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
On
1
10
18

21
24

27
39

47
70
98
99
100

157

175
183
186
187
188
193
196
202
212
221

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 1
 2
 3
 4
 5
 6
 7
 3
 9
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
 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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                                                               vi
 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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                                                                 vii
1


2


3


4


5

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
16
17
IS
19
20
21
22
23
24
25
      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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                                                                         xi
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.  6o6olซ.
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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                                                                              XX
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         ป
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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                                                                               XXI
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
 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




25

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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 —
          ซ•• 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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                          	10
                            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              NRซ 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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                                                              11
                         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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                                                              12
 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 arซ
     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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                                                               15
                          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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                          	    16
 1                            F*  T,  Mayo
 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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                                                          17
                        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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   ^	:	•	•	      IS
 1                          Hon* A* J* Mikra                  *~
 2    Michigan as they will be presented by Mrซ  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              MRซ 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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                          	20
 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 tฉ 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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                                                                22
                        Ao Stevenson
          "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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                                                         23
                        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
                                                 •.^gftt
goal of preserving Lake Michigan, I am sincerely, Adlai

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 1                            Mrs*  S.  Bone
 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
11
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.  Sซ  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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                              Mrs* S* Rome
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 Eซ 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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                              Lป B. Young
                Mr. Mayo*
                MR0 MAYO:  We hare another request for a statement
      on the Federal side, Mr* Chairman, from Mrซ 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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                        Lซ B* Young
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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                          	   29
 1                            Lป B. Young
 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, "ป•ป 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              3ป  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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   	._	 3Q
 1                            Lo  1*  Toting
 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 "ซ•• 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 "ป,, 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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                        L* B* Young
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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                        L* Bo Young
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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                          _  33
                              Lซ 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    tฎ 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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                      Lซ B. Young
of the Technical Committee a program such as the following:
          1ซ  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
  '     cooling  systems, which may include once-through cooling

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                                                                35
 1                           L.  B.
 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$              2ซ  Future  powerplants scheduled for commencement
19     of  operations after July  1, 1976, may be designed according
20     tฎ  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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   	:	36_
 1                          L* Bป Young
 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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                                                                37
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                            L,  Bo  Young
      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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 1                               L.  B.  Young


 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
24-


25

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                                                               39
                               E* Conti
      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 Mrซ 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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   j,	:	:	40-




 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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      	.	41.





 1                             ฃ. Conti



 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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                               E. Conti
     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
1ฐ   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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                                                                43
 I-                               E. Conti



 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 ฐr 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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                                                                 44
 1                               E. Conti



 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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 1
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 3



 4



 5



 6
 7
 9




10
12
37
20
22
2JL



25
                                                                45
                          E.  Conti



 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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                          	46
                               E. Conti
                MRซ 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
23
24
25

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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 1ฐ 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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 5
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 7
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10
11
12
13
14
15
19
20
22
25
                       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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.1                           R. P. Hartley



 2    input in B.t.uป/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               4ป  "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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                          :	;	50_



 1                          R. P. Hartley


 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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                                                           51
 1
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 3
 4
 5
 6
 7
 B
 9
10
11
12
13
14
15
16
17
19
20
21
24
                       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 24ป 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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   	      .	52





 1                          R. P. Hartley



 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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                          	53_
 1                           R. P. Hartley
 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
lฃ    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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 1                           R. P. Hartley



 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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                          .	56_





 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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                          	57_

 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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                                                               59
                             R. P. Hartley
 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
24
25

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   	:	60
 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    sayป  sonie sort ฐf •— 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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 .     facilities and minimize the need for additives*  We just
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                       R, Pซ Hartley
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*
          MRซ 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
mซ 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
lฃ    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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                             R. P. Hartley
 o,
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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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                                                             64
 1                           1* P* Hartley
 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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    	.       	63

 1                           Ro P. Hartley
 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 Drป 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*
lฃ              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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                          	66
 1                          R, P. Hartley
 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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                       H* P. Hartley
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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 1                          R*  P.  Hartley
 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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                       R. P. Hartley
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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      	7P_




                              D.  S. Bryson



      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 jป

      1,000 feet from a  fixed point adjacent to the discharge,



 ฐ    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:


23



24



25

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D* S

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
45ฐ
45ฐ
45ฐ
55ฐ
60ฐ
70ฐ
SO0
80ฐ
80ฐ
65ฐ
60ฐ
50ฐ
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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                          ,	72
 1                            D* S, Bryson
 2              3ป  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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                                                              73
                        D, S* Bryson
          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,tปm,/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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    	;	74_




 1                            Dป S, Bryson



 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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                          	75





 1                           Do S. Bryson



 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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                                                               76
                                D. S. Bryson
        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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                                                                77


 1                            Do Sป Bryson

 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 Bปt<,u0/hour even though it met the standard

 5    adopted of 1,000 feet with a Delta-T of not greater than


 6    3ฐ Fo?

