a month with daily
temperatures fluctuating, as my fingers do (indicating),
I think these maximums simply, put a lid on this,. We ,
as I pointed out in the paper, expect that the temperatures
must and will go well below these much of the time— that
we are not talking about a sustained temperature.
MR. PURDT: The other question that I have relates
now to this matter of the maximum distance of 1,000 feet.
Did you participate in the development of this
rationale, and, if so, could you explain it?
DR. MOUNT: I was involved in discussions regard-
ing the distance that it should be recommended and whether
or not how important my opinion was in deciding on 1,000
feet, I am not sure.
But there is this kind of thinking that first
of all a mixing zone I feel by definition is a place
where receiving water standards are not met. That is, the
conditions are less than we are striving to achieve in the
receiving water.
If our receiving water standards — and I think
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D. I. Mount
2 that these proposals are — are set at about the margin
o where we will experience significant damage if we exceed
. them substantially ~ then there will be some damage
c occurring in the mixing zone. So the question you
ultimately come to is how much sin is acceptable? And
the value of 1,000 feet, as I recall in our discussions, was
arrived at because with the proposed expansion in the number
of plants that this would still keep the area in the mixing
zone at or below 1 percent of the shore area*
MR. PURDY: Now, you say the surface 3 feet —
would the point of measurement be any point within the
surface 3 feet or at a 3-foot depth?
DR0 MOUNTs I can only respond to that from the
standpoint of the biological need, and that would be that
there would not be a significant difference whether you
measured it 1 inch below or 36 inches below* So it would
seem to me that anyplace would be reasonable from the
biological point of view.
20 MR0 PURDY: Because at some point in time, this
plume may float* It may only be a foot in depth* And if
22 you measured it 3 foot in depth, you could miss it* So
23 anyplace within the top 3 feet*
24 DR. MOUNT: Yes, sir.
25 MR, PURDY: Now, in the wintertime there is this
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1 D. I* Mount
2 discussion about the plume may sink, so that on the surface
3 3 feet, you might meet the 1,000 foot requirement, but now
4 how about the effect on the hatching of the eggs on the
5 bottom, and so forth? Does this require special consider-
6 ation?
7 DR. MOUNT: Well, it was my recommendation
# originally ~ I don't remember whether it is in there now
9 or not — that it be specified that the plume meeting that
10 temperature which does not exceed the maximum, or that
11 temperature which is not more than 3° above ambient, which-
12 ever is less that that temperature — anything over that
13 not touch the bottom,
14 MR. PURDY: Okay*
15 MR,, STEIN: Are there any other further questions
16 or comments?
17 MR. MAYO: Dr. Mount, in your presentation on
1$ page 12, you speak to keeping the discharge from the nursery
19 areas and off the bottom as being obvious requirements.
20 In the recommendations of the Technical Committee,
21 there is also a direction to this point in terms of designing
22 the discharge structure to prevent the thermal plume from
23 reaching the lake bottom*
24 At the moment, that kind of a specific provision
25 is not included in the proposed regulations that were laid
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D» I* Mount
on the table this morning for the conferees to consider*
I would gather that it would be your recommendation
that there be a provision in these proposed regulations that
5 the design of discharge structures be such as to prevent the
5 thermal plume from reaching the lake bottom,,
7 DRo MOUNT: Yes, I think this would be desirable*
ME* STEIN: Are there any other comments or ques-
9 tions?
10 1 would just like to ask a general question, Dr«
11 Mount, which may serve to bring out the point in the colloquy
12 you had with Mr* Purdy*
I assume there were times long before Columbus
came to America when conditions were such that there were
15 waters in this area of the country where the heat got so
16 high that fish died because of the heat. Is that a fair
17 assumption?
DR* MOUNT: I am sure that that is true.
19 MR. STEIN: Right,
20 Now, if that is the case — and I think this is
2i going to continue, whatever we do — I really don't think
22 that is what we are addressing ourselves to. If you
23 have natural conditions that are going to create an unusual
24 situation
25 ••• Cries of "Can't hear you" •••
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D. I. Mount
MR. STEIN: If we have natural conditions which
are going to create an unusual situation, this is not what
we are dealing with here. What we are dealing with is
manmade pollution. As I tried to develop with Dr. Mount,
I believe that given these Great Lakes long before
Columbus came, there were certain periods of the year or
areas of the lake where you might have unusual heat
conditions where you were going to get fish kills.
I don't think that any program we can devise will
stop this. Let us suppose we have a relatively remote
area of say Wisconsin or Michigan along the lake where
there is no development and these conditions would occur
again, presumably we would get the same effect.
As we do in many, many of our areas, I think we
are dealing here with manmade impacts. We are not going
._ to — and I don't think you can — hold any industry or
any municipality or any individual responsible for what
happens in nature. We recognize the fact we have these
variances in nature itself.
DR. MOUNT: Yes. I think you have worded it as
22 a lawyer would word it. I would word it according to a
biological principle which would be that naturally occurring
24
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D» S» Bryson
temperature maximums and minimums already limit the dis-
tribution of fish, and if we establish standards which
permit those extremes to be reached or exceeded, then we
are going to have an adverse effect.
MR. STEIN: Are there any other comments or
questions? If not, thank you very much, Dr. Mount.
Mr. Mayo, do you have — or Mr. Bryson — those
reports we promised?
MR. MAYO: Yes. Just a moment, Mr. Chairman.
MR. BRYSON: Mr* Chairman, we have passed out to
the conferees a tabulation of the plants that are either
under construction, operating, or proposed in the — excuse
me — or are in the pre'jjonstruction stages.
On this chart we have shown the name of the plant,
the size, and the type, operating date, the quantity of waste
heat that will be discharged, the present discharge design,
and the required modification.
Now, in summary —
MR. STEIN: May I make a suggestion?
MR. BRYSON: Yes, sir.
MR. STEIN: You know we have a lot of powerplant
operators out here and a lot of people out here and, as I
pointed out, at some of the meetings in Washington, this is
like a grant program. You come up with these generalized
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Do So Bryson
principles, but everyone in the room is interested in what
this is going to do to his plant*
Now, would it be possible to run down this list
just with the first name and indicate what the required
modification of your proposal you believe would require?
Would this be reasonable?
MR. BRYSON: Certainly,
MR. STEIN: Okaye Because I think that is what
the people are waiting to hear. Okay0
MR. BRYSON: Okay. For plants under construction
right now, we have the Zion Plant, Commonwealth Edison that
will require cooling towers. (Applause)
The Cook Bridgman —
MR. STEIN: Please, let's try to do this with —
withhold your applause until the end (Laughter) and Mr.
Bryson will gratefully acknowledge it.
Cooling towers for the Cook plant; Palisades,
cooling towers; Point Beach — and there we have the two
units* The unit that is operating would probably have to
improve the discharge structure or go to cooling towers*
Unit No0 2, which is under construction, would have to go
to cooling towers. Kewaunee plant would have to go to
cooling towersf Michigan City, the new unit, could go to
cooling towers; the old unit would be an improved discharge
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139d
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__ 140
1 D, S, Bryson
2 or cooling towers,
3 For plants that are currently operating, Waukegan
4 would be an improved discharge structure. Winnetka power-
5 plant would be — we do not anticipate that they would have
6 to change their operation at this point. The Bailly plant —
7 excuse me — missed one, Michigan City would have an improv-
g ed discharge structure; the Bailly plant, improved discharge
9 structure; the State Line in Hammond plant, improved
10 discharge structure; the Mitchell plant, improved discharge
11 structure,
12 The Michigan plants, then: Big Rock — it would
13 not appear that they would require modification; Traverse
14 powerplant, no anticipated changes; Cobb-»-Consumer, no
15 anticipated changes; the Campbell plant would probably have
16 to improve their discharge structure; the Deyoung plant would
17 probably not have to change their method; Escanaba Power,
18 no anticipated changes; Oak Creek — it would probably have
19 to improve their discharge structure or go to cooling
20 towers.
21 Now, we move to Wisconsin, excuse me — the Oak
22 Creek in Wisconsin, improved discharge structure or cooling
23 towers; Lakeside plant, improved discharge structure; Port
24 Washington, improved discharge structure; Edgewater, improved
25 discharge structure; Manitowoc Power, no anticipated change;
-------
141
1 D. S. Bryson
2 Pulliam, improved discharge structure; Valley Plant, no
3 anticipated changes; the unnamed plant at Duns Acres would
4 probably be able to meet the requirements with no cooling
5 towers although they are — excuse me, wait a minute, I
6 misread that — the present design calls for cooling towers
7 at that plant. Excuse me, I misread it. The. .addition to
8 the Edgewater plant would require a closed cycle system;
9 the city of Gary plant would require a, closed system, and
10 any additions to other plants would require the closed
11 systems.
12 MR. STEIN: Thank you.
13 Are there any comments or questions?
14 Mr. Purdy.
15 MR. PURDY: Is there any significance in your
16 change from closed cycle system to a cooling tower
17 recommendation?
lg MR. BRISON: When I mentioned cooling towers,
19 we were talking in lieu of the once-through cooling, so
20 we are talking the closed system; we are not talking the
21 once-through.
22 MR. PURDY: Yes, because you could have a once-
23 through cooling tower.
24 MR. BRYSONj Right. No, we are talking closed
25 cycle*
-------
142
1 D. S. Bryson
2 MR. STEIN: When you say closed cooling tower,
you mean closed cycle?
/,, MR. BRYSON: I meant closed cycle*
5 MR0 STEIN: Are we all clear on that?
6 MR. BRYSON: It is the terminology of the table -
7 MR. PURDY: To the extent that closed cycle
recognizes some blowdown«
9 MR. STEIN: Yes* Let me amend that to mean
10 essentially closed cycle. But the only thing I want to do
is get understanding among the conferees.
12 Are there any other comments or questions?
13 MR. CURRIE: Yes, Mr. Bryson, what would be the
effect of the EPA proposal on pump storage facilities?
15 MR0 BRYSON: I am going to have to rely or get
16 Mr. Howard Zar up here to explain the details of — well,
17 let's ask Mr. Purdy to explain the details of the pump
storage that they are talking about in Michigan, and let us
19 respond to that so that everybody is aware of what we are
20 talking about*
21 Let's have Mr« Purdy explain the concept of the
22 system*
23 MR. PURDY: Pump storage is where, during off-
24 peak demand load hours, you use generating capacity to
25 operate large pumps that will pump lake water up into a
-------
1
2
3
L
5
6
7
9
10
11
12
13
15
16
17
20
21
22
23
24
25
143
F. T. Mayo
reservoir at some elevation above the lake, and then at a
later point in time, when you have peak loads you release
that water from the reservoir and it operates these reverse
cycle pumps as turbines and produced power. So from the
standpoint of say heat, you do not add heat to the water
to generate power, but that you do pick up some warming from
the sun in that storage reservoir — or you may.
MR0 BRYSON: How many degrees are you talking
about? Do you have any idea?
MRO PURDY: About 2° of increase in temperature
which at the release rate from the reservoir could mean
about 25 billion, I guess, B.t.u. per hour.
MR. MAYO: What kind of periods of time would this
be applicable, Mr. Purdy?
MR. PURDY: Maybe 2 to 3 hours.
MR0 MAYO: Out of the day?
MR. PURDY: Out of the day.
MR0 MAYO: Power being used for peaking purposes?
MR. PURDY: That is all it is used for is peaking
purpose. That is all that you have storage capacity for.
MR. STEIN: I don't believe we have answered
Mr. Curriefs question. Are you in a position to do that
now, Mr. Bryson?
MR. MAYO: I can answer that, Mr. Chairman.
-------
144
1 F, T, Mayo
2 For the purposes of this material, and for the
3 purposes of the proposed regulation, and in consideration
4 of the nature of the discharge at the storage plant at
5 Ludington, it would seem to me that the requirement for
6 the meeting of the A, 1, regulation would still be there
7 for that discharge,
g Considering the nature of the operation, the rates
9 of discharge determined, as I understand it, 20,000 to 30,000
10 feet per second, the approximate 2° rise in temperature, it
11 appears to us that the constraint that could reasonably be
12 placed against that discharge would be the requirement that
13 tbe A, 1, provision in the proposed standard be met,
14 MR, STEIN: Let me try to put this in possibly
15 simplistic legal terms. If we have the A, 1, requirement,
16 which is a maximum temperature each month, and a require-
17 ment of a rise of not more than 3°» and you give thena
lg a feet mixing zone, this probably could
19 be met in the pump storage operation by appro-
20 priate intake and discharge structures rather than cooling
21 towers. Is that —
22 MR, MAYO: Or closed cycle system,
23 MR, STEIN: Or closed cycle system. That's right,
24 Thank you,
25 Does that answer —
-------
145
1
2
3
4
5
6
7
9
the zone is illegal anyway.
11
10
MRo CURRIE: It is normally said to be 3° at the
12
13
15
16
17
19
20
2i
22
23
24
25
F. T« Mayo
MR. CURRIE: Is that to say that you believe that
in the springtime when, according to Dr. Mount's figures,
any rise outside the mixing zone is illegal that no cooling
devices would be required on the storage plant?
Can you meet with the storage plant without cooling
towers the zero rise at the edge of the zone?
MR, STEIN: Let's clarify the question.
As I understand it, Mr. Currie, any rise outside
edge of the zone, but not if the temperature exceeds the
monthly maximum.
MR. STEIN: Whichever is less.
MR. CURRIE: And I am worried about the monthly
maximum, which according to Dr. Mount in the springtime is
often exceeded by natural temperatures, so that any
addition at the edge of the zone during springtime is
likely to be illegal.
MR. STEIN: Do you want to answer that?
MR« MAYO: That constraint would apply equally
with other discharges.
MR. PURDY: I might point out the volumes of water
that we might be wrestling with. This discharge during
generating periods will be in the range of 60,000 cubic
-------
146
I F» T. Mayo
2 feet per second. So if we are looking at cooling towers
3 on that volume —
4 MR. MAYO: No, Mr. Purely* I think to the extent
5 that a constraint would apply at a particular point in
5 time, it may be in the nature of a refraining from the
7 generation power for short periods of time. I think that
$ would be the logical constraint.
9 MR. CURRIE: Well, if the pump storage facility
10 is subject to A. 1., is it not also subject to B., and
11 therefore closed cycle cooling required?
12 MRo MAYO: We have not considered it to be
13 applicable to B. because of the very nature of the opera-
14 tion and the kinds of volumes of water, and the possible
15 distinction between waste heat, as we had considered it
16 in the fossil fuel and nuclear plant discharges.
U MR. STEIN: Let me call your attention — I
lg don't want to be excessively technical — but B. applies
19 to all new waste heat discharges exceeding a daily average
20 of 1/2 billion B.teu./hour. Does this meet that require-
2i ment?
22 MR. MAYO: I would have to ask Mr. Zar. Just a
23 moment.
24 MR. BRYSON: We couldn't hear the question.
25 MR. STEIN: Read B. It says, "Applicable to all
-------
147
1 C. Fetterolf
2 new waste heat discharges exceeding a daily average of
3 1/2 billion B*t.u,/hour*M
4 Does that pump storage meet that or exceed it?
5 It seems to me this is your essential pointo
6 MR, BRISON: Go aheado Carlos Fetterolf, a
7 member of the Technical Committee, discussed this at length
8 in the Technical Committee, Let him respond*
9 MR, FETTEROLF: When the Technical Committee con-
10 sidered the discharge of heat from a pump storage facility,
11 we did not consider this as waste heat. We considered it
12 as naturally added waste heat*
13 If the Ludington pump storage facility operates
14 for a period of 3 hours, and during those 3 hours adds
15 25 billion B.t,u./hour, it comes out to about 75 billion
16 Bot,u, for 3 hours; and if you divide 24 into those 75>
17 you come up with 3 billion B.t*u*/hour as a daily average*
lg MR, STEIN: You figured that the word "waste"
19 does not apply to a pump storage, that is how they are out — •
20 "**« all new waste heat *.*" — and this isn't waste heat?
21 MR* FETTEROLF: The Technical Committee considered
22 that our charge dealt with fossil fuel and nuclear
23 facilities, and industrial power generation, cooling
24 waters, and we did not consider that pump storage fell
25 into this category. After we studied it and received
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a good deal of information from Consumers Power Company,
we decided not to consider it in our recommendations.
MR. STEIN: Okay. I think I understand you.
Are there any further questions?
MR. CURRIE: Yes, I think I understand that. But
then my question is: If B. does not apply because this is
not waste heat, why does A. 1. apply which also refers only
to waste heat?
MR. MAYO: Well, I think, Mr. Currie, that with
respect to A. 1., in our efforts to provide environmental
protection in the receiving water to the extent that
discharge from this plant would exceed the maximum and the
related constraints, it would not be unreasonable to re-
frain from operating the facilities for those limited perio
of time.
MR. CURRIE: In other words, the heat from a pump
storage plant is just like the heat from any other plants
in terms of the effect to the biota, is that correct? Heat
is, after all, heat?
MR. MAYO: Heat, in terms of its impact on the
biota and our opportunities to control it, I think could
reasonably be subjected to the same kinds of monthly
0, maximum constraints.
24
MR. CURRIE: But, then, the question arises:
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why not subject it also to the closed circuit cooling
requirements of B.?
MR. MAYO: I would offer the observation that the
Technical Committee responded in terms of its evaluation
it was not considered in the category of waste heat but
it can indeed be considered in terms of the category of beii(ig
controllable, and that this would represent a reasonable
set of constraints for that kind of a facility.
MR. CURRIE: Well, are we going to define the
problem in terms of whether it is called "waste" or not,
or are we going to talk about whether it is reasonable to
control this heat?
Is the reason why closed cycle cooling is not to
be required on a pump storage plant, money?
MR. MAYO: No.
MR. STEIN: Well, let me try this. I think I
can remember, and I hope you can, my colloquy with Dr.
Mount.
If we are talking in terms of manmade heat, cer-
tainly the pump storage is manmade heat, and this is what
we are talking about controlling. This doesn't happen
naturally.
Now, it doesn't make any difference where this
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F. T. Mayo
heat comes from, whether it is manmade, as far as I under-
stand it — and, Dr. Mount, you correct me if I am wrong
— whether it is manmade, whether it comes from the sun,
whether it comes from a blockage, whether it comes from
anywhere. As far as the effect on the biota, heat is heat.
But if we don't control manmade heat and
we have a pump storage operation and we want to set this
up as a separate category, maybe we should face that as a
separate category. Maybe it is because the controls are
different. If the key point, for example, is that you are
going to have a critical period in the spring and in the
spring you are not going to need this peaking power
,, or we can cut off the power, maybe we will have to deal
,- with it in a different way.
But I think the distinction is in saying when you
,„ put stuff into a reservoir, let it heat up and then you
run it out, its not waste heat. But when you run it throug
a condenser and heat it up, it is waste heat. I don't
know. If you want to accept that kind of distinction,
, that is all right. I find it a little difficult to take.
MR. CURRIE: So do I, and I was trying to explore
the reason for distinguishing the pump storage from
, other plants.
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MR. STEIN: Well, I think Mr. Mayo gave what I
consider a practical reason if it pans out and if you
agree with it.
What you are saying is that putting a large amount
of water out, if you measure the heat in B.t.u.'s, the point
is that just raising the temperature of this water maybe
2° — they are not raising it 1#, 20, or 2# — and dis-
charging it over a 3-hour period, it may be possible (if
we are dealing with what Dr. Mount is talking about) in
preventing a damage to the biota, perhaps during this
critical period in not using the peaking power and
being able to get by with it for the rest of the year with
the adroit location of discharge structures.
