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                 Temperature Increase (°C) at International Boundary
Source:  Spraggs, 1977

            Figure 5.6-2   RIVER HEAT RELEASE SUMMARY
                              216

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      Egg and  larvae data  collected by Montana Department of Fish and
 Game (1978) indicate   that, during the spring of 1977, walleye and
 northern pike were probably spawning during the period of mid-April to
 early May.  During the spawning period median daily river temperatures
 ranged from about 8.9  to  15°C.  Daily temperature variations were quite
 high and ranged  from 4.4  to 6.7°C.  Larval walleye occurred 1n the  river
 until  mid-May, at which time natural river temperature ranged from  13°C
 to 21°C.

      Studies  by  Koenst and Smith  (1976) on the temperature requirements
 of young walleye indicate that optimal temperatures for egg incubation
 range from 9  to  15°C.   This temperature range closely corresponds
 to the observed  occurrence of ripe adults and larval walleye during
 1977.   The young walleye  were also quite resistant to temperature
Changes slncejthey tolerated up to a 10°C increase over a period of 72 hours
 without adverse  effects on survival.  The high resistance to rapid
 temperature fluctuation by young  walleye was also demonstrated by
 Allbaugh and  Manz (1964).  In the laboratory studies there was also
 good survival to hatch of walleye eggs incubated at temperatures up to
 17.8°C, Indicating that relatively small increases in natural river
 temperature during the spawning season would not adversely affect sur-
 vival.

      The optimal temperature for  growth of juvenile walleye was about
 22°C (Koenst  and Smith, 1976).  The upper lethal temperature ranged
 from 27.2 to  31.7°C as acclimation temperature increased from 7.8 to 26<>C.
 These data indicate that  small elevations in ambient river temperature
 (<3°C) during the juvenile rearing period would also not be detrimental
 to walleye production.  Conversely, it could be potentially beneficial
 since ambient river temperature during much of May are actually sub-
 optimal for walleye growth.  This is an important consideration since
 Johnson (1961) found that cold weather during the incubation period may
 actually be an important  limiting factor in determining walleye year-
 class strength.

      Based on available data for  young northern pike  (Hokanson, et  al.,
 1973), it appears that their temperature tolerances would also not  be
 exceeded by small temperature elevations (<3°C) in downstream areas.

      Pike larvae are apparently more sensitive than walleye to rapid
 temperature changes.   However, in field studies Franklin and Smith
 (1963) found  good survival when temperature changes did not exceed
 0.7°C/hour.

      Furthermore, the  upper lethal thresholds  (96-hour) for both
 northern pike and walleye are about 32°C.  Since the maximum natural
 river temperatures are generally  about 26.7<>C, limited  heating  (2.8°C)  of
 the river during summer would not exceed the upper  limits  for gamefish
 survival.

      In summary, mathematical predictions indicate  that the downstream
 temperature elevations due to power plant operation  on  the  Poplar River
 are a function of:

      •  number of units

      •  flow  in  East Fork


                                    217

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 For the two-unit operation (600 MW) the maximum predicted temperature
 elevation at the boundary during expected spring and summer flows would
 be less than 1°C.  Moreover, during low flows  all  excess  heat would  be
 dissipated prior to the International  Boundary.   Even under situations
 of high flow (>130 cfs) the.maximum.Increase at the border would be
 only about 5°C, and this would decrease rapidly 1n the East Fork.
 Therefore, even under the extreme situations (I.e., two-units and
 high flow) the natural  stream temperatures would probably be reached
 within the East Fork.   The available information on the thermal  re-
 quirements of the two major game fish  present  in the Poplar River indi-
 cates that there would  be no adverse impacts due to thermal releases at
 the reservoir.
 5.6.3.2  Effects of Dissolved Solids Increases

      Increased total  dissolved solids (TDS)  levels  in  freshwaters may
 be potentially toxic to aquatic life.  Tolerance of fishes  to  increased
 TDS is highly variable according to species; however,  it  Is generally
 assumed that TDS concentrations above 5,000  to 10,000  mg/A  would gen-
 erally represent adverse conditions for survival  of most  freshwater
 organisms.

      It should be emphasized that most freshwater species,  especially
 those inhabiting the Northern Great Plains waters,  can tolerate a
 relatively  wide range of TDS concentrations.  This  is  necessary due to
 the high seasonal  variability encountered  in many surface water bodies.
 For example, in the Poplar River, natural  TDS concentrations may range
 from <150 mg/£ during high runoff, to over 1000 mg/Jl during low flow
 conditions.

      In general, the  early life stages of  fish (i.e.,  eggs  and larvae)
 are more sensitive to increases in TDS than  adults  of  the same species.
 Limited data are available on the salinity tolerances  of  eggs of the
 two major species  of Poplar River gamefish:   walleye and  northern pike.
 Peterka (1972)  reports that eggs of both species  displayed  good hatch-
 ing success  in  waters with a conductivity of 1300 umhos.  Based on the
 conductivity -  TDS relationship of Poplar  River waters at 25°C, this
 would represent a TDS concentration of about 860 mg/SL. As  the conduc-
 tivity was  Increased to 4000 umhos (TDS =  2640 mg/jl).   There was no
 hatch of walleye eggs and very poor hatch  of northern  pike.  The
 studies of  Petarka (1972) also indicated that fathead  minnows  (a for-
 age fish in  the Poplar River)  experience no  adverse  effects  on growth
 and reproduction at TDS concentrations up  to 7000 mg/i.

      The water  quality modeling results indicate  that  the highest
 potential for increases in TDS concentrations resulting from flow
 apportionment will occur in the Upper East Fork (see Section 5.3.3).
 With  more than  two units  (1985 and 2000 level  of  development) the
 April  TDS concentrations  in the entire East  Fork  will  be  at  levels
 where  spawning  of  walleye and  northern pike  may be  impaired  in one
year  out  of  every  ten  (i.e.,  90 percent concentration  is  exceeded).
 During  90 percent  of  the  spawning seasons the egg tolerance  limits
 should  not be exceeded 1n  the  East Fork.   In all  other parts of the
U.S.  basin,  TDS  concentrations  during April  should be  below  the toler-
 ance  levels  for  successful  hatch  of gamefish eggs.   This  results from
dilution  by  lower  salinity waters  from the West and  Middle  Forks.

                                     218

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     The only condition which results In IDS concentrations exceeding
the limits for maintenance of fish population during the non-spawning
season is with four units at the year 2000 level of development.  In
such cases relatively high IDS concentrations (4000-5000 mg/£) would
exist in the East Fork during low flow months In the fall and winter.
Although such concentrations would probably be toxic to gamefish, the
more Important limiting factor under Scenario 32 would be the low
flow in the lower East Fork (see Sections 5.6.4).


5.6.3.3  Effects of Dissolved Oxygen Changes

     Adequate dissolved oxygen is essential  for the maintenance of fish
populations.   This is especially true for gamefish species such as
those existing in the Poplar River,  which are generally less tolerant
of low oxygen levels than "rough" or forage species.   There are two
main conditions in which dissolved oxygen may be limiting factors for
the production of stream fish populations:

     1)  During the spawning period eggs and larvae may be
         susceptible to low oxygen levels, especially in
         species which deposit eggs  in the bottom substrate.

     2)  In areas where surface waters freeze during the
         winter, low dissolved oxygen conditions may exist,
         especially in shallow waters at low flow rates.

     Based on recent Quality Criteria for Water (EPA, 1976), a minimum
dissolved oxygen concentration of 5 mg/4 is recommended for the mainte-
nance of gamefish populations.  Based on available water quality
data, it appears that dissolved oxygen levels in the Poplar River are
well above minimum values for gamefish protection during the period of
April through November.  Even in the upper reaches, of the East and West
Forks, the dissolved oxygen always exceeded 86 percent saturation.
Moreover, these high levels were measured after closure of the dam on
the East Fork; therefore, during ice-free conditions no adverse impacts
of apportionment flows on dissolved oxygen concentrations are ex-
pected to occur.

     Dissolved oxygen levels also appear to be sufficient for success-
ful spawning and early development of walleye and northern pike.  Oseid
and Smith (1971) indicate that the lowest dissolved oxygen concentration
for optimal hatching of walleye eggs is 5-6 mg/JL  Moreover, a relatively
high survival to hatch was observed at dissolved oxygen concentrations
of only 2 mg/4.  Hatching time was extended, however, and the larvae
were smaller at hatching when incubated at 2 mg/Jl.

     Siefert, e£al. (1973) found similar results for northern pike eggs
and larvae.  Dissolved oxygen concentrations of about 5 mg/Jl were ade-
quate for hatching and survival to the feeding stage.   Pike eggs may be
                                  219

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 more sensitive to continuous lower oxygen concentrations since survival
 was considerably reduced at a level of 3.4 mg/£.   However,  pike larvae
 are apparently able to tolerate short exposures to low dissolved oxygen
 concentrations.   Peterka and Kent (1976) found no reductions in survival
 of embryos, yolk-sac larvae and larvae maintained for eight hours at
 dissolved oxygen concentrations of 0.6, 2.0 and 4.0 mg/£, respectively.

      Since April dissolved oxygen concentrations  in the East Fork after
 dam closure (since October, 1975) are generally above 5 mg/Jl, no impacts
 on fish spawning due to changes in dissolved oxygen levels  are antici-
 pated.  This conclusion is based on the observed high spawning-period
 oxygen concentrations under spring flow conditions on the East Fork
 which are more severe (in regard to flow and oxygen availability)  than
 would be expected under the apportionment agreements.   This  results
 primarily from the additional scheduled releases  which would add a minimum
 of 1 cfs  to the natural  flow resulting from groundwater accretion and
 surface runoff.

      During the  period of normal  ice cover on the Poplar River,  low
 dissolved oxygen may be an important limiting factor In fish survival.
 In February-March, 1977,  Stewart (1978) observed  large numbers of  dead
 walleye, suckers and carp on the East Fork.   In late February, dissolved
 oxygen concentrations as  low as  0.1 mg/Jl were recorded under the  ice.
 Moreover, in some locations there was no water below the ice or the  ice
 depth exceeded 4.5 feet.   This  lack of available  under-ice  habitat and
 low oxygen levels was apparently the cause of the fish kills.   Similarly
 low oxygen levels were observed  on the West Fork  and,  in conjunction
 with the low summer flows, may  explain the lack of gameflsh  in that
 part of the basin.

      Based on the aforementioned  considerations and the historical
 occurrence of very low flows during January and February, it appears
 that during years of average or  low flows the apportionment  of flows
 and resultant continuous  scheduled releases ( 1 or 2 cfs) will have  a po-
 tential  beneficial  effect on fish winter habitat.   As  indicated  in
 Section 5.2, the flows  on the Upper East Fork at  both  10 percent and
 50 percent frequency will  be greater than the corresponding  historical
 flows.

      Oxygen concentrations in the East Fork during the previous winter
 (1976-77)  (Stewart, 1978) appear  to be satisfactory for fish survival
 (e.g.,  >4 mg/&).   The average winter flows in 1976-77  (1.7-2.3 cfs)
 were similar to  the median winter flows under development Scenarios  28
 through 32.

     There  are also  no  anticipated  adverse Impacts  on  winter fish
 habitat  in  the Middle Fork  due to the  apportionment.   During January
 and  February  there  1s historically  little flow at  the  International
 Boundary of the Middle  Fork or its  major tributary,  Coal Creek.  There-
 fore, during  the winter most of the  flow 1n  the Lower  Middle Fork  has
occurred in  the U.S. part of the  basin  below the confluence  of Coal
Creek.  This  Is true under  historical  conditions and under Scenarios
                                   220

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28 through 30 (i.e., up to three units at 1985 water use).   Scenarios
31 and 32 (3 and 4 units at 2000 water use) include a reservoir on the
Middle Fork and median (50 percent) or low (10 percent) winter flows
would actually be larger than historical flows 1n the Lower Middle Fork.

     In summary, the apportionment schedule which results in the main-
tenance of stable winter flows in the East Fork will not adversely
impact fish survival in winter and should have a beneficial effect
in preventing the occurrence of fish kills during low-flow years.
5.6.3.4  Bioaccumulation of Metals

     Aquatic organisms may accumulate  some  trace metals and  organic
compounds in their tissues at levels considerably  higher  than ambient
concentrations in the water.   Therefore,  it is  important  to  evaluate
the potential for toxic chemical  contamination  in  aquatic organisms
such as gamefish which are utilized as human food.

     The Montana Department of Fish, Wildlife & Parks  (Stewart,  1980)
has recently reported concentrations of mercury in fish muscle tissue
from the Poplar River (Table 5.6-6).   Those analyses  indicated mean
mercury concentrations in walleye flesh of  about 0.5  mg/wet  kg for the
East, Middle and West Forks.   Maximum  values for walleye  flesh ranged
from 0.8 to 0.9 mg/wet kg.  The data for  northern  pike were  much more
limited (only three fish tested); however,  the  values ranged from 0.12
to 0.49 mg/wet kg.

     None of the reported mercury concentrations exceed the  current  FDA
"action level" of 1.0 mg/wet kg.   However,  it should  be emphasized that
the previous FDA value (prior to 1979) was  0.5  mg/wet kg, a  value
exceeded by 44 percent of the gamefish analyzed by Stewart (19GO).

     These data indicate that there is a  significant  accumulation of
mercury in fishes in the Poplar River. Although current  FDA action  levels
are not exceeded by the data, the observed  mercury levels indicate that
excessive consumption (e.g., more than 1-2  meals per week) of gamefish
from the Poplar River should be avoided.

     Stewart (1980) states that the reasons for the relatively high
mercury concentrations are unknown.  Based  on the  fish tissue concentra-
tions and the water quality data, the contamination appears to be present
in all three forks of the Poplar River.  The contamination is, therefore,
apparently unrelated to the reservoir or power plant construction on the
East Fork since walleye and northern pike are sedentary with little
observed migration among river sections.

     The data of Stewart (1980) indicate, however, the need to carefully
monitor mercury and other trace metals in Poplar River biota.
                                    221

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Table 5.6-6  Mercury Content of Fish fluscle Tissue from
             the Poplar River (Adapted from Stewart, 1980)
Sample
Location
East Fork
Middle Fork
West Fork
Species
Walleye
Northern pike
Wai leye
Northern pike
Walleye
Northern pike
No. of
Samples
9
1
10
1
10
1
Mean
mg/wet kg
0.45
0.12
0.52
0.42
0.52
0.49
Range
mg/wet kg
0.32 - 0.80
0.17 - 0.86
0.25 - 0.90
                         222

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     The power plant represents  a potential  source  of additional  mercury
contamination through combustion emissions.   Although the  analyses
performed 1n section 5.6.2.2 do  not Indicate a  significant enrichment of
surface waters due to mercury emissions,  the potential  for further  mercury
contamination should be fully Investigated since  mercury 1s poorly
scavenged by stack gas cleaning  methods and its toxicity and potential
for bioaccumulation is quite high.
 5.6.3.5  Other Constituents

     Maximum concentrations of boron up to 20 mg/& could occur in the
 Poplar River under the apportionment agreement.  No impacts on local
 fish and wildlife are predicted, however, due to the relatively low
 toxidty of this constituent to animal life.  Toxic concentrations
 to  fish are over 1000 times the osmotic predicted concentrations.

 Turbidity  and suspended solids measurements on the Poplar River indi-
 cate that  this constituent is not limiting to fish production.  Even
 during extreme high flow conditions the suspended solids are within
 short-term tolerance ranges.  Any effect of power plant development
 on  the.East Fork would probably be evidenced as reduced suspended
 solids loading due to settling in Cookson Reservoir.  Therefore, no
 adverse impacts of development would be predicted.
 5.6.4  Impacts of Flow Modifications  on  Fish  and Wildlife
 5.6.4.1   Wildlife and Furbearers

      Several  species  of mammals and birds are directly dependent  on  the
 aquatic  habitat provided  by the Poplar  River.  The  two main  groups
 which have a  potential for impact  from  flow modifications  are  furbearers
 and waterfowl.   Both  of these  groups  require specific aquatic  habitat
 characteristics which may be modified by variations in the amount of
 water available in the river basin.

      During the period from 1977 to 1978 the number of observations  of
 beaver and raccoon in the Poplar River  drainage  increased  slightly.   At
 the same time,  the observations of muskrat decreased, while  the numbers
 of mink  remained unchanged  (DeSimone, 1979).   It is generally  believed
 that beaver,  muskrat  and  mink  populations have declined  during the
 last 30  years primarily as a result of  intensified  agriculture and  land
 use practices in the  area.   It is  not anticipated that  the proposed
 action will have an adverse  Impact on furbearers, since  they are not
 directly dependent upon the magnitude of peak  flows.
                                      223

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     Inability to maintain existing channel morphology in the upper
nine miles of the East Fork due to reduced flows may result in encroach-
ment of emergent macrophytes and a concomitant loss in waterfowl pro-
duction.  Recent studies  (DeSimone, 1978) have shown that both waterfowl
breeding  pair density and production wejre_greater In this.portion of
the East  Fork than on sTmllar areas studied on the Middle Fork, Main
River, West  Fork, Coal Creek and Butte Creek.  While it was concluded
that existing submergent  and emergent macrophyte growth provided brood
cover and was responsible, in part, for the greater brood production
in the upper portion of the East Fork (DeSimone, 1979), substantial in-
creases in emergent growth would result in the loss of brood habitat
by restricting access to  the preferred rearing grounds for surface-
feeding species of ducks.  It has been shown that a greater than 50
percent areal coverage of emergents on a water body renders these areas
unsuitable for duck production (Evans and Black, 1956; Stoudt, 1971;
and Whitman, 1976).

     In an assessment of  the effects of altered flow regimes of the
Poplar River, Bahls (1979) stated that flow reductions with two 300 MW
units and the proposed apportionment will result In an expansion of
the macrophyte community within the system.  It was concluded that mac-
rophyte growth within and along the main channel will be most dramatic
in the East  Fork and may  result in 50 percent coverage during the life
of the project.  The results of an aerial survey of emergent vegetation
in several segments of the East Fork Poplar River during July 1979
(DeSimone, 1980) Indicated that at least in the area adjacent to the
International Boundary one section is approaching 50 percent coverage,
while emergent coverage in three other sections ranged from 5.8 to 21.6
percent.  However, additional releases specified under the recommended
apportionment were not made.  Based on the relationship between areal
coverage of  emergents and waterfowl production presented above additional
encroachment In the uppermost reaches of the East Fork will result in a
reduction in waterfowl production.  Progressive encroachment in the
upper nine miles of the East Fork Poplar River resulting in greater than
50 percent areal coverage would result in the loss of approximately
70-80 breeding pairs of ducks and the production of between 300 and 400
ducks annually (DeSimone, 1979).  However, simultaneous Increases 1n
macrophyte growth 1n the lower East Fork and Main Poplar River, where
abundances of emergents are substantially less than the upper East Fork,
could lead to an increase in waterfowl production in these areas and the
supplanting of the breeding areas to the north.
5.6.4.2  Fish

  '   The fish populations of the Poplar River are susceptible to habitat
alterations resulting from changes in river flow rate.  The two major
areas of potential impact are:

     •  Changes in spawning habitat

     •  Reduction in overwintering habitat


                                  224

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The impacts of flow modifications resulting from apportionment on the
winter survival of fish during ice cover conditions  are  related pri-
marily to the low dissolved oxygen concentrations occurring  under low
flow conditions in January and February.  These impacts  are  discussed
in the water quality section (5.6.3.3).

     The main emphasis of this discussion will  involve consideration  of
the flow impacts on spawning habitat for the two major game  fish
species in the Poplar River:  walleye and northern pike.   Although the
magnitude of flows during non-spawning seasons  may also  be potentially
limiting to game fish production, no adverse impacts of  apportionment
are expected due to the continued observed occurrence of gamefish
(Stewart, 1978) during low flow years such as 1976-77.  In such cases
measured flows throughout the basin were less than those predicted
under the most likely apportionment alternative (VI). Therefore,
subsequent impact discussions will be concerned with three main aspects
of fish spawning habitat:

     1)  Maintenance of normal channel morphology

     2)  Inundation of shoreline vegetation

     3)  Prevention of siltation

     Both northern pike and walleye normally spawn during April in the
Poplar River.  Although their spawning seasons  coincide, they require
quite different spawning habitats.  Pike deposit adhesive eggs among
vegetation in shallow water (<15 inches deep).   The  eggs hatch in about
2 weeks.  Walleye spawn over gravel bottoms in pool  tails or riffles
(depth usually less than 1.5 feet).  Their adhesive  eggs settle into
the gravel and also hatch in about two weeks.

     Walleye are an important game fish in the Poplar River and their
continued existence in a prairie stream such as the Poplar River is
dependent upon the maintenance of the existing channel morphology
consisting of alternating riffles and pools with clean gravel substrate
during the spring.  Alteration of the morphology of the Poplar River
to that of a more typical prairie stream  (e.g., uniform gradient, soft
bottom) would result in a loss of walleye production.  Therefore, it
is important to consider the flow regimes required to maintain the
current degraded channel.

     The hydraulics of the  Poplar River are complex.  The bed character-
istics and meandering channel form make velocities at any transect
extremely non-uniform.  The abruptness  with which flood peaks occur
make velocity computation by steady-state hydraulics  equations  inexact
at high flows.  However, these are the  important flows from the  stand-
point of maintaining fish habitats  in certain  portions of the  river.
                                  225

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 Therefore the actual  numerical  estimates  made  in  this  section to pro-
 vide  a  flow and sediment characterization of the  East  Fork may be
 considerably in error.   However,  the  numbers do reveal  some general
 relationships such  that conclusions can be drawn  concerning Impacts
 of flow on fish.

      In order to determine if the Poplar  River can maintain the degraded
 channel appropriate for spawning, two questions must be answered.
 They  are:

      t   What flows  produce the  tractive forces required to
         suspend sediments, and

      t   What duration of the critical  flow is  necessary to
         scour the sediments.

      Flow uniformity  in the channel must  first be assumed.  This will
 necessarily underestimate the scouring potential  over  the riffle areas
 and overestimate in pool  areas.   If pools occur in bends of the river,
 radial  acceleration may keep the  scouring rates competitive with those
 in riffle areas.

      Brown (1978) conducted a study to determine  minimum flow rates for
 maintenance of fish habitats.  In the investigations he collected the
 particle size data  shown in Table 5.6-7.   The  data are broken down
 into  riffle and pool  areas.   In general,  velocities are lower in pools
 and finer sediments tend to collect in those areas.  To maintain the
 spawning habitat of game fish on  the  East Fork, it is  necessary to
 scour the  size fractions from approximately the medium sands to the
 colloidal  clays.  The velocities  required to pick up and transport
 these particles range from about  .52  to 1.04 feet/second.  (Longwell,
 et al_., 1969).

      The approach to  finding the  critical flow required on the East
 Fork  included the use of the Manning  formula.  This equation,
says that the average  stream velocity  (V)  is  proportional to the stream
hydraulic radius  (R) and the energy  slope  (S) and  inversely proportional
to channel roughness (n).  Since the critical velocity  (1.04 fps) is
known, the equation can be rearranged  to calculate R.   The roughness
coefficient  (n) was taken from Schwab, et  al_.,  (1966) and has a range
of 0.45 to 0.6 from streams like the PopTTar.  S was found by dividing
the difference in elevation of the USGS stream gauge at the International
Border and the gauge near Scobey on  the East  Fork  by the total estimated
distance in  river miles between the  two locations.  The value of S used
was 0.00011  ft/ft.  Using these values yielded a hydraulic radius R
and, assuming a rectangular channel, a new flow depth was calculated as


                                   226

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ro
ro
                                                      Table 5.6-7



                                            BED MATERIAL SIZE DISTRIBUTION
1
Sample
Location
f
East Fork
2.5 nlles below
Inter. Border
Cromwell Slab
USGS gage
near Scobey
Hlddle Fork
NcCarty Crossing
near Int. Border
Hagfeldt Slab
Ofstedal Slab
Hest Fork
South of Peerless
Susag Farm
Main Stem
Crowley Slab

Pool(P)
Rlffle(R)

P
R
P
R
P
R

P
R
P
R
P
R

P
R
P
R
P
R
P
R

o,a
M)

O.OS8
0.6
0.34
2.7
0.27
0.5

1.7
2.7
0.21
0.92
0.18
4.7

0.35
4.2
1.4
0.32
0.062
0.31
0.54
0.30

Particle
A?

0.095
4.0
1.6
10.25
1.0
1.8

8
11
0.37
8.3
0.255
10.5

4.3
10.5
10.0
1.8
0.099
1.4
O.OB6
1.6

Diameter
A

0.11
12.5
7.6
20
4.8
8.5

19
21
6.6
18
0.30
19.5

10.0
25.5
30
7.6
0.135
8.0
0.128
10.0

$

0.15
21
12.5
36.5
9.1
14

33
33.5
21
26
0.345
28

15.5
48
40
14
0.16S
15
0.196
17

&

0.18
31
21
52
16.5
22

45
39
39
45
0.44
37

20.5
68
51
32
0.21
22
0.31
24

ft

0.25
39
46
73
31
39

63
49
56
54
0.79
68

39. 5
79
66
56
0.33
41
0.38
47
i i
1
& \
\
0.4 :
45
57 '
84
49
49

80
58
62
58
1.20
75

54
86
68
68
0.45
48
0.45
52
i












                Source:  Brown,  1978


                a
c means that 5 percent of the particles have a diameter less than the value given.

-------
                            depth =


where w is the width of the stream (from the Brown (1978) data).  Know-
ing the new depth and channel width, the cross-sectional area can
be calculated.  The critical flow required to flush sediments from
the fish habitat's was computed by continuity (Q = AV) to be about 715
cfs.  The flow required to overtop the main channel and begin inunda-
tion of the shoreline vegetation areas is somewhere between 220 and
330 cfs according to similar calculations.  This range of values is
supported by the report of Saskmont Engineering (1976) which indicated
that a 250 cfs flow would escape the main channel.  Therefore at flows
which would provide the required scouring velocities the pike spawning
habitats would be inundated.

     Calculating the duration of the required 700 cfs scouring flow is
a more difficult problem.  The first assumption that was made in this
solution was that the reservoir is a 100 percent effective sediment
trap for waters spilling from the upper East Poplar across the
International Boundary.  Secondly, it is assumed that sediment loadings
to the river (excepting the within channel bank erosion) come only
from cultivated agricultural land.

     Using the universal soil loss equation, the annual sediment
loads from cropland to the East Fork can be obtained.  The equation is:


                             A = RKLSCP


where A is the annual sediment loss in tons/acre
      R is the rainfall erosivity factor
      K Is the soil credibility factor
     LS is the slope-length factor
      C is the crop factor, and
      P is the practice factor.