 7              MRo MAYO:  No, I think perhaps you have missed

 g    the relationship between those two points, Mrซ 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 Bซซซuซ/hourป

15              So what it says is that the discharger, whose

16    average daily discharge is more than a half a billion

17    Bซt.uซ/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.tปuป/houz[ซ

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 1                            D, S. Bryson
 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 Aป 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 Bปt*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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                                                               79
                                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 ป 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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                              D* S* Bryson
       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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                                                               82
 1                            D, S, Bryson
 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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                              B, Sซ Bryan
      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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                                                               84
                             D. S. Bryson

 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

25

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                                                                $5





 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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                                                                86





                              D. S* Bryson



 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. Aซ

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                              D. S. Bryson
                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.
                MRซ 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. Sซ 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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                        D, S* Bryson
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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                          	90_





                              D* S. Bryson



      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              MRซ 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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                                                                91
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                        Dป Sป Bryson
          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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               	,       	92_





 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, 1971ป 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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                                                               93
 1                            Dซ S, Bryan
 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 onซ



•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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                        Dป S. Bryson
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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                          	96
 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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                             	 97

 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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    	99_
 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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                                                              100

                                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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                                                              101
 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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   	102
 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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2/|-
                                                              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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                                                             104





 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



,ซ      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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                                                            105
1
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10
11
12
13
20
22
                               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



1ฐ    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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-------
                                                               110
                                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

-------
                                                                    112
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                                                       113
                         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 5ป "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

-------
                          	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

-------
                                                                       116
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                          	117





 1                              D. I. Mount



 2    the time.  I think,again, that is a rather significant



 3    point to emphasize, that these species shown, for example,



 4    around 60ฐ 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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                          	iia
 1                              D. I. Mount
 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/ป-      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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                                                                            119
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    	.	120





 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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 4
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 6
 7
 9
10
11
12
13
14
15
16
17
19
20
21
22
                                                              121
                         D. I. Mount
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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                          	122





 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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    	123
 !                              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 ซ5 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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   ^_	;	124





 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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                                            	125

 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.
12
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                                                               126
                          D. I.  Mount
          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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	127
                        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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                                                           128
 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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                                                               130
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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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                          	131
    I
 1                            D,  I, Mount
 2    move into October,  that  these waters  stay warmer than the
 3    65ฐ 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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                                          __132
 1                            Dป 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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    	134
                             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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                          	135





 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 3ฐ 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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                          	_____136





                              Dป  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, Drซ



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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12
-x
                                                                137
                                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



25

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	133
                        Dป Sป  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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                                                         139
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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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-------
     	__	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-ป-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;

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   	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*

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                                                               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 blowdownซ
 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 Mrซ 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

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                                                         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 2ฐ 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.

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                          	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 2ฐ 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 3ฐป 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 —

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                                                               145
 1
 2
 3
 4
 5
 6
 7
 9
      the zone is illegal anyway.
11
10
                MRo CURRIE:  It is normally said to be 3ฐ at the
12
13
15
16
17
19
20
2i
22
23
24
25
                              F.  Tซ  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?
                MRซ 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

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   	146
 I                            Fป  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

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                                                              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    "**ซ 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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                                                       148

                         F. T. Mayo
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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                                                               149
                         F. T. Mayo



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




25

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                                                        150

                         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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                                 F.  T.  Mayo



                  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



        2ฐ — 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
,ซ      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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   ^	:	    152





 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 2ฐ 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    ฐe 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 2ฐ Fป out.



25              MR. GURRIE:  Let  me move  to a slightly different

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                          	153
                                                           •


 1                            F. T. Mayo


 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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                         	154


                             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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                        F. To Mayo
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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                                                                 156




 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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                          	        15S


 1                            B. A, Tichenor

 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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	159
                        Bo A. Tichenor
          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: "ซ.ซ 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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                                                        	160
 -,                            B, A. Tichenor
 2   order  of  $9ป5 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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                                                         161
                        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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                          	162





 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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                                                               163
 1                            Bป 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*)
 a
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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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                                                                         165
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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                                                                          166
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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                                                                         167
                                                                     4

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<ฃ/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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                                                                        16S
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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                                                             169
 ^                            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 consumerซ
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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                          	170
 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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                    _ 171
                        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, Drซ 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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                                            	     172
 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 ซซ-
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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                                                        173
                        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 ป
          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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                                                               174
                                H. Zar
      requirement refers only to the 3ฐ 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?
                MRซ 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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     	175
 1                           Mrs* Hป Janis
 2              MR, STEIN:  They will stay availableป
 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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                                            	      176