Now, as I understand it, perhaps we can make
a distinction this way. In other words, I would suspect
,« that we would not want to prevent the development of this
facility if we could do it without hurting the biota or
hurting the lake.
Maybe we need a different category. I don't know
that this proposed requirement gets it because of the
general term "waste heat". We may need something else
to get it.
MR. CURRIE: I take it that Mr. Mayo's answer a
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1 F* T* Mayo
2 a moment ago was not intended, when he said that money was
3 not the reason for this exemption, was not intended to say
4 that the cost of control is irrelevant, was it?
5 MR0 MAYO: I want to make it clear that in reach-
6 ing that distinction it wasn't based on any consideration
7 of the magnitude of cost* It would be related to providing
g what you might term the corrective measures. It
9 was made in the context of the character of the discharge,
10 the short period of time of the discharge, and the control-
11 lability of the discharge, as being mitigating factors
12 without consideration of the magnitude of cost for pro-
13 viding once-through closed cycle cooling*
14 MR* PERDY: Mr, Chairman, I think if this has to
15 be controlled that Mr* Mayo offered the only practicum,
16 and that is that you don't use it during that period of time
17 because I really don't know of a cooling tower that could
1$ even approach cooling water down within 2° of the ambient
19 temperature*
20 You nave got some differential there* I would
2i imagine that most cooling towers, the blowdown is going to
22 °e 10-plus degrees warmer than lake water when it is dis-
23 charged, and here I know of no practical way by a cooling
24 tower to get that last 2° F» out.
25 MR. GURRIE: Let me move to a slightly different
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2 question which I do think is somewhat related. I take it
3 that the cost of bringing a plant into compliance with the
4 regulation is not irrelevant. Is that right?
5 MR. STEIN: Who are you addressing that to, Mr, Mayjo?
6 MR, CURRIE: Anyone who is presenting the Federal
7 position here,
# MR. STEIN: Mr, Mayo.
9 MR. MAYO: The cost of bringing a plant into com-
10 plianee is not irrelevant, is that —•
11 MR. CURRIE: — in determining what regulation
12 should be adopted,
13 MR. MAYO.: There isn't complete irrelevance, but
14 I would like to take you back to earlier decisions on the
15 part of this Conference — decisions on the part of the
16 States in general — in the area of water quality standards,
17 The standards were adopted and they represented
lg the best judgment of what was required to protect the public
19 health and welfare in the way of the character of the
20 receiving waters that needed to be maintained. The
2i decisions were made, then, that there were subsequent
22 remedial actions that had to be taken on the part of the
23 individual dischargers, whether we were talking about
24 dissolved oxygen parameters or biochemical oxygen demand
25 or any of the other chemical parameters.
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F, T. Mayo
The constraint then was placed against the dis-
charger to meet an implementation schedule, and generally
.. /•!*,- •• •
the question was not asked ' what is going to be the cost
/1
to the individual discharger? The proposition was offered
that these are the standards; this is the implementation
schedule* And then the individual discharger assumes the
responsibility of meeting that requirement, and he then
assumes the cost of meeting that requirement.
So, in that context, the question of finances,
while not totally irrelevant, was set aside as being the
burden that the discharger had to pay, and the regulatory
agency, the State, placed that burden on the discharger*
MR. CURRIE: I think, I have —
MR. MAYO: And we have indeed found a variety
of circumstances I think where the determination was made
on the part of the discharger that it might be economically
impractical for him to remain in operation and pay the
costs for meeting the constraints, As a consequence,
C si
2Q he discontinued operation or the proposal
2i was foregone.
22 MR. CURRIE: Well, I think I would have some
23 quarrel with that philosophy, both as a question of what
2/j, the law requires and as a question of policy.
25 And, in addition, I think there might be a
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decision drawn between what one does in enforcing existing
regulations after the decision of cost has already been
made and in setting the standards in the first place, which
is what we are asked to do today.
In any event, I take it you are saying that cost
is not irrelevant. I wonder in light of that and your
impact statement as to the impact of the EPA proposal, what
costs are you contemplating for the backfitting of cooling
towers, for example, on the Zion plant?
MR, BRYSON: In checking with our people very
quickly at noon, we do not have detailed cost figures on
each facility, Mr. Currie.
In some of the plants, the cost is going to be
very small. It is a matter of possibly putting in a new
pump or something to increase the flow of water, as a jet
"type thing. On the other plants it is going to require
some additional costs. We do not have the details on each
individual facility.
MR. STEIN: Can you answer the question on the
Zion plant?
MR. BRYSON: On the Zion we do not have detailed
costs right here.
MR. STEIN: All right.
FROM THE FLOOR: Mr. Stein
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1 F. T. Mayo
2 MR. STEIN: No, we are not taking any questions —
3 FROM THE FLOOR: May we ask — there are a number
of public representatives here today, voluntary groups, who
have sat here through the morning. Now, we encourage this
kind of discussion, and so on, but don't you think consid-
eration for nonpaid people who have taken time off from
work, and so on, could be given to allow them to respond
to Ruckelshaus' proposal before detailed discussion of the
proposal is taking place here by the conferees?
MR. STEIN: Let me tell you, we don't take
comments from the floor. I certainly agree with you. I
** thought by keeping quiet myself I could speed things up,
but I see I can't. I see the working press here and the TV
, e You know they have the best job in the world. It may be
-x terrible, but you can't beat the hours. I think you have
._ made a good point. In order to let them go, let's recess
for 5 or 10 minutes, and see if the conferees can think thi
-o over, and determine if they have had enough discussion,
then maybe we can call upon the States and public
witnesses.
We stand in recess.
(Short recess.)
., MR. STEIN: All right. Let's reconvene.
24
I have a couple of public announcements.
25
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B. A. Tichenor
••• Announcements ...
MR, STEIN: We have one question of Mr. Currie on
the cost of the Zion plant. Would you try to answer that?
MR. MAYO: Yes. I believe Dr. Tichenor has
available data that he can direct to that response.
STATEMENT OF BRUCE A. TICHENOR, Ph.D.,
CHIEF, HYDROGRAPHIC BRANCH; AND CHIEF,
CONTROLS BRANCH, NATIONAL THERMAL
POLLUTION RESEARCH PROGRAM, CORVALLIS, OREGON
DR. TICHENOR: For the record, I am Bruce
Tichenor.
I believe the question related to the cost of
backfitting the Zion nuclear powerplant. I think the most
comprehensive data which are available on this were pre-
sented to the Illinois Pollution Control Board during their
hearing of November 5, 1970. This statement was presented
by Mr. 0. D. Butler, Vice-president of Engineering for
Commonwealth Edison.
Mr. Butler was kind enough to provide us with
a copy of this statement plus additional backup informa-
tion, and I think the best thing I could do here in terms
of relating the cost of backfitting would be to make some
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2 comments upon these costs. Now, these costs as presented
3 by Mr. Butler are a matter of record* I should also
4 mention that this information that I am going to present
5 here was prepared in the form of a memorandum to the Great
6 Lakes Regional Office from our Corvallis laboratory.
7 I also believe that each one of the members of
g the Enforcement Conference have received a copy. Is this
9 true?
10 MR. STEIN: Dr. Tichenor, I want you to explain
11 this fully, but I would like to say before we go on with
12 this I thoroughly agree with the man who got up in the
13 audience* You know, the people up here as well as you,
14 I hope, are getting a salary and probably per diem for
15 every day we are here. The people from the industry are
16 probably getting paid, too. We have a lot of people in
17 the audience who have come here at their own time and
lg expense, and I hope we can make this as short as possible
19 to get on with the public presentations. (Applause)
"
20 DR. TICHENOR: If it would be agreeable to Mr.
21 Currie, then, I would just place this statement in the
22 record without reading it.
23 MR, STEIN: Can you summarize it very briefly?
24 DR. TICHENOR: Well, I can summarize it. How
25 briefly, I don't know.
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But essentially what we did —
MR. STEIN: Go ahead.
DR. TICHENOR: — we looked at the data provided
by Commonwealth Edison, and we tried to make some judgment
as to not necessarily its accuracy — I don't want to demean
their engineering abilities — but we looked at the data
to find out if there were better systems that might be
built for that plant.
We also looked into the data available on back-
fitting at their powerplant.
I just have two referenceso One of them was
presented at the Joint Committee on Atomic Energy (Hearings
on Environmental Effects of Producing Electric Power.) It
is in Part 2, Volume 1 of those hearings. And the Edison
Electric Institute data presented there, and I quote here.
It says that: "«.« retrofitting on an existing
plant ..." is $10 to $12 per kilowatt.
Data presented by Mr. D. H. Williams at the
September 1970 workshop session for the Donald C. Cook
nuclear powerplant come out to be a total cost of $20 millioi
which is $9o5 per kilowatt for the cooling facilities them-
selves plus an additional $12 million for the pumping and
transport system. That is $6.7 per kilowatt.
So the total dollars per kilowatt there is on the
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-, B, A. Tichenor
2 order of $9»5 and $6,7 is $16.2 per kilowatt.
o Now, the data presented by Commonwealth Edison
• was in two parts, one for a dry system, one for a wet system,
c I have to look those numbers up. The dry system came out
to $22# per kilowatt; the wet system came out to $53 per
kilowatt. So we have to just put these things in per-
spective,
n First of all, I would like to make a comment about
10 the dry system, I really think that while the numbers are
very interesting, I think the use of a dry system in back-
12 fitting such a plant as Zion with the type of tube condensers
they are now using is really not a practical solution to the
problem,
15 In fact, again, Mr, Williams, during the 1970
Conference or workshop session of this Conference indicated
17 and I quote — well, he said thatt:backfittingy and I quote
—"is totally out of question^1 So I would have to agree.
Now, in terms of the wet system, the data
20 presented by Commonwealth Edison is for a unique sort of
cooling tower. It is really a hybrid wet mechanical natural
22 draft tower. The reasons they went to this are spelled
23 out in their statement, and they wanted to get up high
24 enough so that the fog would not be a problem, but they
25 couldn't get up too high because of other height restrictions
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Bo A, Tichenor
so they settled on a tower which was — I believe — 250
feet tall and was a very unique design*
So, from our point of view, it was very difficult
to determine what the actual costs of this device might
be, although costs given here may be appro priate*
Another point which may be open to question is
the assignment of capability losses and assigning a value
of the $207 per kilowatt, where we feel that maybe the use
of a lower cost gas turbine peaking unit at $100 per
kilowatt might be appropriate,
I think the best thing I could do is just kind of
give a summary of our conclusions* I will just read this:
"In conclusion, we believe that Commonwealth
Edison's cost estimates for backfitting the Zion plant
with a closed cycle cooling system reflect excessively
strict design assumptions and are thus too high. While
the total plant cannot be optimized, certainly alternative
backfitted systems and operating techniques could be
evaluated to minimize the economic impact of installing
such systems. In this respect, the following evaluations
should be made for conventional wet towers:
Ml, A more rigorous evaluation of the fogging
potential of conventional wet mechanical draft towers,
"2, Feasibility studies and cost estimates for
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1 B, A, Tichenor
2 wet mechanical draft tower fog control during critical
3 meteorological conditions,"
4 Now, the reason we recommend this is that if they
5 could go to conventional wet mechanical draft towers, the
6 cost of these devices would be reduced significantly*
7 The fourth one is: "An evaluation of the economic
g benefits derived from increasing the capability of the
9 plant*
10 "5, An evaluation of the use of low cost gas
11 peaking units to be used during periods of capability losso"
12 And, finally, that the last data presented by
13 Commonwealth Edison reflected the increase in cost to the
14 consumer. Without going through all of the details we
15 found that it seemed to us, at any rate, that Commonwealth
16 Edison was putting an undue burden on the residential
17 consumer and the way we figured it, even using Commonwealth
18 Edison's capital cost data, our figures came out about half
19 the monthly cost to the consumer that theirs had.
20 So I would say here that Commonwealth Edison
21 should provide data which more realistically reflect the
22 increasing cost which their residential consumers will
23 bear. In this respect, an evaluation of the portion of
24 of industrial load which will be passed to consumers
25 outside the Commonwealth Edison service district would be
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1 B» A. Tichenor
2 most valuable*
3 I would like this total thing read into the
4 record,
5 MR, STEIN: We will put that into the record,
6 (The document above referred to follows in its
7 entirety*)
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OPTIONAL FORM NO 10
MAY IK2 EDITION
viSA GEN. REG. NO. 27
164
UNITED STATES GOVERNMENT
Memorandum
TO : Director, Office of Enforcement and Cooperative
Programs, Great Lakes Region, EPA, WQO
THRU : Chief, National Thermal Pollution Research Program
FROM : Chief, Hydrographic Branch and Chief, Controls Branch,
National Thermal Pollution Research Program
SUBJECT: Costs of Backfitting at Zion Nuclear Power Plant
DATE: January 15, 1971
'
As requested by your memorandum of November 25, 1970, we have evaluated
the comments and data which Mr. 0. D. Butler of Commonwealth Edison
presented to the November 5, 1970 meeting of the Illinois Pollution .
Control Board. In addition, Mr. Butler sent us a portion of the "back-
up" material used in deriving their cost estimates. These data are
enclosed for your files.
While admitting the fallacy of comparing cooling system cost data for
optimized plant designs with cost data for back-fitted plants, Mr. Butler
himself does just that. He compares the data contained in our report on
the "Feasibility of Alternative Means of Cooling for Thermal Power Plants
Near Lake Michigan" to the estimates he provides for backfitting the Zion
plant. In our view this is unjustified.
Limited data on backfitted cooling facilities are available. For example,
EEI presented data to the Joint Committee on Atomic Energy (Hearings on
Environmental Effects of Producing Electric Power, Part 2, Vol. 1, page
1823) which showed that the cost of providing "thermal effect control"
using wet towers by "retrofitting on an existing plant" is $10 to $12
per kilowatt. In this same reference EEI contends that retrofitting with
dry towers is "probably not possible." In his statement before the
September, 1970 Workshop Session of the Lake Michigan Enforcement
Conference, Mr. D. H. Williams, Assistant Vice President and Chief
Mechanical Engineer, American Electric Power Service 'Corporation,
provided estimates on backfitting the Donald C. Cook nuclear power plant.
He suggested that three natural draft towers, each 500 feet tall and 400
feet in diameter would be required for the 2 unit, 2100 MWe plant at a total
cost of 20 million dollars ($9.5/KW). An additional 12 million dollars
($5.7/KW) would be required for "the pumping and transport systems through
the cooling towers and back to the plant." In addition, Mr. Williams
estimated that summertime conditions would increase turbine back-pressures
from 2.9 inches of mercury to 4.3 inches of mercury"...causing a load
curtailment of approximately 40 MW per unit or some 80 MW for the total
plant." Mr. Williams felt that dry towers "...are totally out of the
.question" for the Cook plant.
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While it is difficult to compare the specific cost items provided by Mr.
Butler with these more general data, it does appear that the Commonwealth
Edison costs are excessive. For example, excluding special earth v/ork,
the total capital investment costs for Zion's wet system equals $28/KW
compared to the $12/KW EEI value and the $15/KW figure given by Mr.
Williams. In terms of capability loss, Commonwealth Edison's estimate
for Zion of 179 MW is more than twice as much as the 80 MW figure provided
for the D. C. Cook plant by Mr. Williams. Thus it seems evident that
Commonwealth Edison has imposed some extreme constraints to come up with
their estimates. It would be impossible to examine in detail all relevant
items appearing in their cost list, but several factors can be discussed:
(1) Dry Cooling Towers
A prime example of an unsound groundrule is the decision to backfit
an existing plant with a dry cooling system. Mr. Butler presents cost data
for a technically possible but economically unrealistic dry cooling system.
Dry cooling systems for large power plants will not use standard surface
condensers. Direct contact condensers in combination with turbines operable
at high back pressures are required. As Mr. Butler notes, such a configuration
would provide much lower cooling system costs than that shown in Exhibit C.
We would agree with Mr. Williams and assert that backfitting with dry cooling
towers is "...totally out of the question."
(2) The Hybrid Wet Mechanical-Natural Draft Cooling Tower
The constraints leading to the selection of a non-conventional,
hybrid wet cooling tower are examples of other unduly restrictive assumptions.
For example, conventional mechanical draft towers were not selected because
of possible fogging. While the potential for fog problems exists at the Zion
site, the selection of a unique and untried cooling device costing millions
of dollars more than conventional units is based on supposition rather than
hard facts. The analysis of fog potential presented in our feasibility
report indicates that meteorological conditions leading to a high probability
for fog occur less than 1 percent of the time near Zion. A more rigorous
analysis of the potential for fog from conventional mechanical draft
towers would be advisable, especially since the cost savings would be
substantial if conventional units were practical.
If it is found that fog problems are severe enough to cause
visual obstruction on highways or in populated areas, an evaluation of fog
control measures should be made. Since the potential for fog problems
exists only during a small portion of the year, the use of fog control devices
at the towers may be practical. Heating the air-water vapor tower effluent
can prevent the formation of an extensive visible plume. Also, variations
in cell loading and number of cells per tower should be evaluated.
The capital and intermittent operating costs of fog control measures may be
substantially less than the increased costs of the hybrid tower system.
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The use of a 250 feet limit on tower height is based upon the heights of
other obstructions around the Waukegan airport. There is at the present time
aii FAA regulation limiting the minimum altitude approach to that airport
at 600'. It may be possible that FAA would consider modifying this
regulation to allow for the presence of a natural draft tower in the vicinity
of the airport. Since the overall cost of conventional natural draft towers
would be millions of dollars less than the hybrid system, such an investiga-
tion would be prudent.
(3) Capability Losses
A major cost item in the data supplied by Mr. Butler is for
:apability losses due to lower'efficiency at high back-pressures and
iuxilary power required for pumps and fans. Mr. Butler assigns a value
of $37,142,000 to. this capability loss for the wet mechanical draft tower
system (179 MH x $207/KW). In assigning an equivalent capital invest-
ment figure of $37,142,000 to this capability loss, it is obvious that the
economic benefits of additional capacity during the non-critical weather
conditions were not evaluated. Using economic data provided by Common-
wealth Edison and assuming that an additional 150 MW would be available
for distribution 75 percent of the year at the stated 70 percent capacity
factor, we computed that at power value of 5 mills/KVIH the equivalent
capital "gain" over the 30 year plant life would be $23 million. Thus
the net cost penalty due to capability loss should be $14 million ($37
million minus $23 million). In the event that the extra capability of
the plant is not able to be sold then Commonwealth Edison should seriously
consider the use of lower cost gas turbine peaking units which would provide
the needed capability during the relatively short periods of time when
severe summertime weather cause excessive capability losses. At $100/KW
the use of these units would make the equivalent capital investment for
capability loss $17.9 million rather than $37.1 million. Thus, in either
case, it appears that the value assigned to capability loss is excessive.
(4) Top Charges
Top charges are assigned at a rate of 12-1/2 percent of the total
Capital investment costs. Naturally, if these capital costs could be re-
duced by selection of more conventional systems, the top charges would
also be reduced.
(5) Cost to the Consumer
In Exhibit E, data are presented which show the additional
monthly cost to the residential consumer is 68
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lised 39.9 percent and commercial consumers 23.3 percent; the remainder
going to losses. If we assume that the residential consumers of Commonwealth
/Edison also consume 100 percent of the goods and services provided by
the industries and commercial establishment in the service district, then
the method used by Mr. Butler to assign the cost increase is correct.
However, it seems highly unlikely that this is the case. Heavy industrial
goods produced in the Chicago area are sold throughout the U.S. and even
the world and any product cost increase due to increases in power cost would
be distributed to these wide ranging customers. Also the Chicago area
;upplies commercial services to large numbers of people which do not buy
"esidential power from Commonwealth Edison. In addition, one should
evaluate the cost increase on the basis of 1973 consumers rather than 1969
consumers since Zion will only then be fully "on-line."