The parameters were estimated from tabulations and figures in Stewart
(1976).  The parameter values are given below.
     R =25
     K = .30
    LS = .20
     C = .23
     P = .80
for a sandy clay to silt loam soil)
slope length 1000 ft, .05 percent slope)
spring wheat) and 0.02 for alfalfa
fall seeded grain, low slope)
Using these parameters the gross erosion is about 0.26 tons/acre.
Zison, e_t al_. (1977) has presented the relationship developed by McElroy
to determine the sediment delivery ratio.  Using the drainage density
given for the East Fork and the proper soil type, this ratio is deter-
mined to be 0.12, yielding a net delivery to the stream of 0.03 tons/
acre.  The contributing area to the portion of the East Fork from the


                                  228

-------
International  Boundary to the USGS gauge near  Scobey  Is  approximately
188 mi2.   Of that, about 74 percent 1s  under cultivation,  or  about
89,000 acres.   This indicates an annual  sediment  loading in the  U.S.
portion of the East Poplar of 2670 tons.   This, of  course, assumed
that loadings from uncultivated areas are negligible  and that no loads
are added in between the reservoir and  the U.S. boundary.

     To estimate the scour at the critical  flow rate,  sediment concen-
tration and flow data were taken from USGS records  for the East  Fork
at the International Boundary.   The suspended  sediment data were
converted to mass flux data and plotted  versus flow rate.  This  plot
is shown in Figure 5.6-3.  A log-log least squares  regression gave
the best fit line shown 1n the figure.   The equation  for sediment
flux in grams/seconds given flow in cubic feet/second is:


                      Flux = 1.16 (Flow)0'97


Substituting 715 cfs into the above, the sediment flux is calculated
to be 680 g/sec.  This represents the amount of suspended sediment
that would move past a point in the river in one  second  at that  flow.
If the assumptions are made that the only sediment  in suspension comes
from overland flow loading and that sediment must be  transported
through the entire length of the reach,  then the  time required to
flush the East Fork would be 41 days.   Realistically, the sediment
probably does not need to be moved entirely through the  system in
order to cleanse critical areas.  The spawning habitat in riffles is
probably maintained due to the movement of sediments  off riffles into
more sluggish areas of the stream.  These areas are usually where
point bars are building up on the inside of bends.  Therefore, the
41 days is a nominal upper limit value.
     According to Brown (1979)  the average distance between areas
of severe bank cutting and hence the distance between corresponding
sluggish areas on the inside of the turns is about 2,000 feet.   If
sediments are only required to  move this distance, the duration of
the 700 cfs flow would necessarily be only about 6 hrs.  Very likely,
the time required for scouring  is between these limits.  For instance,
the clays may move entirely through the system while coarse sands
may be picked up and deposited  2000 feet downstream.  Fine sands might
travel several miles and then come out of suspension.

     The sediment loadings to the East Fork appear to be quite small.
The U.S. East Fork from the International Border to the USGS gauge
at Scobey is approximately 100 feet wide during high flow on the aver-
age.  Sediment with voids weighs about 165 pounds per cubic foot.
Using this information, the mean annual depth increase of sediment
on the stream bed can be estimated.  This depth is 0.0007 ft/year.
At this rate, 120 years would be required to accumulate a one-inch
depth uniformly over the East Fork  (assuming bank cutting is a negli-
gible source).  If siltation occurs as a result of  reduced flows,  it
will likely be a very slow process.
                                   229

-------
  1000
   100
X
3
c
01
in
£
a
vt
   10
  0.1
     0.1
                                    o
 10
Flow (cfs)
100
                            Flux - 1.16 (Flow)0'97

                               rlog-log ' '8S
                             D Prereservolr (1974 - Nov 1975}
                             * Postreservoir (Dec 1975 - 1976)
                                                                                 1000
      Figure 5.6-3   SEDIMENT FLUX  VERSUS  FLOW AT THE  INTERNATIONAL  BOUNDARY
                       EAST FORK POPLAR RIVER

-------
      Analysis of historical records Indicates that on the upper East
 Fork the  peak discharge with a return period of 2 years is 948 cfs.
 Although  it would occur normally for only a short period (e.g., <2 days),
 peak flows  of this magnitude have obviously been sufficient to main-
 tain adequate spawning substrate for walleye.

      Since  the water quantity modeling results are based on total
 monthly flows, it is difficult to predict the exact effects of appor-
 tionment  on the magnitude or duration of peak flows which may occur
 for short periods only.  However, it is reasonable to assume that
 peak flows  on the East Fork are considerably reduced when compared
 with pre-Impoundment conditions.  The scheduled releases under the
 apportionment would be insufficient to affect significant scouring.
 The analysis of spills (Draper, 1979) indicates that with more than
 two units in operation and  flow apportionment, there may be a gradual
 change in channel morphology, especially in the East Fork.  These
 changes would eventually result in an adverse impact on the avail-
 ability of walleye spawning habitat in the form of riffles with clean
 gravel bottoms.

      Several factors suggest, however, that the adverse impacts on
 walleye spawning  habitat may not be manifested for some time after
 initiation  of power plant operation and flow apportionment:

      a Low sedimentation rate.  Reservoir construction has
        actually  reduced sediment load in the East Fork due
        to  sedimentation in the reservoir and reduction in
        bank erosion due to lower peak flows.

      • Continued spawning  on East Fork after closure of
        Morrison  Dam.  Flows on the East Fork during the last
	  _ two spawning seasons (1977 and 1978) have been
        approximately equal to, or less than, median flows
        predicted to occur  with one power plant unit in
        operation.  Although poor spawning occurred in 1977,
        a good year class of gamefish was apparently pro-
        duced in  the East Fork in 1978.
      The spawning success  of pike and walleye  (Stewart,  1978;  Stewart,
 1979) during the last two  years  will  be  examined  in  further detail  in
 order to predict effects of stable flows during April  on gamefish
 spawning success.  These data are important since they were collected
 after closure of Morrison  Dam and two quite different  flow regimes
 were represented:  an extremely  low flow period  in April of 1977,
 and a higher flow in April of 1978 which was,  however, still below
 average for the historical period.

      During both years walleye and northern pike  in  spawning condition
 were found in all three Forks and in the main  Poplar River.  In the
 low flow year of 1977, there was an apparent failure of  the walleye
 year class on the East Fork.  In April  of 1978,  there were many more
 larvae of both walleye and pike collected, indicating increased
 spawning success when compared with 1977.  The East  Fork station
 referred to as Cromwell had the highest mean density of walleye eggs


                                     231

-------
per sample when compared to all other 1978 sampling stations.  More-
over, In 1978 numbers of young-of-the-year walleye per mile on the
East Fork increased to about 13 times the densities measured 1n 1977.
Over the entire river basin 1978 densities of young-of-the-year
walleye were approximately double the 1977 densities.  There was also
apparently a successful 1978 year-class formation of northern pike
on the East Fork as evidenced by the occurrence of ripe spawners and
young-of-the year fish.  It must be emphasized, however, that there
are no actual baseline evaluations of normal fish spawning in the
Poplar River.  Therefore, although 1978 was a good year for year
class formation, 1t may have actually been less than the potential
production under optimal flow conditions.
     All of these data Indicate that the April, 1977, flows on the East
Fork were not sufficient for successful gameflsh spawning, while the
flow regimes 1n 1978 were adequate for the formation of a good year
class.  The conclusion regarding the relative success of the 1978 East
Fork spawning of walleye 1s further substantiated because there probably
was a reduced spawning population due to winterkill.  The large mortal-
ity of walleye observed 1n that area during February and March was due
to low dissolved oxygen concentrations below the 1ce cover (Stewart,
1978).  Thus, the spawning success might have been even greater with a
normal size spawning population.

     Pike typically spawn among submerged vegetation during high flow
or flood conditions.  Several studies indicate that pike prefer sub-
merged terrestrial vegetation such as native grasses, mowed hay or
wheat stubble for spawning substrate (McCarraher and Thomas, 1972;
Forney, 1968).  Others have found, however, high utilization of sub-
merged plants such as Myriophyiium (Frost and Kipling, 1967) or
emergent* such as sedges or rushes (Franklin and Smith, 1963).  Appar-
ently, flooding beyond the primary channel 1s not necessary for success-
ful pike spawning 1n the Poplar River._.This .1s.evidenced by the
occurrence of a peak flow of only 80 cfs during April of 1978.  In
order to overtop the main channel in the East Fork, a flow In excess
of about 200 cfs would be required.

     Examination of the flow data presented in Table 5.6-8 reveals
that during 1977 the East Fork experienced very low flow conditions.
The East Fork April flows at the border and Scobey stations were
considerably less than (~50 percent) natural or historical 10 percent
frequency flows (Table 5.6-9).  Moreover, peak April flows reached
only 11 cfs.  This condition probably resulted from a combination of
an extreme low runoff year and the blockage of flow at Morrison Dam.

     The 1977 Middle Fork flows at the border were relatively higher
since there 1s no Impoundment on that Fork.  The April flows were about
20 percent higher than the 10 percent frequency flow on an historical
basis.

     The April, 1978, East Fork flows (average and peak) at the
International Boundary were approximately equal to the 1977 measure*
ments.  However, flow accretion in the U.S. East Fork sub-basin resulted
In higher peak and average flows 1n the lower East Fork near Scobey
than occcurred 1n 1977.

                                  232

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                                                     Table 5.6-8



                        COMPARISON OF  1977-1979 SPRING aOMS AT SELECTED POPLAR RIVER STATIONS
ro

r*.
Ok
i— i
CO
Ot
"
"
cr»
i— i
MARCH
APRIL
MAY
MARCH
APRIL
MAY
APRIL
MAY
Flow (cfs) at Stations
East Fork
at Border
Peak
5.8
2.9
58
6.2
3.3
3.9
270.0
139.0
Average
2.6
2.4
13
3.6
2.7
3.0
143.0
43.9
East Fork
at Scobey
Peak
22
11
164
220
80
10

™
Average
8.3
6.6
17.9
69.7
24.5
6.1

~
Middle Fork
at Border
Peak
15
15
82
829
709
56
1620
155.0
Average
9.5
11.1
12.4
225
75.4
25.6
325.3
59.7
Main River
at Poplar
Peak
168
210
42
4610
4630
205

-
Average
112
122
31.3
1163
640
150

-

-------
            Table 5.6-9

PREDICTED AVERAGE APRIL FLOWS (cfs)
   IN THE EAST FORK POPLAR RIVER

Station 1
East Fork
at Border


Station 3
East Fork
near Scobey



Scenario
1
2
28
29
32
1
2
28
29
32
PERCENTILE
90
308
301
270
249
63.3
492
437
398
221
50
28.6
28.6"
11.4
2
2.2
48.0
48.4
23.0
20.4
17.7
10
7.7
7.1
1.0
1.0
1.0
13.7
4.3
2.2
0.04
               234

-------
     These comparisons Indicate that average spawning-period flows of
2.4 to 6.6 cfs are not adequate for successful game fish spawning in
the Poplar River.  However, as the average flow in the same river
reach increased to 2.7 to 24.5 cfs, a good year class was formed.
During the successful spawning period, peak flows ranged from 3.3 to
80 cfs, while the poor spawning period was characterized by peak flows
of 2.9 to 11 cfs.

     Comparison of 1977-78 East Fork flows with predicted flows under
apportionment reveals that the measured 1978 average April  flows were
only slightly higher at Stations 1  and 3 than the predicted flows
under scenario 29 (i.e.,  2 units at 1985 water use)(Table 5.6-9).
Therefore, with up to two 300 MW units, the walleye and pike
spawning on the East Fork should be approximately equal  to the 1978
level of success with a return period of 2 years.  However, in one out
of ten years with one or more units in operation, the April East Fork
flow would average only 0 to 4.3 cfs, resulting in severe adverse
effects on game fish reproduction.   Based on the observed spawning-
flow relationships in the East Fork, it is expected that the flow
apportionment has a lower potential for adverse impact on fish spawning
in the main river and middle forks.  However, the apportionment will
also affect flows in the  main river and long-term effects on stream
morphology may occur.
     Recent fish data collected by Stewart (1980)  provide further evi-
dence for the influence of streamflow on spawning  success of walleye and
northern pike 1n the Poplar River.  In 1979,  there was above average
runoff in combination with spring releases from Cookson Reservoir.  The
1979 average April  flow at the East Fork Border station was 143.0 cfs,
compared to 1977 and 1978 flows of 2.7 and 2.4 cfs, respectively.  The
higher 1979 flows resulted 1n the formation of strong year classes as
evidenced by high densities of young-of-the-year walleye and northern
pike In the East and Middle Forks.

     The relationship between spring flow and year class recruitment for
the period 1977-1979 is diagrammed in Figure  5.6-4.  Abundances of
young-of-the-year walleye and northern pike at downstream stations show
a positive correlation with mean April flow near the border in both the
East and Middle Forks.  Coefficients of determination (r2) for the wall-
eye and northern pike were 0.84 and 0.73, respectively.  Although these
data were from two different river sub-sections, and some data are esti-
mates due to low collection numbers, they do  provide an indication of the
strong relationship between flow rate and year class recruitment for both
species.  Flow appears to be a stronger predictor for young walleye sur-
vival than for northern pike as evidenced by  the corresponding r2 values.
In addition, the slope of the walleye data (82.29) 1s considerably higher
than that for northern pike (35.23).  Therefore, as mean April trans-
boundary flow Increases from 10 to 100 cfs the predicted density of young-
of the year walleye increases by 190/mi, while predicted northern pike
density Increases only about 80/mi.
                                  295

-------
 Si
 1
 hJ
 U
 ffl
 UJ
 >•

 b.
 O

 O



 1
     500- •
     400 ••
     30O--
     200- •
KEY'

    A

    o
    WALLEYE

    NORTHERN PIKE

	 BEST FIT LINE FOR WALLEYE

	BEST FIT LINE FOR PIKE
                         10                 100

                MEAN APRIL TRANSBOUNOARY FLOW (cfs)
                                               1000
Figure 5.6-4
  RELATIONSHIP  BETWEEN  FLOW AND YEAR-CLASS FORMATION
  OF GAME FISH  IN THE EAST AND MIDDLE FORKS OF THE
  POPLAR RIVER
                            236

-------
     The flow-spawning success relationship presented in Figure 5.6-4
may be used to provide a quantitative estimate of impacts on fish popu-
lations due to the power plant operation and apportionment.   Based on
natural and historical April  transboundary flows  (scenarios  1 and 2)
the mean young-of-the-year class strength for walleye and northern pike
is about 235/mi and 77/m1, respectively (Table 5.6-10).

     Operation of one 300 MM unit (scenario 28) would result in a 32
percent reduction 1n the young-of-the-year walleye density during a
median flow year.  With two 300 fW units and the  1985 level  of develop-
ment (scenario 29) the predicted impact would be  a greater than 90 per-
cent reduction in young-of-the-year walleye densities.   The corresponding
reductions in northern pike densities for scenarios 28 and 29 are 42
percent and greater than 87 percent, respectively.


     Several important points should be emphasized regarding the flow
related impacts on fish:

     0  The predicted impacts are for the lower portions of
        the East Fork.  The impacts on the already marginal
        fish habitat in the upper East Fork will  probably
        be greater.

     •  The impacts are predicted for median flow conditions
        under the indicated apportionments.  During low flow
        years (e.g., tenth percentile) the impacts under
        apportionment would be considerably greater, probably
        resulting in complete failure of the year class in
        the East Fork.

     t  The predicted impacts are based on the maintenance
        of currently existing channel morphology and sub-
        strate type.  Flow related  impacts on such physical
        conditions would compound the overall biological
        impacts.

     •  Impacts on young-of-the-year gamefish are not neces-
        sarily manifested directly  as changes  in  the size of
        adult fish populations.  Density dependent mechanisms
        may act to ameliorate the initial poor year class
        formation, resulting  in less effect on subsequent
        older age groups.

     It should also be emphasized that the preceding flow-recruitment
relationships are for transboundary flows only and were conducted
primarily to illustrate the apparent influence of instream flow on one
measure of fish production; I.e., young-of-the-year class abundance.
As mean April transboundary flows are reduced below 10 cfs, the relative
decline in young-of-the-year abundance is high due to the logarithmic
relationship described 1n Figure 5.6-4.  This is  illustrated by the
relatively large difference between the 1977 and 1978 young-of-the-year
walleye abundances (3 vs. 69) when the respective transboundary flows
were only 2.4 and 2.7 cfs.
                                      237

-------
                               Table 5.6-10

   PREDICTED  RELATIVE  IMPACT OF FLOW APPORTIONMENT ON YOUNG-OF-THE-YEAR
                 CLASS STRENGTH OF POPLAR RIVER GAME FISH
Scenario
1-2, Natural -
Historical
28 Apportionment,
1975 use
29 Apportionment,
1985 use
No. of
Power
Plants
0
1
2
Mean
April
Flow (cfs)
28.6
11.4
2
Predicted
0+ Density*
(No. /Mile)
Walleye
235
160
<20
N. Pike
77
45
<10
Percent
Reduction
Wai 1 eye
0
32
>90
N. Pike
0
42
>87
0+ means young-of-the-year class.
                                  238

-------
     However, as previously indicated,  there was  considerable  flow
accrual in the East Fork during 1978, resulting in  a  mean  1978 flow at
Scobey of 80 cfs compared to only 11 cfs  in 1977.   Moreover, the egg
abundance data of Montana Fish & Game also indicate the  much higher
spawning success in 1978.  Although walleye and egg production was
relatively high tn 1978, the young-of-the-year abundance was still
considerably lower than that observed in  the high-flow year of 1979.
This relationship suggests that flow-related effects  on  fish continue
to operate after egg deposition and that  low spring flows  may  reduce
egg hatching or larval survival even though egg production is  high.


     Mitigation of flow related impacts on Poplar River fish populations
would  require maintenance of specified instream flows by controlled
reservoir releases.  Two types of flow regimes would  be required:

     •  Maintenance of flow required to provide spawning
        habitat for gamefish during April-May.

     •  Maintenance of peak flows to preserve  channel
        morphology.


     Based on the fish data collected by  Stewart  (1980), it appears that
a transboundary flow of at least 10 cfs during April  and May would  insure
the successful spawning and rearing of  both walleye and  northern pike in
the mid and lower East Fork.  Although  some recruitment  would  occur at
average flows between 2 and 10 cfs, the long-term effects  of such flow
regimes would most likely be a decline  in the  East  Fork  gamefish popula-
tions.   It should be emphasized, however, that the  production  of young
gamefish would increase at flows of 10  to 200  cfs.  Therefore, a spawn-
ing period flow of 10 cfs should be considered as a minimum for maintain-
ing gamefish spawning and rearing at a  level that would  sustain gamefish
recruitment in parts of the East Fork.

     Based on the flow modeling results,  the operation of  one  300 MW unit
with 1975 water use (scenario 28) would result in a median April trans-
boundary flow of 11.4 cfs.  Under such  flow conditions there would be
successful gamefish recruitment in the  East Fork  in average or high flow
years,  if channel morphology were maintained.   However,  during low flow
years (e.g., 10 percentile, Table 5.6-9)  there would  be  insufficient flow
under the apportionment schedule for successful  gamefish spawning.   It is
during such low-flow years that flow augmentation by  increased April-May
reservoir releases would provide mitigation against adverse impacts on
fish populations.

     The previous analyses in this section indicate that a peak flow of
about 715 cfs would be required to provide sufficient scouring of fine
material to maintain the present riffle-pool  configurations.   The required
duration of the peak flow is unknown;  however, it would most likely be in
the range of 0.25 days to 41 days.  Since flows  of this magnitude have not
been historically maintained for a monthly period,  the required duration
of peak flows is probably nearer the lower limit of the indicated range.
In order to provide optimal mitigation, the peak flow release should be
provided shortly before the spawning period in April-May.
                                    239

-------
      The Biological  Resources Committee (BRC)  of the  International  Poplar
 River Water Quality  Board (IPRWQB,  IJC, 1979)  has provided  estimates of
 water requirements in the East Fork necessary  to meet various  biological
 objectives.  The objectives for maintenance of gamefish  spawning  and
 rearing habitat are  15 cfs in April and 10 cfs in May at the  International
 Boundary.   The BRC's April recommendation is higher than the estimate of
 10 cfs contained in  this document.   The committee's recommended require-
 ment for maintenance of channel integrity is an 18-day release, consisting
 of at least 123 cfs  for 16 days and a peak of  700 cfs for two  days  within
 the period.  The BRC's peak flow recommendation is the same as the  flow
 requirements presented in this document; however, no  duration  of  flow was
 contained herein. Based on our evaluation of  the overall range required
 (0.25 to 41 days), the BRC estimate would be of comparable  magnitude.

      An evaluation by Draper (1979) of historical spring peak  flows on the
 East Fork during a 46-year period indicates that a two-day  peak flow
 greater than 700 cfs has occurred in 30 percent of the years.  Peak spring
 flows exceeding 700  cfs for a single day have  historically  occurred in
 43 percent of the years.  These data provide an estimate of the baseline
 frequency of peak flows necessary to maintain  current channel  morphometry.

      The analyses of Draper, 1979,  and computations conducted  as  part of
 this Impact analysis indicate that  with up to  two 300 MW units in operation
 a  two-day reservoir  release of about 700 cfs could be attained at approxi-
 mately the same annual  frequency as has occurred historically  for the last
 46 years.   However,  operation of the reservoir with four 300 MW units would
 result in a much lower frequency of reservoir  spills  exceeding 700  cfs.
 With four-unit operation such spills would be  available  during a  maximum
 annual  frequency of  10 percent.  The actual  potential  for such spills would
 probably be considerably less than  1 year out  of 10,  however.

      These analyses  indicate that with proper  reservoir  operation a channel
 maintenance flow could be released  from Cookson Reservoir at annual
 frequencies approximately those during the last 46 years.   Such releases
 should be  sufficient to maintain the riffle-pool  configuration necessary
 for gamefish spawning and survival.

      Montana  Department of Fish and Game (1979)  has recently published
 recommendations  for  instream flows  to protect  walleye  and northern pike
 in  the  Poplar River.  The April  and May recommended flows are  the same as
 the  BRC's  estimates,  i.e.,  15.0 and 10.0 cfs,  respectively.  Table 5.6-11
 presents the  recommended flows  for  the remainder  of the year for  both upper
 and  lower  reaches  of  the East Fork.

      Flow  recommendations  (Montana  Department  of  Fish  and Game, 1979) were
 based on the  previously  discussed spawning flow requirements and channel
maintenance flows.   In addition, flows  for the  remainder of the year were
 based on the observations  that  game  fish  seem  to  be maintained at flows
 less than mean flows.  The months of January and  February are exceptions
 in that the recommended  flows are higher  than mean  flows due to the poten-
tial for under-ice mortalities  at low flows.
                                      240

-------
                           Table 5.6-11
RECOMMENDED INSTREAM FLOWS FOR THE EAST FORK OF THE POPLAR RIVER
Month
January
February
March
April
May
June
July
August
September
October
November
December
East Fork Flow (cfs)
Upper Reach*
2.0
2.0
5.0
15.0
10.0
5.0
3.0
3.0
3.0
3.0
2.0
2.0
Lower Reach"1"
3.0
3.0
5.0
15.0
10.0
5.0
4.0
4.0
4.0
4.0
3.0
3.0
      Boundary to Highway 13 bridge
      Highway 13 bridge to mouth
                             241

-------
     The overall effects of Apportionment VI on Poplar River game fish will
be primarily associated with changes in spawning period flows and channel
forming flows.  The effects of modified instream flows during the remainder
of the year are much more difficult to quantify.  Although predicted flows
under apportionment are less than recommended instream flows under low
flow conditions, the effects on fish are unknown.  A beneficial effect of
apportionment may exist, however, during January-February of low flow
years.  Under such conditions, natural (predevelopmentj flows may reach
very low levels (see Figure 5.2-16).  Under the apportionment schedule,
flow would be maintained at 1.0 cfs, only slightly less than existing
conditions (1975 use and reservoir) which would tend to mitigate against
under-ice mortality of ganefish.  Therefore, the 1.0 cfs release would
tend to mitigate against winter gamefish mortalities although it is lower
than the Montana Department of Fish and Game recommendation of 2.0 cfs
for the upper East Fork.  Actual flows would be higher due to ground water.

     The evaluation of flow related impacts on fish has been oriented
towards walleye and northern pike, the two major game species in the Poplar
River.  Modifications in flow may effect other species as well; however,
impact generalizations are difficult to develop due to the variety of fish
species present and the lack of specific life history information on non-
game species.  Some species may be adversely affected by reduced flow,
while others may benefit from conditions under flow apportionment.

     Modified flow regimes can also be expected to influence the community
composition of benthic macrolnvertebrates in the Poplar River.  Previous
studies have indicated that many of the Ephemeroptera and Trichoptera of
the Poplar River are dependent upon flowing water habitat.  The long-term
changes in stream morphometry predicted under apportionment will result
in a reduction of stream dependent taxa and an increase in macroinverte-
brate fauna adapted to ponds or slow moving streams.  The overall effects
are difficult to assess due to the complex interrelationships of potentially
lowered densities due to the loss of riffle habitat and the potential in-
creases due to stimulation of macrophyte production.
                                      242

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Saskmont Engineering Company, Ltd.   1979.   Evaluation of Recirculating
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Schaefer, J., et.al_.  1978A.  Costs of  dryland  crop production in Sheridan
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Schaefer, J., et al_.  1978B.  Costs of  irrigated crop production in Blaine
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Schwab, G.O., R.K. Frevert, T.W. Edminister and K.K. Barnes.  1966.  Soil
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Shourbagy, N.E. and A. Wallace.  1965.   Sodium accumulation and sodium
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                                   253

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                                254

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                                 255

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                                   256

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Environmental Protection Agency.  August, 1977.
                                  257

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                              7.   Public Comments
      The Draft EIS was made available to the public  on  August 15,  1980.
.The public comment period was open until October 20, which  was 45  days after
 the notice was published in the Federal  Register on  September 5.   The public
 hearing on the Draft EIS was held September 23,  1980, at 7:30 PM at  the
 Scobey Parish Center in Scobey, Montana.  Testimony  was heard from 16 people.
 The letters and written responses are included in Part  A and  the excerpts
 from the public hearing record and the responses are included in Part B.
 All comments have been addressed by a response in this  chapter, a  change
 in the DEIS, or both.  A list of commentors is given below.
                                   Part A
      Agency
 Saskatchewan Environment
 Environment Canada
 Agriculture Canada
 U.S.  Department of the Army
 U.S.  Department of Health &
    Human Services
 U.S.  Department of Housing &
    Urban Development
 U.S.  Department of Interior
 Office of Area Director
 U.S.  Water & Power Resources Service
 U.S.  Geological Survey
 U.S.  Soil Conservation Service
 Montana Lieutenant Governor
 Montana Water Resources Division
 Three Corners Boundary Association
 Daniels County Health Department
 Missouri River Basin Commission
 District Sanitarian
 Montana Historical Society
 Morrison-Maierle, Inc.