 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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                                                              177
 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
2Zซ-    public representation of all technical committees.   The
25    League in Elm Grove, Wisconsin,  sent in  a statement  which,

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                                                      	178





 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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                                                              179





 1                             Mrs, H. Janis



 2    speculation  on  the  land  involved) before  construction starts,



 3    and  before operations  begin.  All levels  of government and thซ



 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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                          	161
 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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     	132





 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



 ฃ   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* Hซ 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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                                                               134
 1                          Mrs* Lป 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
20
21
22
23
24
25

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 ONORARY PRESIDENT:
  SEN. PAUL DOUGLAS
PRESIDENT EMERITUS
  AND FOUNDER:
  MRS. JAMES H. BUELL
      ru*tซ*
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^ ฃ. ^^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 eoปfereซae to a decision to pro-
pose a deflMlte aปd adequate thermal and water eleaปllปess
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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                                                                   137
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 Vปซ% Jaekซซซ Street
       Ckleage, HllDปU 60604
               It May
        Lake C*naty Cซซaซil ซf
        M, IBซ., wiปk tป gt
CซuปซH, tkat ซ• are •pp*>ซ4
Mle*isป*ซ Vซ far** pปgalatlBg water
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                                                              183
 1 j                           H. G. Zander
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                STATEMENT OF HENRY G0 ZANDER, III,
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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 Gป   „
      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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                                         	139
                          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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                                             	 190





 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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   	191





 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



lฃ    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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                                                      	192

   i
 1 ;                            H. G. Zander
   !

 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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                                                              193
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                            Hon. Po Jซ 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 24ป
                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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                                            	      194


 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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                                                     	196
 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. )

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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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                                 -2-
                                                                          199
       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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                                 -3-
                                                                         200  '
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


                                                                 Lฃ
permit unnecessary pollution from electrical generating plants  whiซh 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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                                  -4-
                                                                        201
       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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     	                                               202
   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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    	.	203





' 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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                           	204


 1                               T. Falls

 2   The pressure here can drop in a very short time interval to

 3   the order of 0,5 pซs0i.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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                                                               206
 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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                                                               207
 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.)
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 DEDICATED  TO   THE   PRESERVATION  OF   OUTDOOR   A M E RI CฐA
                        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.     2ฐ9

 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.ฃ 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, ฃ0 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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                                                         213
 1
 2
 4
 5
 6
 7
 o,
10
11
12
13
14
15
16
17
19
20
21
22
23
24
25
                        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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                          	214




 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 20ฐ 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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                                                               215
 1
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 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 95ฐ F. and other species that prefer

-------

-------
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 iปest 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

-------
                          	216



 1                                A. Pancoe


 2    temperature in the range of 86ฐ 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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                          	.	217





 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

-------
 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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     	     219




                                  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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                                                              220
 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 5ป000 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                MRป 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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                                                              221


                             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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                                                               222



 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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                                                               223






                                  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.



,ซ                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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                                                                224
 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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                                                               225
 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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                                  	226




 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  1ฐ


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



lฃ    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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                                                             229


                              Mrs. L. Botts

                .-.
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                          	230
 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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                                                              231
 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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                                                       	233


 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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                                                               234
 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 1ฐ 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,    1ฐ 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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                                                             235
-.                             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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                          	236





 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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 3
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 5
 6
 7
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 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
                                                                227
                          R. Cramer
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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                          	233




 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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 1
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 3



 4



 5



 6



 7



 &



 9
10
11
12
13
15




16
17
19




20



21




22



23



24



25
                                                               239
                         R. Cramer



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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                	240





 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#99ป 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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                                                        241
 1
 2
 3



 4



 5



 6



 •7
 9
10
11
12
10
20
22
2/.




25
                         R. Cramer



          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



ฐn 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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                          	242



 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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    	243

    i
 1                              R.  Cramer

 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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                          	  244
 1                           Mrs. Hซ 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-
lฃ     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,tซu,'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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                                                              245
 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    1ฐ  Fป>  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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                                                               246





 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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     	247
                            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, Dป 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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                                                                       249
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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                                                                      250
 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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                                                                    251
        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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                                                                        252
   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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                                                                       253
                         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 itป 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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                                                                     254
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

-------
                                                                      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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                                                                      256
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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                                                                      257
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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                                                                     253
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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                                                                     259
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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                                                              266
                               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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                             	261
   'I   '


 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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    	.   	;	262




 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. 56~034ป the January



12     25ป 1971ป 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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     	:	263
 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 thanง20 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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                          	264





                              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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