Assuming that the residential consumers of Commonwealth Edison purchase 20
'percent of the output of industrial goods and 75 percent of the commercial
services of Commonwealth Edison's industrial and commercial customers one
can show that the residential consumer should pay only 24.5 percent + (0.2)
(39.9 percent) + (0.75) (23.3 percent) = 50 percent of the cost increase,
whatever that true cost may be. At any rate, the 68<£/month or 6.5 percent
cost increase to the residential consumer is unrealistically high.
In conclusion, we believe that Commonwealth Edison's cost estimates for back-
fitting the Zion plant with a closed cycle cooling system reflect excessively
strict design assumptions and are thus too high. While the total plant
cannot be optimized, certainly alternative backfitted systems and operating
techniques could be evaluated to minimize the economic impact of installing
such systems. In this respect, the following evaluations should be made
for conventional wet towers:
1. A more rigorous evaluation of the fogging potential of conventional
wet mechanical draft towers.
2. Feasibility studies and cost estimates for wet mechanical draft
tower fog control during critical meteorological conditions.
3. An evaluation of the cost of raising the minimum approach to
Waukegan airport to allow conventional wet natural draft towers.
4. An evaluation of the economic benefits derived from increasing
the capability of the plant.
5. An evaluation of the use of low cost gas peaking units to be
used during periods of capability loss.
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Finally, Commonwealth Edison should provide data which more realistically
reflect the increase in cost which their residential consumers will bear.
In this respect, an evaluation of the portion of industrial load which
will be passed to consumers outside the Commonwealth Edison service district
would be most valuable.
Bruce A. Tichenor
Mostafa A. Shirazi
Enclosures
cc: Bartsch
Stein
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^ B, A, Tichenor
2 DR. TICHENOR: Does that answer your question?
3 MR. CURRIE: What was Commonwealth Edison's
4 estimate of the total cost of wet backfitting at Zion?
5 DR. TICHENOR: I will have to look. It is on
6 the order of — I have their first one; they did make a
7 revision — I believe it was on the order of $116 million.
g MR. CURRIE: And your estimate?
9 DR. TICHENOR: We don't have an exact estimate.
10 MR<> STEIN: Didn't you say half?
11 DR. TICHENOR: No, the half has to do with the
12 increase in cost to the consumer«
13 MR0 STEIN: What is the increase inxcost that
14 Commonwealth Edison figured they would have to have for
15 the consumer?
16 DR. TICHENOR: Well, again, these values have
17 been revised by Commonwealth Edison. I don't have the
lg revised values with me. I believe their increase in cost
19 to the consumer for mechanical draft wet towers was 68
20 cents.
21 MR8 STEIN: Sixty-eight cents per average bill
22 a month?
23 DR0 TICHENOR: Per month, yes*
24 MR. STEIN: And you figured —
25 DR. TICHENOR: It would be about half of that.
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1 B. A, Tichenor
2 MR. STEIN: Thirty-four?
3 DR. TICHENOR: Something like that, yes,
4 MR0 STEIN: All right. Thank you. I think that
5 is the thing you want.
5 DR. TICHENOR: Let me answer Mr, Currie a little
7 more. It is really very difficult to determine the cost of
3 backfitting unless you go through a complete engineering
9 evaluation and we have not done that with the Zion plant.
10 MR. CURRIE: Are they likely to be off by as
11 much as the factor of 10?
12 DR. TICHENOR: I don't believe so, no.
13 MR0 CURRIE: So we are talking maybe $20, $30, $40
14 million in your figures for backfitting the Zion plant?
15 DR. TICHENOR: Yes, that probably would bracket
16
MR. CURRIE: Do we know, especially in the light
of Dr. Mount's statement, that what we are worried about
19 is the proliferation of a large number of plants, that it
20 ' is worth $20 to $40 million to backfit Zion?
2i DR. TICHENOR: Are you asking me that question?
22 MR0 GURRIE: I am asking those who advocate the
23 Federal position that question*
24 MRe MAYO: It is our position that — I think
25 it was very frankly stated in Mr. Ruckelshaus'
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B, A. Tichenor
recommendation that for the plants currently under con-
struction not yet in operation that there be a requirement
that these facilities use other than once-through cooling*
I think that was very pointedly stated in the Federal
position. It addresses itself to all of those plants under
construction and not yet in operation, including Zion.
MR, CURRIE: I was just wondering what ^quantifi-
cation of the benefits of cooling towers we had to balance
against the cost which would be inflicted?
MR, MAYO: The same kind of a quantification of
benefits we had when we established water quality standards
that were applicable against all of the municipalities, all
of the industries. It is just the same approach,
MRo CURRIE: Well, I have a different question
with regard to the impact statement as to Waukegan. It
is suggested that adoption of the proposed standard would
require only an improved discharge structure there, and I
wonder, Dr« Tichenor, is that based on — on what assumption
as to the location of the fixed point adjacent to the dis-
charge from which we measure the 1,000 feet is that based?
DRo TIGHENOR: I didn't make that evaluation.
Someone else would have to answer that question,
MR, STEIN: Why don't you do it right from here.
Save yourself some time*
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1 B, A, Tichenor
2 FROM THE FLOOR: Mr. Stein, it is getting very
3 late*
4 MR, STEIN: I am sorry, I told you I sympathize
5 vdth you — I am just the Chairman, The conferees represent
6 the State and the Federal Government, You can see for
7 yourself what they want to do, I have made the point that
8 they are in charge of this, I am not going to cut them
9 off,
10 FROM THE FLOOR: Well, we are telling you what
11 we would like to do,
'
12 MR, STEIN: I understand it, and so would I,
13 I would like to do what you would like to do, but I am
14 governed by the conferees,
15 FROM THE FLOOR: Can we have a guarantee from
16 the conferees that they will allow the public to speak ««-
17 all of us here — tonight before we go home, before every-
lg body goes home, that all of the public witnesses will be
19 allowed to speak?
20 MR, STEIN: No, you are not going to have a
21 guarantee. My responsibility is toward this reporter here
22 who has been working since 9:00 o*clock this morning.
23 Go ahead,
24 FROM THE FLOOR: Your responsibility is toward
25 the public, Mr, Stein,
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H, Zar
MR, STEIN: That is righto And I would suggest
that if you want us to proceed in an orderly manner — you
heard that I sympathize with your point of view— if you
keep doing what you are doing and interrupting, you are just
prolonging this*
Mr, Bryson*
MR0 BRYSON: While I am walking over here, can
you repeat the question?
MR. CURRIE: Yes, The statement as to the impact
of the EPA proposals on existing facilities says with
regard to Waukegan that all that would be required is
improved discharge structures and not a cooling tower »
I wonder what the assumption was on which that
conclusion was based with regard to the question of the
location of the fixed point adjacent to the discharge?
MR, ZAR: I think the assumption was that the
company would be allowed to place the circle of 1,000 foot
radius at its convenience at some fixed point,
MRo CURRIE: Is it also assumed, as I think Dr,
Mount said, that during some months — paragraph A, 10 —
will require a zero rise from ambient at the edge of the
zone in the springtime?
MR. ZAS: No.
I think the improved discharge structure
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H. Zar
requirement refers only to the 3° rise*
MR, CURRIE: Only to 3 degrees?
MR0 ZAR: That is correct*
MR, CURRIE: But there is the additional require-
ment that we not exceed the monthly maximum at the edge of
the zone,
MR. ZAR: That is correct,
n MRo CURRIE: So that this is not a full explana-
10 tion of the possible effect of this on Waukegan?
11 MR, ZAR: If on that occasion during the year
12 when the water temperature was near the temperatures of
the maximum monthly table, then it would not be a complete
evaluation, that is correct,
15 MR, CURRIE: And is it also true that if improved
discharge structures were built, but no cooling towers
put in, this wouldn't help us on the problem of the
organisms drawn through the condensers?
MR« ZAR: Of itself, that is correct.
20 MR. STEIN: Are there any other questions or
comments?
22 Do we have any more on the Federal presentation?
23 MR. PURDY: Mr. Stein, I would waive any questions
24 at the moment with the hope that the Federal witnesses would
25 stay available.
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2 MR, STEIN: They will stay available»
3 For the present time, that concludes the Federal
4 presentation* We will keep the people available to answer
5 questions later*
6 We will proceed with the States* On ray right, as
7 I indicated before, we will start with Michigan, and we
8 will give each State an opportunity to make one statement
9 and go on, or call on someone to make one statement and go
10 on to the next*
11 Mr, Purdy*
12 MR, PURDY: Is Mrs* Harry Janis, Chairman of the
13 Lake Michigan Inter-League Group, the League of Women
14 Voters, here?
15 Mrs. Janis*
16
17 STATEMENT OF MRS. HARRY JANIS, CHAIRMAN,
18 LAKE MICHIGAN INTER-LEAGUE GROUP,
19 LEAGUE OF WOMEN VOTERS, CHICAGO, ILLINOIS
20
21 MRS. JANIS: Thank you* It pays to come from
22 a far distance and be represented by the far right end of
23 the table.
24 I am Mrs* Harry Janis, Chairman of the Lake
25 Michigan Inter-League Group of the League of Women Voters*
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1 Mrs, H, Janis
2 League membership and participation in the Group is from
3 the Illinois, Indiana, Michigan and Wisconsin areas of the
4 Lake Michigan Basin.
5 Leagues in the Lake Michigan Basin are agreed that
6 the possible delerterious effects of thermal additions to
7 Lake Michigan far outweigh any possible beneficial effects.
g For this reason, we request that some form of cooling be
9 required for all powerplants now under construction or
10 planned for the future. The technique of such pre-cooling
11 can be determined by the engineering needs of the plant
i
12 location, but we are agreed that once-through cooling must
13 be prohibited.
14 We are further agreed that no radioactive wastes
15 should be discharged to the lake and that stack emissions
16 must be reduced to the minimum which is technically feasible.
17 The recent agreement between Consumers Power
18 Company, conservation groups, and the Atomic Energy
19 Commission regarding the operational permit for the
20 Palisades Plant, South Haven, Michigan, includes a
21 prohibition on thermal wastes and the elimination of all
22 radioactive effluent. This agreement we hope sets the
23 precedent for recommendations from this conference.
24 League members believe that the watershed, or air-
25 shed, approach to environmental problems is essential for
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1 Mrs. H. Janis
2 the protection of Lake Michigan. We encourage the continuing
3 operation of the Four-State Enforcement Conference or
4 another regional entity which would guarantee a public
5 forum. If the question of standards controlling thermal
6 discharges is at least temporarily solved,by the President of
7 the Palisade plant agreement, there are many other subjects
8 which demand a regional approach, and control, i.e. dumping.,
9 dredging, pesticides, land fills, mercury, industrial
10 pollution, to name just a few.
11 League members in the Lake Michigan Basin have
12 been studying the possible effects of powerplants on the
13 Basin. In recognizing the many alternatives in choosing
14 types of power sources, discussion was not limited to
15 nuclear powerplants which, of course, did bring up the
16 particular subject of thermal effluent.
17 Except in the instance of particular members,
IS League members do not claim expertise in technical areas.
19 They are, however, well-informed, intensively concerned, and
20 want answers with technical back-up and not projected
21 suppositions. We turn to experts, such as yourselves and
22 your staff, for this type of research and research analysis.
23 Provision should be made incidentally in these studies for
2Z«- public representation of all technical committees. The
25 League in Elm Grove, Wisconsin, sent in a statement which,
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1 Mrs. H. Janis
2 I believe, sets the background for our approach to
environmental problems. They wrote, "The course of this stud]
4 and discussion brought this League to strong agreement on
5 some broad principles. We feel that all action in the area
5 of environmental quality should be directed toward pre-
7 serving or bettering our environment and that policy should
g be designed to prevent deleterious effects on the environment
9 which can reasonably be predicted on a scientific basis.1*
10 Specifically, League members want effective high
11 standards for Lake Michigan. Because of the interstate
12 character of the lake, the prime responsibility for the
13 determination of these standards should be at a Federal
14 level with participation by the responsible regional and •
15 state governments. We think that Federal standards should
16 be sufficiently high to protect the lake. Federal standards
17 would preempt state standards which are not equally as high,
18 or higher. The States and/or regional agency with the
19 resources to do the job should be responsible for enforce-
20 ment with supervision and intervention by the Federal
21 Government to ensure prompt and strict compliance.
22 * The public must have the opportunity to participate
23 at each step in setting standards. There should be well-
24 publicized hearingsbefore land is purchased (with options
25 to purchase land beforehand to protect inflationary land
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1 Mrs, H. Janis
2 speculation on the land involved) before construction starts,
3 and before operations begin. All levels of government and th«
4 public should participate in the granting of permits,
5 As we have heard today in so many ways, there is
6 an urgent need for impartial studies and research on all
7 methods of power generation and techniques to alleviate any
# adverse impact on the total environment. There should be
9 impartial analysis, coordination and cooperation in these
10 projects to eliminate duplication and to guarantee free
11 exchange of information. The regional approach should be
12 considered in all planning, land use projections, population
13 density studies and the projection of other multiple uses.
14 An overwhelming majority of local Leagues in the
15 Basin asked that consideration be given to the limitation
16 of the use of the Lake Michigan shoreline as the site for
17 future powerplant production. Because of the technology now
IB available to transmit power for longer distances, many
19 League members suggested inland sites with low population
20 density and the incorporation of closed cycling and/or
21 onshore cooling techniques,
22 The increasing demand for power was recognized,
23 but League members urge development of techniques to limit
24 the consumption of power. The "better life" may be here to
25 stay but the need to preserve Lake Michigan is here.
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1 Mrs. H. Janis
2 Consumer education is one way of encouraging the reduction
3 of power demands instead of the consumer-selling job that is
4 now being done to encourage the use of electricity and electri
5 appliances,
6 To encourage the reduction of electricity, rate
7 schedule adjustments should be studied to discourage
unnecessary usage without penalizing low-income families and
9 without putting undue hardship on industrial needs. Whether
' 10 it would actually limit consumption was questioned, but it
11 was suggested that the extra rates could pay for "clean"
12 operations and necessary research, not for extra profits,
13 The public has been exposed to all of the conflictin
14 reports and projections as to the effects — beneficial or
15 deleterious — of thermal effluents. Everyone is aware of
16 the possible uses of heated water and also aware of the
17 possible ecological damage in long-range projections.
League members cannot predict how research will decide the
19 issue, but they do urge protection for the immediate future.
20 One League writes back with the recommendation urging "pre-
21 vention before damage, not a cure after damage", Wilmette
League suggests, "For now, cool it," Lake Michigan is too
important for all uses to the 13,000,000 people in the Basin
to be subjected to uncertain experimentation,
25 The type of cooling system should depend upon
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1 } Mrs, H. Janis
2 the specific site under discussion. Onshore, closed cycle
3 techniques should be encouraged. Wide margins of extra-
4 protection should be incorporated in the construction of new
5 or enlarged plants. Meeting just minimal standards is not
6 considered to be enough. Plans for complete elimination of
7 heated effluent should be required for new plants and
sufficient land should be acquired to make the implementation
9 of these plans feasible,
10 Thermal effluent should be measured at the point
11 of discharge for easy identification of the heat source and
12 a constant record of heat discharged. Measurement at points
13 within the mixing zone, outside the mixing zone, and at
14 other points in the lake should be taken for research and
15 study purposes. One League suggested comparing temperatures
16 at these points with temperature readings which existed for
17 a long period of time before the plant commenced operations.
The emphasis on research, planning and study was visible
19 over and over again.
20 Although this Conference is particularly concerned
21 with thermal standards, the use of nuclear power requires
simultaneous attention to radioactive emissions. The
long-range, still unknown effects of radioactive emissions
on the food chain and on the entire ecosystem are of intense
25 concern to League members. Extra unnatural exposure to
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1 Mrs. H. Janis
2 radioactivity can possibly cause genetic or health
3 abnormalities. If there is such an effect, it would not
4 be a reversible source of trouble. Similar to pestisides,
5 mercury or other pollutants, it would be in the water to
6 I stay.
7 League members want — and I'm sure everyone
£ else does, too — the environment arid all of its
9 inhabitants to have the highest possible protection from
10 radioactive emissions in air or water. They encourage
11 research on new types of power development as quickly as
12 possible and the application of the known technology for
13 maximum protection now.
14 The problem of the transportation and disposal of
15 radioactive wastes is acute. Where and how should these
16 wastes be stored? How can these wastes be safely trans-
17 ported to disposal sites? How long must surveillance
18 be maintained?
19 As League members,we will work to educate our
20 communities on the need to protect Lake Michigan. As
21 consumers, we are willing to pay the price.
22 Thank you.
23 MR. STEIN: Thank you, Mrs. Janis, (Applause)
24 Do yOU have any comments or questions?
25 I have one, and I want to thank you very much
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133
Mrs* H« Janis
because you have something in your statement that I have
been trying to sell to the professionals practically every
day for 6 months or a year, I haven*t been able to get
this across and you put this as well as anyone, I want
to thank you for putting this in.
That statement is: "Thermal effluent should be
measured at the point of discharge for easy identification
of the heat source and a constant record of heat discharged,
1C Measurement at points within the mixing zone, outside
the mixing zone, and at other points in the lake should be
taken for research and study purposes."
I want to thank you very much.
MRSo JANIS: Thank you.
MR. STEIN: It is indeed anomalous to have a
League person put out something that I have been trying to
get across.
MRS. JANIS: Thank you.
MR. STEIN: Let us go on.
MR. MILLER: Mrs. Jack Troy, Munster, Indiana,
President of Save the Dunes Council.
MRS. BOTTS: Mr. Chairman, Mrs. Troy was unable
to remain. I have been requested by three Indiana groups
to submit their statements for the record.
I am Mrs. Lee Botts, Executive Secretary of the
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1 Mrs* L» Botts
2 Lake Michigan Federation, which is a clearing house for
3 conservation and citizen groups in all four States around
4 the lake*
5 I will not take time to read all three of these
6 statements because of the time — the short time remaining
7 for the rest of the public*
All three statements call for protection of Lake
9 Michigan from waste heat from nuclear plants,. The state-
10 ments are from the Save the Dunes Council; the American
11 Association of University Women, Indiana State Division;
12 and the Lake County Council of Conservation Clubs and
13 Affiliates, Inc.
14 Thank you*
15 MR, STEIN: Without objection, all of these
16 statements will be entered into the record as if read*
17 (The documents referred to above follow in their
entirety*)
19
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ONORARY PRESIDENT:
SEN. PAUL DOUGLAS
PRESIDENT EMERITUS
AND FOUNDER:
MRS. JAMES H. BUELL
ru*t«*
ORGANIZED IN 1952
ENFORCEMENT CONFERENCE
Chicago
PRESIDENT:
MRS. JACK M. TROY
1512 PARK DRIVE
MUNSTER. INDIANA 46321
PHONE 219-630-5843
MARCH 23, 1971
To Environmental Protection Agency:
The Save the Dun*a Council urges that the federal government
assume Ita share of the burden of protecting Lake Michigan
by proposing a definite thermal standard and waste diaposal
limits that would apply to all state areas involved.
The Council has a record of long and costly experience in
trying to battle agaLnat gread odds to save the ahorca and
waters of Lake Michigan from harmful and despoiling use.
Cur beat help has always come from federal agencies rather
than state and local officials. Bat any gains haTC had to
involve persistent and intelligent study and action by Individ-
ual citizens and groupa. We are cheered at some of the re-
cent gains made in influencing utility companies to take steps
that seem to be in the public interest with regard to reducing
the threat of raising lake temperatures and contaminating
wastes.