 Fort  Peck Indian Tribe
     Name

R. Carter
W. Draper
D. Cameron
A. Thomsen
T. Moore

R. McKinney

J. Rathlesberger
T. Whitford
0. Marcotte, Jr.
C. Geiger
V. K. Haderlie
T. Schwinden

L. Humbert
M. Fitz
C. Hanson
E. Gustafson
M. Sherfy
M. Watson
R. Schneekloth
D. Johnson
J. R. Sims
                                  258

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                                  Part B
     Agency
Montana State Representative
Montana Air Quality Bureau
Daniels County Commissioner
Three Corners Boundary Association

Northern Plains Resources Council

Daniels County Women Involved In Farm
   Economics
     Name

Mr. D. Nathe
Mr. H. Robbins
Mr. B. Tande
Dr. J. Sims
Mr. M. Gunderson
Mr. M. Halverson
Mr. L. Humbert
Mr. E. Lund
Mrs. H. Waller
Mr. 6. Farver
Mrs. A. Danielson

Mr. A. Lund
Mr. B. Cromwell
Mr. J. Wolfe
Mr. K. Lee
                                  259

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                                                              Saskatchewan
               Environment
ro
o\
o
Sihfli 1065 Vlelorl* Avo
Regln*. Cinicta
84P JVS
                                                             File P7-4-14

                                                             October 16. 1980
Ivan H. Dodson
Director, Montana Office
Environmental Protection Agency
Federal Building, Drawer 10096
301 South Park
Helena. Ht.  S960I
USA

Dear Mr. Dodson:

              Draft Environmental  Impact Statement
              for "Impact of Canadian Power Plant
              Development and Flow Apportionment on
                     the Poplar  River Basin"

I would like to express the appreciation of this department 1n
having been provided the opportunity to comment on the above-noted
draft environmental Impact statement.  The Poplar River development
Is a project which has received  much prior study both at the
provincial and the International level.  He are therefore, particularly
interested In your study Insofar as  H represents the environmental
Impacts from the American perspective.

The documents provided us were circulated to several departmental
personnel having expertise In the various Impact areas dealt with
In the report.  The review that  was  undertaken was qualitative rather
than quantitative.  In other words,  we did not attempt to duplicate
nodelling results, for example.

The report evokes a largely favourable reaction from our department.
The type and degree of the various Impacts are generally well
documented and In most respects  agree with work done here 1n
Saskatchewan.

Some items, due to their presence In or absence from the report did
attract our attention and we offer the following comments for your
consideration in the preparation of the final Impact statement. The
cements are organized under four headings; Project Description, Air
Quality. Mater Apportionment and Water Quality.
                                                                                                                   lv«n U. Dodson
                                                                                                         October 16,  1980
                                                     Project  Description

                                                     It Is  felt that the report would have benefitted substantially  from
                                                     a more detailed project description.  In discussing specific  impacts
                                                     the report made reference to various development scenarios.   In many
                                                     cases  It was not made clear which scenario was the most  probable and
                                                     which  proposals were more remote possibilities.   From our point of
                                                 1)   view,  a  two unit, 600 W development is most probable and therefore
                                                     the Impacts from such an installation should receive greater  attention
                                                     than those resulting from a single unit or a four unit project.  This
                                                     could  be accomplished If the most likely development scenario was
                                                     emphasized and other proposals were given secondary status.

                                                     It should be made clear that we do not argue with the Investigation
                                                     of the full range of possible Impacts.  Rather,  we feel  it Important
                                                     that the reader be able to grasp relatively quickly the  nost  probable
                                                     consequences of the project Implementation.

                                                     The Saskatchewan Power Corporation (SPC) would be the best source of
                                                     information regarding the project.

                                                     Air Quality

                                                     The modelling and Interpretive work described In the report is  a
                                                     confirmation of our own previous Investigations  and opinions.

                                                     It may be of value to you to be aware of our control  philosophy as
                                                     it applies to this plant.  The Regulations under The Air Pollution
                                                     Control  Act stipulate the following standard for S02,  for  example:

                                                                         1-hour       450 jig/m'
                                                                        24-hour       ISO jjg/m*
                                                                         1-year        30 ug/m

                                                     The Coronach Power Plant will be controlled to meet this standard.  A
                                                     continuous monitor will be placed In the critical  azimuth  range of 120°
                                                     to 170 .  Any exceedance of this standard will  lead to a requirement
                                                     of SPC for the appropriate level of emission control.

                                                     With respect to the licensing of unit No.  2. a decision  with  regard to
                                                     SO. emission control will be based on the monitoring of  the operation
                                                     ofunlt  No. I and modelling studies of the two unit operation.
                                                                                                                            Responses to Saskatchewan Environment

                                                                                                              1)  Sentences have been added to  1st paragraph of Chapter II p 5 stating
                                                                                                                  that present plans call  for operation of 2 units (300 MM each).   Two
                                                                                                                  additional units could be built in the future and are also considered
                                                                                                                  In the EIS.  Present plans for air quality controls and operation of
                                                                                                                  the ash lagoons have been added to this chapter also.

                                                                                                              2)  Information on air quality standards has been added to Chapter 3
                                                                                                                  •Alternatives*.

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ro
ot
           3)
           4)
           5)
               Ivan W. Godson
                                                     October 16.  I960
Water Apportionment

The draft report appears to contain Misinterpretations of the  recommended
apportionment agreement.  In the case of the Middle Fork  Poplar River.
the report evaluates a 60 per cent use of the natural  flow In  Saskatchewan
while the reconmended apportionment permits a maximum  of  40 per cent use
of the natural flow.  This Is of some concern since such  a Misinterpretation
results In an apparently larger Impact on downstream flows than should.
In reality, be the case.

The several apportionment options studied and the Impacts fro* the* are
difficult to Interpret.  Could the results of the studies be simplified
In the suMmry chapters of the report in a more understandable fora?
Hater Quality

The sections of the report dealing with water quality suffer somewhat
because of the numerous options analyzed and the difficulty, as  stated
earlier, of Identifying the nost probable water quality Impacts  as
opposed to those having a low probability of occurrence.

As you are aware. SPC has made modifications to the originally proposed
ash lagoon operation.  It will be a sealed, reclrculatlng  system with
no decant.  Our approval of the ash lagoon operation under The Hater
Resources Management Act prohibits overflow or discharge from the lagoons
to Cookson Reservoir or the East Poplar River.  Further,  if monitoring
around the ash lagoons Indicates seepage nay be greater than five litres
per second to Cookson Reservoir or two litres per second to the  East Poplar
River, SPC will be required to provide this department with mitigation
proposals.

Regular and comprehensive monitoring of ground and surface water quality
Is also a stipulation of the approval.

I hope that the foregoing comments will be seen as being 1n the  spirit
of constructive criticism and that they are consequently of value to
you.  I reiterate to you the overall positive reaction we  have to your
report
               If we can be of further assistance to you In regard to this  matter.
               free to contact me at the above address.
               Yours/
              X  L. Carter
               Deputy Minister.
                                                                    feel
                Responses  to Saskatchewan Environment

3)  The sumnary (p.   1)  Incorrectly  stated  that the now on cue
    Fork would be reduced  by 60 percent.  The correct value of a 40
    percent reduction was  used  In the modeling studies and analysts of
    impacts.

4 )  Table F-2 showing differences In West and Middle Fork flows under
    the alternative apportionments has  been moved  from the Appendix to
    Section 3.2.1.   Other  changes were  made in this section to emphasize
    effect of the alternatives.

S)  Ash lagoon operation as presented here  was discussed on p 21 of the
    draft EIS.  Requirements for monitoring and mitigation If seepage
    exceeds specified limits have been  added.  A statement has been added
    to to Section 5.3 to indicate that  scenarios 4A and 8A,w1th the ash
    lagoon seepage Included, represent a worst case and that SPC plans on
    reclrculatlng the ash  lagoon seepage.

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ro
                                        - 3 -
14)   6.  P. 22,  4th para.   The first unit  is  now ready for  start-up
         and  the second  is  under construction.

15)   7.  p. 60,  last para.   The wind rose  plots referred  to seem to
         be  in  Appendix  B-l as opposed  to  A-8.

16)   8.  P.  72,  2nd and  3rd paras.  Does  this discussion  deal with
         the  highest values in all directions or the areas  of highest
         SO2  concentrations in the U.S. only?  Interim EPA  model-
         ling results  (IJC  Appendix E.  p.  5-77) show the  highest
         annual S02 concentrations west of the plant between      *  -
         Coronach and  Rockglen.  The  isopleths of annual  S<>2 con-
         centrations  In  Figure 5.1-4 have  not been  fully  completed  to
         the northwest of the plant to  show this.

17)   9.  P.  126, last  para.  The  figure of 30 ac-ft/month of sub-
         surface {low  from  the ash  lagoons to the East Pork seems
         high.   This equates to about  14  L/s whereas the  predicted
         ash lagoon seepage to the  river  Is expected to  be  less than
         2 L/s.

18)   10. P.  127 to p.  143.   The crop  yield reduction estimates pre-
         sented are dealt with  in detail  in the attached  comments by
         Dr. Cameron  of  Agriculture Canada.  Some additional contents
         arc as follows.

          (1)    The crop yield  reduction tables on page 132  to 141 are
                 open  to major misinterpretation  In the  manner they are
                 presented.  The  tables should contain  the expected
                 frequency and actual  estimated quantity of crop  lost
                 over  an extended  time  period.   Presenting only
                 "maxlmusi yield  reductions" as a percent stakes it dif-
                 ficult to appreciate the extent of crop loss on  aver-
                 age or even  in  the majority of  years,  since  It  is a
                 condition that  would rarely occur.   Also, It should  be
                 established  whether the crop could have been  irrigated
                 in  that  season  without the power  development since  It
                 would have  been a very low run-off year.

 19)        (il)   P.  131.  The method of developing the regression equa-
                 tions  for boron (and correspondingly the curves  in
                 Figures  C-l.l  to G-1.4  in Appendix G)  is highly  ques-
                 tionable.   It  appears that the  Baton and Fox  irriga-
                 tion  water  boron concentrations have been reduced  sub-
                 stantially  to  account for  soil  adsorption in obtaining
                 the "equilibrium In soils  solution*  concentrations
                       Responses to Environment Canada


14)        Current status of plant Is known.   Paragraph has been updated.


15)        Text reference corrected as stated here.


16)        The discussion on p. 72 of the draft EIS deals with the predicted
     SOo concentrations In the U.S. shown In Figure 5.1-S.  In general, the
     EIS deals only with possible Impacts tn the U.S.  The text has been
     changed to Indicate that the SO- concentrations referenced tn this
     section are those that occur In the U.S.


17)        Seepage given here referred to no  reclrculatlon case.  Sentence
     has been added to explain planned ash lagoon operation which would have
     seepage of 2 liters or less.


IB)        The tables In the text are for example purposes only and the condi-
     tions under which these yield reductions were evaluated timed lately
     precede each. Complete tables showing  all losses evaluated under each
     scenario are shown In Appendix G.  These losses were computed assuming
     no moisture stress for future or present yields.  The quantity Issue Is
     not dealt with In the crop effects section.  However quantity was consid-
     ered In the economic evaluations.


19)        Full expanatlon given In Appendix  G.

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               used for deriving  these curves.  Yet  both Eaton and
               Fox used sand  as the soil in their  experiments and
               concluded  that they would not expect  any significant
               boron adsorption or fixation.  Hence,  the soil solu-
               tion concentrations would have been comparable to the
               concentrations in the water applied (simulated irriga-
               tion water).   It is unclear in this document how the
               boron adsorption capability for  sand  was determined
               and applied  to the boron concentrations of the water
               used.in  the  experiments, which ranged up to 25 mg/1
               and 32 mg/1  in the Eaton and Fox experiments respec-
               tively.   It  is probably quite valid to apply a high
               adsorption factor to the Poplar  River basin soils in
               estimating effects but inappropriate  to assume much
               adsorption in  deriving the curves  from the
               experimental data.

20)       (iii) P. 139  to  p. 141.  The percent yield  reductions pre-
               sented  in  the  tables on these pages are based on the
               In (EC  x  SAR)  vs percent yield  functions in Figures
               G-1.5 to  G-1.8 of Appendix G.   It  is  interesting to
               note that  when these same functions are applied to
               measured  saturation extract data for  the basin
               (Horpestad,  1978), one computes  an oat yield  reduction
               as high  as 92 percent at one  station  (sample  109) and
               78 percent at another  (sample  119).  Significant yield
               losses  are also indicated at  other stations and for
               other crops.  As a means of  validating the  functions,
               it would  be appropriate  to compare the yields  that
               were actually achieved  in the  sampling year with  the
               yields  predicted by using the  functions.   In  other
               words  how close was actual crop reduction  at  sampling
               point  109 to  the 92 percent  reduction  predicted by
               applying the  function.   Presenting this  information
               would  help qualify  the  accuracy of the yield  reduc-
               tions  estimated on  pages  139  to 141.

21)        (iv)  P.  140, Table 5.3-4.   The source data  used for this
               table  should  be re-examined.   The  1.6  mg/1 boron  value
               for  the Fort  Peck  Reservation soils,  at  least,  is
               highly questionable.   The  source document  (Horpestad,
               1978)  indicates that  these  were hot  water  soluble
               measurements  and  that 6  of  the  11  samples  were of
                insufficient  quantity to conduct boron analyses.   For
                these samples boron was listed  as  "non-detectable".
               Yet  it appears  that all 11  values  were used in the
               averaging process,  assuming  the 6  "insufficient
               sample" values  had  0  mg/1  boron.


                       Response to Environment Canada


20)        The calculations done  1n making this point are not a correct use of
      our methodology.  A point measurement was used as Indicative of a basin
      response,whereas our methodology was based on basin average soil  properties.
      It is quite likely that given specific data for one point 1n the  system
      that yield predictions would be  poor for any given crop.  However, on the
      average, predictions should be reasonable.  Predicted yields would vary.
      For example,  taking data  for site  #107 yields well into the 100 percent
      productivity range are predicted.


21)        The "NO" in the original  tables was Interpreted as "not detectable"
      Instead of "not determined".  The average hot water soluble boron concen-
      tration should be 3.5 Instead of 1.6.  This has been corrected in the
      final EIS.

                                    265

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22)   11.  p.   205.  The  use of Figure 5.6-4  to  predict young of year
         fish abundance should be re-assessed  because of basic
         inconsistencies in the text.  For  instance,  it is stated on
         page 200 that  the Cromwell station on the East Fork had  "the
         highest mean density of walleye eggs  per sample when
         compared to all other 1978 sampling stations" and "about 13
         times the densities" of young-of-the-year measured in 1977.
         On  the other hand, Figure 5.6-4 suggests that the walleye
         and pike populations in 1978 should have been almost
         non-existent at the average flow of about 2.4 cfs.  The
         conclusions presented in the summary  (p. 2,  2nd para) are
         evidently based on applying Figure 5.6-4 to  anticipated
         river flows without consideration  of  what has been observed
         to  occur with  low flow conditions.

23)   12.  P.  208.  Support for the IJC Biological Resources Committee
         peak flow recommendation of 700 cfs for two  days should be
         qualified by taking into account the  natural flow variation
         prior to development.  Analyses in the attached document
         entitled "Comparison of Natural Spring Flows in the East
         Poplar River with Estimated Spillage  from Morrison Dam"
         shows that 20  m3/s (700 cfs) for 2 consecutive days in
         spring occurred only 30 percent of the years under natural
         conditions and for a single day duration only 43 percent of
         the years of record.  On the other hand, the volume of water
         that would have been spilled at Morrison Dam in spring with
         two units operating during the period of record would have
         been sufficient to permit a 2 consecutive day release of 20
         m3/s in 33 percent of the years.   This comparison
         between the natural and two unit spring flows should be
         pointed out.
                        Responses to Environment Canada


  22)      Additional discussion of flow recruitment relationships is incorpor-
      ated  in Section 5.6.4.2.  The conclusions presented in the summary are
      not directly dependent on the absolute values presented in Figure 5.6-4,
      but are based on the generic relationship between spring flows and young
      of the year recruitment as discussed in this document and in the series
      of progress reports by Montana Department of Fish, Wildlife and Parks.


  23)      The comparison of peak flows under natural conditions to flows with
      the reservoir has been added to Section 5.6.4.2.
                                   266

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rv>
               OMCNTS ON CROP YDOD SECTIONS Of TIB KPA. RETORT WTITLED

                    •OffACT OF CANADIAN POWER PLANT DEVELOFHOrr AMD


                       FLOW APPORTIONMENT ON TIE POPLAR RIVER BASIN"


              _ Compiled by D.R. Cameron, Agriculture Canada, •• a critical

                        review of ona portion of the EPA Report.

                Prepared for  the  IJC Poplar River Study Committee Members.



                                  HAM POINTS OT COHCIRM


24)   1   The approach for calculating  aoil eolation concentration* of B doee not

          appear to be vary valid.


25)   2.  The TBS-to-EC cDnveralon factor  need  by EPA (1 EC • WO IDS) doH not

          appear to be correct for the  Poplar River baein waters where 1 EC S

          670 IDS.

26)   3.  The EPA predicted salt  concentration  la «oll eolation (EC,,) are generelly

          hither than  those predicted previously by Rhoadas (1979) and Cameron  (1979).


27)   4." The adjusted SAR valuee are generally uied to relate SARiw to SARje. but

          this report  uaee a  different  approach.


28)   5.  The In (SARsEC) ve. yield relationship is a novel approach that haa not

          really been  tested  before to  any great extent to my knowledge. The pit-

          fsLW of this approach, if any,  remain hidden.


29)   6   The Interpretation  of the data to derive the In (SARxCC) - yield plot, can

          be improved  considerably. There is else probably more available data in

          the literature that can be found and  used.


30)   7   The EPA yield reduced graphs  are biased In favor of higher losses  at

          lover In (SARxEC) values then would occur in reality.


31)   8   According to my Interpretation of EPA's graphs, yield reductions to

          alfalfa would be negligible.


32)   9   Predicted yield reductions for wheat, barley, and oats sau high  end

          a further nore detailed examination of the literature should be done to

          Investigate  these results.
                        e*»ponsc» to Agriculture Canada


24)        The prediction of boron effects on crop yields i.«i «*«n p.',<*«. :".y
      qualitative   (see, for example, Ayers and Mescot,  1976).  A methodology
      was developed to relate soil boron concentrations and the reaction of
      plants to these concentrations.  The methodology was developed using the
      best available data.  A detailed derivation of the Methodology and the
      assumptions  era shown In Appendix G.  Based on comments on the draft EIS
      several changes have been Made In the Methodology.


25)        Calculations Involving the conversion of TOS to EC have been changed
      according to this recommendation.


26)        For a leaching fraction of 0.1 the EPA estimates are higher, although
      for leaching fractions of 0.2 or greater the  values are comparable.


27)        The relationship between SAR In Irrigation and drainage water was
      noted by Bower. Ogata and Tucker (1968) to be
                                CAB   •  -1 *  COD
                                "^dw    frrsiwiw                       ID

           therefore        VLT -  SAR


           making  the substitution
                                     /..i


           Into 1  yields equation (3) which Is analogous to the expression of
           Kamphorst and Bolt (1976) for EC; that Is
                                  SAR,.. -VU (1-f) SAR,..
                           SAR  -—12_	!«
                                     VCF f (SP/FC)


28)        The idea of using combined SAR and EC values to estimate  crop yield
      losses was developed after review of the literature on this subject.  The
      functions were parameterized using published  values of the three variables
      EC. SAR and  yield.  In son* cases SAR was not directly reported but calcium,
      magnesium, and sodium data were Included and SAR was calculated by Tetra Tech.
      This approach has not been used by others to  our knowledge.


29)        Me feel that the data  have been regressed properly.   The regressions
      were based on linear least  squares,  where the procedure Is subjective.
      as Cameron has pointed out.  Is in the  selection of the threshold  for declining
      yield.  Me did not as he has  stated, use all   the 100 percent yield  data  In
      the regressions.   Only the  incipient 100 percent value (i.e.  the  farthest
      100 percent  value to the right) was used  in the regression.   This incipient
      point should be Included.   Other thresholds could be subjectively set.


30)        See response 29.


31)        Based on our interpretation of the available data we feel justified
      In retaining our  conclusions  of crop yields' due to salinity effects.  It
      should be pointed out that  the yield values on page 13 of Cameron's commits
      attributed to EPA are not the correct  values  because the diluting effect
      of seasonal  precipitation has not been Included In his calculations.


32)        An extensive literature  review was conducted to obtain the data used
      to develop our Methodology.

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r\>
Ol
oo
      Boron:   Appendix Cl p. 200


          The approach und by EPA le rather unique.  They ore ualng • different

      technique,  elnoet a "backdoor" technique, for eatlnetlng tell eolutlon equili-

      brium B concentration!.  Their prlae iiiumptloa (which i* reeeoneble) la that

      the B aoll eolutlon concentration la directly related to the edeorbed B con-

      centration In the eoll.  There are, however, lome probleeia in developing thle

      concept:


33)   I   From the literature they related Intercept! and alopea of the Langmulr

          adaorptlon leotherm to CEC.  Their beet flte accounted for only 101 and

          381 of the variation.

34)   2   The calculated K  end Q coefficient! of the Langmulr equation ere derived

          tram ateady-etata laboratory experlmente on dlaturbed aolle under etlrred

          or agitated condition!.  It la doubtful If euch coefflclente can be

          applied to an undleturbed atruetured  field eoll under dynamic flow

          condition!.


36)   ]   The maei balance  equation (2) doea not appeer to be correct In aeveral

          waye:

           (a)  The unit! do not Batch (I.e., e>| B/g» of eoll ve. •! B/l of eoll

               aolutlon)

           (b)  The correction factor (SF/pe) ai given  In equation  (Jb) cannot be

               applied to  the field iltuatlon.  The condition of aaturatlon  (SP) may

               apply  at  the tie* of Irrigation, but not when the equilibria con-

               centration  Be  le reached

           (c)  The moil  balance equation doee not  take Into account the maaa of

               boron  loat  by  leaching -  I.e.,  there le no  leeching fraction.


36)   4    A  more realletlc approach would have  bean ai follow*:

           •ad. - vlv  »lw - ». B. -  Vfr B^

           where  Bade  • mean °f  • adiorbed per  given unit volume of eoll,

           vlw -  volume of  Irrigation water  applied, Biw -  concentration of B In

           Irrigation  water. Ve  • volume  of  water  remaining In  the  given volume of

           aoll'after  Irrigation (end poaalbly  after plant  uie), Be -  equilibrium

           B  concentration In the  aoll aolutlon. Vdu .  volume of drainage water loat

           from  the  unit  volume  of  aoll,  and Bjw -  concentration of B  In  the  drainage

           water.
                                                                                                                                   Responses to Agriculture Canada
33)        Cameron's point is justified.  Because  the  parameters of the Langmulr
      expression have not been evaluated  for  Poplar River basin soils they had
      to be estimated from data In the literature.  The best fit of literature
      slopes and Intercepts of the linearized Langmulr plots with a parameter
      which had been measured in the Poplar basin was  with the soil cation ex-
      change capacity.  These regressions were accomplished with conventional
      least squares techniques.  The literature data encompassed many types of
      soils and hence a wide variation of Langmulr coefficients.  The power
      functions which relate Langmulr slopes  and Intercepts to CEC represent
      the results of an averaging process.  Because of the wide variation around
      these mean values, the coefficients of  determination of these regressions
      are low.  However, no other alternative for estimating these coefficients
      was better.  We note that an Independent analysis of boron adsorption
      capacity (Sasknont  Engineering,  July 1979) based on field measurements
      gave 0.011 mg-B/g.  The value used  for  the upper basin In our calculations
      was 0.0187 mg-B/g.


34)        This point is debatable.   Agitated, dispersed soils will probably
      have higher Q values than Jit situ soils  because  aggregates will  be broken
      up exposing more sites for adsorption under experimental conditions.  This
      may be countered by the fact that this dispersion also provides increased
      gradients for Introduction of native boron Into  solution which is In turn
      available to occupy some of the adsorption sites.  In another regard, Tanjl
      (1970) studies boron adsorptlon/desorption In soil columns for these dif-
      ferent soils In which the field profile  was reconstructed and each horizon
      compressed to field bulk densities; in other words. In situ conditions were
      approximated.  Langmulr 'K' values were  higher (by aTactor of 2) on the
      average 1n_ situ but lower for one soil.  From these observations no definite
      conclusion corTbe reached as to the relative magnitudes of parameters In
      situ versus In laboratory experiments.   Certainly no quantitative adjusT-
      ment is supportable on the basis  of these limited observations.
                                                                                                          35)        a)  The correct units of the parai
                                                                                                                equation are given In Appendix 6.
                                             sters in the boron mass balance
                                                                                                          36)        The mass balance equation has  been revised to include drainage of
                                                                                                                boron during leaching.  The equation can still be solved by hand using
                                                                                                                the quadratic formula as shown In the  revised Appendix 6.

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ro
CT»
vo
               the above •»••  balance equation la a little wore  complicated to solve
               (although by Baking certain aaauaptlona  It  can be done).   The pleat  uptake
               at vater ebould be  Included In the veter balance  and perhapa B uptake by
               plaata.
      37)   5.  Equation  (3b) aod thus equation (4) are  derived with eone aaauajptlooa
               (not preacated  In the report)  that appear to  be inaccurate.   Ualcaa  EPA
               can abow  the rationale of their aaauaptlooa uaed  to derive the ma*a  balance
               equation, their reaulta have little validity  at thla atage.
38)   1.  A note reallatlc derivation of the eoll B concentratlona vaa given by
          Khoadea (1979) and Cameron (1979) at the Scobey IJC Bearing*.
      2   A acre coapreheoalve Interpretation of the B data with regard to crop yield*
          vaa alao covered by Rhoadea and Caacroo, although their view* began to
          differ et thla point.