In our view the time is now for strong action by the govern-
ment to back up the gains won by eitizena with respect to
avoiding the loss of our four-state major resource—Lake
Michigan, j^ £. ^^a^ "T^r^i SAVE THE DUNES COUNCIL
Mrs. Jack Troy, president
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AMERICAN ASSOCIATION OF UNIVERSITY WOMEN
Indiana Slate Division
Statement to the Enforcement Conference, March 23, 1971, Chicago
To The Environmental Protection Agency:
The Indiana Division of the American Association of University
Women as part of a nationwide endeavor to recognize, rescue,
and protect environmental assets, wishes to add its voice to
the plea for federal government help !• saving Lake Miehiga*.
We hope you will some at this eo»fere«ae to a decision to pro-
pose a deflMlte a»d adequate thermal and water elea»ll»ess
standard that will protect the lake against misuses.
There is not time in saying the lake to wait for the delay of
state legislatures to act individually or cooperatively to
keep further harm from occurring. We hare worked In Indiana
with Indifferent results to persuade our legislators and looal
officials to take protective action. In light of the decis-
ions of utilities in Michigan and Indiana to respond to citizen
persuasion to take measures to protect the lake, we think it
is prime time for building on that example.
We hope the federal government itself will take the responsi-
bility of holding the line for the good of the environment
and the general public—set standards and help make them en-
forceable •
INDIAHA DIVISION, AAUW
per Mrs. L. W. Bicker, Division Board
1154 Ridge Road
Munster, Indiana 46323
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Lake County Council of Conservation Clubs and Affiliates, Inc.
Dedicated to the Preservation of Our Natural Resources
J PECK
4526 PIERCE ST
GARY I NO 46408
Lake Mleklga* Feleratle*
53 V»«% Jaek««« Street
Ckleage, HllD»U 60604
It May
Lake C*naty C««a«il «f
M, IB«., wi»k t» gt
C«u»«H, tkat «• are •pp*>«4
Mle*is»*« V« far** p»galatlBg water
eltker way *f Lake MleMigam.
Marek IT, 19T1
Cl«b« an*
wit! year 4 3taU
P*llaU«i t» Lake
ea* aegree
Very timly yeu?§,
L*s rtjt
Prealdeat
^^L*^A*4LsS , \*£^l^-'
Seeretary
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1 j H. G. Zander
ii
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STATEMENT OF HENRY G0 ZANDER, III,
9
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MR. BLASER: We have a number of requests and I
am just taking them in the order that they have written in
or they have been given to me. First is Mr. Henry G» „
Zander o Is he present?
Mr* Zander.
PRESIDENT, EVANSTON-NORTH SHORE BOARD
OF REALTORS, CHICAGO, ILLINOIS
MR. ZANDER: I am Henry G, Zander, III, and I
am here in the capacity of President of the Evanston-North
Shore Board of Realtors.
Gentlemen, the Evanston-North Shore Board of
Realtors is exceedingly distressed at the failure of the
Federal and State participants in this Enforcement Conference
to agree upon and impose a thermal discharge standard
regulating the release of heated water into Lake Michigan*
Such a standard should protect the ecology of
Lake Michigan and the health of aquatic and land biota —
including man — which depend on the lake. The standard
should also permit an orderly expansion of electrical
generating capacity to serve the needs of industries and
residents in the Lake Michigan basin.
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H. G. Zander
The 1,100 members of the Evanston-North Shore
Board of Realtors — and their families and customers
live and work in the basin. The basin's ecological integrity
and energy needs are both of vital concern to the Board.
We are not scientists. We don't know what the
thermal standard should be. We realize that scientists
cannot agree among themselves on what the standard should
be because there has been no concerted research effort to
determine precisely to what extent and under what conditions
Lake Michigan can tolerate heated water discharges.
This kind of research should have been undertaken
years ago. The need for it is generally recognized now, but
now we cannot wait for it. A standard must be set at once
because energy needs are increasing at a rapid rate
throughout the Lake Michigan ba^sin and nuclear powerplants
must be built to satisfy much of the increase in demand for
electricity. The utlity companies are building these plants
right now, but in most cases facilities for control of
heated water discharges are not being incorporated in these
plants,
The utility companies (with the exception of one firm
in Indiana which has announced plans for cooling towers
before undertaking construction) have not been willing to
control heated water discharges from their plants. The
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1 H. G. Zander
2 utilities are waiting for someone — for this Enforcement
3 Conference — to tell them that they have to control heated
4 water discharges.
5 By delaying adoption of a thermal standard, this
6 Enforcement Conference is merely ensuring that consumers
7 ultimately will have to pay more for electricity. We
& understand that Consumers Power Company in Michigan will
9 spend $10 million for cooling towers and a system to reduce
10 radioactive emissions at its Palisades plant. Conservation-
11 ists have bludgeoned C.P.C. into doing this by successfully
12 delaying approval of an operating license for the Palisades
13 plant, which has stood idle since last spring at a cost of
14 between $10 and $15 million. C.P.C.'s customers will pay
15 higher rates for electricity because the plant stood idle --
16 because the company didn't install equipment to protect the
17 environment until forced to do so.
18 Similar delays and legal maneuvers will undoubtedly
19 occur on a plant-by-plant basis around Lake Michigan in the
20 absence of a thermal standard.
21 The Evanston-North Shore Board of Realtors is
22 concerned that a situation similar to the Palisades case may
23 develop when Commonwealth Edison Company is ready to begin
2Zf operating the first nuclear reactor at Zion next year.
2^ Edison says its reserve capacity is now about three
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1 H. G. Zander
2 percent — a level which the U. S. Office of Emergency
3 Preparedness and the Federal Power Commission consider
4 dangerously low. We fear that Edison's reserves may be even
5 lower next year, and that the Zion plant will mean the
6 difference between an adequate power supply and a power
7 crisis of catastrophic proportions in the North Shore area
8 where we and our real estate customers depend on Edison's
9 ability to meet our electricity needs.
10 Last summer our Board of Realtors wrote to Clarence
11 Klassen and Walter Hickel to urge that the thermal question
12 be settled as soon as possible so that any modification
13 to the Zion plant which might be necessary to meet a thermal
14 standard could be made in the course of construction with a
15 minimum of delay.
16 Because no standard was set, the Zion plant is
17 now almost a year closer to being completed. Modifications
l£ will undoubtedly be much more difficult and costly to make
19 now, but, if a standard is imposed at this time, modifica-
20 tions should be easier to make now than when the plant is
21 finished and ready to operate.
22 We are calling for imposition of a potentially im-
23 perfect standard now. We recognize that, but we feel it is
24 essential that action be taken now. What's more, we
25 believe the standard should be strict enough to provide a
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!
2 i "cushion" against the possiblity that future scientific
3 evidence may dictate further modification of nuclear
i
4 generating plants. It would be disastrous to under-control
5 thermal discharges now and then go back later to install
6 additional controls and disrupt the orderly expansion of
7 electrical generating capacity. In our view, it is better
to run the risk of over-controlling now. After all, what's
9 at stake is nothing less than the preservation of our most
10 vital natural resource — Lake Michigan,
11 On behalf of the entire Evanston-North Shore
12 Board of Realtors, I thank you for giving us the opportunity
13 to tell you of our position on this critical question,
14 Thank you,
15 MR. STEIN: Thank you* (Applause)
16 Are there any comments or questions?
17 If not, may we call on Wisconsin,
IB MR0 FRANCOSi Mr, Chairman, conferees, I will ask
19 the indulgence of the Wisconsin people who indicated that
20 they wanted to participate in the Conference proceedings
21 today. However, I do have a statement of Governor Lucey
22 that I would like to read into the record. It is a short
23 statement and will not take very much time,
24 I also have a few short comments of my own to
25 offer, and then I would suggest perhaps we defer any
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Hon. Po J« Lucey
discussions so that we can proceed with the public sector
of these proceedings,
However, I will remit to the conferees as to
how they want to proceed,
This is a statement by Governor Patrick J, Lucey
at the Lake Michigan Enforcement Conference March 23 and 24»
STATEMENT OF THE HONORABLE PATRICK J,
LUCEY, GOVERNOR, STATE OF WISCONSIN,
PRESENTED BY THOMAS FRANCOS
MRo FRANCOS: "The State of Wisconsin cannot
afford to gamble with the future of Lake Michigan,
Scientific evidence indicates that heated effluents may
cause serious damage to the quality of Lake Michigan and
the life it supports. All necessary precautions must be
taken to prevent irreparable damage to Lake Michigan,
"The primary sources of heated effluent entering
Lake Michigan are the electric power industries. Almost
one-half of the water used in the United States is for
industrial cooling with the electric power industry using
70 percent of that amount. Forecasted growth in electrical
power demands show that by the year 2000, the waste heat
load to Lake Michigan will be 10 times the present amount,
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1 Hon. P, J. Lucey
2 Until we know the exact effects of thermal discharges on the
aquatic environment, we must require the use of technically
feasible cooling systems.
5 "All new and existing electrical power industries
6 must be required to construct cooling facilities by early
7 1973. The cooling facilities should be constructed in a
manner enabling the system to be closed or open. A 3
9 increase in temperature at the point of discharge would be
10 permitted at certain times of the year if the industry
11 submitted proof that the discharge would not affect the
12 quality of the water or the life it supports. The use of
.
a combined opened-and-closed system would permit the
recycling or holding of heated effluent at certain times
of the year.
"The exact affects of thermal discharges on the
17 aquatic environment are not known. Therefore, a two-
phase environmental study program should be conducted under
19 the guidance of the Federal Government.
2Q "First, an intensive study at one site should be
2i developed for field work during the winter of 1971-72 with
22 a preliminary report due in October 1972. It is
23 recommended that the Waukegan and Zion generating stations
24 in Illinois be utilized. Already, a private laboratory
25 has proposed an intensive-study program at this site.
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195.
Hon. P. J. Lucey
With appropriate guidance by the U.S. Environmental
Protection Agency and possible Federal support, the study
could be expanded to encompass all aspects of thermal
effects on the lake.
"Second, current investigation should be under-
taken under criteria developed by the conferees at all other
existing powerplants on the lake. These studies should be
accomplished by October 1972 and should include, but are
not limited to, flow and temperature of the cooling water
and the effects of passing plankton, fish eggs, and fish
larvae through the condensers."
That completes the Governor's statement.
Governor Lucey fs statement is concise and to the
point. He clearly reflects his concernfor the quality of
Lake Michigan. I believe it also expresses the general
public impatience and concern that this Conference come
to grips with the thermal issue and proceed with recommen-
dations.
The Governor has directed the Wisconsin conferees
to make it clear that his statement is a declaration of
Wisconsin objectives in dealing with thermal discharges to
the lake. The Governor also recognizes the existence of
perhaps technical and time limitations and perhaps the
limitations of the legal authority of the Conference and
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1 T. Frangos
2 perhaps the limitations of present State and Federal legis-
3 lation.
4 We, as conferees, are prepared here today to
5 concur in recommendations of this Conference that are pro-
6 gressive and supportive of the Wisconsin programs for
7 protecting the quality of the lake. They are also committed
g to pursuing all other State and Federal mechanisms currently
9 available in supporting new Federal and State legislation
10 to secure the Wisconsin objectives for the control of
11 industrial discharges.
12 This completes our statement, and you may want
13 to defer any discussion until you hear from the other
14 public people.
15 MR. STEIN: Thank you very much. (Applause)
16 I suggest we defer questions until
17 later.
lg I think it should be recognized, and I think it
19 is fair to state that, on its face, at any rate, it looks
20 like a stricter position than the Federal position.
21 Michigan.
22 MR. PURDY: I am wondering if Ruth Collins from
23 the U.A.W. is here.
24 Again, you don't look like Ruth Collins.
25 MRS. LEE BOTTS: I wear many hats.
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Mrs. R. Collins
Mrs. Collins is the International Representative
of the Department of Conservation of United Auto Workers,
headquartered in Detroit. She says in her statement that
she is appearing here today speaking for the U.A0W. Vice
President Olga Madar, Robert Johnston, Director of Region
4, Illinois and Iowa, and Harvey Kitzman, Director of
Region 10, Wisconsin and Minnesota.
Again, I will not take time to read the entire
statement which Mrs. Collins asked me to submit on behalf
of United Auto Workers. It does call for protection of
Lake Michigan from waste heat from powerplants.
Thank you very much.
MR. STEIN: Thank you.
Bo you want to put that statement into the
record? Without objection that statement will appear as
if read.
(The statement above referred to follows in its
entirety. )
-------
Mr. Chairman:
My name is Ruth Cpllins, I appear here today speaking for UAW Vice
President Olga Madar, Robert Johnston, Director of Region4, Illinois and
Iowa and Harvey Kitzman, Director of Region 10, Wisconsin and Minnesota.
We wish to express the concern of our Union's million and one-half
members and their families about the serious threat to ou,r lakes and streams
by our failure to take effective steps to stop the practices that cause the
pollution, and to remedy the damage already done. We are not experts in
the field of ecology.
Our Union has actively engaged in efforts to preserve our environment
and to prevent the destruction of ovsr natural resources of which water is one of
the most important. We are becoming increasingly concerned over the realization
that the long-sought for peaceful use of atomic energy poses a more serious
threat to humanity and the environment than did the atomic bomb because of the
k
accelerated growth of giant nuclear plants in America.
In response to the nation's growing need for electrical power, atomic
energy has emerged as the new technology for its provision. While the develop-
ment of peaceful uses for nuclear energy through a partnership of industry and
government may be applauded, many scientists are beginning to ask whether
our pressure for speed in commercial development of nuclear power generating
reactors does not present more problems than the benefits they are supposed to
produce. The matter of cooling water from these generators is one of these
i
problems.
There are presently 55 plants in operation or under construction in
the United States, with an increase of 450 estimated during the next decade.
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It has been estimated that in the next five years, 19 nuclear plants with
a power capacity of 12,470, 000 kilowatts will be located on the shores of the
Great Lakes, and will discharge 20, 000 cubic feet of hot water per second into
Lake Michigan. Utility Companies estimate that by 1990, installation will be
39, 300, 000 kilowatts. The waste heat would raise about '8 billion gallons of
water every day by 15 degrees fahrenheit.
In other words, the operation of the nuclear plants which are planned
will be equivalent to a heated, man-made Mississippi River flowing into the
Great Lakes.
Since temperature is the most important single factor governing the
occurance and behavior of life, this torrent of hot water could disturb the
delicate relationship between temperature and marine life, thus bringing about
destruction to aquatic life. It seems incredible that we have moved so rapidly
to such a massive application'of this new technology (which will subject our
environment and Great Lakes to this greater heat stress as well as to radio-
active wastes than they have ever had) - before its full effects are known.
Our members are among the millions of citizens who are becoming
increasingly incensed at the absurd contention that they have to choose between
power and pollution. People are beginning to speak out against a power industry
which uses a threat of'"black-outs" to frighten the public and conservationists
into quiet, so that the utilities can pollute at will.
In Illinois, the UAW has filed suit against the Commonwealth Edison
Company in Zion, charging that their proposed nuclear reactor plant would
cause deterioration of Lake Michigan through the excessive discharge of
heated water, and asking an injunction to prevent the utility from using Lake
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Michigan water unless it is returned to the Lake at its natural temperature.
In Michigan, our members have intervened in the Consumer Power licensing
i
request for a nuclear plant in Midland. "We supported the action of the inter-
venors at Palisades.
This kind of preventure action is needed, and will provide the industry
with the initiative to find ways of dissapating heat or using it for beneficial
purposes. It is more economical to incorporate the new technology in new
construction than to correct disastrous mistakes after their occurance.
Once a plant is built and the economy of the community is tied to its
operation, it is often difficult to enfo'rce needed standards and regulations.
Strong regulations are necessary because we cannot continue to
L£
permit unnecessary pollution from electrical generating plants whi«h the
••- . ' ~ - '
rest of the world is trying to clean up an environmental mess that threatens-
i.
survival of the planet. Power plants are unique- --- in that they are public
utilities --they have been granted a monopoly to do business in these states
and so, have a higher degree of responsiblity than other business.
Mr. Chairman as 1 said at the beginning of my statement, we are not
experts in the field of ecology. Maybe this is why the technical committee-
conclusions and recommendations appear to be confusing or contradictory.
In recommendation #4, the committee recommend that all thermal
electric power generating facilities using or planning to use Lake Michigan
water for dissipation of artificial waste heat be required to have closed cycles
cooling systems. Unless it has been demonstrated that ecological damage does
not or will not occur from once - through cycles.
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The committee further recommends that in depth studies be made to
determine the effects on the ecology. I fail to understand how the committee
can reach conclusions and make recommendations and at the same time agree
i
that the studies to date are inadequate.
The main order of business today should be to set standards to protect
waters of Lake Michigan from damage due to heated waste waters.
We agree with the policy recommended by the Federal Water Quality
Council in May of 1970 which would require Lake Michigan water users to
return the publics water at no more than 1 degree hotter than when withdrawn.
Mr. Chairman Thanks for hearing our view on this matter.
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f • .———. -- " - •— •• - ' —
i
1 i T. Falls
i
2 MR. STEIN: Indiana.
3 MR. MILLER: Ted Falls, President of the Porter
4 County Chapter of the Izaac Walton League of America, from
5 Chesterton, Indiana*
6
7 STATEMENT OF TED FALLS, PRESIDENT, PORTER
COUNTY CHAPTER, IZAAC WALTON LEAGUE OF
9 AMERICA, WHEELER, INDIANA
10
11 MR. FALLS: My name is Ted Falls. I am President
12 of the Porter County Chapter of the Izaac Walton League.
13 A great deal of what we have presented here has
14 already been said and said very much better, so I am going
15 to abbreviate my speech to save time
16 We would like to make the point that there are
17 questions that have come before this Conference both at
the last session and at this which have not been answered
19 and we would like to make the point that these answers are
20 readily available. Much of the time, the tests that were
21 necessary and the studies that were necessary were at hand
22 for the investigators, but they were ignored,
23 Why do salmon and trout seek warm water? Is it
24 j because they seek the greater activity possible to cold-
25 blooded animals in the higher temperature, in spite of
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' 1 T. Falls
2 scarcity of food? Is it because their prey is attracted to
3 the warmer water? Fishermen report extraordinary vigor
4 in taking baits around the plumes. Is this because they
5 are hungry, or because of heavy feeding?
6 A study would be a relatively simple investigation
7 of stomach content down the food chain present. At the
g bottom of the scale are the plankton, which certainly are
9 not in increased abundance because of the heat: rather,
10 the quantity of live survivors is sharply decreased, as is
11 generally acknowledged.
12 What is the actual effect of passage through the
13 condenser system on small fish and the survival of plankton?
14 How many, and what, are entrained at the intake? There are
15 a number of existing intakes inshore, and at various
16 distances offshore, for industries and municipal water
17 systemst A study at the cribs and filter beds might reveal
18 important information.
19 What is the effect of pressure stresses in passing
20 through the system? 1) There is a relatively slow pressure
21 drop along the intake conduit. The time rate can be
22 calculated accurately. There is a limit to the time rate
23 to which a fish can accomodate. 2) There is a sharp
24 pressure drop between the pump intake and the rotor blades.
25 Pumps are designed close to the limit imposed by cavitation.
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1 T. Falls
2 The pressure here can drop in a very short time interval to
3 the order of 0,5 p«s0i.a. This is a ratio of 25/1 to 30/1
4 to the habitat pressure. This means that the air sac of a
5 fish could be expanded to 25 to 30 times the original volume.
6 Rupture will be the consequence. Immediately past the rotor,
7 the pressure increases to approximately 2? p.s.i.a., reducing
g the buoyancy of the air sac of any survivors to half or less
9 of the natural habitat. This will leave them helpless.
10 Simple field measurements will be necessary to determine the
11 scale of pressures in the system, and the time sequence.
12 This then can be duplicated rather simply in the laboratory
13 for direct observation.
14 What is the effect of temperature shock, especially
15 on plankton? The operating temperature of powerplant conden-
16 sers is 40 to 60 degrees above intake temperatures. Contrary
17 to the impression given by published data on condenser
13 discharge water, 50 to 60 percent of all water circulated in
•
19 the system, with entrained life, will be subjected to this
20 highest temperature, a rise in a very short interval* It is
21 elementary to collect samples at the discharge end of a con-
22 denser system for laboratory study of survival, with intake
23 samples for control. Current reports of kill are so cursory
24 that the subject seems to have been avoided by the
25 investigators.
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_ 205
T. Falls
What is the effect of jet plumes discharged close
to the bottom, as at Zion? An accurate forecast can be made
from present knowledge in biology and other fields. Because
of the nature of fluid flow, turbulence will sweep the
bottom over an area greater than the plume. The cumulative
temperature effect will accelerate all bottom life that can
resist the scouring. Dr, Colby has demonstrated the
acceleration of the season for fish hatches. In this
connection, it is interesting that Dr, Ayres reported gravel
beds in his bottom survey of the Bent on Harbor area, but
did not map them. Biologists, as well as fishermen, should
know that gravel is the spawning bed for important fish
species in the lake food chain. None of Dr. Ayres1 study
recognizes the presence of either fish spawn or fry, even
though one sampling series was at the season.
What will be the consequence of increase of plant
life in inshore water? This cannot be a laboratory study;
but it is a challenge to assemble our present knowledge and
make a decision. In spite of Dr. Ayres1 failure to find
benthos in the shore area of vigorous wave action, all can
observe attached algae species growing in the surf. We also
know that elevation of temperature contributes to this
growth. The consequence is an increase in the contribution
of organic material on the bottom, with eventual pondweed
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1 . T. Falls
2 types offshore.
3 We wish to submit the following position:
4 Powerplants now in operation are an adequate field for study
5 of the consequences of the addition of heat to the ecology
6 of the lake. Studies up-to-date have ignored essential
7 phases. Adequate studies will show genuine and intolerable
g damage to the lake. There is no limit below which
9 proliferation of powerplants along the lakeshore can be
10 tolerated.
11 Powerplants in the course of construction should
12 be required to use an alternative method of cooking — or
13 cooling. (Laughter) Plants now in the planning stage must
14 be located inland, where there is room for cooling ponds.
15 Our study indicates that evaporative cooling towers will
16 prove to be extremely objectionable and will have to be
17 abandoned within a few years of first operation.
lg All additions to existing powerplants must be
19 forbidden the use of the lake for once-through cooling.
20 All studies of the impact of powerplants (and
21 other industries) on the ecology of th,e lake must be under
22 the direction of an impartial committee. It has become
23 obvious that studies controlled by an industry are weighted
24 by their interest.
25 All monitoring of effluents must be held under
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1 T. Falls
2 the strict surveillance of impartial government agencies.
3 Thank you.
4 MR. STEIN: Thank you, Mr. Falls. Tour whole
5 statement will appear in the record.
6 (The statement above referred to follows in its
7 entirety.)
9
10
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IS
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DEDICATED TO THE PRESERVATION OF OUTDOOR A M E RI C°A
Jjaafe Walton Heague of America
PORTER COUNTY CHAPTER, CHESTERTON INDIANA 46304
To: Four-State Enforcement Conference on Pollution of Lake Michigan,
Chicago, Illinois,
March 23, 1971.
Submitted by: Ted Falls, President,
Wheeler, Indiana U6393.
Gentlemen:
Lake Michigan is a vast resource. To citizens as people it has many values that
I do not have to discuss here, to only a small part of which a dollar value can
be given. To citizens responsible for the management of our power supply, and
for the management of industry, it is a vast source of cooling water at a
remarkably low temperature, with a vast capacity for industrial and human wastes.
Recently, the alarm raised by environmentalists has been resolved into the
question: How much abuse can Lake Michigan stand? A parallel question is
asked by the power companies: How dense can the power plant population become
before interference reduces the advantage of low temperatures?
How much abuse can Lake Michigan stand? This question cannot be answered beyond
question until damage is done. Then it is too late. Lake Michigan cannot
repair itself as Lake Erie might. It is a vast pocket, with minuscule flow-
through. Dr. John C. Ayres notes industrial damage now in progress. I quote
from his "Benton Harbor Power Plant Limnological Studies" for American Electric
Power Service Corp. and Indiana and Michigan Electric Co., dated November 1967,
Bart I, page h' "There is a lack of detailed knowledge in many regions, but we
know of disrupted normalcy of the benthos at Milwaukee, in the inshore region
from Chicago to Michigan City, and at the mouth of the St. Joseph River."
How dense can the power plant population become before interference reduces the
advantage of low temperature? The answer to this question bodes ill for those
who would preserve the lake for its dollar-free values. The power companies have
supported scientific studies of Lake Michigan at great expense. Their interest
is to justify their use of this "vast resource and dump". We are told of their
concern for preserving unsoiled the ecology of Lake Michigan, and that their
studies support growth to 29 large power plants (1967). How many more since?
Their attention to the ecology of the lake has been cursory at best. There is
a body of scientists who disagree with their conclusions. A few have appeared
here.
This points to the value of the Bureau of Fisheries, no longer limited to
commercial fishing, or to the interests of sports fishermen. They can now
operate in broad fields concerning the environment. To date, their work has
not been directed in depth to the problem, although they have put some very
-------
. PCRTER COUNTY CHAPTER, I7AAK WALTON LEAGUE Page 2. 2°9
pertinent information before this Conference. They have not reached a point at
which they can offer summary conclusions. I do not need to describe how they can
be blocked by interests that their findings might embarrass. Citizen environment-
alists do not have the funds to sponsor the projects of, scientists in other
institutions. Generally, independent scientists, such as have appeared here,
find great difficulty to find sponsors for their studies purely in the matter of
environment.
It might be of value to point out here that no broad, effective program of study
will result without leadership? and it is in the hands of this Conference to
provide that leadership. You should create a committee — or propose it to
the Department of the Interior or the Environmental R?otection Agency — which
would see that all essential phases of the ecology of Lake Michigan are covered.
This committee "sKould include academic scholars and practical field men, as far
as possible environmentalists, "hard-headed" as against "hard-core". It also
should provide a means to speak to the layman — too much of the knowledge that
is the basis for judgement is in esoteric language.
There are a number of questions that have come before this Conference unanswered,
and are asked among environmentalists. Some of them can be determined simply
and directly. We ask: Why have they been ignored? We would like to discuss
several of these questions.
Why do salmon and trout seek warm water?
Is it because they seek the greater activity possible to cold-blooded
animals in the higher temperature, in spite of scarcity of food? Is it
because their prey is attracted to the warmer water? Fishermen report
extraordinary vigor in taking baits around the plumes. Is this because
they are hungry, or because of heavy feeding?
A study would be a relatively simple investigation of stomach contents
down the food chain present. At the bottom of the scale are the plankton,
which certainly are not in increased abundance because of the heat: rather,
the quantity of live survivors is sharply decreased, as is generally
acknowledged.
What is the actual effect of passage through the condenser system on small fish
and the survival of plankton?
How many, and what, are entrained at the intake? There are a number of
existing intakes inshore, and at various distances offshore, for industries
and municipal water systems. A study at the cribs and filter beds might
reveal important information.
What is the effect of pressure stresses in passing through the system?
1. There is a relatively slow pressure drop along the intake conduit.
The time rate can be calculated accurately. There is a limit to the
time rate to which a fish can accomodate.
2. There is a sharp pressure drop between the pump intake and the rotor
blades. Pumps are designed close to the limit imposed by cavitation. The
pressure here can drop in a very short time interval to the order of o.£ psia.
This is a ratio of 2?/l to 30/1 to the habitat pressure. This means that
the air sac of a fish could be expanded to 25 to 30 times the original
volume. Rupture will be the consequence. Immediately past the rotor, tbe
pressure increases to approximately 2? psia, reducing the buoyancy of the
air sac of any survivors to half or less of, the natural habitat. This
will leave them helpless. Simple field measurements will be necessary to
determine the scale of pressures in the system, and the time sequence.
This then can be duplicated rather simply in the laboratory for direct
observation.
-------
PORTER COUNTY CHAPTER, IZAAK WALTON LEAGUE Page 3. 210
What is the effect of temperature shock, especially on plankton?
The operating temperature of power plant condensers is 1|0 to 60 degrees
above intake temperatures. Contrary to the impression given by published
data on condenser discharge water, £0 to 60 % of all water circulated in
the system, with entrained life, will be subjected to this highest
temperature, a rise in a very short interval. It is elementary to collect
samples at the discharge end of a condenser system for laboratory study
of survival, with intake samples for control. Current reports of kill
are so cursory that the subject seems to have been avoided by the
investigators.
What is the effect of jet plumes discharged close to the bottom, as at Zion?
An accurate forecast can be made from present knowledge in biology and
;. other fields. Because of the nature of fluid flow, turbulence will sweep
the bottom over an area greater than the plume. The cumulative temperature
effect will accelerate all bottom life that can resist the scouring.
Dr. Colby has demonstrated the acceleration of the season for fish hatches.
In this connection, it is interesting that Dr. Ayres reported gravel beds
in his bottom survey of the Benton Harbor area, but did not map them.
Biologists, as well as fishermen, should know that gravel is the spawning
bed for important fish species in the lake food chain. None of Dr. Ayres1s
study recognizes the presence of either fish spawn or fry, even though oae
sampling series was at the season.
What will be the consequence of increase of plant life in inshore water?
This cannot be a laboratory study; but it is a challenge to assemble our
present knowledge and make a decision. In spite of Dr. Ayres1s failure
to find benthos in the shore area of vigorous wave action, all can observe
attached algae species growing in the surf. We also kniw that elevation
of temperature contributes to this growth. The consequence is an increase
in the contribution of organic material on the bottom, with eventual pond-
weed types offshore.
The question: How much abuse can Lake Michigan stand? has precipitated a
discussion in which the major issue has been lost in details. It has been
estimated that a soluble pollutant in the lake, once terminated will be
diluted $0$ in 100 years, such is the relation of volume to outflow. This
applies to the lake as a whole. The southern half will take longer. Actually,
the problem narrows to the inshore waters, where there is the greatest
concentration of life. Nutrients, as they are added to what is already in the
lake, enter the life system and lock in for a much greater time than the
hypothetical pollutant of the estimate. Heat, added to the inshore waters,
enhances the activity of the life system, obviously to become the wrong life
system. Unfortunately, even when it becomes apparent that industry has over-
balanced nature, it is extremely difficult of impossible to stop industry.
It is even more difficult to correct the condition in nature. We think it
is reasonable to apply our intelligence to the control of these problems
before we are overwhelmed by the consequences of neglect.
We wish to submit the following position:
Power plants now in operation are an adequate field for study of the
consequences of the addition of heat to the ecology of the lake. Studies
up to date have ignored essential phases.. Adequate studies will show
genuine and intolerable damage to the lake. There is no limit below
which proliferation of power plants along the lakeshore can be tolerated.
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POSTER POINTY CHAPTER, IZAAK WALTON LEAGUE . Page It. 211
Power plants in the course of construction should be required to use an
alternative method of cooling. Plants now in the planning stage must be
located inland, where there is room for cooling ponds. Our study indicates
that evaporative cooling towers will prove to be extremely objectionable
and will have to be abandoned within a few years of first operation.
All additions to existing power plants must be forbidden the use of the
lake for once-through cooling.
All studies of the impact of power plants (and other industries) on the
ecology of the lake must be under the direction of an impartial committee.
It has become obvious that studies controlled by an industry are weighted
by their interest.
All monitoring of effluents must be held under the strict surveillance of
impartial government agencies.
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212
1 A* Pancoe
2 MR. STEIN: Are there any questions or comments?
3 Now, we will go to Illinois,
4 MR. BLASER: The next speaker is Mr. Arthur
5 Pancoe, Scientific Director of the Society against Violence
6 to the Environment and Campaign against Pollution.
7
g STATEMENT OF ARTHUR PANCOE, SCIENTIFIC
9 DIRECTOR OF SOCIETY AGAINST VIOLENCE TO
10 THE ENVIRONMENT AND CAMPAIGN AGAINST
11 POLLUTION, GLENCOE, ILLINOIS
12
13 MR. PANCOE: My name is Arthur Pancoe. I am
14 Scientific Director of the Society against Violence to
15 the Environment and Campaign against Pollution.
16 I have appeared before this Conference on two
17 previous occasions to tell you why I believe it is inadvis-
lg able to allow thermal diffusion into Lake Michigan from
19 electric generating plants.
20 At this time, I will bring before the Conference
21 five major dangers amongst otheilthat have not at any other
J'"
ctorily.
23 The first peril 1 wish to emphasize is the
24 inability of plankton to withstand the rapid temperature
25 rise across the condenser.
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A. Pancoe
In Dr. Donald W. Prit chard's paper of 1970 before
this Conference, supporting the use of the lake for cooling
water used in generation of power, he disucsses in detail
the various aspects of the problem with the ultimate con-
elusion that presently proposed plants will have no measur-
able effect on the overall lake temperature. In this I
concur0 But the subject Dr. Pritchard deals with in most
detail is how to discharge the cooling water in a way which
will allow the most rapid dilution of the thermal plume.
Why is this the major concern of his presentation? I
suggest the answer may be found on the bottom of page 20
of this report.
"For example, in the case of the Zion Power
Station, the time of transit of the condenser cooling water
from the condensers to the point of discharge will be
approximately 2 minutes. In order to minimize any possible
biological effects of using the surface waters of Lake
Michigan for cooling, the condenser cooling water flow
system should be designed to minimize the time of transit
of the heated effluent from the condensers to the point
of discharge." Note: Dr. Pritchard even though a proponent
of using the lake for once-through cooling purpose, and
a Commonwealth Edison witness at the last Conference, uses
the words ",.. minimize any possible biological effects."
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1 A. Pancoe
2 This means there is a problem here, and at the very basic
3 level of the food chain. Since only 10 percent of the energy
4 radiated to the lake is available to man and is manifest at
5 this microscopic level of the food chain, as we move up
6 the food chain, each level is at most 10 percent efficient.
7 We can readily see that we are taking a risk at the most
g basic level of life, and the dangers, if we are wrong, are
9 not insignificant.
10 Yesterday I received a call from Dr. Thomas
11 Roos, the Biologist of Dartmouth College ~ and I might
12 point out that this is his exact specialty — who
13 expressed deep concern over this use of lake water. He said
14 that the sudden rise of 20° F. across the condenser, in his
15 opinion, will kill most, if not all, the Phyto and zooplank-
16 ton. He stated that the two minutes of anticipated time
17 that plankton is exposed to the extremely warm water
lg may not seem much in the life of an individual, but must
19 be correlated to the one and a half or two day life span
20 of the form of life in question.
21 He reiterated the danger to the entire lake's life
22 if harm comes to this primary level of the lake's food chain,
23 I might point out that Professor Roos formerly
24 lived on the North Shore and has an overall familiarity with
25 the lake.
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1
2
3
4
5
6
7
9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
A* Pancoe
It should be noted here that it is estimated that
all inshore water will flow through, on the average, one of
those plants three times per year. To the extent that the
Palisades and Bailly Station Plants are intending to use
cooling towers, the magnitude of this problem may be
reduced. It is recognized that the inshore water is
biologically the most productive portion of the lake, and
the biota being drawn through these plants is the base upon
which all fishes, and to some extent fowl, depend upon for
life.
According to Dr. P. F. Gustafson of Argonne (see 21:'a)
National Laboratory in a paper also presented previously
before this Conference — and it is a part of Commonwealth's
position — little, if any, environmental changes can be
detected about the discharge areas from existing fossil
plants operating about the lake. But he goes on to say
"... but secondary, more subtle, effects at some distance
from the point of input may take place.1* But can it be
denied that there is an ideal optimum temperature for the
growth of blue-green algae, and such an ideal environment
will be created artificially and rat'her permanently in a
boundary area about the mixing zone?
This algae has some species which multiply most
profusely at 95° F. and other species that prefer
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A
U of C-AUA-USAEC —
215a
ARGONNE NATIONAL LABORATORY March 29, 1971
Mr. Murray Stein
Assistant Commissioner for Enforcement and
Standards Compliance
Environmental Protection Agency
Water Quality Office
Washington, D. C. 20242
Dear Mr. Stein:
If possible I should like to have the following statement entered
into the record of the Lake Michigan Enforcement Conference held in
Chicago on March 23-25, 1971.
On March 24, Mr. Arthur Pancer, Scientific Advisor to CAP and
SAVE in his written statement referred to parts of my presentation to the
Four State Workshop in September-October 1970 as "having been made in
support of Commonwealth Edison. "
I should like to clarify the point that the Great Lakes Research
Program at Argonne National Laboratory is a scientific one, with the objec-
tives of determining the physical and biological fate of thermal and radio-
nuclide discharges into large lakes. It is not unlikely that our conclusions
will at times be supportive to the position of one or more parties to the
Lake Michigan question. My presentation was meant solely to convey our
research findings and scientific judgments, and not to support the utility
industry.
Although not a participant in the recent Enforcement Conference, I
watched the proceedings with interest. I must congratulate you on your
patience and skill in moving things along, as well as in keeping the overall
peace.
With i»est regards,
Sincerely yours,
Philip F. Gustafson
Associate Director
Radiological Physics Division
PFGrfrc
9700 South Cass Avenue, Argonne, Illinois 60439 • Telephone 312-739-7711 • TWX 910-258-3285 • WUX LB, Argonne, Illinois
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1 A. Pancoe
2 temperature in the range of 86° F. This algae is already
3 found in abundance at the Southern end of Lake Michigan.
4 It is very adaptable and will even grow well within the
5 plants' cooling systems where the water is at its highest
6 temperature,
7 Here is an interesting point: Mr, George E,
8 McVehil on behalf of Commonwealth Edison Company testified
9 before the Illinois Pollution Control Board last November
10 that if cooling towers were installed at Zion fog conditions
11 would exist in the Zion area, as the result, various
12 numbers of days per year, depending upon the type of
13 towers installed, I am somewhat surprised that Dave Currie
14 did not raise this with all of the scientific perception
15 that he has shown here on the platform today.