      TPS (EC,C) - Appendix Cl - p. 202
39)   1   The TDS-to-EC converalon factor uaed by EPA (I EC - 480 TDS) doea not
          appear to be correct for the Poplar liver baaln (1 EC • 670 TDS).
                       TPS           EPA Converalon     Poplar River Converalon
                       700                 1.46                   1.04
               i       1000                 2.08                   1.49
                      1300                 2.70                   1.94
          NOTE:  The 1C value* uaed by EPA are about 40Z higher than the  true EC
          valuea In the Poplar Xiver.
40)   2   Equation (5) la "outdated".  Work by Rhoadea and othera haa ahown that
          thla equation la not alvaya an accurate prediction of aoll aolution
          equilibrium concentrations.
41)   3.  The following table ahoua the comparison of ualng equation (3)  to predict
          aalt -equilibria* concentratlona In the ooll aa oppoeed to the BCthodology
          proposed by Rhoadea (1979) and Cameron (1979).
                         Responses  to AqiMrul u--» fan**}

37)        These equations hive been replaced *nd the Impacts reevaluated with
      the new uss balance procedure detailed under the response to Caneron's
      coments.

38)        The methods used to predict boron concentrations In the soil have been
      revised to Include the leaching fraction and to Incorporate the convents
      of CMeron and others.

39)        Calculations Involving the conversion of TDS to EC have been changed
      according to this recommendation.

40)        Cameron has used the word "outdated".  He believe a more appropriate
      Modifier Might be "not appropriate to all field situations*, as the reminder
      of his statement Indicates.   The work referred to by Rhoades Indicates that
      a short-term salt iMbalance My be allowable In the lower soil profiles
      since Most crops preferentially use water from the upper soil zones.
      Eventually these salts must be removed, however, to maintain productivity.
      Ayers and Hestcot, 1976. have stated that the crop may Maintain productivity
      using a leaching requirement  less than that predicted by the equation to
      which Cameron refers.

41)        Because of the supportive nature of the results for leaching fractions
      of 0.2 or greater we believe  we have used the correct methodology for
      estimating soil salinity.

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Predicted Equilibrium Concentration (EC,,)*


ECtH
1.0






f
- 0.6
- 1.0
- 0.6
• 1.0
- 0.6
- 2.0
- 0.6
- 1.0


LF
0.1
0.1
0.2
0.2
0.3
0.3
0.4
0.4
Iron
EPA
EC.
8.0
S.O
3.8
2.5
2.4
1.7
1.8
1.3
from Rhoadai
(1979)
- linear
average
3.7$

2.58
2.0J
1.74
fro* Cuieron
(1979)
- weighted
everege
2.93

2.17
1.83
1.60
                   •Assumed SP/FC - 2.0 and EClw - 1.0
     42)  4.   The  EPA values for the low leaching fraction (0.1) are definitely over-
               eatlmated with equation (5).  Generally, those for flood Irrigation (f - 0.6)
               are  higher concentrations than predicted by Rhoadea and Cameron, but the
               aprlnkler (f - 1.0) ere consistent at leaching fraction* between 0.2 and 0.3.
     43)   3   In light of the assumptions used In any of these proposed methods, I euspect
               that the estimates given In the EPA report for EC,e equilibrium concentra-
               tions are reasonable for leeching fractions near or greater than 0.2.

j^         SAR - Appendix Cl - p. 204
°   44)   l   i have not apent very much time examining the origin and derivation of the
               SAR equations (8) snd (9), nor do I at this stsge see any real reason to do
               ao.
     45)   2   The commonly  accepted prectlce for relating Irrigation water SAR to
               resulting soil SAR Is to calculate on adjusted SAR.  The details of this
               calculation are described by Ayers and Uestcot (1976) end briefly reiterated
               In the  IJC Poplar River reports.
     46)   3   The haiard, If any.  from sodium  (SAR) on the  Irrigated soils of the Popler
               River will be one of  reduced permeability.  The adjusted SAR's are not nearly
               high enough to ceuse  any direct  toxic effects to  the crops.
     47)   4   The SAR effect on permeability In  Irrigated lands is related to salt  concen-
               tration.  Irrigation water with  a high salt content can also have a high
               SAR without any  reduced permeability effects.  In other words,  the more salt,
               the higher  the critical SAR value  can be.
                                                                                                       Responses to Agriculture Canada
                                                                              42)        See response 41

                                                                              43)        See response 41

                                                                              44)        See response 27

                                                                              *5)        Cameron Mkes reference to the method of Ayers  and  Uestcot   (1976)  for
                                                                                    determining   soil  SAR.   First, the  adjusted  Irrigation  water   SAR    Is
                                                                                    calculated by •
                                                                                              SAR,dJ - SAR1w (1 * (8.4 - pHc))       (10)
                                                                                    where SAR(dj - the adjusted SAR
                                                                                          SARtw  • SAR of the Irrigation water,  and
                                                                                          pHc    • a parameter which Indicates the tendency
                                                                                                   of the Irrigation water  to precipitate
                                                                                                   or dissolve line.
                                                                                    Then the adjusted SAR Is used In an empirical relationship to  estimate the
                                                                                    soil SAR.  They do not present a methodology for determining the SAR of  the
                                                                                    soil solution which accounts for the leaching fraction.   Klarlch (1978)  has
                                                                                    stated that SAR values In the Poplar River should be adjusted  upward "about
                                                                                    0.5 as a result of calcium and magnesium carbon precipitation".   Sensitivity
                                                                                    analyses with the boron mass balance equation show that  much larger  changes
                                                                                    than 0.5 may result from changing the leaching fraction.   Thus.  It appears
                                                                                    that the Inclusion of leaching fraction In the predictive methodology may
                                                                                    be more Important than the dissolution/precipitation adjustment  for  this area.
                                                                                         In addition the method by which SAR Is adjusted Involves  a  knowledge
                                                                                    of the concentrations of Na , Ca . Mg , HCOi and CO, In  the  Irrigation
                                                                                    water.  These constituents were not Individually modeled  and therefore no
                                                                                    predictions were made for alternative scenarios.   Thus Equation  (9) could
                                                                                    not be utilized In our studies.
                                                                              46)        No comnent.

                                                                              47)        No comment.

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•vl
     Appendix Cl - Jo (SAR M EC) nrmuf yield* -p. 209


48)  i.  The Poplar Uvtt water* huvt relatively  low SAR value* and it 1* *erlou*ly

         doubted that SAR values will have  any noticeable effect on the crop yield*

         in the irrigated portion  of  the  Poplar  River  ba*ln.   A threshold value of

         SAR - 10.0 wa* *et  by the Ueee and Water Quality Objective*  Comlttee

          (1979) of the  International  Poplar liver Study.

49)  2   I have examined ao>t  of the  reference* u*ed to derive figure* C-1.5  to

          C-l.B.   Hone of the reeaarcher*  have plotted their data  (po**lb}y  for good

          reacoo)  in  the f**hloo proposed by the EPA when the interaction of (SAR •

          EC)  Is examined.   The idea 1* novel.  The paper by Torre* and Blnghaai  (1973)

          had little  to do with the effect of SAR, rather it concentrated on the

          effect of NO) on Mexican wheat*.

50)   3   The paper by Chang (1961) caution* on the non-linearity of  the SAR (related

          to ESP) for given value* of EC  - -

          "...The departure fro* a  linear relation when both exce** ESP and *alt are

          preient *>ay,  theoretically, hinder  the  deaonatratlon of linear correlation

          between crop  yield and a  *Ingle-value  *oll property, *uch •• ESP or coluble

          •alt* ..."

          Chang (1961)  goe*  on to  itate that "... **llne  irrigation water containing

          3000 po« dl**olved aalta did not  deprea* alfalfa  yield  unle**  the  sodium

          content of  the Irrigation water wae high ..."  (aee hi* Figure 1  below).

          HOTt:   3000 ppn  Is about three  tl»e* the expected TDS  level* in the Poplar

          River.

!>1)    *  Bernstein  and Fearion (19*6)  do *how a yield reduction In alfalfa of  12X

           (with  VAMA) as the toll ESP increeced  fro* about A.O to 20.0.  According

           to Ayirs  and Ueatcot (1976 - p. 95) tltli would be equivalent to irrigation

          water SAR value Increaae* of 3.6 to 18.0.

           Sl»llar yield decreaae*  for the untreated aolla  (without VAMA) are clot*

           to 381. showing the  effect of  lodiun on permeability end related phyalcal

           conditions that can  affect plant  growth nod yield.

           NOPE-   Thrre  are  two problems  with the Interpretation  of this data -

           (a)  Yields  In Figure  I  (fro*  Dcrstcln and  Pearson - see below)  are

           repotted av  freah uelghta  .  The author*  point out in  their paper  that
                                                                                                                                     Responses  to Agriculture Canada
                                                                                                            48)
                                                                                                            49)
          No carmen t.
          Although the paper  by Torres and Blnghaa (1973) was not intended
    to assess the effect of salts and SAR on wheat yield directly, Ca, Mg,
    and H* were reported so that SAR could be calculated and yield regressed
    on In  (EC x SAR).   SAR In nutrient solutions ranged from 0 to 72.  Yields
    were averaged across nitrogen treatments to give a mean response to salts
    and SAR.

50)       Cameron's comments  see* to point to the Importance of evaluating
    Interactive effects of both conductivity and SAR.  The predicted TOS
    levels are greater than 3000 pp* on the Cast Fork at the International
    Boundary with four 300 MM units and year 2000 levels of development.


51)       Both yields  with and without VAMA were used In the In (EC x SAR)
    versus yield regressions.


    a)    Cameron has  correctly pointed out that In the data of Bernstein
    and Pearson (1956)  the fresh weights and dry weights of alfalfa do not
    decrease  collnearly.  However, the deviation Is only 1.7 percent (I.e.
    dry weights varied between 19.3 and 21.0 percent of the fresh weight).


    b)    It  Is unclear In this comment to which "data" Cameron Is referring.
    Bernstein and Pearson's (19S6) studies had ranges of SAR from 0.9 to 48.


52)       The articles which  are noted here were available to us during our
    analysis.

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                      i
                     lilf MllwH p«rnlit>«>, DIP. M «l(«lf«
                     jritlil (HHHiim tipuli to t»f Mill •» IMal Mllow
                    • U »k» ..m. «nJ yj«M .a..1.1.4 W |»«. fcj. ««<
                    I 4lk minuet)
                                                              (Chang  1961)
                                                                                                          52) 3.
                                •XCBANOBABUt MOIUM AND rtANT T1HO
                                                                           .  281
ro
                   Pie I Erract or EiniiiiaiMU 8omon Purtmm on YinM or BUM,
                       Ctotu, <•• AtrAWA QIOWII oa T»o Sou vim an wmevr VAMA
                             (ternnceln and P««r»oo)
dry v«lght»  lacr«a»*d contlftcntly «• p«r cent  frcih  wclglit with locretalng
ESP.   (In oth«r word*, the aqulvalcat dry weight curve*  ID rig.  I (Barnttcla
•od P«r*oo) Mould not d*era««c •• iharply •• Indicated.)
(b)  Till extrapolctlon of data between citlanted SAR  valuta of  3.0 and 18.0
leave* rooa  for doubt when the hlgheat predicted river water value* are
near 9.0.  Die  Information pr«*ented 1> not detailed  enough to deteralne
a critical cut-off point (threenold point) at which jrlelde begin to decreaae.
I bellev* a  cut-off, point of SAR • 10 la cotnonly uaed for Irrigation water*.
It would *ee» that the In (SAX * EC) relationship verau* yield baa not been
widely uaed  and tected by expert* In the field.
Ihoadee (1977)  haa ahown that Irrigation water with an EC  of  l.S (over 1000 pp>)
ceo be uMd on  a aoll with a aurface ESP of nearly I) without any reduced
peraeablllty (eeo Pig. below - Rhoade* 1977).  I auapect that the EPA reaearcher*
•Ight benefit from aucb reference* aa Haa* and Hoffman (1977). Oater  and
•hoed** (197t). Ihoadee and Merrill (1975). and Ayera and  We*tcM (1976).
                                                                                                                                            (Rhoade* 1977)

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{,3)   6.  If figures G-1.5 to G-1.8 are deemed to be acceptable, then  they should be
         analysed and regressed properly.  In most cases the EPA threshold point
         for the beginning of yield reduction is far too low.  In these graphs, a
         realistic eyeball fit probably would have served a more useful purpose.
         The EPA versus my choices for threshold values are shown below:
                         Critical In (SAR z EC) threshold values
                        at which yield reductions being to occur
                  Crop           EPA criteria          Realistic Choice
                  Alfalfa            1.7                     4.0
                  Wheat              0.4                     2.6
                  Barley             1.5                     2.7
                  Oats               1.8                     3.0
         The revised EPA graphs are shown on the next four pages.  It is apparent
         that the EPA regression lines are biased to the LHS because they included
         all the 100Z yield data.  This data should have been ignored and the yield
         decrease information should have been regressed.  The more realistic
         estimates of threshold values that I have presented above are derived from
         a "best fit" line through the yield decrease data.  In one sense, the more
         realistic threshold estimate is conservative in that the EPA 1001 yield
         is too high as it is biased toward the extreme high yields.  In reality
         (when accounting for variability) the 90-952 yields are probably more
         representative of "average" 100Z yields.
54)   /.  If the In (SAR z EC) is used, then it must not be forgotten that the SAR x
         EC interaction will be predicted less accurately than any single measurement
         by itself,
55)   8.  Using EPA's equations for predicting soil ECe (eq. 6) and soil SARe, results
         were obtained for the situation where ECiw - 2.0 (TDS = 1340) and SARiw « 9.0.
         These values resemble some of the worst average conditions thay may be encoun-
         tered in Poplar River basin, namely those of Station 12, the outlet to the
         Missouri.  Similarly, the predicted In (SAR x EC) results were calculated for
         the next worst situation at Station 8, the northern boundary of the Ft. Peck
         Indian Reservation.  Here EC values of 1.5 (TDS - 1005) and SAR values of
         0.5 were assumed to be realistic averages.

                        Responses to Agriculture Canada

53)         See  Response 29.

54)         Comment  noted.

55)         See  Response 31.
                                      273

-------
<  100
_l

!? »
** «fl



S-
!^ «0

2 90

< 40

g ,o
in
u
a
10
10
                                                 \
                                                               A  Chlf>». 1UI (till lou)

                                                               X  Itmuli ••< Ptmon. list
                                                                  I^IUIPH l»u)

                                                               a  ItrnmU «nd Nirtaii, HSi
                                                                  (China city)

                                                               T  Mrtknn. KM (low Milt)
      -1
                                          145

                                         In (SAR  •  EC)
     Figure 6-1.5    PERCENT ALFALFA YiaO VERSUS  f(EC.SAR) IN SATURATION  EXTRACT
                                                               UT
  100.


   w


   10


   to


   •0


   »0


   40 <


   >0


   10'


   10


    o
        xJ
                                                                   ItnuuU ««d Nirun. IISI
                                                           v— tfrni»»4i»-«fid-f»«nM.- 11U

                                                              (CklM
                                                            A  Tirrtt tn4 llnfUw. Ml)
                                                               lund)

                                                            Q  Hikratri tut ttnrar. I>H

                                                               (* Ixdlia »ll<)

                                                               Utrthem. I'M (low tolli)
                                  i       J       4      »      \       r       *      t

                                        In (SAR i EC)         \
     Figure G-1.6   PERCENT WHEAT  YIELD VERSUS f(£C,SAR)  IN SATURATION EXTRACT
                        274

-------
2
   too
   *0
   to
are
7  to
UJ
>  90
g?
t-

S  10
U

Ul  10
0.


                                          \
                               OT:
                                   Htlun, tl 0
                                   (HoMi till lew)

                                            Ftiriwi. IIM
            -2
                                      214

                                      IntSAR •  EC)
    Floure fi-1.7  PERCENT BARLEY  YIELDS VERSUS f(EC.SAR)  IH SATURATION EHRACT
   100

I-
O 10
o
ci T0
> .0
2
C JO
   40
X-l
                                6 limtUla iM Pt4rtea. HSi
                                X  Itrmnu IM Purun. HM
                                   (Ckln cli7)

                                *  Ntkretrt »d CtafMr. |«M
                                   (t ll>*l«« Mill)
                                      InlSAR . EC)
      Flgurt G-1.8   PERCENT OAT YIELD VERSUS f(EC. SAR) IN SATURATION EXTRACT
                       275

-------
                                                                                          13
                       Predicted  ID (EC x SAX) values uelng EPA equations
                    EClv    SAR
                               lw
                                                EC
                                             ,,    SAI|C   !„ (EC
                      2.0
                      1.4
                             9.0
                             6.5
                                    0.2
                                    0.3
                                    0.2
                                    0.3
0.6
1.0
0.6
1.0
0.6
1.0
0.6
1.0
7.(
5.(
4.
3.
S.
3.
3.
2.
> 13.7
) 10.0
10.6
8.2
9.9
7.2
7.7
5.9
.6
.9
.9
.3
.0
.3
.3
.7
     56)   9
The predicted yield decreases from optimum yield  (given the above Information)

are ahown below:

                                       Z Yield reduction  from
                    SAR|W                    optimum*

Alfelfe
Wheat
Berley
Oats
Alfelfe
Wheat
Barley
Oats
Cameron
OX
38Z
S6X
70Z
OZ
17Z
28Z
231
EPA
40Z
42Z
42Z
6«
27Z
23Z
29Z
47Z
ro
                         2.0      9.0

                       In (SAK z EC) - 3.9



                         1.5      6.S

                       In (SAR x EC) - 3.3
                  •Yield reductions were calculated using C-1.5 to C-1.8 graphs ss
                   modified by Cameron and •• originally presented by EPA.


         NOTE:• The primary difference between my prediction and EPA'a Is that 1 do

         not show any Impairment of alfalfa yields.


     SAR - EC Impacts en Crop Yields - Main Report - p. 136


57)   ..  The EC unite used In deriving the C-1.5 to C-1.8 graphs were In units of

         •mho/cm (I think, rsther then wmho/em) as suggested on p. 138.


58)  2.  F. 138. pars. 2 - on examlnstion of the data, I cannot agree with the

         conclusions reached in this paragraph.


59)  3   Under one the worst conditions, alfalfa yield reduction was shown to be

         negligible rather than the 48Z proposed by EPA.


     4   Combined effects of B. SAR. and EC - alao see appendix, tsbles C-1.2 to C-l.J.
                                                                                                                                   Responses  to Agriculture Canada
                                                                                                          56)
                                                                                                                See  response 31.
                                                                                                     57)         Cameron  Is correct.  The units on page 138 for EC have been  changed
                                                                                                           to onto/cm.


                                                                                                     58)         Again, these conclusions are based on an objective analysis  of the
                                                                                                           available data.


                                                                                                     59)         This point has already been commented upon (see response 53).


                                                                                                     60)         The effects of boron and salt accumulation on crop yield were  assumed
                                                                                                           to be Independent and additive.  The effects of salts on plant growth are
                                                                                                           primarily osmotic (Rhoades. 1977).  Plants under salt stress  have fewer
                                                                                                           and smaller leaves.  Boron excesses produce symptoms of an acute  toxicant
                                                                                                           such  as leaf  necrosis.  Although several studies have been done pointing
                                                                                                           out the Interactions of calcium, potassium and nitrogen and boron (Berger,
                                                                                                           1949)  there Is no basts for quantifying an Interaction between high salts
                                                                                                           and boron.  It would seem, however, that plants already In poor health
                                                                                                           are probably  more susceptible to boron Injury.


                                                                                                     61)         As discussed above, the yield changes due to boron were  added  to the
                                                                                                           yield  changes due to the combined effects of salinity and sodlclty.  This
                                                                                                           Is the best method presently available.
     60)


     61)
               I have  no  Idea  how the  EPA research  team managed  to  couple the B effects

               and  the salt effects.   Perhaps  I missed a  section In the report.

-------
                        CAMERON'S REFERENCES
Ayers, K.S. and D.W. Westcot.  1976.  Water quality for agriculture.   FAO Irrig.
      and Drainage Paper 29.  97 pp.
Bernstein, L. and G.A. Pearson.  1956.  Influence of exchangeable sodium on the
      yield and chemical composition of plants:  i. green beans,  garden beets,
      clover and alfalfa.  Soil Sci. 82:  247-258.
Cameron, D.R.  1979.  Poplar River boron and TDS objectives.   Rept.  to IJC
      Poplar River Hearings, Scobey, Montana, Oct. 16-17.
Chang, C.W.  1961.  Effects of saline irrigation water and exchangeable sodium
      on soil properties and growth of alfalfa.  Soil Sci. 91:  29-37.
EPA.  1980.  Impact of Canadian Power Plant development and flow apportionment
      on the Poplar River Basin.  Draft Environmental Impact  Statement, Montana
      EPA Office.  227 pp.
International Poplar River Water Quality Study.  1979.  Appendix D:   Uses and
      Water Quality Objectives.  171 pp.
Oster, J.D. and J.D. Rhoades.  1976.  Various indices for evaluating  the effective
      salinity and sodicity of irrigation waters.  U.S. Salinity Lab., Riverside,
      Calif.  Int. Salinity Conf. Proc., Texas Tech. Univ., Labbock,  August 1976,
      pp 1-14.
Maas, E.V. and G.J. Hoffman.  1977.  Crop salt tolerance - current assessment.
      J. Irrig. and Drainage Div., ASCE 103:  115-134.
Rhoades, J.D.  1977.  Potential for using saline agricultural drainage waters
      for irrigation.  Froc. Water Management for Irrig. & Drainage.   ASCE, Reno,
      Nevada, July 20-22.
Rhoades, J.D.  1979.  TDS and B standards.  Rept. to IJC Poplar River Hearings,
      Scobey, Montana, October 16-17.
Rhoades, J.D. and S.D. Merrill.  1976.  Assessing the suitability of  water for
      irrigation:  Theoretical and empirical approaches.  FAO Soils  Bull. 31:
      69-109.
Torres, C. and F.T. Bingham.  1973.  Salt tolerances of Mexican wheat:  i. Effect
      of NOs and NaCl on mineral nutrition, growth, and grain production of four
      wheats.  Soil Sci. Soc. Amer. Proc. 37:  711-715.
                                    277

-------
                                     ntPARTMCNT  Or  THC  ARMY
                                     UMAit* notNICV COH**V Ol I Ni.lttl < MS
                                     »«I4U t FOtl OfHCt »MO COUHIMQUtf
           62)
           (3)
r\>
*«4
00
                      •ini IO
                      AlltMtlON Ol
                                                              L'j-.l  UO-:
                                                                 "i 1 0!II9RO
                                                             TE1RA I UCH INC.
                                                              LAFAYETTE. CALIF
                                                                       19 September  1980
                                                                                                                                        (MOftAHOUM
                                                                                                                                         or CALL
) vau mm ouuo or—
                                                                                                                                                            veu MM mitu> ST—
                MIOPD-A
                Mr  <•• in- T'iy)i>r
                Lnvlroiincntal Protection Agency
                Fnleriil Building, Drawer 10096
                101 South Park
                Helena. Montana  $9601
Drar Mr. Taylor

Ue htiv- rwlrveii the Draft Environmental Isjpact Statement concerning the
of Cum. 1 1 m fuurr Plant Development and Flow Apportionment on the Poplar River
Dailn nnl have the following comments.

     «.   it would appear that there la an error In the presentation of the
'Irtatlcl flow re>lw a 50/50 illvlelon of flaw at the border.

     b    It appear* that almost nil of the water quality data u«ed had been
<>l>t»ln<'
-------
                        DEPARTMENT OF HEALTH AND HUMAN SERVICES -  f) p T n O 1QOO
                                           REGION VIII                      J " '  ^ J ."OU
                                     FEDERAL OFFICE BUILDING              	
                                        ,96. STOUT STREET               TcTRATECH'NC
                                     DENVER COLORADO  8O294              LAFA'/r=T~f-  C ~ ' ' C '
                                      October 2,  1980                    "~   w  U"'-''

                                                                           OFFICE OF THE
                                                                      PRINCIPAL REGIONAL OFFICIAL

                                                                             ROFEC

             Mr. Gene Taylor
             Environmental Protection Agency
             Federal Building, Drawer 10076
             301 South Park
             Helena, Montana  59601

             Dear Mr. Taylor:

             This Department has reviewed  the Draft Environmental Impact Statement
             on Powerplant Development  and flow apportionment on the Poplar River
             Basin.

64)          The Poplar River Basin  Area of  northeast Montana has experienced a
             minor influx in population in recent years.   This is due almost entirely
             to the oil and gas exploration  activity  and  has no relationship to  the
             Canadian powerplant construction nearby.  In general, the local populace
             in the affected Montana area  is aware  of the powerplant project, and
             apparently has little,  if  any concern  about  it.

             No significant impact on social conditions in Northeast Montana is
             evident.

                                                  Sincerely yours,
                                                   lomas £.  Moore,
                                                  Director,  ROFEC
                                                  Regional Enviromental Officer
                 Response to Department  of  Health and  Human Services

64)        The population changes  presented in  Table 4.10-1 are not ascribed to
      power plant construction.
                                        279
-------
      REGIOHVIII
                       DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                                    REGIONAL/AREA OFFICE
                               EXECUTIVE TOWER • 1405 CURTIS STREET
                                   DENVER. COLORADO BOM?


                                    September 17, 1980
                                                                          8SOQ-OJ4A4
           Mr.  Gene Taylor
           Environmental Protection Agency
           Federal Building, Drawer 10096
           301  South Park
           Helen*, Montana  59601

           Dear Mr. Taylor:

           Thank you for the opportunity to review and comment on the draft
           Environmental Impact Statement (CIS) of the Impact of Canadian Power
           Plant Development and Flov Apportionment on the Poplar River Basin.

           Your draft ha* been reviewed with specific consideration for the
           area of responsibility assigned to the Departaent of Housing and
           Urban Development (HUD).  The review considered the proposal's
           compatibility with local and regional comprehensive planning and
           impacts on urbanised areas.

65)        The  Missouri River Basin Commission has been preparing a
           comprehensive plan for the area included in your CIS.  It is not
           clear in your draft CIS that their plan was considered   They may be
           contacted at:

                               Missouri  River Basin Commission
                                 Upper Missouri River Basin
                                    1123 Missoula Avenue
                                   Helena, Montana  S9601

           If you have any questions regarding these comments, please contact
           Mr.  Carroll F. Goodwin, Area Environmental Officer, at FTS 327-3102
           here in Denver.

           Sincerely,
                           ney
           Director
           Program Planning and Evaluation
                                       AREA OFFICE
                                      DMVW. Colorula

                    Response to Housing and  Urban  Development


65)        The Draft Basin Plan was completed  1n July  1980 after  preparation  of
      the DEIS.  The Plan has been reviewed.   However,  the plan covers a much
      larger area and does not present Information  for  the Poplar River basin
      Itself.

               280
-------
                     United States Department of the Interior

                                 OFFICE OF THE SECRETARY
                                  WASHINGTON, D.C. 20240

                                                     NOV 2 4  1980
      ER-80/927
      Mr. Gene Taylor
      Environmental Protection Agency
      Federal Building
      301 South Park
      Helena, Montana  59601

      Dear Mr. Taylor:

      Thank you for your letter requesting the Department's comments on the Draft
      Environmental Impact Statement (DEIS) for the impact of  a Canadian Power
      Plant on development and flow apportioiment in the Poplar River.Basin,
      Montana.

  • /   Apparently,  contradictory statements about the apportionment of flow in the
66)   Middle Fork  Poplar River (whether the flow is to be 60 percent or the
      reduction in flow is to be 60 percent) suggest the possibility that
      calculations of the data presented in the DEIS may have  been based on an
      incorrect interpretation of the recommended apportiornvent.  The Department is
      also concerned about the adverse impacts that will occur on the Fort Peck
67)   Indian Reservation once the plant commences operation in Canada.  Steps must
      be taken to  insure that the rights of the Fort Peck Indian Reservation are
      taken into account.  Additional comments explaining these two points are
      included in  the attached materials.  Specific comments are also included in
      the attached memoranda from the Bureau of Indian Affairs, Water and  Power
      Resources Service, and the Geological Survey.

      Thank you again for the opportunity to review the document.  I  hope you will
      find our comments and recommendations helpful.
                                                       Sincerely,
                                                     Femes  H.  Rathlesberger
                                                      Speoial Assistant to
                                                      Assistant Secretary
                                                      Policy,  Budget,
                                                      and Administration
                    Responses to U.S. Department of Interior

66)          The DEIS calculations are  correct.  See response  3.


67)          One of the purposes of the EIS  1s  to  identify adverse impacts so
             that mitigation measures can  be determined.


                                       281
-------
                                                               UNirtO
                                                                              GOVtllNMtNT
ro
(X>
ro
                                                       memorandum
            tiwlroiir.oni.il Aiulity
            Review of Jrult environmental st.iti.mcnc  anil Appendix for the Impact of
            tho Canadian I'ovor Pl.int on Development  and Flow Apportionment, Poplar
            Rlvtr Biiln. /.illc/ Uailals ami !'oo5 80/927)

            Assistant Secretary, Land and Water Resources
            Attn:  Claire Ncwcorecr
      From:   Office of the Area Director [Sah'tu. <£  JtmJU+n
          In accordance with our Central Office'* request  to review and provide
          consents on  the  subject stateaent to your office,  we  wish to submit the
          Col lowing cor., .cnts:

          Tills office  I ,  understandably disturbed to read  of the adverse impacts
          th.it will occi.r on  c'ic 'ore Peck Indian Reservation once the co*l fired
          [ciicnc Ing pl-int co=aences opercclon In Canada.  The  plant Is scheduled
          to la operational in October 1930. vlth a second  300 MW unit to be
          operatlon.il  In  1982.  Adverse lapse t a attributable to plant operation
          Inclujr:

68)       1   Reduced  flow of SOX of the West Fork and at  least 601 of the Middle
              Pork.  Sujaer flows In the East Pork will be approximately Ji-651
              less with one pot.-or plant and up to 80! less with four power plants.

          2   Resultant voter quality will be decreased with possible haraful
              effects to  croplands, fish, furbearors, waterfowl, etc.

          )   S02 concentrations froa two 300 MW units could exceed the Class 1
              PSD regulations proposed at the Fort Peck Indian  Reservation.

          Considering thi: above  It  Is our suggestion that  all steps that can be
          taken to protect cater and sir quality should be undertaken,  lister flows
          should be apportioned as  equitably as possible and provide adequate
          waters fur the  development of Indian lands.  It  Bust  be remembered that
          Indian water rights have  been established by Judicial decree.  The
69)       Indians' prior  and  parivaount rights were sustained in the U.S. Suprene
          Court case foulliarly known as "Winters Doctrine". The Winters Doctrine
          embraces reservation  rijhts whether created by treaty statute, or executive
          urdcr.  bc/ou or after  statehood.  The waters reserved cannot be preempted
          by non-InJIinc pursuant to State law.  It is loportant to remember that
          durinc  the-  q,. Dillon  cm  process th.it It has been determined that die
          court:, have consistently  held that the nature of the  right was such that
          sufficient water h.is  been reserved for uccoapllshlng  the purpose for
          which the reiccx jtion was established and to provide  for the present and
          future needs of the Indians, whatever the use and without limit.
                                                                                                              Assistant Secretary. Land and Water Resources
                                                                                                              Attn:  Claire Newcomer
                                                                                                              September 18, 1980
                                                                                                              Page 2


                                                                                                              We submit that every step oust be taken to insure  that the right* of
                                                                                                              the Fort Peck Indian Reservation are taken into account and that
                                                                                                              apportionment Is mad* on an equitable basis.
                                                                                                                                         Ot.-U
                                                                                                                           Responses to Bureau of  Indian Affairs
68)         TMs st.te.ient 1s  Incorrect.  The flows would be ,redr"? JL.
            on the West Fork and up to 40 percent on the Mldd e '«**»••
            reconaended apportionment only If Canada retains Us full allotment.
            The construction of the two proposed reservoirs on the Fort Peck
            Indian Reservation would Increase the water available for use on
            the reservation.

69)         A discussion of the Winters Doctrine and Boundary Waters Treaty
            has been added to  the  EIS In Chapter 2.  The projected future water
            uses on the Fort Peck  Indian Reservation have been Included In We
            water quantity analysis.
    I
                       Buy U S Savings Bonds Regularly on the Payroll Savings PUn
                                                                           IHCV *••*}•
                                                                           Oft* r •>*«*« I4t CrHtlfJf.lt I
                                                                           MlvMtt
                                                                                                                                                                    1 I
-------
         US-ISO
tkuoranduM
                                    "SEP 18*98°
lot
Front
Subject!
          Corel »3 loner
          Attention:  7uO
                   Director. Billings. Hootnna
          Draft CiiVlronoentrl StetCBenb ana Appendix (or toe
          Power Plant, Poplar Elver baaln Montana (ER 00/927) (Mr.
          Jonu'n Auguat 26 lino)
       Fer  oral Instructions froa Mr.  Specht,  vo are suboittlng our comenta directly
       to you r.itber thin >lr.  Clancuard as requested in Mr.  Jonet'e oeaoraaduB.

       The  proposul povrr plrat ami flow apportionment will  have no direct effect  oo
       projects of ttt Water end rover Rasourees Service.

  70)  Tbe  cBolyals of impacts would bo luprnved if  available figures were need  rather
       llwn oJJcctivca.  Far.e 59 rrfere to "ilruif leant breed led populoeioas of  vatar-
       fovl" which InfLprctrtlon of data on par* 192 reveals to be 140-160 breeding
IV)     pairs.   Oa pace 1!)1 It la reported that "frcei 1977  to 1978 the nuuber of
00     obsoivatlono of beawr and raccoon .  .  .  Increased  sllchtly." "Slightly" could
***     suien (run 10 to 11 or froi* 110  to 111 vlth vastly different significance  when
       no projections on  nuubere of aulxule are presented.

  71)  Blscuksious of t lie. proposed apportionooat la  the euaaary and in  Section 1.1
       (I/OUT  Quantity Inpocta) uly  tnot tSi flows in tlis  basin will  bo reduced
       under condition* of  the npportlonsent.   Tlie proposed  epportlonuonc statca
       that  i'i3 natural flow of the Coplar Uvur shall bo  divided equally eubject
       to coiHlltlons lapaicd on earh tributary.   It  further  etatcs that Canada ohall
       deliver at Irast 60 percent of  the natural flow of  Kiddle Fork end that the
       natural Cow of the Vctt Fork shall be  divided equally.   The statements la
       the  .•'iiT.^ry (ot-conU  paragraph and in Section  1.1 -  second paragraph)  do not
       correctly convoy the nonnlnx of tin proposed  apportlonacnt.   If  the rocoMDonded
       OM>orilonaent i*e(  not interpreted correctly,  any analysis or scenario laood
       upon  that Intcitritallon would  be Incorrect.   The Lanailian use of  Poplar
       baaln vater would  be llcitcd to tlio |>erccntag*a ae  atated ID ths rocaaMaded
       Apportlonr.cnt.

  72)  Several references in tho r<.|
-------
                      i  CO\
                 ! r, .
                                                              "•
Tn
       •«r. 1. P. Bjah.-n.  Chief. Rcv.cw i>-»nch.  n»'iS,
             CnUioniwiial Affairs Office,  l.j  n),  htiton,  VA

"•»«  '-Claude 0. Ceiger.  Hi'drologlst. USOS. KP.D, Lawrence.  fJ
                                       lr?act SUtimnt,  PopUr Rlv«r
        The Oreft rnvuonr.«ntsl Irpjtt SUU'Xf.t.. * Inpact cf Csnadlrn ft4?r"~
        PUcit Otvtlcpnsnt £iid DOM A|'p5rtiownt 01 Ihe Pooler River Bislnr.  ----
        prepar<-.1 t.y the U.S. Ehviroir..;-nte» Prsttctlon Agency, Itontsn* Otfles.  .-  .
        lull l?rn glvtn a cursoty rovtcw bgctusu of th? llrnltrd fir* wfletalc.
        The following tuggestiont tnd co-runts «rt offered for your eonvldcratioit:
    76)
ro
00
        part. 1.  Su.UMry of fnyt»un->»nta1 JTOtctt:  "Tho PopUr Blwer flows  will
             be rcducircfuniier cpndltioi.% or t(M Te'connended «pt>ortionn«nl up  to
             SO percent of the nitur*! floK In titf West Fork'  and tributaries
             -end" up to <0 "peicenl of th» natural flow on the Hi3dTeToric~7v

                  This paitgraph «):o r^.-.tlons "sunur flow.".  In which n«nths
             do "sunttor flows" occur)  II* flow on the East fork at tho boundary.
             for July, is estlihiiU-d to be orebter under the proposed apportlnn-
             P -nt, with one p^er plant in epmtian. than under natural conditions.
             it is as»uvcd that the reduced f)^ («rccnta9es, docunentH in tMs
             ptragrcph. arc referenced to thi boundary and not to sc*e otlicr  loca-
             tion in the Ustn.
                                        Pace 1
        1.1  VW« WWHTJTYlHfACTS
  78)
                para,  t;   Thr n«»n annual i»turaj_flow of  the  Poplar River, at dclcr-
                winti  at  the USGS paging station near Poplar,  Montana. MS estimated
                to br  9?,560 acre-feet (S(« Poplar BSvtr Ta«k  Force Report, d&ted
                Jantsry l27ff. Appendix B, p;ge C-.I6).  About 3S  percent of this mean
                animal natural flow co~:s fron Ciiutfi   Th: annual riytural MOM on thi
                tait Fork et"t>ic fcounlsry has MripwJ frara  2.643  acrc-to.-i ta *6,791_
                acrc-fcct (See Poplar Rivor lask rcrc« P.cuurl, da tod January 15/0.
                Appendix  8, page 0-30).
      fit
                            V.f.
                                                 r> //i
                                                                                                                                  Responses to U.S.G.S.
                                                                                                     76)
                                                                                                     77)
                                                                                                     78
                                                                                                                  See response 3.
                                                                                                                  Sumer  flows refer to June through September.  Flow reductions are
                                                                                                             discussed on p.  139 of the final EIS and show reductions fro* natural
                                                                                                             conditions In June and July based on the release schedule fro* the res-
                                                                                                             ervoir used  In the model.


                                                                                                                  The value of 83,860 ac-ft is the expected or median annual flow
                                                                                                             (see Table 4.4,2).  The sumnary has been changed to show the  mean
                                                                                                             annual flow  of 92560 ac-ft.  Both values are  now shown in Table 4.4-2.
                                                                                                             The percent  flow from Canada 1s 35 percent  based on the mean annual flow.
                                                                                                             The percentage of 32 was based on the median  year.  The flow range has
                                                                                                             been corrected.
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19)
 80}
 81}
82)
83}
 fer». 2:  "The  flom". at__the  baur.isr.v.' xtli tc nJu^v-J ui^.r .. ...unm*
     57 th! recorT'indeTappiriVcii-int op to 59 f.rrtft of Uit ' si-en
     1\Q4 on the tlest Fork* irtd trtlutertei ''•net" us to 10 "psrecnl ot
     th» natural f I ox on tlwfRTdalTForC*" In wMcJTwiuTv is rsu-«>:r
   •  flows" occur?   The flow  on ths test Fork at the Uundarj, for July.
    •fs estimated to be greater under the proposed ipportlonntnt. with
     one power  plant in operation, then under natural condition*.   It
     is assured tUt the reduced  flow percentages, documented »rt this
     paragraph, are  referenced to the boundary and not to »oae other  .,
     location In the batin.       . -                . •  > <.      ......

 1    lit all fairness. It should bt noted tint shortages Mould occor  tn
 >    the year 2030 even if the United SUtes received 100 percent of  the
     natural flcm. as determined  at the boundary.   ',.'•"'    i   •   , ..

 -   It Should  also  be noted  at this tine thit the remainder of this   "  ."'~
  '  review it  purely academic 1f the proposed apportionment for the
     Middle Fork was interpreted  Incorrectly.  It has been stated,  in*    "~
     correctly, that the flow on  the Middle Fork could be reduced "at
     least 60 percent of the  natural flow'.  This interpretation Mould    ,."•
     result in erroneous computations of flow, not only on the Kiddle   :.  ,
     Fork but on the Poplar River beloM the confluence of the East  Fork
     and below the confluence of  the West Fork.  I have been tn contact
     with the Montana Office  of the environmental Protection Agency,
     concerning this interpretation, and they have teen unable to provide   '
     •ny satisfactory answers.  As further support of the Incorrect
     interpretation  theory, page  9? of the tnvlronwnUl Impact Statement   -
     produces a *bar graph* defining the various Canadian water uses on
     th* Middle Fork for the  year 2000.  This "bar graph* defines appro«1-
     nately 6.900 acre-feet of Canadian usage, whereby the Canadian share
     of the natural   f low, under the proposed apportioAnmt. would be no nor*
     than S.1B4 acre-feet.                            .       ' ',
3.2 FLOW MlATtD ALTEHIlftTIVES

3.2.1 Alternative Flow Apportionments

para. It  Twenty-t»o "alternative apportionments were considered?
para 2:  'The mean* natural 'flow of the Poplar River at the basin outlet Is"
     T27.C cfs {See Poplar feiver Task Force Report, dated January 1976.
     Appendix 8, page B-36).
                                                                                                                                          to  U.S O.&.
79)
80)
                                                                                                   81)
                                                                                                   82)
                                                                                                              See responses 76 and 77.
                                                                                                              This point  Is discussed in Chapter 5 and  is discussed In the expanded
                                                                                                              iry.
          As discussed in response 3,  the flow apportionment was  Interpreted
      correctly and confirmed by Richard Karp who did the andeling for the State
      of  Montana.  Canadian water uses  are projected values by Canada shown to
      consider what future diversions night be without apportionment and when
      interbasln transfers night take place, but are not used by the model.


          Twenty-two flow apportionments were considered by the Poplar River
      Test Force in 1976 but only four  apportionment alternatives  were selected
      to  be evaluated by the EPA.  These alternatives were endeled along with
      the no apportionment case and the present case with the Cookson Reservoir.
      This section has been rewritten to explain the various apportionments.
                                                                                                   83)        Value in  EIS was based on median flow.
                                                                                                         summary and Table 4.4-2.
                                                 This has been changed  tn the
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        1.
              C:.i.:.>;i
                                        ?.•&<•  ">i

             _1<-2:   Tt-5 rassn annual ntturel  flus ca  not  aorce  »>Uh  fupt
             River lask Force determinations  (M;  Poplar  River Task Force
             dated January 1976, Appendix 8.  pgcs 8-28.  8-29. 8-30. end BO6)
5.? VATCR
                           IMPACTS
        S.Z.I Methodology

        5.2.1.) F)OM Scenartoi

85)     para. 2:  'The historical niter uses wire then added to the observed  flows
             to give the natural flows under predevelopcnent conditions with no
             apportionment."  The natural flow, at various points, was determined
             by the Copier River Task Force (Ste Poplar River Task Force Report,
             dated January 1976, Appindix 8. psgts 8-28 -to 8-39).  natural  flow, by
             definition, is the flow that would tove occurred in rivers and streams
             without the influence of man on the flow regime.

86)     para. 3:  'Flow in Cow and Cost Creeks (stations 2 and S) must be at  least"
            ~<6 "percent of the natural No*".

             "If flow releases are nesdfd to n*et the apportionment, the releases are
             t»de froa stations 2 and 5 first and station < second."  There are no
             futilities iron \.h1ch to make releases at stations 2 and S.
87)     Figure 5.2-3:  Urder the conditions of the proposed apportionment, Canada will
             not receive 6,900 acre-feet of water In the year 2000.  Also, the power
             plant symbol of the legend is missing.

                                      Pages 96-93

88)     Figures 5.2-2. 5.2-3. 5.2-4;  Is the "Reservoir Evaporation", referenced 1n
             these figures, natural evaporation or both natural and forced evaporation?
89)      Figure 5.2-4:  The title of  this figure should bo "Canadian Water Uses on
              the West Fork and tributaries'.
                                       Pace MO

 90)      para.  2:  "In June all  scenarios bring ebxit a 63 percent reduction in trrs
             natural flows".  There  would br w ruction in the "natural  flow";
             howver, there would  bi a reductici In the "obserte^ flew".
                                                                                                                                 Responses to U.S.G.S.
84)        Table 4.4-2  has been changed to Include nean annual  flows In ac-ft
      along with the median flows (or expected values).


85)        The subject  report states: "Natural streaaflow estimates were derived
      by adding upstream  consumptive uses to estimated historic flows".  The
      text In the EIS has been revised to clarify this  point.


86)        The percentage of flow was changed from 60 to 40.  The releases are
      made at stations  by the computer model  to simulate the apportionment.
      This has been  made clear in the text.


87)        See response 81.  Power plant legend has been added.


88)        The reservoir evaporation In the figures Includes both natural and
      forced evaporation.  A note has been added to the text explaining this.
                                                                                            89)        Figure title has been changed.


                                                                                            90)        Text changed to read "from natural flows".
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91)




92)


93)
     94)
ro
CO
-j
     95)
96)
             are. 5:  "The :nt VI «ri ;i*.'I3itd «S SO psrccnt ot the nsturil II
            P»ra. 1:  flow on the Cast fork *t (•'« loundary is expected to be greater,
                 Tn~ July, undtr the propped apvortion'aent thin under natural conditions.

            para. 4:  "In tht V'sM fork at the International Boundary. flow under
                 sccnirlos c'Ci through 32 v.ill t>s zero for all nonths."  H5* would this
                 be passible under th* proposed appstviowuenl, when It specifically
                 sUteS. "Tne lot si naturcl f ion of the Vest fork Poplar Diver and all
                 Us tributaries croiiinn :h> international boundary shall be divided
                 tcuilly brtir«e.i Canade and the United States but the flow at the Intcr-
                 Mtlorul baundsry in e«ch tributary snail not be depleted by more than
                 60 percent of Us natural flow. "7
        para.  1;   *lhe water uses In Kirch (1975) «er«  estlnuted at' «l "ac-ft
            ?or  spreader irrigation/ B4 *ae-ft for  stock and J7.5 ae^Tt for
            fwnitlpal v.»trr supply* (See Poplar River  Task Force Report, ditcd
            January  1976,  Appendix A. page A*2Z}.  Ktich of the spreader irrigation
            re()uirti>cnt  Is fulfilled with runoff from  tributaries downstream from the
            boundary, as noted tn th» prf ceding reference, and does not depend on
            ttater crossing ths lyuniiry on tnt Cast  Fork.

                  "The available water tcfore diversions Is estfnatcd as*
            C01  *tc-H"  (fro-  Appendix C, peg* fc-33, of Poplar RWer task
            Force Report and computer run, utlr/j the proposed apportionment
            with tto power plsnts In operation).
            Table esiorl3t»d *1th p»ra. ?:  twkvyily, tn« available water fs the sane
                 for (5Fch,  April (noted in paragraph 1), August, and Stptc^bsr.  This
                 would not l« possible, as there «c/jld be spills occurring occasionally
                 In torch  end April; anJ dictated by the proposed apportionment, the
                        continuous release Is subject to change on September 1.
                                           Page
97)
            table  5,6-8-.   It  Is  difficult to toHi'ire that  the flow on the E«st Fork
                near ScoOty  wrwlrt be icro under scenario  32 and a 10 percentllu.
                This should  be  checked.
91)
                  Response* to U.S O.s.


Text changed to read  "West Fork and tributaries*.
92)        These diagrams show that July flows are not greater under the appor-
      tionment according to the mdellng results for EPA's scenarios.


93)        The zero flows  on  the Uest Fork were for the  case  of a 1  In  10  year
      drought.  Zero  flow on the  conputer results Means less than 0.004 hn /month
      or 3.2 ac-ft/Month.   In addition  the Poplar River Task Force (1976, Appendix
      6, p.  B-6) stated that flows were assined to stop on the West Fork  at  the
      International Boundary  during December  to February under natural conditions.
      Flows on  the  Middle Fork at the boundary were assumed to stop from January
      through March unless an early thaw occurred for that year.  A note has  been
      added to the beginning  of  the nodellng  section to explain this.


94)   The water uses given here are the values used in the modeling work.   The uses
      may have been updated by the IJC  after  1976.  While It is true that some of
      the spreader Irrigation 1s net from small tributaries, the model  used a
      conservative approach and subtracted all uses fron the main stea Poplar and
      the forks as appropriate.


95)        The 601 ac-ft does not  consider the prescribed schedule of  releases to
      the East Fork from the  reconaended apportionment.   Additional water would
      probably be available from spring runoff but this Is not Included here because
      the EPA wanted to use a conservative approach.


96)        The available water Is  at the same minimum level  In March,  August and
      September only for the  1 in  10 year low flow case.


97)        These flows are derived from the model runs in ac-ft/month so the flow
      could be low but not actually zero (see response 93).
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             5                ,-3,. ^^

        L, 0. Dor.tan                            ""  X"
                                       APPSKD1X

                                       Page 1S3


98)     Table E-4:  For the year 2000, on the Riddle Fork,  the Canadian water
             usage of 6,870 ac-ft is incorrect because,  under th*  terras of the
             proposed apportionment, Canada \s entitled  to  no nore than 40 per
             cent of the natural flow.  Ths esiireted  mean  annual  natural flow
             of the Middle Fork is 12,961 ac~ft  (See Poplar River  Task force
             tejort, dated January 1976, Appendix  B, page 8-29).
                  The Vfcst Fork total > for the year 2000, is also incorrect  if
             tftrs figure does not include tributaries of th? West Fork.


         In Sunrory, due to time restraints arid the lack of so^e pertinent
         infomation, it is difficult to provide a thorough review of this report.
         However, based upon some of the discrepancies noted previously,  it n\»y
         be advisable to make a more complsta evaluation of the report.
        •
        Thank you for the opportunity to meke cosments and offer suggestions.
                                           Claude 0. Geiger
                             Responses to U.S.G.S.


98)        As discussed  in response  81, these are projected water use figures   in
      1978 from  Canada  and  are not used in the modeling at all.  The mean flows
      have been added  as discussed in response  78.   Tributaries to the West Fork
      are included.
                                      288
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         Agriculture
                          Sul
                          ComcivJIiun
                          Seme*
                                   P.O. Oox 970
                                   Oozeman, MT
                                   59715
                                                          October
     99)
    100)
    101)
ro  102)
CO
10
    103)
    104)
Gent Taylor
Environmental Protection Agency
Federal Building. Drawer 10096
301 South Park
Helena. NT  S9601

Dear Mr. Taylor:

He have the following contents to offer on the Draft Environmental
Impact Statement for the Impact of Canadian Power Plant Development
and Flow Apportionment on the Poplar River Basin.

   i  Page 28, first paragraph   The total water requirement for gravity
     or pump irrigation was estimated at 7.7 inches.  It should be
     further explained that this is for one Irrigation only, and not
     the need*  for the entire growing season.

  2. Page 30. first paragraph.  It may be worth Mentioning that although
     there is little federally-owned land In Daniels County, there Is a
     considerable amount of state-owned land.

   3. Page 33. third paragraph.  Safflower and sunflower are two Important
     crops In the Daniels County area, and that may need Mentioning.

  4. Page 46, second paragraph.  Hercurlc Acetone Is no longer widely
     used in the United States as a fungicide for treatment of wheat
     seeds as stated here.

   S  Page 106,  last paragraph.  The assumption of an overall 651  Irrigation
     efficiency (Including both conveyance and field efficiency) appears
     quite high unless the entire conveyance, delivery to field and to
     sprinklers. Is in concrete lined ditches, canals or pipelines.  Any
     open, unllned conveyance ditches would reduce  this efficiency.

   6  Page 107.  Discussion of  Irrigation Requirements.  A range of about 2
     to 3 acre  feet of diverted water is shown to be needed for alfalfa
     in the  area, depending on whose figures you wish to use.  After the
     figures are given.  It Is stated that the Soil  Conservation Service
     approach Is more reasonable  than those made by others.   It Is not
     clear,  however, which volumes are predicted by the Soil Conservation
     Service.   This needs to  be cleared up   It should also be made clear that
     the 63* efficiency used  Is only for a sprinkler and pipeline convey-
     ance system, and not open, unllned conveyance  ditches such as flood
     systems.
               "•*• . r-~ ,«**
 • fc'r
                                                                  i »:' i
                                                                                    ,
                      Reipontfy to Son  Consgrvatton Service


 99)        After 7.7 Inches "per Irrigation application"  has been added to  the
       text.


100)        Sentence was added giving percent of State owned land In Daniels County
       as 23.9 percent (Table A-2.2).  Location of these lands was shown In  Figure
       A-2.1 of the Appendix.


101)        After 'winter wheat", "safflower. sunflower" has been added to the text.


102)        In the text "Is widely" was  changed to "has been used".  After "basin*
       the following sentences have been added to the  text.   "This material  can
       no longer be Manufactured but existing supplies can be used up.   Other sources
       of the mercury could be domestic  sewage, dewaterlng of the coal  seams, power
       transmission facilities submerged by Coofcson Reservoir and an abandoned waste
       dump near Cookson Reservoir (Testimony at Public Hearing,  1980).   A detailed
       analysis of this problem 1s needed and should be undertaken.  This would
       require field sampling of the reservoir, river, and ground water which 1s
       outside the scope of this CIS".


103)        The efficiency of 65 percent was based on  the  efficiency estimates for
       sprinkler Irrigation by the Poplar River Task Force (1976) and is reasonable.