16 I concurred in this prediction in a letter to
17 the Illinois Control Board, but I believe he failed to
1$ mention that similar fogging conditions may very well occur
•
19 over the lake in the area of discharge. That is, a large
20 amount of the heat loss from the area of thermal plume
21 will be due to increased surface evaporation, as a result
22 of increased heat, I suggest that anyone with any back-
23 ground in physics or chemistry or meteorology would
24 obviously see this point. You can't depend upon the
25 evaporation to dispose of the heat when you want to in one
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1 j A, Pancoe
2 discussion to get rid of it so it isn't going to harm the
3 lake, and at the next moment when you are talking about
4 fogging conditions completely overlook the same phenomena
5 of physics. You will note in Dr. Pritchard's testimony
6 mentioned earlier he specifies that approximately 15 percent
7 of the heat lost from the lake is due to evaporation,
g While he was discussing this figure in a different context
9 — I don't know, assuming that no one would bring it up in
10 the context I am now bringing it up — its application to
11 my point is obvious. Also, Dr, Gustafson mentions this
12 problem in a very peripheral and running through way in his
13 report. I suggest should the fogging over the lake be
14 less intense than above towers — now, remember what I am
15 saying, it will be less intense — but will cover more
16 area, the total effect on the environment of say, Zion
17 _. which has been used as scare tactics — might very much
be the case as if cooling towers were there. That is, if
19 there is an intense fog about the towers no one really cares
20 about it but if the wind is blowing in the direction of
21 Zion and it diffuses out over the area, it will lose its
22 density and cause a fogging problem. This exact condition
23 will occur in the lake in front of the plant and will move
24 in over Zion with the same inshore wind so what is right
25 for one site is right for the other. Let's get rid of the
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1 A, Pancoe
2 scare tactics about this fogging business,
3 In lakes and ponds (lentic environments) the
4 biota are synchronized in their life cycles by changes in
5 water temperatures. If man in a major way distorts this very
6 finally turned gradual and sequential mechanism of the
7 inshore waters in the spring of the year, the consequences
3 may be far more dramatic than we can even envision. For
9 a detailed description of this possible danger, I refer you
10 to the previous paper I presented here in September 1970,
11 with special reference to paper attached to that report, by
12 J. J. Resia of the Department of Biological Sciences,
13 Northwestern University.
14 I also received a call in unison from two of the
15 world's most eminent limnologists today, Dr. John Magnuson
16 of the University of Wisconsin had this to say and he wants
17 this as an overall position read into the record. He has
13 perhaps done as much work on the life of the lake with
19 regard to fish and thermal plumes as any man now alive.
20 His overall position is that we should not --> and I repeat,
21 and he will back this up — we should not take a chance.
22 Most of the research that has been done has been done with
23 warm water lakes.
24 He wished me to bring before this Conference a
25 point that I think is unique. He is as much concerned, if
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A, Pancoe
not moreso, with the fact that fish will by their own nature
be repelled from the thermal plume and the areas of the
thermal plume at certain times of the year as he is with
5 the idea that certain fish will be attracted.
6 Now, remember what he said. He is as much concern-
7 ed with the fact that these fish will by nature leave the
area of the thermal plume as he is by the idea that certain
9 of the species will be attracted to the thermal plume. And
10 he wanted this read into the record today.
11 I will conclude with my final point. I wish
12 to point out what I believe to be an erroneous idea that
13 now or in the future will it be possible to isolate, for
14 example, heat alone, as a specific contributor to the death
15 of Lake Michigan.
16 Synergism: The detrimental effects of heat,
17 chemical fertilizers, chemical pollutants, sewage, bacteria,
and solid wastes being discharged into the lake may very
19 well in combination be far more disastrous to the lake
20 than the study of any one of the perils alone might suggest.
21 I also suggest that fish congregating about the discharge
22 area might be subject to very disproportionate degrees of
23 radioactive discharge either accidental or on purpose.
24 If damage does occur from the heat, it will be
25 subtle at first and may not make itself manifest for years
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1 A. 'Pancoe
2 or even decades into the future. Damage will be
3 accumulative, as Lake Michigan does not have a rapid change--
4 over of water. I also suggest that at no time will it be
5 provable that heat alone is responsible for the damage.
6 In a statement to me yesterday, Professor Arthur
7 D. Hasler, of the University of Wisconsin, one of the
world's outstanding limnologists, expressed deep concern
over the direction we are going with regard to disposing
10 large amounts of heat into the lake. He stated to me that
11 he would much prefer to see this heat disposed of into
12 the atmosphere at this time.
I would like to conclude by presenting to the
Conference over 5»000 signatures of people from Northern
Illinois requesting that this Conference adapt a standard
allowing no thermal discharge into Lake'Michigan from
electric operating plants, either under construction now,
or planned for the future, since alternative means of
10 distribution of the heat are available.
20 (Tne above-mentioned signatures are on file Hq.EPA
Thank you. (Applause)
22 MR» STEIN: Thank you, Mr. Pancoe.
23 Any comments or questions?
If not, may we hear from Wisconsin.
25 MR. MACKIE: Is Mrs. Robert Erickson here?
MRS. ERICKSON: I,wanted to speak tomorrow in
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Mrs. G, Knapp
2 relation to another thing than thermal discharges, please.
3 MR. MACKIE: Mrs. Grace Knapp.
4
5 STATEMENT OF MRS. GRACE KNAPP,
6 I MILWAUKEE AUDOBON SOCIETY,
7 MILWAUKEE, WISCONSIN
9
MRS. KNAPP: I wish to make this statement on
10
behalf of the Milwaukee Audobon Society.
11
We wish to make clear our stand on the
12
discharging of heated water into the lakes and rivers by
13
powerplants
14
It is a well known fact the demand for more and
15
more electrical power has been increasing. To supply
16
that demand, greater power sources are needed. This has led
17
to the building of more powerplants, including the nuclear
power companies.
19
We are not opposed to powerplants as such —
20
nuclear or otherwise. We are opposed to the discharge of
21
superheated water into our lakes and rivers, because we
22
are not satisfied that sufficient evidence of the
23
ecological impact of such action has been obtained. We
24
are convinced that it is foolhardy to gamble with the
25
long-range welfare of man and his environment for the
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1 j Mrs, G. Knapp
!
2 sake of an immediate and perhaps only too short-lived gain.
3 We therefore firmly stand beside those who urge
further honest, diligent study now, so that when we go on
to build, our progress may be truly beneficial.
And, at this time, I wish to state that the
Milwaukee Audubon Society will have the privilege of hosting
the National Audubon Convention, and as one of our main
9 speakers we will have the pleasure of having William D,
10 Ruckelshaus, Administrator for the Environmental Protection
11 Agency, This convention will be held on May 20-24 and
12 we invite you all,
13 Thank you
MR. STEIN: Thank you
15 May we go to Michigan?
16 MR. PURDY: Mr. Chairman, I believe this completes
17 the public or private individuals that — oops, a hand up
here? I don't have the name.
I know I have some statements to be made on the
20 topic for tomorrow but
21 FROM THE FLOOR: Still for Michigan?
22 MR. PURDY: This is for Michigan.
23 That completes the private individuals from
Michigan, Mr. Stein,
25
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M." Stein
MR. STEIN: Okay.
Again, we want to give everyone an opportunity,
but as I indicated, we just cannot do the impossible.
As many of you who have been at the conferences before
know, the product of the conference is the record. I
think the records have been useful, since some of the state-
ments that we have heard have analyzed past records. There
is only so much a court reporter4 physically can do in one
day, and we are not going to be able to continue this
indefinitely. So I think we are going to have to make a
determination. I have just checked with Mrs. Hall, and
10 I am not sure that we are going to be able to continue
/,.
5
6
IT
•ii
22
24
25
much longer today.
,c Let's call on Illinois.
MR. MILLER: Indiana.
,« MR. STEIN: Indiana.
MR. MILLER: All right. Mr. Ted McDonald,
Livingston Hills Association.
2Q FROM THE FLOOR: Mr. McDonald had to leave.
2_ MR. MILLER: Then this would conclude all of the
names that I have for public presentation from Indiana.
MR. STEIN: How many more do you have?
MR. BLASER: About 21.
MR. STEIN: How many more does Wisconsin have?
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1 M. Stein
i
2 MR. FRANCOS: Total number?
3 MR. STEIN: Yes. No, not industry just citizens,
4 MR. FRANCOS: Just one more, I believe.
5 MR. STEIN: All right. Let's go in order.
6 MR. FRANCOS: I am sorry. We are done.
7 MR. STEIN: What?
8 MR. FRANCOS: We are finished.
9 MR. STEIN: You don't have any more?
10 MR. FRANCOS: Other than industry.
11 MR. STEIN: No, I suggest we leave industry.
12 I would like to make an equitable provision with
13 Illinois to see where we could get a reasonable cutoff
14 tonight. Are there several people who you feel we have to
15 call and we have to accommodate? .
16 MR. BLASER: All right. Let me suggest, I would
17 ask time estimates on those folks —
IS MR. STEIN: I really don't think we can go more
19 than another half hour with the reporter.
20 MR. BLASER: Well, the next person has asked for
21 3 minutes; the next 10; the next, 6; the next I do not
22 have the time*
23 Incidentally all of ours are in time of receipt.
24 These that I have were received by letter before the
25 meeting.
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1 Mrs. L. Botts
2 MR. STEIN: May I suggest this. We will go
3 another half hour and we will both make a judgment on the
4 half hour when it is up.
5 MR. BLASER: I might ask that those who speak —
6 if they could condense their reamrks and move along rapidly
7 it will enable others to have the chance to speak.
$ MR. STEIN: Why don't you just manage your own
9 time.
10 MR. BLASER: Okay.
11 Mrs. Lee Botts, you have spoken for others. You
12 had asked to speak for yourself though quite a while ago.
13 This is the 3 minutes. Right, Mrs. Botts?
14 .
15 STATEMENT OF MRS. LEE BOTTS, EXECUTIVE
16 SECRETARY, LAKE MICHIGAN FEDERATION,
17 CHICAGO, ILLINOIS
13
19 MRS. BOTTS: I am not speaking for myself, I am
20 speaking for the Lake Michigan Federation.
21 The purpose of the Federation is to provide
22 information to citizens of Wisconsin, Indiana, Illinois,
23 and Michigan for public policy decisions on the lake.
24 In recent months we have devoted much effort to
25 increasing citizen participation in the enforcement
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1 Mrs. L. Botts
2 conference. Unfortunately, to date, the chief result has
3 been to undermine citizen confidence in the capacity of
4 government to deal with the problem of preserving Lake
5 Michigan.
6 The issue before this Conference today is a therma
7 standard for Lake Michigan, specifically whether the waste
g heat from nuclear powerplants operating or being built on
9 the lake shores should be disposed of in lake waters.
10 Briefly, I wish to review for you the history of the
11 enforcement conference so that you will understand why this
12 session probably offers the last opportunity for resolving
13 the thermal question in this procedure; so that you will
14 understand why a despairing public will turn to other
15 means to achieve protection of the lake if the enforcement
16 conference continues to fail.
17 The Lake Michigan Enforcement Conference was
13 initiated in 1965. In his opening remarks Chairman Murray
19 Stein extrolled the conference technique, saying, "We
20 consider as successes those problems which are solved at the
21 conference table, rather than in court." This is how the
22 thermal question has been dealt with to date around the
23 enforcement conference table: In February of 1969 when
24 the five large nuclear plants with their eight new reactors
25 were in the early stages of construction, the enforcement
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22?
1 Mrs. L. Botts
2 conference heard a technical committee report from F, W,
3 Kittrell, consultant to the Federal Water Pollution Control
4 Administration* Today, two years later, with one Point Beach
5 reactor in operation, another ready, and all the other
6 nuclear plants finished or almost finished, what progress
7 has been made in the enforcement conference toward a thermal
g standard?
9 Today, we have another technical committee report
10 which says essentially what the Kittrell report said: that
11 there is a risk to the lake from the waste heat but we cannot^
12 really know until more studies are done. What was Mr.
13 Stein's response to the Kittrell report? Why, he said that
14 if the PWPCA coordinated a comprehensive study as recommend-
15 ed, there was no assurance the result would not call for
16 another study. "This can," he said, "Go on forever,1*
17 Ladies and gentlemen, today we meet after a full year of
1$ conferring on thermal effects, beginning with a plea by
19 myself and others at Milwaukee last March 30 that the
20 thermal question be resolved. We have had open executive
21 sessions, and closed executive sessions and a 5-day
'*
22 workshop and feasibility studies to back up a 1°
23 position that was repudiated and a compromise offered in
24 terms of B.t.u.fs that was abandoned almost as soon as it
25 was offered.
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22S
1 Mrs. L. Botts
2 And we still know what we knew in 1969: that to
3 put the waste heat from nuclear powerplants into Lake
4 Michigan may threaten the life of local areas, with unknown
5 consequences for the whole lake. What we know best of all
6 is that if we wait for studies by government, and if we
7 wait for decisions based on studies, Mr. Stein is probably
g right. This conference can go on forever, and in any way
9 that really matters, it can get nowhere.
10 Meanwhile, of course, the utilities have continued
11 to build the plants as they were originally designed.
12 Through no fault of their own — for how could they do
13 otherwise when not directed by the agencies charged with
14 regulating disposal of waste heat — while the conferees
15 have conferred in the enforcement conference, the power
16 companies may have spent millions of dollars for intake
17 and discharge systems to the lake they will not be able
l£ to use, expenditures which will ultimately be paid for by
19 you and me. I say may have, because there is one exception
20 to what has happened to the nuclear plants, and that is at
21 the Palisades plant at South Haven, Michigan.
22 There the public intervened in the operating
23 procedure and was ready to go to court if necessary to
24 achieve what this enforcement conference has not achieved:
25 protection of Lake Michigan from the waste heat. Mr.
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Mrs. L. Botts
.-.
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1 Mrs. L. Botts
2 nuisances in inshore areas and are becoming increasingly
3 abundant offshore throughout the lake. Other diatoms
4 indicating extreme degradation of water quality in the
5 Great Lakes entered Lake Michigan between 1947 and 1964 and
6 are Becoming more widespread. Although their numbers
7 are small, their presence indicates that the pollution of
g Lake Michigan is reaching critical levels. I direct you
9 to the work of Dr. Eugene Stoermer so far ignored in this
10 Enforcement Conference. For your information, I submit
11 this scientific report from the Great Lakes Research
12 Division of the University of Michigan with the full
13 details of these facts.
14 Mr. Chairman and conferees, Lake Michigan needs
15 your protection from every possible risk and the public
16 demands that you provide it. Waste heat from the nuclear
17 powerplants poses a risk because the full consequences
13 are not known. If you cannot resolve this question around
19 your conference table and move on to deal with others
20 equally or more serious, then the public must turn
21 elsewhere.
22 You must act now, or I fear that the public will
23 turn to the courts and to interventions in licensing
24 procedures, at great cost to everyone.
25 Thank you.
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1 R. Cramer
2 MR. STEIN: Thank you, (Applause)
3 MR. BLASER: Mrs. Botts, the next two speakers
4 you had requested a place for them — John Landrum and
5 Miss McKee.
6 If I may, since you are relinquishing — since
7 the Federation has been represented, I would like to move
8 on to some others. May I?
9 MRS. BOTTS: Right.
10 MR, BLASER: The next speaker whom we have
11 received a request from was Peter Martinez representing
12 a Committee against Pollution.
13 MR. CRAMER: I will speak for him.
14 MR. BLASER: You will speak *for him. That was
15 my question. Fine.
16
17 STATEMENT OF ROBERT CRAMER, CAMPAIGN
1& AGAINST POLLUTION, CHICAGO, ILLINOIS
19
20 MR. CRAMER: My name is Robert Cramer. I am
21 here on behalf of the Campaign Against Pollution, CAP, in
22 Chicago.
23 We would, first of all, like to register an
24 extreme objection to the fact that the public has been
25 forced to remain here through all of the dickering over
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: 232
R. Cramer
2 specific technical points today and not given the same
•5 consideration as representatives of the AEG and the Federal
••' i
4 Power Commission who came here to represent industry's
5 position. We have a number of people herei as you know,
6 Mr. Stein, who are not paid, as they are to come represent
7 interest's at this morning's session. And we would like to
ask that those who don't get on today will be on first
9 thing in the morning.
10 The major difficulty in preparing a response to
11 Mr. Ruckelshaus' proposal this afternoon is to attempt to
12 say imaginatively one more time what our organization and
many others have said for so long—that no one — most
14 especially a private corporation — has the right to
15 use a public lake to dump their wastes, thermal or other-
16 wise, especially where there is abundant evidence that
17 waste would do major damage to that lake.
In the last few weeks, two major power companies
19 have agreed to install closed cooling systems to prevent
20 the damage of their thermal waste to the lake. It is par-
21 ticularly an light of these decisions that we must be quite
22 clear that any proposal short of one which would require
23 closed cooling systems on all of the giant thermal polluters
24 is a sellout to the corporate interests who desire so much
25 to be free from public regulation in these matters.
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1 ! R. Cramer
i
2 | With the agreement of NIPSCO and the Consumers
3 Power Company to install closed systems, it is the Common-
4 wealth Edison plant which is remaining the most outstanding
5 potential thermal polluter to the lake.
6 Now, we feel that this plant must not be allowed
7 to open unless it has a closed cooling system, and that
8 any proposal short of that is unacceptable,
9 Apparently Mr. Ruckelshaus has decided to yield
10 to the considerable pressure of many public groups who
11 have supported the general position that closed cooling
12 systems are necessary.
13 We must laud this recommendation as a major
14 victory for those who have demanded tough regulations and
15 responsibility to the people. We strongly urge that the
16 standard be adopted by the full Conference and enforced
17 immediately, and that it be amended to prevent plants under
1# construction from opening without closed cooling systems
19 if they violate the regulations.
20 Now, this talk about letting plants open without
21 cooling facilities simply provides another loophole whereby
22 the power interests can stall just that much longer,
23 Once a utility gets a plant on line, it's got all the clout
24 or power, if you will, because you are not going to close
25 down that plant if it fails to comply. The only lever we
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1 R. Cramer
2 have is to prevent it from opening until it does install
3 such a cooling system.
JL Now, we have heard all sorts of tough policy
5 recommendations before. We started off with Nixon Adminis-
5 tration's now famous 1° thermal limit grandstand play of
7 May 7, 1970, and the people of this area have witnessed
3 a show, on the part of the Federal and State regulatory
9 agencies, that has resembled at least a bad rendition of
10 the Keystone Cops ever since, except that the issue is much
11 more serious than that. We have seen delay after delay.
12 We have witnessed Mr0 Stein's backroom shenanigans in
13 Grand Rapids, where he attempted to back down from the
12, 1° recommendation behind closed doors0 We were subjected
15 to the utmost in reassurance when we expressed fears last
16 November that the appointment of the new Technical Committee
17 was another stalling tactic0
m Now, almost 5 months later, we have an unclear
19 report from the Technical Committee, and we finally have
20 another recommendation — a brand new one — from the Federal.
2i Government. I might note that after almost 5 months of
22 that Technical Committee deliberation, the report of that
23 committee has now been scrapped for all practical purposes*
2^ As a result of this experience! we demand no
25 more stalls. We demand immediate action by this Conference,
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-. R. Cramer
2
4
5
5
7
9
10
11
12
16
17
19
20
2i
22
23
24
25
and immediate enforcement.
I must add several further gannets. As residents
of Illinois, and especially in light of the NIPSCO and
Palisades decisions, CAP is shocked that the Illinois
Pollution Control Board has not taken a tougher position
on this mattero (Applause)
The Illinois Pollution Control Board has had the
audacity in the past several weeks to propose that Edison
be allowed to operate their Zion plant using 3 billions of
gallons of water a day — of our lake water — to do their
cooling, especially at the same time when they realize the
danger of thermal pollution to such an extent that they
have proposed a moratorium on construction of all further
nuclear plants on the lake. A deal like that with Edison
simply cannot be tolerated* Edison will yell and scream
that at this late date it would cost them a fortune to
backfit the plant with cooling equipment — and with
inflated figures, of course.
Well, if it will, it is their own fault for
having continued the construction on the old blueprints
for over a year and a half while they have dragged out a
decision on the thermal regulations precisely so that they
could cliam it would be impossible for them to comply.