104)        Because EPA used essentially the same method as  the SCS does for estima-
       ting crop water requirements this comment is superfluous and has  been deleted.
       Sentence on p.  107 of DEIS changed to read "the field  and  conveyance  ef-
       ficiency for sprinkler Irrigation of 65 percent".
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105)
ro
      Page 2

      7.  Page 1*7. Spreader Dike or level Border Irrigation.  These two types
         of systems should not be confused.  Spreader dikes or waterspreadlng
         ly.lntr, Oil*«.- tho'.c u',c
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                                        ^'liilr nl ^Uitiil.iiui

                                  $s
                                                October ZO. 1980
 Mr   Ivan  Oodson, Director
 Environmental  Protection Agency
 Federal Building. Drawer 10096
 301  South Park
 Helena, MT  59601

 Dear Hr>/06asWi:-~  —

     The  following  comments and attached agency documents represent  the
 response  of  the State of Montana concerning the draft Environmental
 Impact Statement on the impact of the Canadian Power Plant Development
 and  the Flow Apportionment on the Poplar River Basin.  I commend EPA for
 extending the  comment period on this extremely technical and complex
 public document to  provide for a thorough public analysis.   Montana's
 attached  cumnents represent not only an analysis of the technical air and
 v/atcr Impacts, but  also a genuine concern for the social and economic
 impacts that my occur.  The quality of Hfe and protection of our agricultural
 Industry  In  Montana cannot be overlooked or considered insignificant.

     The  State of Montana has been closely monitoring the progress of the
 Saskatchewan Power Corporation (SPC) power plants since the fall of  1974.
 He have testified before the International Joint Commission (IJC) on
 several occasions relative to the SPC project.   He are currently engaged
 in a comprehensive air and water quality and water quantity monitoring
 program and  data exchange agreement with the Canadians.

     In 1977,  the Montana Legislature passed a resolution establishing a
 it
-------
                    EXECUTIVE SUMMARY OF COMMENTS
          POPLAR RIVER DRAFT ENVIRONMENTAL IMPACT STATEMENT
                            presented by
                      Water Resources Division
     The relative importance of irrigation in the Poplar River basin

became a sensitive issue early in  these international proceedings.  Whether

it should or should not have become an issue is no longer relevant.  The

merits of a multimillion dollar thermal generating plant or;the merits of

a half million acres of dry land crops overwhelm the merits of irrigating

approximately 3500 acres of a very restricted variety of crops.  Never-

theless, the practice of irrigating crops provides a livelihood to a

handful of farmers in the basin.   Its importance to them as individuals

should not be diminished or overlooked.  Yet, numerous statements are

made in the EIS that either directly or indirectly serve to do just that.

     Exclusive of predicted air quality impacts, the operation of the

plant and its ancillary facilities near Coronach will almost certainly

impact irrigation more than any other use.  Therefore, the following

concerns are expressed.

     Roujhly three fourths of the  total volume of surface water that

passes through the Poplar River basin in an average year does so during

a rathsr short lived runoff period each spring.  Although water quality

records preceding the L-r.poundr.ent  of water on the East Fork are meager,

there is adequate evidence in support or* the view that the quality of the

frecr.et has been good.
                               292
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    Ill)
ro
    112)
    113)
    114)
     It la not unconon to observe at any of the boundary stations,
measurements of total dissolved aollda (IDS) to to leas than 400 eg/1
or snasuronenta of dissolved boron to bo loss than 1.0 oig/1 during the
runoff.  Realization of this Is particularly Important to my party that
would desire to store utter for the purpose of Irrigating.  It la equally
Important to those who Irrigate already, requiring water of a satisfactory
quality as to lo*cfi salts out of the root zone.
     As it stands, there la no objective being recomendod to protect
tSui historically (toad quality of the freshet and there la virtually no
aentlon of its importance in the CIS.  In fact, Judging from various
staUiants in it, one would be led to believe that the quality of water
in the baair 1= always poor.  If a flow weighted average value were to
be calculated for parameters such as TDS and boron, it la likely that one
vouH not conclude so readily that the water quality ia poor.
     Soon, the plant will begin igniting coal and generating electricity.
The Saskatchewan Power Corporation my, if it so chooses, operate in such
a nanner that each spring a year's accuaulatlon of compounds and elements
could be "rinsed out*.
     The 1103 1 logical solution Is twofold.  First, aore extensive water
quality 3o::itorln;j ia necessary at all boundary stations during the period
of runoff.  Second, the state should seek to have established objectives
to be cut at the international boundary during the runoff.  The objectives
chjoli 'jc uln-54 principally at protecting against olovatod TDS and boron
cunccntr jll una .
     The operation of a single 300 HH generating unit nay prove to bo
liui'mCli Kit.  Thorn iliould be concnrn, however, that tlw Addition of
a s«:<-.r.J, third or fourth unit nl;;ht produce alftnlficantly jdvnrsu Uipacts
In this ruiprd.  But,  such ispocts could so unrecognized until tho concepts
ad'.aiced hire are accepted.
                                                                                                                            Reiponset to Montana Mater Retourcem OWIiion
                                                                                                          HOW       A discussion of Inpacts due to reduced spring runoff MS discussed on
                                                                                                                 page 121 of the DEIS.  A flow-weighted average Is not meaningful for describ-
                                                                                                                 ing the quality In  the sunaer when the twst critical conditions occur.  Ita
                                                                                                                 water quality  section of Chapter 4 has been expanded to discuss seasonal
                                                                                                                 differences.
Ml)
                                                                                                          112)
                                                                                                          113)
                                                                                                                      This  Is unlikely If a release schedule such as specified In the ap-
                                                                                                                 portlonaent with the  large release spread out over the Irrigation season
                                                                                                                 Is  followed.  Any spill In the spring would be comprised Mostly of runoff
                                                                                                                 which would taprove reservoir quality.  In addition, wen of the chemical
                                                                                                                 Input Is fron the ash lagoons which will not be discharged to the reservoir
                                                                                                                 under the  planned mode of operation of SPC.
                                                                                                                Canada
            The water quality monitoring prograai being developed by Montana and
            la Is mentioned and  recommended In the EIS.
            The EPA did not direct that  numerical quality objectives be determined
       or analyted.  The IJC was responsible for developing such objectives.  A
       discussion of how the IJC recommended objectives compare to the scenarios
       analyzed has been added to Chapter  3.
                                                                                                          114)        The  Impacts of adding power plant units has been clearly shown by the
                                                                                                                modeling  scenarios.
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f\J
                                      TECHNICAL COMMENTS
                       POPLAR RIVER DRAFT  ENVIRONMENTAL  IMPACT  STATEMENT
                                          presented  by
                                   Water  Resources  Division
      Section  1.1  '.Ijtor Quantity Impacts  (Sunmary)

US)       Par:-T.-O'I 3 of Page  l:  Th-j statements rogardlnfl  the  apportionment

      of flowj according to  the recoawended apportionment  schedule  are  incorrect.

           The .i;>i«TtionT>enl schedule calls for  an equal sharing of the total

      natural  flow of the West Fork  as Measured  at the  international boundary.

      The flow or any of its tributaries shall not be depleted by awe  than

      60 percent  (presumably by Canada).  Therefore,  the United  States  would be

      entitled to not less than 50 percent of the West  Pork  and  not laaa than

      40 percent of  any of its  tributaries.                          •

           Furthuraora, the  United States  Mould  receive not  less than 60 percent

      of the  total natural flow of the Middle Fork,  as  measured  at  the  Inter-

      national  uo'jnlar*y.

           Th3 :tj>.u-nunt  Is  made  that  flows on the East Fork will be made up

      of  i c-mUauo.j. release  from the reservoir of  1  to  3 cfs.   It would b»

      3PI. >prl..t"  to Mention also that duiund releases  will  augment flows and

116)  that  the l-.^i-.'j  1  to  1  cfs are  minimum flow requirements.  There will be

      flow;  in o.'cess of  1  to  3 cfs, particularly durlnc,but not limited to,

      sprinr rue jf!.

            Rup.jC<:dly,  throuchout tho  manuscript,  the 300 :iw generating unit3

      ar...  r»r<.rrg'j  to  as  power plants.   There i-j one potrar plant at Coronach

      un1  11 i.. inliclpatcd   that thare  will  eventually be two,  three or four
                                                                                                                                Responses  to Montana Mater Resources Division
                                                                                                         115)      The sunmry Incorrectly sUted that the flow on  the  Middle Fork
                                                                                                              Mould be  reduced by 60 percent.  The correct value of •  40  percent
                                                                                                              reduction was used In the nodeling studies and analysis of Impacts
                                                                                                              (see Table 3.2-1).


                                                                                                         116)      In reality the 1 to 3 cfs on the East Fork Is a minimum.   Additional
                                                                                                              water was Included In the model ing according to the specified schedule
                                                                                                              of demand releases and spring runoff If the Cookson Reservoir was full.
                                                                                                              The sumary has been expanded to explain the East Fork flows In detail.
                                                                                                                117)
                                                                                                                   Test has been changed to "units".
-------
ro
IO
tn
 118)
              units  in  place.

                  Paragraph 1 of Page 2:  The word irregordleu conveys • double negative

              •caning.   Ita use,  as  such,  ta not acceptable unless the Intent la clearly

              •cant  to  be nunorous.

                  Paragraph 2 of Page 2:  Miat'a wrong with slayly winter habitat for

              gaae fish?  Also, the laat sentence should probably not refer exclusively

              to decreased duck production; rather, decreased waterfowl production In
 120)  section  1.2  Hater Quality Impacts  (Suanary)

            Paracraph 6 of Page 2:  We recoaswnd that the a ta tenant "March to Hay

       flow" bo expanded to -March 1 through Hay 31 flow".

            General:  He suggest that • statement be added to this aectlon,

       particularly  in view of the statements nade In the last paragraph of the

       section.  The statement to be added should discuss briefly the various

 121)   alligation alternatives that have been proposed by the Saskatchewan Power

       Corporation, such as the proposal to divert Middle Fork uater Into the

       East Fork at a point downs trea» fro» the dan.


       Section  3.S  Flo* Related Alternatives

            Porajr ij>hj 3 and * of Page 13:  He find these accounts to be very

       difficult to understand.  Does the  discussion baaimting In the fourth

122)   paragraph a-.auae that one, two, three or four units would be in operation?

       Perhaps anotnw table or a «ore careful, nore explanatory discussion

       would be MI inproveannt.  The confusion regarding the limber of operating

       units sssined carries forth also to paragraphs 1 and 2 on page IS.

            Paragraph 2 of Pago 16:  Reference to the domand releases as "one

 123)   tiro releases" is nl 3 leading.  He undTiiand thst the demand roloajos,

       once agreed upon and initiated, would be available to the United States
               Responses to Hontana wat«r R«»ourc«» IMvlHcm


118)      The word "Irregardless" has been  deleted.  The original  Intent was
     to say that after full flow apportlonMnt all the acreage could not be
     Irrigated every year even with the proposed  reservoirs.


119)      Mlnter habitat would convey the same Meaning as overwintering habi-
     tat so text has been changed.
                                                                                                         120)
          The text Intended to Mean March through Hay flow and has been changed.
121)      This alligation measure has not been agreed  to by  SPC.   It Is un-
     acceptable to EPA because tapacts would result fro* decreased flows
     on the Middle Fork and fro* construction of the diversion systoa.
     Dilution of poor quality water Is not acceptable  to EPA as a  means of
     meeting water quality standards.


122)      Table F-2 from the appendix has been saved to this section.  The
     nuaber of power plant units Is one In 1975 and four 1n  2000.   This Is
     not Important since flows on the East Fork are detenrined by  the same
     release schedule.


123)      The term "one time release" was used to distinguish It from the
     continuous releases of 1 to 3 cfs according to the proposed apportion-
     ment.  The text has been changed to 'scheduled release* since the
     flow would probably be discharged only at stated  times.  The  schedule
     In the model per IJC and EPA request was during the Irrigation season
     (Table 5.2-1) based on Middle Fork now.  Suggestions are made In
     the EIS to change this schedule to aid other uses as well  as  Irrigation.
-------
ro
to
                                             -3-
            upon request and at any tine betuaen Juno  I and May 31.  It la logical
            to ns3u:nc that tho concept of demand releases was developed in order to
            satisfy eoro than ona requirement.
                 ri-:J  .;-r .".: / r«7cria dsV.ij ':-;,. to I?:;, isrir.J releases s
            b« available to the United States according to the following schedule:
                      Volume of  »eleasa
                        1000 acre feat
                         500 acre feet
                         300 acre feet
                                                     Frequency
                                                    3 years In 10
                                                    5 years In 10
                                                    2 years in 10
     Section 3.3  Water Quality
          Paragraph * of Page IT:  The discussion of Modification* in the
     operation of the ash lagoons refers to a decrease of IDS concentration In
     the East Fork by 10 percent.  To which condition la such a decrease
     compared?  Likewise, it Is not clear to us which condition is the baseline
     for a comparison in the subsequent discussion of reduced boron, levels.
          Table 3.3-2 on Page 19:  The word adsorption in Misspelled in the
     heading.

     Section 4.3  Land 9se
          Ths importance of irrigation in this baaln has been an extreaely
     sensitive issue throughout these technical Investigations and International
     proco'idin^.  Regardless of thJ relative insignificance of irrigation,
     aa compared to dry land farming, tho very livelihood of a significant
     nunber of farrars depends heavily upon tho availability and quality cf
     Irrigation water.
          It is our poaltlcn that statements juch as thoso nade in the last
125) aentonce of Paragraph $ are not inocuous, aa perhaps intended.  In fact,
                                                                                                                             Responses to Montana Hater Resources Division
124)        Both the TOS and boron concentration comparisons Mere nude
       using the model results for scenario 4A (with ash seepage to
       reservoir, one 300 MM unit and 197S wter uses) and scenario 28
       (no decant to reservoir, one unit and 1975 mater uses).
125)        Chapter 4 describes 1975 condltons.  rfhile Irrigation Is
       vlUI to farmers who practice Irrigation, only a snail percentage
       of the crop acreage Is presently Irrigated.  The major Issue Is
       whether future Increases can be made In Irrigated acreage given the
       apportionment and water quality constraints.   A discussion has
       been added to the economic tapacts section discussing impacts on
       Irrigated farmers.
-------
no
to
     suck statements carry with MM* the potential to dialnlab tho Laportance
     of irrigation In the Foplar River baaln.
     Cecil' i *.5  Mfeter Quality
          Parocraph 3 (excluding list of parameters) of Page 46:   It la  stated
126) that tht TD3 values, aa anaaured In the Boat Fork near the International
     boundary In 1975, fall In the range of 1050 to 1790 ng/1.
          ChesUcal analyses reported by the U.S. Geological Survey for toe
     period of Oecoxber, 1974 through September, 1975 ahow TBS valuea ror  the
     2as? For1.: at the International boundary fell In a range or 669 to 1460
     me/i.  It la Misleading and erroneoua to Infer that the water In the  Bast
     Fork la nocesaarlly of a poor quality.  It la at tinea poor In quality;
     however, during runoff, when the overwhelming bulk of the atreaa'a  annual
     discharge historically passed through tho basin, tho Water's quality  waa
     In fact good.  This reallxatlon la vital to the Fort Peek tribes and
     tholr plans to store that runoff.  It la equally vital to any irrlgator
     in the basin, who auat count on water of a good quality for hia flrat one
     or two applications in the spring, alnce It la not often possible in  the
     autur-i to leach out the accumulation of aalta In the soil.
          Jtocords of subsequent years support our contention that TD3 valuea
     art not  aa high as tha values that are often reported out of context.
     Froa October, 1975 to September, 1976, TD3 values, aa ewaaurcd In tho
     East  rort: at the International boundary,  exceeded 1000 «g/l  only In
     Itoverber and Docanbor.  In eoat regaining months, •eaaurasants fell In the
     ron>;o of 853 to 950 m«/l, but in March and »i>i 11, TD3 values were aa  low
     aj 101 to COO eg/1.
          With the•• data in mind,  wo ur^e against any jtatomant  that leads to
     tho c'lctu.ian that th* quality of Mater la Generally pcor.   A flow
     w«ic'it«d average of T03 valu?s shauu ^ho  opposito to bo true.   Yet,
                                                                                                                             Retpon«es to Mont«M U«t>r Retourcet 0>v>tton
                                                                                                               126)    »«   T5f" ¥'luts are •*•" v*Iue*'  Miter "lth T05 9r««ttr thin
                                                                                                                      500 ao/l cannot bf classed as "good" for use as a public water
                                                                                                                      supply  since this 1s a violation of the secondary drinking water
                                                                                                                      standards  for which the Meter Is also used.  However, 500 SM/I
                                                                                                                      water Mould be acceptable for irrtoatlon.  The quality was tetter
                                                                                                                      during  spring runoff prior to the reservoir than at other tiavs
                                                                                                                      of the year.  The decrease In runoff to the river due to the
                                                                                                                      fjpoundiiient does result In higher TDS concentrations (Karp, 1979).
                                                                                                                      The additional Increase after tapoundnent in TDS concentrations
                                                                                                                      due to ?r«»t1on of one 300 NH unit Is SMI I.  A discussion of
                                                                                                                      seasonal differences has been added to Chapter 4.
-------
                                              -5-
                                              -5-
ro
       127)
     IKK.IV.TO in the Eic, as far an wo have  been  abla  to ascertain,  IMS this

     point been discussed.


          The •  mi-- rolnl can be raised with respect to boron values.   Tho

     U.j. C;olo .,1: >! Survey watnr quality rocorJa  of  19fO report  a  slightly

     lower ran-.: of boron in the water of the  East Fork (2.3-3.0  mg/1) than

     is reported on Page 46 (2.5-3.7 mg/1I.  In  tho case of boron in  the

     irr: j-ii-on -i.it..-:-,  :tw presence of 4.0  mg/1  over  an extended  period mlpnt

     •;iry well rid^i.* the yield of a crop to the extent that it becomes'1

     e: ,-JU--Jl!y unsound to irrigate It.   While the  reduction in yield, as

     exorcised in terns of the entire county,  nay show a vary small  change,

     thit jlcti:.uc njy affect a few individuals to the extent that they might

     no longer h iv: the option of growing a particular crop.

          Pji-acr ijjhj 1 and 2 of Pace 47:  We again argue with the TDS values

128) reported for the Middle Pork and the main sten of the Poplar River. What

     la the source of those values reported?  Water quality records of the

     year 1976 shew TD3 values as low as $11 ng/1  in  July and 865 mg/1 In

     Aucust on the Middle Fork.  On the main stem, a  TDS value of 234 ng/1

     was -.sasu.-od in July and 872 ng/1 in August.

          Gn.iU-1, tt-iv; fratpnnted TDS values can bo misconstrued; however,

     v • r:it.rut- nut we -•"•) written in the EIJ a slanted Interpretation of

     'no •.•.ry ciucieil parameter.;, total dissolved  solids and boron.   The


     att.-ic*-. -•.! '.J'-.!-- 3uraarl:i>3 all of the recent iljto -will able for TDS

     a;i3 t>3ron -J- recorded in the U.S. Geological  Survuy annual publication,

     'Alter 1c-Qu'".L^ Data for Montana.


129)      Tabl» "..o-l on Page S3:  Hantcrnach  Couloo  in mispellttd.


     Section 5.T.1.D Water UJCH


                    4 of Pago 107 (second to Ij3t  lino):   ... a 10  percent
                                                                                                                               Respontes to Montana Water Resources Division
                                                                                                                127)         Boron daU Mere obtained fro* the USGS (Water Resources Data
                                                                                                                       for HDntana 1975)  and fro* the Montana State Water Quality Bureau
                                                                                                                       sampling network stations.  Our analysts In Chapter 5 snows that
                                                                                                                       crop reductions due to boron are less severe than reductions due
                                                                                                                       to salinity.  Yield decreases were for crops Irrigated with Poplar
                                                                                                                       River water only,  not for the entire county.


                                                                                                                128)         The water quality data discussed here and throughout Chapter 4
                                                                                                                       are for 197S and are sunmarlied In Appendix A of the EIS.  The data
                                                                                                                       were collected In  1975 by the USGS and Montana State Water Quality
                                                                                                                       Bureau.  The range of data points has been added to better describe
                                                                                                                       the quality.  Data discussed In this letter 1s post-Impoundment data.
                                                                                                                129)
Text corrected.
-------
INJ
U>
to
     Section 5.2.3.2  Uses Dependant on Spring Hater
          General•  This section nay be an appropriate one to Include some
130)
     mention of tha fact that the spring freshet provides irrigatora with an
     opportunity to loach salt* out of the soil.  If this Is  not  the appropriate
     aectlon to make the point, then It should be dlacuaaed in a  previous
     •ectlon on Mater quality.
     Section 3.2.3.2
          Paragraph 3 of race 122:  ". . . with little or no  Irrigation  In
     Au£jrt arid SaptmtMr."
          Although there My be relatively little irrigation  In the basin,
131) those who Irrigate often punp water out of deep pools in the late auMer,
     even when It appear* there is zero flow.  Those who practice this method,
     proper or not, are, for all practical purposes, pumping  groundwater.
     Both toe United States and Canada contingent on the Mater Uses and  Water
                                          t
     Quality Objectives Canute* observed this practice and  were In fact
     Inforaod at a public meeting that this practice ia necessary to some
     farmers.

     Section 5.3.2,1  Boron Impacts on Crops
          Paragraph 2 of rage 129:  "The crops studied were alfalfa, wheat,
132) barley, and oats, although at preeent the latter two crop* are not  usually
     in l^ tod."
          Once again,  a ooemlngly inocuoua statement actually has the effect
     of leading the reader to believe that irrigated borloy la not so important
     In this basin.
          Ask Evan Benson,  Rick Anderson,  Ann Lund,  Shopman Johnson, ralmor
     Tetcon.  Ton Daviu,  fan Lee,  Oarroll fladacor or Barry llandy  now Important
     barley Is oa u cover crop or ao a cash crop uhon tho proper  combination
     of good ranagenent  and uater aak« Baiting barley possible.   He balie/e
    tit.u In every y««r at  least  • few of those  persons  Mentioned, and probably
   other*,  irrigate barley.
                                                                                                              110)
                                                                                                                             Responses  to Montana Hater Resources Delvltlon
A discussion of spring runoff quality has been added to Chapter 5.
                                                                                                              131)        The mdel allowed for Irrigation diversions directly from the
                                                                                                                     river which in these Months could not be fully *et.  If deep pools
                                                                                                                     filled by ground water ere available, then these demands  or, at
                                                                                                                     least • portion of thei. could be met.
                                                                                                              132)        The last part of this sentence has  been deleted.   However, it is
                                                                                                                     Important in estimating economic  Impacts to know which crops are
                                                                                                                     Irrigated and how much. A discussion  in  the economics  section  has  been
                                                                                                                     added stating that reduction In crop  yield may result  in  significant
                                                                                                                     losses for the farmers presently  using Irrigation Mater from the
                                                                                                                     Poplar River.
-------
133)     On page 203 of the Appendix, the conversion factor is too high.   Proper


    conversion factors are given on page 55 of Appendix A of the International


    Poplar River Water Quality Study.  (The result is that the TOS values given


    in this draft EIS are too high by about 15-20Z).


134)     On page 14 of the EIS report, the tabular data is not extracted accurately


    from the cited reference.  The boron values for the lower basin were determined


    differently from the upper basin and the values of zero were assigned to


    those samples that were not analyzed.
               Responses to Montana Water Resources Division


133)        This  error has been corrected,


134)        This has been discussed in response to other consents.  (See
       conroents of W. Draper).
                                   300
-------
CA>
o
                 \	-f^r^^—    VL.    ~fl
                    >L    «v     "^W**.      '•*"*• '-**
                      v^           _       _
                              Three  Cornets Boundary Association          _
                                  PO.Bo»676Scobejr Ml 592630 SF P O'  p J • J 6
           Sipt. IT. 1900
    ROf*Ol* I* •  -»•»•• »— —
    Rtriennl  Ailninlatrntor,  Reflon 8
    lijitu 103, lOCO lincoln  Ot.
    Denver, CO   8a">5


   : Denr Vr.  WlUinu*.

         I iui wrlline on behalf of the Three Corners Boundary Association,


    a  rou? of furiM-re. rancherc and other citlaens In Uortheast Montana.


         Our first review of ihc Draft Environmental Inpnct Statement on the


    1-07) .r River Basin (K?A 938/5-30-003) Has done little to restore our faith


    In Ihc c°vc-rrx,^?A.


136)     Second, we object to the fuet that  the languace of th« DEIS is im-


     r.r-lr.Mc and alnoit useless to the c«eral public.  Exasiples abound.


    7MB is  In direct conflict with 1502.S of the  nbove cited resulatlons.


         Third, and soat  Important, tne b-iS conplctely fails to axmtion the


     J-..0? Boundary Waters  Treaty. whlc«i is of central  litportence  in  the Water


     Ap-.ui-tlt«incnl decision  the  EIS vas lr.tJ.nicd to udJreJS.

         The U.S. State  rn|*rlnint Is rfti^snsibl* for prei.ervlnc the Intcj-rl'-j


137) of the Treaty,  whit-. •<«•.  In .s-rt. tr.at "waters flo-lno «cross the touni-.ry


     r.> ,11  M.I  I-  |.,il..l".l on  .il.l.cr ride to Vr.s Injuiy of health or prcpoi ly


     rn tl.'  oth. i.  'I'"-- In. I.  of .•%••» a r-fare-ice to the treaty in the FPA .locur--.t


^   •'-.«•» n-r'cct of tit- c-nti.il <-'.rv. !•. -.!«• dlaciiualcn.


                                      ( •„ -)


              AN AfFlllATC Of  tHf NOHMfPN  PIAIMS  »fSOO«Cf  COUNCK
    Mo
    •m-.te
                                    -2-



138)    Will the effect of tn« reeomer.^d International Apportlorweot of


    the vater. of theWlr ni»er violate Article IV of the Treaty, or


    it notT  If  H vlll, what alternative! tre available!

         Your pro.pt attention to this ratter vlll be appreciated.
                                                                                                                                              Yours truly,
                                                                                                                                              Lee Humbert
                                                                                                                                               S.airr.»n, TC3A
                                                                                                                          Responses to Three Corners Boundary Association
    13S)        A legal notice of the public hearing on September 23. 1980 MS
           put 1n the local newspaper In Scobey by  the EPA as stated by the
           EPA Hearing Officer (Hikes HcClave at the Public Hearing. "Also, a
           notice of the  time and place of the meeting accompanied each draft
           EIS that MS sent to each Individual and organization listed on
           the front of the EIS.  This list Includes all area newspapers.


    136)        He agree  that parts of the draft EIS Mre difficult to read.
           Me have attempted to remedy this problem In the final EIS though
           M cannot exclude technical discussions  of a highly complex subject.
                                                                                                            137)       Me agree with the Importance of the Treaty.  A description of
                                                                                                                   the Boundary Maters Treaty of 1909 has been added to Chapter 2.
                                                                                                                   The objective of the EIS Is to Identify potential Impacts.   It would
                                                                                                                   be the responsibility of the Injured parties to Identify violations
                                                                                                                   of the Treaty and take legal remedies.


                                                                                                            138)       Mitigation measures of air quality, irrigation, and fish and
                                                                                                                   wildlife  Impacts are discussed 1n Chapter 3 and 5 of the EIS.
-------
                               MERLE D. FITZ, M .O.
                                 BCOBEY, MONTANA
                                      eaau

                                   September  2^,1980
                                                                      487-5000
      Environmental  Protection Agency
      Federal Building, Dravrer 1009G
      301 South Park
      Helena, Mt.   59501
                                               RE:  Impact of Canadian
                                                   Pov/er Plant Devel-
                                                   opment and Flow
                                                   Apportionment on the
                                                   Poplar River Basin
139}
        Dear Sirs:

        I wish to cxprosc ray  Department's and my pcrconal concern -about
        the problems v/ith supply of water available for Municipal use
        in Scobey.  It is quite  evident that the changes in water flow
        on the East Poplar  River Basin, and any future changes in the
        Middle Fork, will have adverse  effects on Scobey's water supply
        both Quanity (Section 5-2.3-1 Draft Environmental Impact State-
        ment - pages 117-120) and Quality (Section 5«3.*f  D.E.I.S. -
        pages !Zf2-lif3).  The  final Environmental Impact Statement must
        make this very clear  to  the general public and to those people
        on the I.J.C  who negotiate v/ith the Canadian Authorities over
        water control in this River Basin.
                                               M.D.Fitz, M.D.
                                               Director, Daniels County
                                               & City of Scobey Health
                                               Department.
                      Response to City of Scobey Health  Department
       139)        The section on effects on the municipal  water supply of Scobey
              In the  summary has been expanded.
m

               •*••'•:'•:''
              •!.•{:•*.'«; •;;.
:•:-;:!':
                                             302
                                                      Hi!
                                                                        •iL
                                                                                   t..
-------
 Missouri River  Basin  Commission
        M«Md W (toll
          Ouwnwi
  Wsmn ft. MwwU. South Dun
                                                 • Om*». IMnrftt «I14

                                            "A PftiHtonttfl Slali-FtOtrfl flhwr Basin Comminlen"

                                             8«ptnb«t 26, 1980
      Mr. Boq«r
      te9ion*l
      Mflon VIII, U.S. HivlroniMtal
        Protection Agency
      Federal Building
      H*l«na, Montana  $9(01

      Doc Mr. WilliMMi

           The MRBC staff na« reviewd a copy of th« Draft BnvironMntal Upact
      StatoMnt  (OBIS) and Afpcndi* on "Xuftet of Canadian Po*»r riant OevalogMnt
      and rioM ApportionMiit of tha Poplar Uvac Baaln.*  the following ganaral
      coimnta and attached •pacific ooaenta are offered for your consideration.

      General Ccaaenta

           Overall the DEIS, •• written, la extremely difficult to understand.
      Throughout the docuient, hypothetical environmental conditiona ere discussed  in
      detail, which are predicated on the inpleaentation of various flow
      •Fportiomant*.  These projected enviromentel conditions are then .Interwoven
      with discussions of topacta associated with proposed power plant development
      and detailed discussions of water demands for future irrigation development in
      the D.S portion of the ropier River Basin.

  140)     The Drsf t «s would be siuch sealer to follow if the power plant
      development snd the flow eppoctioraxnt questions were discussed separately,   it
      is suggested that the BIS analysis focus on an evaluation of alternative  flow
      apportionments lather than emphasising the analysis of tha lapsets associated
      with a recosmended apportionment that apparently has been developed without the
      benefit of detailed BIS studies.  Tha detailed discussions of projected
      Irrigation developments end air quality Impacts also tend to overshadow the
      issue of flow apportionment.

   141)     Another general comment is the inconsistent use of abbreviations and
      terms.  For example, the capacity of tha power plants la shown aa "MMa" in
      several places while in others it ie shown as *MH,* the more conventional
      abbreviation.
                                COMMISSION MEMBER!
                                                                                                           Mr. Roger t. Mills
                                                                                                           September M. 1»80
                                                                                                           rage Two
                                                                                                        142)    Also, tha verb tense used throughout the OBIS makes  it difficult to
                                                                                                           distinguish current conditions from those which  are projected.  For example,
                                                                                                           page >, the fleet paragraph,  the third  line Infers that the reservoirs are la
                                                                                                           placet but other references indicate that these  are potential developments.

                                                                                                                Thank you for the opportunity to review thia DBI8.   I trust  that these
                                                                                                                 its anft those which are attached will be helpful  In  finalising the Bis.

                                                                                                                                                  Sincerely,
                                                                                                                                                  Carroll N.  Heman
                                                                                                                                                  State Director
                                                                                                           MnVeck

                                                                                                           Attachment
                                                                                                            eei
                                                    John B. Acord, MRBC Member
                                                    Gary Piltt. MRBC Alternate
              Ittparmtiu
*»n lnMthr. Dtfammm af
                                                                                                                         Responses to Missouri  River Basin Commission
                                                                                                           140)        Text Intended to say Irrigated acreage  Is expected to Increase
                                                                                                                  substantially after construction of two  proposed reservoirs.

                                                                                                           141)        Because of the number of flow apportionment alternatives. It
                                                                                                                  Mas decided that we should describe In detail the  Impacts for the
                                                                                                                  recommended apportionment of the IOC In  the main tody and to discuss
                                                                                                                  differences In tapact for the other alternatives.   It was also
                                                                                                                  Initially decided to present an Integrated assessment of all tapacts
                                                                                                                  of the flow apportionment and power plant development.

                                                                                                           142)        The abbreviation for power plant capacity has been changed to
                                                                                                                  "MM" throughout the report.
-------
141)
                                   SPBCIPIC COMMENTS


                                         on the


                     DrVlllUNMKMTAL IMPACT BTATRMENT CM IMPACT OP CANADIAN

                 PIIWPR PLANT MVILOPMRNT AND PLOW APPORTIONMCMT CM mi


                                   POPLAR RIVBR BASIN


          Th*  fnllowlni djwienta are principally editorial and are part of the


    CetMlaalon'a September  2t.  IflO, response  on the MIS,  Mi-pact of Canadian


     Power D*v*lop»*nt and Plow Apportionment on th* Popular Rlvar Baain*i


     Th* pagination of th* OKI I aumary la Incorrect.


     On ih* third |M of the MIS aunary the  following correotlona ahould be Bade.


             Undai  ionqoaalonal. M*rlen»e la •Isepelled.


          -  iintlwr  tli* Montana Hating. "Old Neat Regional Coasilaslon* Is not a


                po|..irt*»nt uf the Interior,  'Bureau of Outdoor Recreation"


                ahould b* deleted and replaced  by Heritage Conaervatlon and


                Ko. tut ion Service, which  la ahown.  The 'Bureau of Reclamation*


                should r>» changed to Nater and Power Reaourcea Service.


     On the fourth page of the DEIS aumary the 'Mlaaourl Rlvar Baain Cuwlaalon* la


          ahown Incuirectly ae part of the U.S. Department of the Interior.  The


144)      Co«a> I a* I on should be Hated aa a Joint 8tat*-P*d*ral entity.


     Page 4, eecoral paragraph, aecond line.  The phraae *of the Sour la Red River


14ft)      Baain,'  ahould r>» deleted and aubatltute of the MlaaouM River Baain.


     Page t, laat paragraph, aeooxl line.  The aoronvn *MP' ahould b* defined.


146) page 12, laat paragraph.  Thla paragraph dlacuaaea SO and 90 percent


          eundltlona and ln)lcat*a that If SOj control waa  Increased to SO percent,


          all claaa  t  atandarda  would be aiet.  la there an  Interta point between (0


          and 90 p*rcent whrct atandarda alght be Bet?  If  so, thla point ahould be
                Reipoimt to Mtuourl Hlver Basin Coimtttlon
141)        Correction* noted.


144)        Changt MII Mde.
14S)        "ESP* stands for electroitetlc prsctplUtor.  Thli 1s tpclled
       out In the tent.
146)        Bstsd on th* Modeling reultt. the Cl«»s I PSD »Und«rd for
       •witaMB 24-hour SOi  concentrations cannot be satisfied tn the
       northern portion of  the Fort Peck Indian Reservation with 60 per-
       cent sulfur wide (SOi) control  of stsck emissions.  As Indicated
       In Table 1.1-2, the  predicted S0» concentrations exceed the Class 1
       standards by a factor of four.   Therefore, 75 percent control of
       SOt e»lsslons fron the stack would result In compliance with the
       standard.  However,  to attain this level of SOi emission control.
       flue-gas desulfurliatlon procedures such as alkali scrubbing
       (removal efficiency  of SOt or More) wist be Implemented.
-------
U»
           identified and dleeuaeed.
147) p«t«  l), third paragraph,  third aontane*.  th* eontone* (Mould be rewritten to
           reflect that unliMd fallow ar«ai oon»«rv« wat*r foe th* n**t eoeeon'e
           crop, not for crop* planted adjaoant  to  tttaa).
148) Pag*  17, firat paragraph,  a*eond line.  The location ahould bo 41° SO'.  «iia
     Junction U notth of th* N*st Pock btfuroatlon.
149) p*9«  It, third paragraph,  aooend aentenee.  Th« yaar or period the valua (or
           anqlar-daya c*f«i> to li mcloar.
ISO) pag*  lot, lest paragraph,  eaootrt line.  KM word potential ahould b* addid
           ah*ad of *conatruction.*
     Pag*  107, tint paragraph.  TtiJi paiaeraph ahouid b* rovlaod to *'t*t* that
           tk*a* *>• potential r*a*r«olr* and hav*  not boon built.
151) pag*  107, otcond paragraph, fourth Una.   figure 4.1-1 abovlng total potential
           •vaporatlon for Jun*  through iiptMbor la not r*f*rr*d to In th* U*t.
152) Peg*  107, aooand paragrafh, **v*nth lln*.  It would b* oor* aoourat* bo
           aubtraot groving Maaon proolpitatlon rather than annual u**d in thla
           r*f*r*nc*.  Mao uhat  about moll •oiatuc* content at atari of growing
           ••••on?
153) Pag*  107, third paragraph,  aacond eontono*.   Alfalfa I* en* of th* tint eropa
           to *gr**n-up* In th*  •pring, and on* of  th* l*at to etop growing In th*
           (•II.   A* Nay M - a*pt*ob*r 20 growth  period atat*d In alfalfa MOM too
          ahort.
154) P*g*  107, thlid paragraph,  ninth lln*.  Chano* !• •la*p*ll*d.
155) Pag*  107, third paragraph,  ninth lln*.  ThU  a*nt*no* lnf*ra thit all
          precipitation r*c*lv*d ttat Jun* through e*pt*ob*r la *ff*otlv* In M*tlng
          coniuiptlv* uaa*.  Thl« li not aoouraUi • portion la loat through
          •vapor«tIon and runoff.
                                                                                                                                R*SPons»» to mnouH River Bjtln Con»ln>on
                                                                                                             147)       Sentence changed to say "conserve water for acreage planted the
                                                                                                                   following year".
                                                                                                             148)       Text changed to 48  SO*.
                                                                                                             149)       The period when the angler days Mere Measured hat been added.
                                                                                                             ISO)       Sentences Mere changed to 'proposed construction of two reservoirs*
                                                                                                                   and 'proposed Installation* rather than 'expected Installation*.
                                                                                                             151)       deference to Figure 4.5-2 Is deleted.
                                                                                                             152)       The sentence In ojuestlon It In error.  Norrlton-Nalerle subtracted
                                                                                                                   11.0 Inches of natural rainfall from their calculated consumptive use
                                                                                                                   of 33.0 Inches.  This 11.0 Inches It not the annual precipitation.  The
                                                                                                                   sentence will be changed to read. 'Subtracting a precipitation depth of
                                                                                                                   11.0 Inches and dividing by ...'.  Apparently Norrlton-Mater1e did not
                                                                                                                   account for Initial toll Mater.
                                                                                                             153)       The Irrigation teaton hat been changed to Nay 1 through September 20.
                                                                                                             154)       Text corrected.
                                                                                                              155)       The Mthodology hat been changed to that only 'effective* precipita-
                                                                                                                   tion It tttuBod to supplement soli water.
-------
   1S6)   Page 117. last paragraph, lait line.  The references to 'outdoor water* here


              and throughout the following paragraph! should be defined and explained.


   157)   Page 125, n««l-to-l«st sentence.  Thla atatemnt  la not coneletent with the


              discussion on page 5» regarding (lih habitat.


   158)   Page 149, firat paragraph.  The adverse effect* of energy  requirements should


              also be described In this discussion of sprinkler Irrigation.


         Page 160 and  161.  The discussion of costs should be Bade  clear.  The fixed


              Investment costs should be differentiated from the annual or recurring


              costs.


   159)   Page ITS, second paragraph, third line.  Susceptibility Is Misspelled.


         Pag* 176, last paragraph, fourth line.  Pteclpltators  la Misspelled.


         Page 161. third paragraph,  iteai 3.  Solubility Is Misspelled.
                   Responses to MltiouH River Basin Consist Ion



156)       Sentence changed to add that outdoor water uses Include lawn and
      garden watering, car washing, street cleaning, etc.



157)       Fish habitat on the West Fork Is not as good as along the East
      Fork and Main steti of the Poplar.  Text on p. 59 expanded to discuss
      this observation.



158)  Annual fixed and operating costs for Irrigated crops have been added.



159)  Typographical errors have been corrected.
CO
o
at
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                                 DISTRICT SANITARIAN
                                  AHTIM: f0.9fftm.mnit
            Bnviroinental Protection Agency
            federal Building, Drawer 10096
            301 South Park
            Helena, Mt.
                                                         October 16,  1980
                                                         RZt   lopaot of Canadian
                                                              Power Plant Bevol-
                                                              opnent and How
                                                              apportiGBBent OB the
                                                              Poplar River Baain
            Beer 31m
            I wiah to ezpreee my oonoem ore* four queetlone that were relaod in
            •y Bind while reviewing the B.P.a. Draft E.I.8.   Thoee ojoeetloni are
            ae follow*i             /

        160)   1)  Why wee not the alternative of Inetalling flu* gaa  daeulfurl*-
                    atloa ooMlpejeat on the flanadian power  plant oonaldared for
                    reducing the aennnt of MI released Into the atewepbere? (p.-9)
        161)   2)  What water eouree.  other than the PopUr  Rtvor, would rooharge
                    the ground water for a well located farther away fro*, the
                    eubject river at Soobeyf  (p.-120)
        162)   3)  What Bltlgatlng oeaeureo can bo implemented to control or reduce
                    TDS  ooneentratlona and aoount of 80||  in drinking  water obtained
                    froei the Poplar BiverT  Bow aueh will  they be filtered out by
(.,                  ooveaent through the aolle, into the ground water  whloh le tap-
O                  P*4 tot Scobey water?  (p.-1lt2)
-•I      163)   b)  Bow far freei the Canadian power plant will enough atejoepherlo
                    pollution occur to cause aold rainT (p.-177)

            I would certainly appreciate It If the final B.I.8. could  enever the
            above qneatlone Bore thoroughly.  Aleo, ae the Tri-County  Sanitarian
            for Daniel*, Deoaevelt and Sheridan Countlee,  all of whloh Bay be
            eeaevhet lapaetod by the Coronaeh Power Plant, X would appreciate a
            copy of your final Z.I.S.
            Sincerely your*,
                      R»«pon»«» to County Health O»p«rtiMntm


160)       SO, control by  flut gas desulfurliatlon «|u1paent «t 60 and 90
      percent contra)  levels MM considered.  Results are shown In Table 3.1-1.


161)       Recharge to the glacial aquifer is fro* the Poplar River, Infiltra-
      tion of direct precipitation, and son from the overlying Flaxvltle
      gravel fonutton to  the east of Scobey.


162)       Data taken  at the Scobey Municipal Mil and the East and Nteole
      Forks of the Poplar  River In 1976 (Klarlch. 1978) Indicate that little
      •Ulgatlon of TBS  and SOa concentrations occur due to aweeant through
      the alluvium. The quality of water In the Scobey Mil should be sow-
      mat better than the quality of the East Fork given In this CIS because
      some recharge occurs froa ground water.  Also, the river water is coablned
      East and Middle  Fork oater not Just East Fork water as shown In the
      ejodel results.  Treatment processes are available to remove TDS and
      $04 (e.g. 1on exchange, reverse OMosIs) but they are expensive.


163)       The Ojuestlon  1s the subject of major research efforts both In
      North America and  In Europe.  Expected emission levels froa the SPC
      plant will contribute S02 and NOX which can result In rain with a
      low pH.  The laoect  of acid rain In an area depends on the buffering
      capacity of the  soils and surface water.  As discussed on p. 171-172
      and 177-180 of the DEIS, buffering capacity Is high.  Thus, no «ajor
      tapacts fro* acid  rain are predicted.
            Elonoro CuetefRon,  B.S.
            Dlitrlet Sanitarian
            DG/vlk
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   164)
                  MONTANA  HISTORICAL  SOCIETY

                      HISTORIC  PRESERVATION  OFFICE
                 225 NORTH ROBERTS STREET • (406) 449-4584 • HELENA, MONTANA 59601

                                    August  19, 1980
            Mr. Gene Taylor
            Environmental Protection Agency
            Federal Building,  Drawer 10096
            301 South Park
            Helena, MT  59601

                                    Re:
                            Impact of Canadian Power Plant
                            Development and Flow Apportionment
                            on the Poplar River Basin.
             Dear Mr. Taylor:
    Thank you for the opportunity to  review this Draft Environmental
Impact Statement.   Although the issue  is not addressed within  the report,
it appears there will be few effects on cultural and historic  properties,
in Montana.

                        Sincerely,
                                    Marcel la Sherfy
                                    Deputy  State Historic Preservation Officer
            TAF/MS/det
                    Response  to Montana Historical Society
164)       A map of historic places 1s presented as Figure 4.10-1.  A discus-
     sion of the likelihood of effects on cultural and  historic places  has
     been added to Section 5.4.1.
                                  308
-------
                   MORRISON-MAIERLE.  INC.
                            CONSULTING ENGINEERS
                        STRUCTURAL       Wmt MttlMCM
u>
o
                                                                                                                                             r.
                                                           October 20. I960
                     Max Oodson
                     U.S. EirrinmenUl Protection Agency
                     Federal  Building
                     Helen*.  Monteiu 59601
                     dear Mr. Oodson:
                          Enclosed Is • copy at coaMnts prepared on behalf of
                     the Fort Peck Sioui and Asslniboine Tribes respecting the
                     Draft  Environ-ental Isjact Statement  for the Popl".  These
                     coMfits are the seM  as those delivered to you on October 17.
                     1980.

                                                           Sincerely,
HOMISON-WIERLE. INC.
                                                                                                                                             M)
                                                                                                 m fon no. IIBIMI mici TO THE OMFT EIS. IHMCT or
                                                                                      CMHOUN POKI fU«l OMlOMDff AM FIM «fKWU«M«lir OH IK POPUM MVtt
                                                                                      SUM. PMMUO IT HMUSflHMOU. IK.
                                                                                      I.  IM MIS la tataraly IMM I* t«* top*.  Tkt *»ly MUr
                                                                                      lopart MtaiMd )i «Mt raMltlflt ftM> Mat ky Caooda iHtkoM oMrtl «f
                                                                                      MUr «Mllly tt UK taumMI«Ml kwn*ry.  SUU 0«tnri«»n •rftclilt
                                                                                      km M «iu uxt (Mrmtu mtwtlM »t I>PKU M u* Untu< tuui «M*r
                                                                                      cmdltlMM if merle MUr sptllty crIUrU it tin IntirMUml
                                                                                           Ik* gwnnlM M • tfoMitr*«i cmmtiy of ttfUr of ipMlflld qutllty II
                                                                                       •Undird ua KOfltt (ntinwtloMl pnctlei  Hi Uw CoUrwlg llvir in*
                                                                                       UnlUi Sttut fMrwilM* Hu)c» I.MW.OM icrcfMt p*r jwar. Md UH U.S.
                                                                                       lui Oftnttt t«»tntt tt •niton* «f Otlttn u t«r«*Ut tkat Uw MlUlty
                                                                                       •f «M wur will not OCM« M4 rill I (TIM p«r Itur  iKMtty. Ill*
                                                                                       InttfMtliMl J»«M taBltllM rvuiMMM ulliilty •tJKtlMB ttr ttt
                                                                                       Swrll tl«*r U MMlWta »t. . .*•» accvUkU CMMtnttM »f I .Ml «/b>.
                   Qutllty «vld*1
      hcucii. U «IMntlit* (M Cft ISOO.I)
                                                            Hike Watson
                      W/dal
                      Encl
                      cc:  Dave Johnson
                           Fort Peck  Sioux I Assinitoine Tribes
                                                                                           Mil It mmtnvt «*-«IUTMtli« km MM iMlut«< (ScwurlM 4.1,1,
                                                                                       II. M, a, » ood U). mlf *w tlUraallM KtlM tr tin •MraMMt •'
                                                                                       Cimdi Md tk» V S. KM kMi t»«it>Ud .  . wcxitnlltd MUr ajMllty «l
                                                                                       IM InUnxtloMl kMMtry vK* Mt fall kwdM af •Itloatlan a* tht UntlW
                                                                                       SUUi; (Saa Sactla* S.l.S). lUMrlc MUr OMllty crlUrlt at Uw l»Ur-
                                                                                       ittttonal bauntary It • M(kly rtutMbl* tlUnutln. a* alUrrutlva ibavt
                                                                                       vkMi Uw laUnHtlanal Jttat Cwtliila* (IX) ka< anpanditf CMildtrabl* tl
                                                                                       and afforl.

                                                                                           Nat t» litclvd* avaliutlaft af nuatrlc MUr a>ulUy crlUrla at Uw
                                                                                       kawdary la U fnntrtu Suta kaaarUaM «Klilan-a«ton.  Mitt ratftct u
                          I- O BO. *M» ' «mi.MIN«»»IMUl -MILIM» "Oil I «N» 9'H.OI - »«O«« »0« 41J SOW •
                                                                                                                                             Itt)
                                                                                                                                                     Tka oat«*n «f i
                                                                                                        rlc crllarlt Mt Mt flktllnd at tM tta* of IM
                                                                                      •Mr oMlity RodtllM and prtparatlM of IM IIS. TM mowlc crtUrla
                                                                                      okJactlM of 1000 •o/T *r IHO *•/! TO tat ktm aotlMtN ml*) IM
                                                                                      ««roprlau tUMrlot.  Ihlt hat Mtn added to CMpttr 3 and IM MRWry.
                                                                                      At tipltlwd Mr I ttr. tM PWPOH of tklt lit Mt I* naluatt flow
                                                                                      apporllonml alurnatl«M andpMir plant oparttIon on tM U.S.  TM IIS
                                                                                      Mt Uktn • coMtnatlM approach inwlno unit IM tffottt Hill M ultk-
                                                                                      •ut Mtar oddity ohjacttm. Tklt CM |I>« Uw SUta OtpartMnl raatMt
                                                                                      Md dtu to prttt for lapMlnt th»» akjocllm If Mck » court* af action
                                                                                      It utocud.
-------
         the  environmental  consequences  of enuring  into an agreement with Canada.
         the  State  Department  has  no basis to  evaluate  the effects of controls at
         the  boundary.   It  is  inappropriate for  the  EPA to deteraine that an alter-
         native  action  embracing numeric criteria at the boundary  is unreasonable
         and  to.  therefore, exclude that alternative action froo consideration.

             Additionally, CEQ guidelines require:


             '.  .  .agencies to assess the positive  and negative effects of
             the proposed  action  as it  affects  both  the national and inter-
             national  environment " (40 CFR 1500 8(3)(c))

         The  DEIS failed to consider any alternative  that would require Canada to
         provide  water  of specified quality at the international boundary.   Con-
         sequently, there was no assessment of any positive water quality effects
         accruing to the U.S. from numeric water quality criteria at the boundary.

  166)   2.   The DEIS  failed to properly  evaluate the property damages from water
         quantity reduction and water quality degradation on Fort Peck Indian water
         rights and irrigation development potential.  In depth investigations by
         the Fort Peck Tribes show current crop production per acre on dry  farmed
         lands at $77.00.  Crop production would increase in value to $350.00 per
        acre with irrigation,  a net increase of $273.00 per acre.   With reservoir
        storage on the reservation,  dependable water supply is expected to  total
        6.000 acre-feet less with apportionnent to Canada than without  apportionment.
        The six thousand acre-feet is sufficient to  Irrigate  a minimum  of 2,060  acres.
        Consequently, the reduced flow of the  river  would result  in  reduced  nvtnuci
        from crop production in the  amount of  1560.000  per year   The DEIS does  not
        nention any annual  damages stemming from reduced  water supply,  title  to  which
        resides in the Tribes.   (See  pp. 2 and 3 of  "Recommended Numeric Criteria at
        International  Boundary,  Poplar River Basin"  April  1979, Water Uses and Water
        Quality Objectives  Committee.  Poplar River Water Quality Board).

             The DEIS  speculates  that  water quality  will decrease  alfalfa yields by
        15 to 21  percent, in SO percent  of the years on Fort  Peck  Reservation, (See
        p  213.  Appendix G, .1  leaching  fraction)    For 10,000 acres irrigated
        within  the  reservation, the resulting  crop losses will  be  valued at $630,000
        per year.   For  20.000  acres the  value  of the losses will be $1,260,000.

   167}       The  statement  that:
             "The  preceding discussion  of  Impacts  has presented the worst case
             situation."   (DEIS, p.  165)

        is  clearly eroneous   The DEIS  contends that the maximum possible losses In
        farm  income in  both Daniels  and Roosevelt  Counties will be $1,130,000 per
        year.  Hore losses than given in the DEIS  can be expected on the Fort Peck
        Indian Reservation alone.  Employment  losses and secondary impacts were
        notably absent  in  the DEIS.
                          Responses to Hprrlson-Haierle
166)       Table 5.5-2 (P. 163 in DEIS) shows the estimated change in fanners'
      Income that would result from the reduced water supplies under the ap-
      portionment.  See response  168.

167)       The wording has been changed from "worst case"  to "pessimistic situa-
      tion".  Greater Impacts could occur if all irrigated lands were damaged by
      TDS to the extent that no crops would grow for some  period of time.  It
      is unlikely that farmers would allow this to occur.
           The loss of $1,130.000 is net income, not gross farm receipts.