In the light of Ruckelshaus and the albeit unclear
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1 R, Cramer
2 report by the Technical Committee, we find it completely
3 unacceptable the Illinois Board has taken the position it
4 has, and we might add that we have reason to believe that
5 if the State does not concur and if other States do not
6 concur with a strong Federal proposal, that it may be years
7 before the Federal Government is able to enforce any tough
g standard on any of these companies. And I would like to
9 get back to that and ask a question regarding it at the
10 close of my remarks,
11 Now, as I said, we desperately hope that the
12 Federal Government will assume its responsibility in the
13 area of thermal pollution, but we must make clear that
14 regardless of what you do here today or tomorrow, so far as
15 the people are concerned, the plant at Zion will not go
16 into operation without a closed cooling system. Our group
17 and others will tie it up in court, in regulatory agencies,
18 We are going to fight Com, Ed. *s proposed 1001 percent
19 rate increase. No company that is not facing its environ-
20 mental responsibility deserves more money, and we intend to
21 see that they don't get it. We will be initiating direct
22 action against this company,
23 Let me say again: That plant won't open without
24 a closed system. And I might add that CAP and many other
25 groups are becoming increasingly alarmed concerning all of
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the safeguards of nuclear plants, and we intend to see that
EPA and the Illinois Pollution Control Board begin to look
further into this whole matter and in particular GAP will
be sponsoring a series of rallies concerning nuclear plant
safety with Senator Mike Ravel who will be here at our
invitation April 22-23. Senator Ravel, as you may know, is
a prominent proponent of a 5-year moratorium on the con-
struction of all nuclear plants.
Let me close by saying one further thing. The
people of this Nation are tired of corporations that think
they have the right to run the government because they have
a lot of money. But the time has come for Edison, at least
so far as the Zion plant is concerned, to face the public
music. We are going to see that it faces that music, and
we hope that the Federal and State Governments will begin
to take their responsibility seriously.
Thank you very much. (Applause)
I would like to add one question, Mr. Stein and
Mr. Mayoi Is it not the case that if the States do not
comply to bring their standards into compliance with the
proposed Federal regulation even if it is passed by the
Conference that it could take many years to enforce on any
individual company the proposed regulation? And if that
is the case, is this not just a charade?
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1 R. Cramer
2 MRo MAYO: As I mentioned in my comments following
3 the reading of Mr, Ruckelshaus' letter this morning, we want
4 very much to approach theestablishment of standards and
5 the establishment of adequate controls on those plants not
6 yet in operation on a most cooperative basis. But that
7 there should be no question at least so far as the plants
& under construction are concerned that the EPA intends to
9 employ whatever opportunities are available to it in the
10 way of administrative processes or legislative authorities
11 to work toward the establishment of those controls, whether
12 we can approach it cooperatively with the States, or whether
13 we must act unilaterally in whatever of these administrative
14 procedures are available to us, and if we need, then, to go
15 without the States,
16 From the standpoint of the standards, the Federal
17 Water Quality Act prescribes the procedures that are neces-
18 sary for the Federal Government to promulgate standards
19 and to have them adopted in the absence of a collective
20 approach on the part of the States, This is a long
21 procedure,
22 MR, CRAMER: It is a long procedure. And if Mr.
23 Currie —
24 MR. MAYO: Currently before the Congress is
25 proposed Federal legislation to amend that procedure
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considerably and shorten the time. But in the absence of
the passage of that legislation, the procedure is, in
fact, a fairly long one that requires perhaps a minimum of
a year or a year and a half depending on how drawn out the
procedures are.
MR. CRAMER: So that if Mr. Currie and the
Illinois Board refused to bring their standards into com-
pliance with the Conference standards, they would be in
effect preventing the enforcement of these standards for
at least one and a half to two years. Is that correct?
MR. STEIN: No, I don't think you are looking at
this correctly.
You have several routes to go. We, at least,
have as many routes as your private interest group or
private citizen's group has to go before a regulatory agenc|r
as an intervenor or go to court under the River and Harbor
Act, to protect something. As a matter of fact, we have
more routes.
Now, the question of how long it will take is
another question. The standard route, obviously, is
governed by statute. But we are right now and it is a
matter of public record — and I think" we are in litigation
so I won't want to speculate or discuss the case too
much — right now — we have a case filed against the
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1 . R. Cramer
2 Florida Power & Light Company. This case is before the
3 courts. That may take some time before the courts. But
4 in the same way as any citizen group or anyone takes
5 something before the courts, until the situation is
6 resolved, perhaps the plant won't open until there is a
7 court decision.
I would guess that we can get to the courts
9 in any case at least as fast or faster probably than any
10 citizen group or private citizen can get to it. We may
11 not be able to use the standards but we surely can go to
12 court. If you have looked at our latest cases, you know we
are going to court.
By the way, as you may know, the River and
nc Harbor Act of 1#99» which is being used now, covers the
discharge of all wastes. Although we are concerned largely
with industrial wastes, it says all sorts of wastes except
liquid wastes from streets and sewers. One of the
questions which has come up in that Florida Power & Light
20 case is whether the heated water coming from a powerplant
is, in fact, discharged. You get them under the 1#99 Act.
22 The court has not ruled on that question. I don't want to
23 surmise whether they will rule on that or if the case will
be solved before that. But I think you can expect us to
25 take fairly rapid action.
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MR. CRAMER: Will you assure the rest of the
people here who have not been allowed to testify today
that they will be allowed to testify first thing tomorrow
morning?
MR. STEIN: Now, look. I think we are trying to
approach this in a gentlemanly way.
MR. CRAMER: Indeed.
MR. STEIN: I have tried. By the way, I urge
that the citizen's groups be put on as early as possible.
Our present plans call for the citizens to go
°n first. We are making every effort to do, so. This is
the way we are proceeding and will continue to proceed when
we convene tomorrow morning.
MR. CRAMER: Thank you very much.
MR. PURDY: I have a question.
This relates to your statement where, on one
hand, you seem to applaud the decision of Consumers Power
to backfit their Palisades plant and install cooling
towers, the closed cycle system. And, as I understand this
agreement, they will move into the, say, low operating
testing here in a short period of time, and from there, if
this proves successful, to go into the operating. Yet
the cooling towers will not be installed as they use the
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1 R. Cramer
2 natural draft for another 42 months.
3 But with respect to other facilities, you seem
4 to indicate that you were in complete opposition to their
5 going into operation even though they might agree to put
6 in cooling towers within a specified period of time. This
7 seems to be a little inconsistent. I am wondering —
8 MR. CRAMER: Well, we applaud the decision of
9 Consumers Power is better than nothing. We certainly would
10 have preferred had they installed cooling facilities prior
11 to the time they open their plant. I would note that, of
12 course, Consumer has agreed to do that in a specified
13 amount of time. I think that a really unfortunate situation
14 would occur in .the event that we allow an outfit to open
15 up without at least gaining a commitment from them — a
16 written commitment — that they would, in a specified
17 period of time, have installed this equipment. But I
IS think that the optimum situation would be to prevent any
\
19 of them from opening until they have cooling facilities.
20 MR. PURDY: I can agree that this might be the
i
21 optimum, but I was wondering if your group is totally
22 opposed to the operation if there is a binding agreement
23 that these facilities will be installed within a specified
24 period of time.
25 MR. CRAMER: We feel, in the case of the Zion
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2 plant, that it is perfectly feasible that Commonwealth
3 Edison should be able to install cooling facilities, if
4 they begin immediately, prior to the time when they
5 necessarily have to open that plant, and we are going to
6 press for that. In the event a situation develops where
7 we can reach a compromise agreement, I am sure we would be
g willing to discuss it. But I think that is what we ought
9 to press for as a representative of the public interest.
10 MR. BLASER: The next speaker is David Comey,
11 Director of Environmental Research, Businessmen for the
12 Public Interest.
13 FROM THE FLOOR: Mr. Comey had to go to Racine
14 to deliver a lecture on nuclear safety and he asked if
15 he could be called in the morning.
16 MR. BLASERi Shall we break now? Or do you want
17 to — I am willing to stay if you want —
IB FROM THE FLOOR: I have asked to speak, sir.
19 I filled out a card.
20 FROM THE FLOOR: I wrote a letter.
21 FROM THE FLOOR: Could I suggest that you ask for
22 those people who cannot come back tomorrow —
23 MR. STEIN: Mrs. Botts, you took the words right
2^ out of my mouth. I am sorry I can't have you sitting up
* here with me.
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1 Mrs. H« Sherman
2 How many people just can't come back tomorrow?
3 All right. There are two,
4 MR. BLASER: How about ladies first— even
5 today — Women's Lib. notwithstanding.
6
7 STATEMENT OF MRS. HARRIET SHERMAN,
8 CITIZEN, CHICAGO, ILLINOIS
9
10 MRS. SHERMAN: My name is Harriet Sherman. I
11 am a citizen-taxpayer. I am on no foundation. I am not
12 with any lobbying group, registered or otherwise. I am
13 just a citizen, on no payroll.
14 The points of view made by a citizen might seem
15 irrelevant or inappropriate to the technicians and poli-
16 ticians who set up Conferences such as this one, Never-
17 theless, the public has the right to present what it con-
l£ siders important, and sometimes it is the responsibility of
19 the politicans and technicians to adjust their agendas to
20 include what the public feels and needs to be said. The
21 matter at issue is larger than plumes and B,t«u,'s, larger
22 than the pollution issue.
23 It has to do not really with the electrical
24 power structure of the country but the social power structure
25 as Well. To limit the discussion to technical points
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1 Mrso H, Sherman
2 conceals the fact the public rights are being taken from
3 them and handed to those few whose social power is increased
4 by the decisions of Conferences such as this one,
5 Who will hear the public in this matter? The
6 Atomic Energy Commission casually tosses out a citizen!s
7 statement for the margins might be half an inch too small
3 or it is not double-spaced, which costs the citizen extra
9 stencils to have made to double-space petitions.
10 The press, whose owners have interlocking
11 interests with the power companies, ignore what does fit
12 their interests,
13 Who are the scientists and technicians who set
14 the so-called safety standards? How many of them are past
15 or present employees of the power companies? How many
16 are employees of universities whose board of trustees are
17 men such as Morgan Murphy, Thomas Ayers and others — these
1$ are local people; I am sure Michigan and Indiana have
19 their own locals — who are the directors and officers of
20 the power companies,
2i Who are the power companies? All this fuss about
22 1° F»> out how much fuss about the fact that these important
23 public utilities are owned by hidden trusts? Start research
24 ing in your respective States, Trusts that are masks for
25 what? In some cases, foreign cartels. The public has the
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1 Mrs* H. Sherman
2 right to know who is benefitting from these decisions of
3 yours. Who is it that controls the utility that is critical
4 in our daily lives?
5 i Just yesterday the news reported Commonwealth
6 Edison's concern that there will be brownouts in Chicago
7 if the No. 3 Dresden plant doesn't get into operation soon*
g This so-called news report is obvious blackmail. But if
9 Edison is not above blackmail, what else will they do to
10 us through their control of more and more power? Last
11 year they turned off electric power in Chicago to contract
12 home buyers though these home buyers were not in arrears
13 on their bills. It was apparent then that Edison was using
14 its weight to crush the resistance of contract home buyers.
15 How far will they go in time to come?
16 I am not going to ask Mrs. Botts to read this*
17 I am putting into the record ray petition before the AEG
1$ and I am .going to read it myself because I think Mrs. Botts
19 would choke on it.
20 I contend — this was my fifth contention before
21 the AEG when I requested to intervene a month ago — I
22 contend that not enough study regarding site, facing
23 navigable waters of the Illinois River where the confluence
24 of the DesPlaines and Kankakee join, and construction of
25 this plant by Commonwealth Edison and Bechtel Industries.
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Mrs. H. Sherman
2 Also the coincidence of the Chicago & Illinois Midland
3 Railroad paralleling the below mentioned nature reserve.
This reserve is called Goose Lake Prairie. A couple of years
5 ago Mrs. Botts was all over the map asking everybody to
6 push Goose Lake Prairie, and we spent —- the State of
7 Illinois — $2.5 million barely a year and a half ago.
Yes, Mrs0 Botts, the Open Lands Committee. We spent $2.5
9 million to acquire this Goose Lake Prairie, right next to
10 Commonwealth Edison's Dresden plant. Why didn't you tell
11 us that, Mrs. Botts? There is no sign where the prairie
12 really is. You would have to go by the tracks of the
13 Commonwealth Edison Midland Railroad to find it. You have
14 done a great disservice to the citizens. Maybe something
15 will happen — maybe an investigation. It is a real goosei
16 (Laughter) This area is the last of the so-called original
17 prairie in Illinois, a heritage of all of the citizens.
That is what the propaganda from the Open Lands Committee
19 told us.
20 I am just ending this now, but I am putting this
21 into the record. It is a big joke, especially for the
22 taxpayers. It is a sad situation.
23 MR. STEIN: Thank you very much.
24 (The document above referred to follows in its
entirety.)
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In the Matter of
Commonwealth Edison (Dresden Nuclear power Station Unit 3)
Requesting leave to intervene of Harriet Sherman
Docket No, 50-249
NOTICE
Tos Mr. Stanley To Robinson Jr0
Office of the Secretary, U0 S. Atomic Energy Commission
Washington, D.C, 20545
Mr. Joseph B. Knotts, Jr.
Counsel for the AEC Regulatory Staff,
U. S. Atomic Energy Commission, Washington, D» C. 20545
Aigie A, Wells, Esq.
Chairman, Atomic Safety and Licensing Board panel
U.S. Atomic Energy Commission, Washington, D.C* 20545
Mr. Leroy Stratton
Bureau of Radiological Health,
Illinois Department of public Health
Springfield, Illinois 62706
Mr. Arthur C. Gehr, Esq.
Isham, Lincoln & Be ale
One First National plaza, Forty-Second Fllor
Chicago, Illinois 60670
Mr. Byron Lee, Jr., Assistant to the president
Commonwealth Edison Company
P.O. BOX 767, Chicago, Illinois 60690
Mr, David Dins more Comey, Director, Environmental Research
BPI Action Fund, Inc. - Suite 1001
109 N. Dearborn, Chicago, Illinois 60602
Mr. Gordon B. Sherman, president
BPI Action Fund, Inc., Suite 1001
109 No. Dearborn, Chicago, Illinois 60602
please take notice that on • I am
sending the Atomic Energy Commission, 20545, Washington, D. C.,
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Secretary, to be filed, this Notice, Affidavit and attached
petition with exhibits, copies of which are herewith served upon you.
Harriett Sheridan, citizen, pro se,
7110 So. Crandon Avenue
Chicago, Illinois 60649
t-Laza 2-3083
Subscribed and sv/orn to before lue
tiiis day of , 1971.
Notary i- uolic
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STATE OF ILLINOIS ) SS^_ AFFIDAVIT. including PROOF OF SERVIC
COUNTY OF COOK )
Harriet Sherman, being first duly sworn on oath, deposes
and says:
L That she is the one who is asking for leave to appear and
intervene in this matter, that the petition and exhibits attacheded
hereto is by her subscribed, that she believes the facts contained
therein to be correct and true, that the other matters contained
therein are matters of record or of law, and that in either case
she believes them to be true.
2, That she served the within Notice and this Affidavit
together with petition on those named by mailing copies of the
same to attached list, duly addressed, sealed and stamped
envelopes, and depositing in U; S; Mail Box in front of post Office,
2207 E. 75th St., Chicago, Illinois on January 25, 1971.
Additional copies have been sent to DepU of Transportation^
U.S. Dept. of Health, Education & Welfare. U.S. Dept. of
Defense, the Office of the president of the United States- William
Scott, Attorney General of Illinois; John Mitchell, Attorney General
of the United States; etc,
Harriet Sherman
Subscribed and sworn to before me
this day of , 1971.
Notary Public
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BEFORE THE ATOMIC ENERGY COMMISSION
PETITION TO INTERVENE IN THE GRANTING )
OF LICENSE TO COMMONWEALTH EDISON )
COMPANY OF CHICAGO ) Docket No.
) 50-249
REQUEST FOR LEAVE TO FILS APPEARANCE )
OF HARRIET SHERMAN: Citizen, Taxpayer, J
pro Se and REQUEST FOR COMMISSION )
INVESTIGATION* )
Now comes Harriet Sherman, pro se, and requests the Commission
1. Leave to intervene in this hearing.
2* Request this Commission to investigate in the
above as hereinafter set forth.
3. That there be open hearings for press and public.
Before stating contentions 1 wish to ask that one of the Commis-
sioners, Mr. Clarence E. Larson, disqualify himself, inasmuch
as he is president of the Nuclear Division, Union Carbide Co,, 270
Park Ave., New York, N. Y., according to Standard fcpoor's
Directory and his immediate superior would be Mr. J. Harris Ward,
Director of Union Carbide and Chairman of the Board of Common-
wealth Edison of Chicago, the applicant, thus creating a conflict of
interest.
1 would like to have information regarding Mr. James T. Ramey's
background in addition*
Mr. Wilfred E. Johnson, one of the Commissioners has worked
for General Electric in the past. I hope that this will not allow
for undue favortism to Commonwealth Edison inasmuch as they have
a working agreement with Edison at the Dresden plant.
In addition, I wish to speak for my fellow citizens and protest
that a great burden is put upon the resources and educational back-
ground of any citizen daring to protest the actions of his government.
Questions of his interest in a subject by the government (See Exhbibit
A - Budget of the U.S. Govt., AEG) should not even be asked.
It is enough that the citizen is sufficiently aware and wants to know
what is happening. Unnecessary hardships are being placed against
the citizen who is taxed and forced to support research, buy expen-
sive typewriters, copying machines, paper, etc., and then forced
to spend additional sums asking the government what they are doing.
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I support an educational system that does not include law as a
necessity for every citizen. If the government by innuendo in its
regulations and rules literally forcing citizens to support an addi-
tional private burden; it means no citizen can any longer afford to
go to the government or must go to a profession that some consider
a*FIFTH COLUMN within the structure of government*
I—self-serving
Finally, this petition originally was presented to your Commis-
sion, sent certified mail as of Dec. 18, 1970. After checking the
certified return cards, I find that the mail was received by your
Commission and Regulatory Staff on Monday, Dec0 21st and Tuesday,
Dec. 22nd respectively, and signed by a Mr. Sellers and Mr. Sachs.
Mail is generally considered filed the moment it hits the box at the
Post Office.
I note that though my petition was submitted before the December
20th deadline, the AEC did not take action on it until January 8, 1971,
because of what they called "administrative oversight. " In the mean-
time, the AEC granted Commonwealth Edison permission to load -
radioactive fuel and "perform certain tests" at the Dresden plant.
This action was taken in agreement with Businessmen for the Public
Interest, a private group which has also filed a petition to intervene.
(See Exhibit B).
STATEMENT
Harriet Sherman states that she is a citizen of the United States
and a resident of Cook County, Illinois, she is a taxpayer and an
occassional researcher into court corruption and judicial conflicts
of interest.
She states further, as follows.
I recently became aware of certain discrepancies regarding the
licensing of the Dresden nuclear power plant, on Route 66, near
Morris and Dwight, Illinois. Upon exploring certain facts on my own,
it became apparent to me that neither the public's interest nor mine
has been adequately safeguarded in the licensing and the further pro-
posed licensing of Commonwealth Edison Company to operate this
atomic facility.
My contentions, with supporting exhibits, are submitted below.
Further information is available.
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CONTENTIONS
1, I contend that inadequate publicity concerning previous hearmgs
prevented adequate protection to the health and welfare of my fellow
citizens from the possibility Of dangerous nuclear emissions from
this plant.
A children's hospital, the William Fox Center, and a women's
reformatory are located at Dwight, in Livingston county, downwind
from the Dresden plant. Although these children and the women
prisoners are dependent upon public officials for their safety, there
was no representation from Livingston county at previous hearings
on this matter. Further, these hearings were so poorly publicized
that the head of the Fox Center told me, in a telephone conversation,
that he did not even know about them.
(In the case of the women prisoners, the AEC must be concerned
that i\ does not violate their constitutional guarantee against cruel
and unusual punishment, by permitting them to be kejfrt in a
declining environment.
2. The Union Stockyards has announced that it will move to a
site which is less than 10 miles from the Dresden plant. The
Campbell Soup Company processes both asparagus and tomatoes in
the area. The counties adjacent to this plant, including Grundy,
Livingston and LaSalle counties, are major sources of grain,
poultry, cattle feed, dairy products and other agricultural produce
for the Chicago market and other parts of the country.
Certainly the public which will purchase the meat and food
products from these counties is entitled to an environment which
does not contaminate the food before they receive it» In previous
AEC hearings pertinent to the Dresden plant, assuarances of
safety were given by university scientists whose testimony must
be . impeached on the ground that these scientist s are in a
practical sense the employees of the party seeking the license.
The annual report of Commonwealth Edison for 1969 notes, for
example, that one of its directors, Lowell T. Coggeshall, is a
trustee of the University of Chicago. Standard biographical
references indicate that he is also a vice president of the University
of Chicago, Among >._ .-.: the other officers and directors of this
company, J. Harris Ward is a trustee of the University of Chicago..
Joseph L. Block, Albert B. Dick III, Brooks McCormick, and
Morgan Murphy are trustees of the Illinois Institute of Technology.
Mr, Murphy is also a member of the Citizen's Board of Loyola
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University, and John Andrew Barr is a trustee of Northwestern
University,
I contend that professors and students whose livelihood and
careers are in the hands of trustees, who are at the same time
applicants for the license in question, can not be regarded as
impartial witnesses.
3. It came to my attention last fall that members of an organiza-
tion known as the Southside Contract Buyers League were being
harrassed in various ways, apparantly in order to force them to
leave the homes which they had been buying under contract arrange-
ments with Universal Builders, Inc. and its subsidiary, Chatham
Town Homes, Inc. Some of these contract buyers had been evicted
from their homes and had returned to them, but some of the others
had not been evicted at all. In either case, however, they', were
subjected to harrassment, such as the removal of plumbing from
their homes, the smashing of furniture, mysterious knockings
upon their windows at night, telephone threats, etc. These things
were obviously intended to intimidate the contract buyers.
In my capacity as a civic researcher, I had occasion to visit
many of the contract buyers and to attend their meetings. I saw at
first hand the results of this harrassment--broken windows,
kitchens from which sinks had been torn, the mounts from which
gas meters had been removed by unidentified strangers, etc. I was
told by these contract buyers that their electrical service had been
arbitaarily discontinued by the Commonwealth Edison Co., although
they were not in arrears in their bills. They regarded this--and
rightly so, I believe—as part of the harrassment to which they were
being subjected.
Later, on Aug. 25, 1970, various members of this group filed
suit in the Circuit Court of Cook County (70C 12091), charging that
unknown to them, the Catholic Archbishop of Chicago was the bene-
ficial owner of the homes they were seeking to purchase.
The suit, still pefclnlpig, also charged that a Catholic organization,
the Gamaliel, Foundation, while purporting to support the Contract
Buyers, was actually "attempting to prevent losses to contract
sellers and to their business associates namely defendant Catholic
Bishop of Chicago."
Named also as a defendant was one Gordon Sherman, who is known
to the Atomic Energy Commission in his role as head of the Business
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255
Men for the public Interest. Inc., an intervener in this hearing.
The suit charged that Gordon ,Sherman had "used the defendant
Gamaliel Foundation and other means as a conduit, funnel, or
front, to convey money to some of the defendants... all in respect
to the matters herein described, to cool off and compromise these
plaintiffs' rights, and to attempt to force the resumption of payments
by members of SS CBL to the contract sellers. "
It should be noted here that both the Catholic Archbishop of
Chicago and the Gamaliel Foundation, which was established and
operated by the Jesuit Society, are subject to the spiritual anc'
practical leadership of pope Paul IV, "Supreme Pontiff of the
Universal Church" and "Sovereign of Vatican City," as he is des-
cribed in his official title.
It should be further noted that the president of the United States
last year appointed Henry Cabot Lodge Jr. as the official represen-
tative of the U* S. government to the Vatican government, of which
Pope Pius VI is, as pointed out above, the sovereign head.
Thus, in effect, the Catholic Archbishop of Chicago is the agent
of an alien or foreign government.
I submit as an attached exhbit, a reproduction of pp 94-95 of the
book, "The Vatican Empire, " by Nino JLo Bello, (pocket Book edi-
tion, 1969), wherein there is reference to the Moatecatini Co., which
is "bound to the Vatican with hoops of steel," and to the Edison
Company, with which it was merged to form Montecatini-Edison.
It is further described in this book how the Vatican state, through
its vast financial investments has obtained control of various public
utilities, including electric utilities, in Italy a^d other countries.
The acquiring and control of these utilities by the Vatican state
is usually done in a concealed manner, so that it is not publicly
known that the company is in fact owned or otherwise dominated by
an alien or foreign interest, that is, the Vatican state and its agents.
Often this control is achieved through the Vatican's so-called "Uomini
di Fiducia," a foreign term meaning, "men of Trust," who serve as
its nominees on the boards of directors of such firms.
An article appearing in the Chicago Daily News, Dec. 31, 1970,
headlined, "Catholic Assets Here Listed at $85 Million, " refers to
a financial report which was recently published by the Catholic
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Archbishop of Chicago. In this article it is stated that.
"The report listed security investments of the archdiocese as
worth almost $30 million last June 30* *'... and that "Archdio-
cesan investments are handled by the investment counseling firm of
Stein, Roe & Farnham, which last June 30 had placed almost: $9
million in common stocks, $8.2 million in U.S. government secur-
ities and almost $8 million in corporate bonds."
Thus it is known that Catholic Archbishop of Chicago, au agent
of the Vatican state, has invested millions of dollars in unidentified
corporations.
I submit that if these investments have been made in the stocks
and bonds of the Commonwealth Edison Co., that it would follow in
logical sequence that the Catholic Archbishop of Chicago would
thereafter use his influence as an owner of the bonds and shares to
elevate his "Uomini di Fiducia" to the board of directors of Common-
wealth Edison Co. and thus control it in the interests of a foreign
state.
I further note that under U.S. Code Title 42 #2153 and Title 42
#2133, that a license to operate a nuclear electric plant may not be
issued to an alien or foreign-controlled company.
I contend, therefore, that it is the obligation of the AEC to in-
vestigate the ownership and control of the Commonwealth Edison
Co,, through the hearings in which I seek to intervene, before
issuing any further licenses to this company.
4. It is primary to the interests of the people of Chicago that no
agency of the government, civil or military, and that no private
group of individuals, such as the directors of a corporation, for
example, should ever be in a position to use electrical power, a
vital essential of modern urban life, as a weapon of control over
the people.
It is contended here that such a possibility exists C. in the pre-
sent licensing situation, and I arn seeking to intervene ia this
hearing because, quite frankly, I do not trust you. On the contrary,
there is a seeming appearance of collusion in this respect between
the AEC, the Commonwealth Edison Company, and the Business-
men for the Public Interest, Inc.
This doubt--which I believe is shared by many of my fellow
citizens--can only be reduced if there is a public airing of the
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matter and a cynical public observer, such as myself, is present
not merely to observe your dealings, but with full right to delve
into all aspects of your operations and organizations, as they ap-
pear to threaten the public safety.,
Briefly, in support of my contention, J offer the following.
a. The Atomic Energy Commission was born in the wartime
secrecy of atomic bomb development and production, aud one of its
major functions today is the gathering of intelligence regarding the
military nuclear capacity of other nations. Furthermore, as shown
in any edition of the Congressional Directory, a publication of the
United States printing Office in Washingto,n, D.C., the Atomic
Energy Commission includes a Division of Intelligence, a Division
of Military Application , and a Military Liaison Committee.
The Atomic Energy Commission, therefore, is obviously not a
purely civilian agency, but one with military overtones and military
interconnections.
It is wortth remembering that only within recent weeks, the
Chicago news media have carried reports of spying upou noted local
public figures by military intelligence agencies.
As for the Commonwealth Edison Co., I point to the following.
testimony
a. jn recent, little-publicized--. -:.. ./ .before a Congres-
sional committee, a spokesman for the Electronic Industries
Association, speaking against repeal of the Emergency Detention
Act of 1950, said "Detention of security risks whether Communists,
radical members of the so-called 'New Left,f or whoever, in time
of dire need, we believe, is a proper course of action. " (See Chicago
Sun-Times, June 22, 1970, p. 64). I believe that Commonwealth
Edison Co. is closely linked to the Electronic Industries Association,
either through its own membership, or for example, through its
partnership with the General Electric Co. at the Dresden plaat.
b. As cited in my third contention, in the instance of the south-
side contract home buyers, this company has already shown a
willingness to use its control of electrical service as a means to
force Chicago citizens into desired patterns of political and economic
behavior.
c. It must be noted, too, that William Ayers, the son of Thomas
G. Ayers, president of Commonwealth Edison, has been identified
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in the press as a leader ofc the so-called "Weathermen", aa organ-
ization which is regarded by many thoughtful people as a group
whose purpose is to create incidents such as the bombing of public
places (perhaps including electrical plants), which will bring about
repression of the people by the government.
It is strangely coincident that William Ayers was a close associ-
ate of one Diane btightoa of Dwight^ Illinois, who was supposedly
killed last year in a Weathermen "bomb-factory", all of this ac-
cording to a most questionable series of articles appearing in the
Chicago Daily News last September. (See attached exhibits). The
Chucago Daily News is a publication owned by relatives of the
Oughton family.
It is further strangely coincident that Diaae Oughton is the daugh-
ter of James Oughton, president of the First National Bank of
Dwight (which adjoins the Fox Childrens Center), head of farming
a nd dairy corporations in the area downwind from the Dresden
plant, and an individual whose financial future is clearly tied with
the development of the area (as through the location there of
factories aad refineries, near a nuclear power source).
d. Furthermore, as indicated ia attached reproduced pages
from the book, "Captive City" by Ovid Demaris, the Commonwealth
Edison Co. has been closely associated with coal companies which
.... Demaris describes as crime-dominated. Along this line,
I make reference also to Morgan Murphy Jr., son of a Common-
wealth Edisoii director, who is at the present time a business partner
of one Thomas A. McGloon, aa owner of the Civic Center Bank of
Chicago, along with such crime figures as Joha D'Arco, John p.
Kringas, and Anthony Fellichio, and who have been so identified in
court records.
It appears to me that a company, such as Commonwealth Edison,
if it is intertied with crime, is subject to blackmail pressure by
federal authorities seeking at some time to use electrical power to
suppress the rights and rightful actions of Chicago citizens.
e. In reference to Gordon Sherman, head of Businessmen for the
public Interest, Inc., it has already been pointed out that he has
been named in a court suit, which I believe has merit, as a collabor-
ator with the Gamaliel Foundation in attempting to subvert the inter-
ests of the Chicago coatract home buyers while acting in the guise of
a friend. If this is later shown to be true, then, of course, it would
not be unlikely that his role is similar here, that is, falsely wrapped
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in the mantle of a protector of the public, whereas he might in
fact again be "working both sides of the street," as stated in the
court action.
WE WANT NO POLITICAL BLACKOUT OF ELECTRICAL
POWER IN CHICAGO '.
5. I contend tiat ^ot enough study regarding site (facing
navigable waters of the Illinois river) and construction of this
plant by Commonwealth Edison and Bechtel Industries. Also the
coincidence of the Chicago & . . Illinois Midland Railroad
paral .elling tae below mentioned aature reserve. I contead that
with the acquisition of Goose Lake prairie by the taxpayers of
Illinois for the sum of $2, 000, GOO one aad a half years ago, tnis
area will become a real goose to the citizens by prematurely
killing off the last original prairie ia Illinois (a heritage of all
the citizens). Much rare flora and fauna will be irretreivaJjiiy
lost.
CONCLUSION
The circumstances of all this require an investigation.
Further, the public interest requires such an investigation.
WHEREFORE, Harriet Sherman, as ' aforesaid asks for
an investigation, and for sucn other procedure as the public
interest demands.
/s/ Harriet Sherman , pro se,
7119 S. Crandoa Avenue
Chicago, Illinois 60649
PLaza 2-3083
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Bertoncini
2 MR* BLASER: There is a gentleman who is not
3 going to be able to be here tomorrow who is able to speak
4 now.
5 DRo BERTONCINI: I apologize to the Board* I
6 only have ten copies of this statement,
7
STATEMENT OF DR* PETER BERTONCINI, THE
9 COMMITTEE FOR ECOLOGICAL ACTION,
10 BELLWOOD, ILLINOIS
11
12 DR. BERTONCINIt I am Dr. Peter Bertoncini. I
13 am employed at Argonne National Laboratory. I am a chemist*
I am not an expert in nuclear power generation.
At this time, I am making a statement as a private
16 citizen as a member of a Committee for Ecological Action.
17 We have a short summary at the beginnings The
Committee for Ecological Action recognizes there exists a
19 controversy in the scientific community over the effects of
20 hot water discharges on the Lake Michigan ecosystem.
21 Because of this controversy, we take this opportunity to
22 state our basic opposition to the use of Lake Michigan as
23 a laboratory to study the effects of thermal pollution as
24 has been suggested by representatives of certain power
25 companies.
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1 j P. Bertoncini
2 We appreciate the efforts of the power companies
3 to avoid at all costs unnecessary capital expenditures.
4 However,, we feel that such a short-sighted goal should #ot
5 be permitted by the U.S. Government in view of the obvious
6 financial benefits to be realized from a viable Lake
7 Michigan; particularly, since the present state of the art
# of closed cycle cooling system technology is such that it
9 is unnecessary to use once-through cooling at any existing
10 or planned source of thermal discharge to Lake Michigan.
11 While I personally agree with the representatives
12 of certain major power companies that nuclear power is the
13 answer to our future power needs, a view that is not shared
14 by everyone in our organization, I would like to state that
15 unless more concern is shown by government and industry
16 alike to the undesirable side effects of the tremendous
17 quantities of heated effluent which is a by-product of
IB power generation I will be opposed to each and every nuclear
19 and fossil fuel plant on the lake.
20 As we stated in our abstract, we propose, closed
21 cycle cooling systems for all potential Lake Michigan heat
22 sources. The present state of the art in the cooling
23 tower industry is rapidly advancing. Recent testimony of
24 Mr. Joe Ben Dickey of the Marley Company, a cooling tower
25 manufacturer, before the Illinois Commerce Commission
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1 P. Bertoncini
2 hearing on the question of Commonwealth Edison's
3 intention to build a 5,200 MWe. station in Brookfield
4 Township, Illinois revealed that there presently exists
5 technology to build cooling towers of the size necessary
6 to cool the two Zion units, for example, at a small
7 percentage of the total capitalization of such stations and
# with none of the dire effects to the environment predicted
9 by the representatives of certain power companies.
10 I would like to summarize a part of Mr. Dickey's
11 testimony which appears in Docket No. 56~034» the January
12 25» 1971» hearing of the Illinois Commerce Commission.
13 Parenthetically I should add here that Mr.
14 Dickey was subpoenaed to testify and it should be noted
15 that cooling tower manufacturers have not volunteered to
16 testify against their potential customers. It might be to
17 the Conference's benefit to call some witnesses from the
13 cooling tower industry to testify as regards cost estimates
19 of backfitting, and so on, since there seems to be a
20 tremendous contention, and it seems to be a very grave
21 point of concern of the Illinois Pollution Control Board
22 in particular.
23 As regards wet mechanical draft towers, Mr.
24 Dickey states that he has knowledge of some 65 to 70 major
25 mechanical draft towers built or contracted from I960
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1 P. Bertoncini
through 1972 and some 42 natural draft towers built or
contracted in the same period in the U.S. I should add
he further states the aggregate total for mechanical and
natural draft towers he has been associated with to be
approximately 47,000 MWe. The testimony covers the
development of wet mechanical and natural draft towers from
the installation of machines of approximately 100 MWe. in
the early 1960's through the contracting of machines of
1,100to 1,300 MWe. machines in the recent past and the
application of such equipment to installations of 2,000 to
5,000 MWe. generating capacity.
The relevant testimony in regard to mechanical drafjt
towers is contained in pp. 2296 through 2306 of the ICC pro-
ceedings ~ along with other pages of Mr. Dickey's
testimony — and in regard to natural draft towers is
contained in pp. 2307 through 2321. The costs of such
towers is estimated by Mr. Dickey to be less than§20 million
19 ' for the mechanical draft towers and $34 to $36 million
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for the natural draft towers for the 5,200 MWe.
installation proposed for Brookfield Township. Scaling
down to the 2,200 MWe. installation at Zion, for example,
would, I suppose, get a proportional decrease so that
the backfitting would perhaps be of the same order of
magnitude as the proposed installation in Brookfield
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P. Bertoncini
Township, Such an expenditure seems to us to be miniscule
compared to the potential damage to the lake which could
result from unchecked thermal discharges.
5 Mr. Dickey also addressed himself to the exagger-
6 ated claims of certain power industry spokesmen as to the
7 environmental effects of cooling towers. His testimony
as well as that of Dr. Eric Aynsley corroborates the
9 findings of the Department of the Interior's publication
10 on the "Feasibility of Alternative Means of Cooling for
11 Thermal Powerplants Near Lake Michigan," Mr. Dickey also
12 testified of a recent breakthrough in the design of wet
13 cooling towers which would virtually eliminate the tendency
14 of these towers to fog and ice. The breakthrough involves
15 a combination of wet and dry towers to remove the fogging
16 problem. He mentioned laboratory tests which were quite
17 impressive to Dr. George McVehil who had predicted adverse
effects due to the siting of cooling towers along the
19 lake. Dr. Hosier, Dean of Earth Sciences at Penn State
20 and a meteorologist, was also quite enthused about this
21 development. Subsequent personal conversations I have had
22 With officials at the Marley Company have indicated that
23 a prototype is installed and operating in St. Joseph,
24 Missouri at the St. Joseph Power and Light Company station
and that preliminary results as of several weeks ago show
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P. Bertoncini
a reduction by 75 percent in the icing and fogging*
This reduction was obtained without any optimization of the
equipment. These developments should go far towards
removing the last objections to the installation of closed
cycle cooling by the power industry.
Our organization has thus concluded after
studying the testimony before the ICC, and after reading
various publications sponsored by the U*S. Government as
well as material furnished by Commonwealth Edison, that
it would be folly to jeopardize the viability of Lake
Michigan for a few tenths of a mill/KWH difference in
electrical power cost to the consumer.
MR0 STEIN: Thank you very much,,
Are there any comments or questions?
You know, I sit through these things and I
always figure that one of these days I am going to learn
something new. Today I really learned something new: that
when someone starts a sentence with "retrofitting," the
cost estimate is going to be higher than if they start
the sentence with "backfitting," and with that we will
stand recessed until $? 30 . tomorrow.
DR. BERTONCINI: Mr. Chairman, I have 1,400
signatures supporting our position on —
MR. STEIN: That will be received as an exhibit.
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P. Bertoncini
(The documents referred to by Dr. Bertoncini
will be on file at Hq. EPA and the Regional Office,
Chicago, Illinois.)
(The Conference adjourned at 5:25 p.m.)
* U.S. GOVERNMENT PRINTING OFFICE: 1971-441-074/264
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