                                     310
-------
c*>
168)      The DEIS also assumes. Implicitly, that the Irrigated acreage now in
     production results In farm receipts of about $50 per acre.  In Table 5.5-5
     the "Maxim- Possible Impact on Far* I new*" Is $1.130,000 If 22,524 presently
     Irrigated acres were taken out of Irrigation and subsequently dry famed.   It
     ft respectfully submitted that the value of Irrigation In Increased crop pro-
     duction Is a minimum $273 per acre, not $50 per acre.   Therefore, If the 22,524
     Irrigated acres were placed in dry fares, the loss of crop value would be
     $6,150,000 per year.

169)      in further denigrating the value of irrigation the Draft EIS claims
     that by year 2.000. . .The largest absolute and percentage lipacts would
     occur  (n Roosevelt County where fan income could be reduced by 6X.  .  ."
     The DEIS falls to recognize that this "maximum possible Impact" would
     Involve the destruction of 100% of the Irrigated lands in the area and
     seriously damage numerous farm and ranches.  The OEIS hat not evaluated
     the impact on the farms involved or on the livestock Industry.   Costs of
     importing livestock feeds to the area, as experienced during the 1980
     drought, would destroy the local livestock Industry within several years.
     The OEIS further falls to consider the loss In land values, tax base and
     employment opportunities within the balanced irrigated and dry fare) economy
     of Daniels and Roosevelt counties.

170)        The hypothetical "maximal possible Impacts" should abandoned and
       replaced with probable  Impacts.  Specifically the  final EIS should state:

            *    loss In crop values  from presently Irrigated acreage.
            •    number of firms affected.
            •    impact on present livestock industry fro*  loss of hay base.
            •    future losses within Fort Peck Indian Reservation as summarized
                above.
                                                                                                                                 Response* to Morr
-------
  171)  3.   The DEIS presents  one  alternative  for mitigative measures to reduce
        impacts of  saline  irrigation waters.  That alternative  is  full mitigation
        by  farm operators  within  the United  States.  Those  operators  are expected
        to:

             0    improve  conveyance (p.  146)
             0    line  on-farm  conveyance (p. 146)
             0    alter irrigation  practices (p.  146)
             0    switch to  more  effective system (p.  146)
             0    receive  irrigation education  (p. 146)
             0    provide  greater leaching (p.  162)

        No  mention  is made of the costs  in dollars to  U.S.  operators.  Costs should
        be  presented.   Moreover,  no evaluation  of impacts was provided with respect
        to  10, 20 and 30 percent  increases in irrigation application  to leach soils
        damaged by  upstream  water quality degradation.  With respect  to increased
        leaching requirement the  EIS should, as a minimum,  address the following:

             0    impact on  water rights  of  increased  diversions for  leaching.
             0    increased  fertilizer costs of unavoidable leaching  of nutrients.
             0    increased  drainage costs.
             0   . percentage of lands  that would be  lost to saline seep from
                  increased  application  of water.

             The failure of  the DEIS to  consider an  alternative of water quality
        control at  the  international boundary and resting the full burden of water
        quality mitigation on U.S. water users,  leaves the document totally one-sided
        and of no value'to Canadian or U.S. decision makers.

                         Response to Morrison-Maierle
171)       A discussion of costs of salinity  mitigation has  been added to the
      economic  impacts section.   A discussion of saline seep has been  added  to
      the water quality section.
                                       312
-------
172)       The statcoents on pages 106, 107. and 131 of the OEIS respecting

      irrigation water requirements should be revised and any reference to 18.7

      inches per year diversion requirement should be deleted.


173)       The comparison of diversion requirements is meaningless and has no

      merit In the EIS.  No conclusions are affected by the number selected for

      diversion requirement, and the OEIS presents an Issue strictly unrelated to
      the purposes of the EIS.


           The determination of 18.7 inches per acres as a gross diversion.require-

      ment by Tetra Tech is clearly erroneous for the following reasons:


           •    alfalfa consumes water and produces crop yields long before  the

                first spring frost and long after the last spring frost.  Accepted

                practice for determining the growing season of  alfalfa provides

                for beginning growth when air temperatures average SS degrees and

                ending with the last killing frost  (28*  Frost as  distinguished

                from last frost-free day).
                                                                                            • i
U)
       175)
       176)
      177)




      178)
               water Is consumed  and otherwise  lost within the crop root zone

               during the non-growing  season; a factor not considered by Tetra
               Tech.


               measurement of consumptive use (San Juan Agricultural- Experiment

               Station. New Mexico; Snake Conservation Research Center, Idaho;

               Roza  Research Plots, Washington, among others) conclusively show

               that  the Blaney Criddle equation with published crop coefficients

               (.85 seasonal coefficients) predicts as little as 60 percent of

               actual consumptive use.   Moreover,  crop yields are proportional

               to consumptive use.


               Hay, a principal  month of the growing season,  was not considered

               by Tetra Tech.


              Tetra  Tech did not  consider  that  only a percentage of total

              precipitation is  effective In meeting crop water requirements.
                         Responses to Horr1son-M«lcrl»


172)       Based on further Investigation of the transpiration demands of crops
      grown In the Poplar River basin diversion (requirements have been changed.
      The extent of these changes will be apparent In the following comments.
      These new calculations show that the diversion requirement of IB.7 Inches
      Is too low.  Such references to this value have been changed.


173)       The Irrigation requirements determine the amount of water diverted
      from the Poplar River.  It was  necessary to compare various estimates to
      see If the values used In the aadel were correct.  In addition, the
      amount of acreage which can be  Irrigated and therefore future economic
      Impacts are directly  dependent  upon diversion requirements and thus are
      a vital part of the EIS.


174)       The first sentence of this comment is not understandable.  The USOA
      Irrigation Guide for   Montana ttotes that alfalfa consumes water between
      Nay I and September 29.  As a result of coonents we have defined the
      Irrigation season as  beginning  May 1 and ending September 20.


17S)       Mlnter losses were assumed to be negligible compared to growing
      season losses.  Because the soil freezes and the ground may be covered
      with snow, little migration of  water out of or Into the root zone Is likely.
      Furthermore, the maintenance requirements of water for a dormant perennial
      are extremely low.


176)       This 1s a valid  point.  However, the under prediction Is not as low
      as 40 percent.  The Blanay-Crlddle method underpredlcts by about 20 per-
      cant (I.e. predicts 80 percent  of  crop requirements on the average).  This
      has been accounted for, and crap consumptive use estimates have been revised.


177)       Pursuant to these recommendations and those of others, we nave In-
      cluded Nay In the Irrigation season.


178)       Effective precipitation calculated according to Doorenbos and Prultt
      (1977) Is being used Instead of total precipitation In all pertinent cal-
      culations.  Ho correction Is  made for soil storage.
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              The data presented are so grossly inaccurate that a shadow is cast over

         the credibility of all technical determinations in the DEIS.


  179)   5.    If the DEIS at page 1 is intending to conclude that the Fort Peck

         Tribes are limited to irrigation of 4,186 acres rather than the full acrea9e

         entitlement of the Tribes, the statement is untrue and should be deleted.

         Any determinations by EPA or its agents that the capability of the land is

         less than proposed by the tribes will be met with strong objection.


         The findings from EPA's operation studies of the Tribes' reservoirs and

         other supporting bases for making determinations limiting the Tribes' use

         will be required.
                          Response to Morrison-Maierle


179)       The DEIS does not refer to capability to Irrigate but to the number
      of acres that can be irrigated in the summer when four 300 MW units are
      operating, the recommended apportionment Is in operation, the two reservoirs
      on the Fort Peck Indian Reservation are 1n operation, and there is a median
      flow with no consideration of carryover storage from the previous year.
      The full acreage of 20,618 acres was considered in the EIS.  If carryover
      storage from wet years is available, then the acreage could be irrigated.
      In fact the inflow to the reservoir would be higher than predicted in the
      model because no structures presently exist on the Middle and West Forks
      to restrict the flow coming across the International Boundary to the ap-
      portionment allowance.  The summary has been expanded to explain this.
                                      314
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<*>
•-*
en
                             COMMENTS ON THE
                 DRAFT  ENVIRONMENTAL IMPACT STATEKBMT
                    IMPACT OP CANADIAN POHBR PLANT
                  DEVELOPMENT AND PLOW APPORTIONMENT
                        ON THE POPLAR RIVER BASIN
                                   BY
                          ROBERT D. SCKNBEKLOTH

          I wont to thank you Cor the opportunity to present my
     concern* about the 'Draft Environmental Impact Statement" on the
     Poplar River Basin and surrounding areas.

180)       The concerns  of various persons and organisations were vary
     aptly presented  at previously held hearings.  Along with-the
     concerns, Major  shortcomings of the  International Poplar River
     Mater Quality Board's final report were exposed and discussed,
     all.' in some detail.  They are a matter of record at  this tine.
     I realize this involves a volume of  material which may account
     Cor your apparent  oversight of and non-use of this information
     in other preparation of the Poplar River Draft Environmental Im-
     pact Statement.  I would, therefore, like to call your attention
     to some additional references of record that I feel deserve
     further and careCul consideration.
          International Joint Commission  Hearing Transcripts:
              Sept. 10, 1979 - Roades—pages 205-214'
              Sept. 10. 1979 - Sims—pages 249-259
              Sept. 11. 1979 - Schneekloth—pages 10-33
              Oct.  16. 1979 - Schneekloth—testimony
              Oct.   16, 1979 - Stoneberg, Ronald P.—testimony
              Oct.   16, 1979 - Roades—Final comments.
          I am unable to refer you  to the page numbers of  the October
          transcripts as they were  not made available  to us.

          There were  other items, which would probably have altered
     the context of  the impact statement had they been given the con-
     sideration they  deserved, such as:

           1   Molybdnosis and other possible problems  of this type.

           2   Liver  pyrosis of Northern Pike - which wasn't predicted
              but  made its presence known after  some  $800,000 had
              been spent.

           3   Mercury contamination and lack of  Collowup.

           4   High Incidnece of  respiratory disease - livestock  and
              human  and  the  added synergistic effects of smokestack
              emission*, water  pollution and weather extremes.
                                                                                                                       R«tponiei to SchneeHoth
                                                                                              IN)      The Transcript of the September. 1979 public hearing MS used  to
                                                                                                    prepare the DEIS.  The Transcript of the October. 1979 hairing was  not
                                                                                                    available to EPA.  However. EPA personnel were present and their notes
                                                                                                    were used to prepare the DEIS.  Also. Rhodes or It ten testlmny and
                                                                                                    later response was available and used to prepare the DEIS.

                                                                                              181)      Nvlybdnosls Is a chronic cattle disease caused by Imbalance of
                                                                                                    the copper-oolybdenui ratio.  Because the critical factor Is the ratio
                                                                                                    and not a specific limit the IJC did not specify a criteria for mriyb-
                                                                                                    denus.  High values of molybdenum were measured in a few wells In the   -
                                                                                                   .Frenchsan Formation In Saskatchewan.  This formation Is below the one   -
                                                                                                    which Is being mined and where ash lagoon seepage would enter.


                                                                                              182)      This statement cannot be addressed because the location and circum-
                                                                                                    stances of this occurrence are not given.


                                                                                              183)      See responses 102 and 249.


                                                                                              184)      Health effects were addressed on p. 90 of the EIS.   These statements
                                                                                                    here cannot be addressed directly due to lack of specific Information on
                                                                                                    where they occurred and under «hat conditions.


                                                                                              185)      Due to the nature of the project Impacts on range) and will  be minimjl.
                                                                                                    Data were not available to nake quantitative estimates.   Agricultural
                                                                                                    personnel In the U.S.  Oepartnent of Agriculture  and Montana were consulted.
       181)

       182)



       183)

       184)



       IBS)
           5.   The increase  of lung cancer by some forty-eight  percent
               in areas surrounding coal  fired plants.

           6.   The glaring lack of input  into the whole process by
               Range Management scientists.
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                                    -2-
186)           7.  Lack of input  from trained and experienced Agricult-
                  ural Finance people.

187)       Many of the agricultural costs here  figured with prices from
     the low end of  the price cycle.  No economic impacts were  expressed
     using parity prices, target prices or prices from the top  part
     of the price cycle.

          In addition to the above mentioned references, I am enclosing
     copies of TCBA  testimony presented at the September and October,
     1979 hearings.
                                     Robert u.  Schneekloth
                         Responses to Schneekloth


186)       The personnel who conducted the economic analysis  have experience
     in assessing agricultural  impacts in Montana.


187)       The figure used for additional  income from irrigated agriculture
     was $50/acre.  This is well above the $42.50/acre reported by Lufe (1979)
     and allows for generous price increases.
                                316
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 188|
Good Evening;  My nnoe is DnvUJ Johnson,  I no here to convey  the vlewj and wintlMnt
of the Pt. Peck Tribes concerning the Draft EIS Tctre. tack has done for the RTA.
Flrat J personally would like  to ony thot I on bucoaln/; dUllluslonod with tho
Eovlromenlal Protection Agency.  Tho rcjwrt which EPA hna contracted to o private
consulting fin tram California nnd endorsed aa a Environmental Impact Study aeewt to
ba nothing more inao a report,  a light weight Literature review.  This 1 OB afraid,
la not why EPA tns created nor  la it cloaeto Uie quality of work which ono would
                                                                   '•»»
e*pwct U ae* coning from the Rogion VIII hondfpwrtnrit of BPA.  Hell. Bealdes that
                                                                                                                                  Retponiet  to Johnion
       point,  I would like to now apeak for Uie PT. Peek Tribal Council.  The Pt.  reck
       Tribca  Imve stated their views and position concerning apportionmnt of the Poplar
       Nlvtr -HI i-oi.orti at three provlouo Imarlnnr: tiera In Ucobey in front of the
       Joifil Cciwltiuloii.  Wo ha»e |>m*lou9ly otatod our poalllon which T will repeat now,
       and 1 quote • T)K> Pt. Peck Trlben contliuo to nsaert tholr Full Dibits to nil the
       Uaturjl H'jwn of Uie Poplar Rivor,  uncle  nlnluhed in Quantity and Quality."   Thla
       pool Lion had been ajserlod conulatantly  alnce consideration of appartlonmant of Uw
       Poplar River.  Th«-ro 19 Mo Change in the poaltlon of Iho Trlbos.  This poaltion
 189)   la predicated upon Iliworotia U.S.  Court declolona, primarily UKI Hlntera Doctrine,
|      Vhorc thu Suprcne Court oittabllahed the  doctrine of lapllod Roaervatlon of  Motors..
i
      The Hlntcra ReaerwKt Waters Nlntita  Doctrine providea that upon the eatobliahMnt
      of Mny Koddi-ul Indian Raaevation  tho United SUitea Reaervea apportonnant woter than
      unapporprlalvd to the extont needed to accomplish tho purpose of tho Reservation.
      Thlu Minlora Klfjit Vost.i on tho date of  tho Creation of tho Reservation and in superior
      to tl>" rlrfita or  any FuVtura appropi'iatora.                                           <
      How we see  that >TA tma Ipnroi our clalsj and that such an ignorance has resulted
      in an  Inpncl  .-lUiti'nent iihl> h does not addro:is the true potential lapaets of tho
      Candlan  fewer Pljnt on the  local environment and econoay.   You should not be unware
      thut tho Ft.  feck Trlboa uro rulylnr, on furturo agricultural dovolopmont to improve
      the poor economic conditions on the  reservation and to bring Indian employment la vela
      up lo ntrh  iii-i..     vi* surrouno'inR region.   Aerlcvltural development on tho   •   _ •>
168)
                                                                                                                The EIS Included results of air md water quality mode
                                                                                                                                 » ara WffA
                                                                                                                                                            " SPC and I X
                                                                                                           his
                                                                                                                                                                IH(lters'
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                  is the prlnary stepping stone the Triboo havo to b«como socially and
      rconuelcally snlf aufflcoat.
    — Th» Poplar hiver la the Inrflont of tho Interior Ho.nnrvotlon Streams, and ovar 126,000
      acres of lrri(.ablu u>lla could be nerved from the river If adequate water aupply
      vero available.  However Ute Matvt-M Stroom Plows or the Poplar River could supply
      only « tinuii portion of the uater required for ao large an acorage.  Several resevoir
      sites exiut in the Baain that Mould store water during high flows and distribute
      it tor trilc-itlon during dry periods.  With the construction of two reaevolra en the
      Poplar  Hivor, Iho Ft. Peck Tribes could Irrigate 15,000 to 20,000 acres.  We have
      determined that crop reciepta Mould exceed ttPJ/ruHtoO OPlt&v  Ho havo alao determined
      thoI the Impact of the Poplar River apportionment proponed would reduce annual crop
      receipts by an estlmjlud $f>75,000 even with both storage roaovolra in operation.
      It is irportaiit to rocoptlxa that other benefits would be reduced also for the Tribes.
     -Tho ft. Peck Tribes foal thai since tho Poplar [(Ivor la the largest of the reservations
lOA)                                                         *»*"•
 wf  interior streams and hos the moat development potential,* that all poaslbln consider-
      ation to r.ivt.n the full development of the resource  as a step In tho Improvement
      of tho reservation economic conditions and toward tribal self sufficiency.
      Now, wf feel the Evlronnental Protection Agency*Irresponsible in Insuing an Impact
      Study which .draws sow very strong conclusions with out qualifying nor providing
      any  sort of justification for those conclusions.  A very good example of thin la on    |
      poetafond 2 of the main Impact statement.                                              (
     -•Hero KI-A lias concluded that only A, 186 ocron of land can to Irrigated out of the
      Poplar  Hiver nonr Poplnr.  That is basically all they say about that, and'In very
      strong  lancuafle, with out Justification for their statement.  Tho Pi. Peck Tribes
      havu apcnt nundredj of thousands of dollar* to study tlw potential and feoaoabillty
      of Irrigating out of  the  Poplar Rlvor.  Aa I havo previously mentioned, Wo havo con-
      cluded, with  tho  help of many experts that uo in fact can Irrigate 15,000 to 20,000
      at res  from the  Poplar River.  How  the environmental Protection Agency la  trying to
       tell us that  thei    -e only *,186 acres thlch could bo irrigated from the Poplar
191)
                                                                                                                                  Response* to Johnson
                                                                                                      190)       An expanded sumary his been prepared for the final CIS which Includes
                                                                                                            the major reasons for the conclusions and iny qualifications.
                                                                                                      191)
See response 179.
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    192)
CO
                                                 (1)
       River.  Ttey are Baking  this statement MlUi out any sort of technical Justification.

       1tw> Ft. rock Trlboi Mill not tolorata thin statement and Inalat that It to removed

       Trot* tl-.o lUiport.

       Ke ara especially aura that tetra-tock the »o called environmental apeclellnts have     '

       not conducted nor are capable of conducting tho engineering etudles necessary to

       deterrJM the irrigation potential of the Poplar Diver Haatn.

     — It la this aort of arbitrator and c4preclous statements which EPA ha£>endor*ed

       that Hakes the Ft. rock Tribes weary or their capability and position concerning

       the Protection of human health and the Environment.  As I have mentioned, the propoaed

       apportlonMnt of the Poplar River would result In en eatlmated annual loos of $675,000.
   -\a 4k* 4"V»«. •
       Tutra teck ..nd KPA hiivo not iiaaeuuiri iho ocunoalc and aoclol Impacts of thin propoaed

       apportionment as it relates to Uio Ft. Potk Tribes.  You have merely discounted the Tact


       that to do havo u very piod Irrigation development potential in the Poplar River.

193)   Furth*ri!»re you huve indicated in your report that the propoaed Federal Cluis I Air

       i.tond  "•   '       •" •-     e       '.•'•''

                              .  The report projects oxceedenco of the standard but doou


       not irxllc.iio »*.alh»r It Is the 3 hour or 24 hour standard which la being exceeded.

       iior li*.4 i».my ll»jj.ll will IPO nxc*orir kn i-adlus of 2% the power plant, resulting

       in a  dollar lo»a of at least $177,408 annually In Donlele County alono.
                                                                                                            192)
                                                                                                            193)
                                                                                                                                             Responses to Jchn-on
     The EM Is aware of the need for agriculture) development to Improve
economic conditions on the Ft.  Peck Reservation.   It MS issued that
Irrlgitlon systems would be Installed only on  that acreage Irrigable with
wan flows for June.  The natural  variation  In rainfall Mill not allow
20.000 acres to be Irrigated every year even with  both reservoirs.  Therefore,
the estimates presented tend to overstate  possible Impacts, because It Is
unlikely that all 20.000 acres  would be fully  developed with Irrigation
systems.


     As shown In Table 3.1-1. the Modeling results Indicated that the
operation of two units with zero percent SO* control would result In the
contravention of the 24-hour maximum PSO standard  at the proposed Class 1
site at the Fort Peck Indian Reservation.  The maximum 3-hour concentra-
tion for the same plant operating characteristics  Is equal to the maximum
allowable level.  The predicted frequency  of violation of the 24-hour
Mxlnum SO? concentration Is low.   For example, the second highest pre-
dicted 24-Four S0» concentration along the same azimuth on which the viola-
tion was predicted. 1s below the allowable standard.  The results of the
same model using Meteorological data collected over a three-year period
at Scobey. Hantana (Gelhaus, 1980) Indicate  a  violation of both the 3-hour
and 24-hour maximum allowable S0> concentrations at the proposed Class I
area with the operation of a single 300 Nl unit.   Estimates nof the frequency
of violations of these standards were not  provided by Gelhaus (I960).
                                                                                                            194)
     As Indicated In the response to  the coMients of Mr. Gunderson, no
supporting evidence for the 1  to 2 percent  loss 1n crop yield predicted
by the State of Montana's Scientific  and Engineering Advisory Panel was
presented.  The relationship between  sulfur accumulation In soils and
loss In plant yield has not been demonstrated.
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                                           CO.
     Your  report  has not thouroughly investigated this prediction and again has made

     another arbitrary statement,  and I quote " Comparison of predicted concentrations

     of S02, NOx  and participates  with acute and chronic threshold limits for selected

     plant species Indicate no detectable Impacts on the tevestrial vegetation" unquote




     The Ft. Peck Tribes demand that the EPA undertake the necessary studies to determir?
195)
     the Impact of the proposed Poplar River Power Plant on the environment, the social

     welfare and  the economy of the Ft. Peck Indian Reservation and its residents.

     We feel that the intentional  disregard of the tribes prior and paramount rights to

     the use of the water of the Poplar River and bhe omission of the Tribes previously


     stated and published plans for the use of the river consititules sore neglegence of

     the Federal  Feduciary and trust responsibility of the Environmental Protection Agency\
                                   Response to Johnson


 195)       This EIS represents the findings of an extensive investigation into
       the environmental and economic  consequences of the proposed Poplar River
       apportionment.  Discussion of the impacts of the various apportionment
       scenarios on the Ft. Peck Indian Reservation is an important part of the
       EIS.  Me have tried to fully respect all Indian rights in this  analysis.
                                      320
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              COllfCC Or AOHCUtTMte
    DEfftKTMENT OF PLANT & SOI SCIENCE


MONTANA STATE LMtVEHSTTV. BOKMAM 99717

   October «, 19SO
               Mr. C«n« Taylor
               EnvlrowMntAl Protect loo Agency
               Federal Bunding, Driver 10096
               301 South Park
               Helena. MT  i960!

               Dear Mr. Taylor:

                    Till* lector contain* wf additional written eonsnt on the EPA draft
               EIS, "Impact of Canadian Power Plant Development and Flow Apportionment
               on (lie Poplar »l»er Basin", ETA 908/5-80-003 dated July 1980.   Further to
               ay oral comsuni presented at the public hearing In Scobey, Mr  on Sept.
               2), 1980 (copy attached), the EPA is requested to utilise the  following
               comenta In revlelog the draft CIS and in their future contract Ing actlvl-
               tlea.

                    Although It doee contain see* ueeful eaterial, thla draft IIS la
               organised and written oe poorly that It preclude* the Intended objective
               of protecting the O.S. cttliane and their interesta In the Poplar liver
               Basin.  In addition, the draft CIS la locking technically, eapeclally  In
               the areas of aoll chemistry, crop physiology, agronoay and Irrigation
               agriculture In general.  It la my cootentIon that thla is the  result, of
     1          the failure of EPA or their contrector, Tetra Tech Inc., to engage the
C*>   :          services of certified professional soil scientists, crop physiologists,
•^             end afronoe>l*ts to ssslst with the agronomic «nd Irrigation aspects of
               this stujy.  It Is recoeotended that ell future EPA activities  of this
               nsture, et any location. Include the use of such certified professlonela.
               The cuoperetlon of the American Registry of Certified Professionals In
               Agronomy, Crops and Soils (AkPACS) can be readily obtained by  contacting
               their Executive Director. Dr. Martin Openstuv, AIPACS.  477 Sooth Sogoe
               load. Madison. HI J3711.

         196)       Th
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       198)
ro
ro
       199)
crop y|,•!.!•.. ,1,1 not sup|iort  tlilj  ivni-r.ill/od  conclusion.  It  HUUKIJ to me
lint our  >l ih.. |>i obi.-mi ulil cli  III')  pn-p irurs ol  Dm dr.ift MS li.vl In
I nt'Jipi. i i i < thi-lr ii.it i  Is  relit'I  1.1  cnnputlnn damage* due  to yield
tejuctlons ol  irrigated  crop* i^ilcli Imp.ict*  primarily on the Irrigation
firmti*, luit I* presented on e  prorated hasls as Impacting on all tlie
f iirm-ij of  Hie B.i8In  Including  dryland timing and range grazing opera-
tions.  rr.'tiTit Inn "">  Impacts  In  this manner would he acceptable If. and
only If,  In tliu same  parigruph*  In  tiunmiry and rlnowhore In  the report
t lie  topii.  IH jdilriised,  that  tho Impact on the Individual Irrigation
f tr-«-r U  '-IH ilMed,  e.g..  Irrigated crop yield* will be reduced by 101,
401, or Mit annually  and possibly  Irrigated  agriculture will b* precluded
entirely.   Tlila loratltutos a  significant Impact on each and every Indl-
vldnil Intuition fnrmor In tho Basin and must ho HAted a*  such even
thouKh th-ie lo-i»e* can be  made to  appear Insignificant when diluted
uttttln the  l,i|i 1^1* of the total  farming community la the Basin.

     Also,  to  naVe the  empirical functions to predict yield  reduction* of
       c-l. Jue~ t'5'Increasing Uvula  of  boron, TDS and SAR nor* acceptable
and  to enph.itlc.illy  Indlcnle  their  limitation*, they chould  b* qualified
hy  nt.itIn;;  In  thu summary,  and  every other place In the report where they
are  d I seamed, e.g.,  page 1JV  page 141,  that they were applied to compute
yield  reductions  of  Irrigated  crop* by considering the effect* of boron,
IDS  and SAR to be additive  when. In fact, It has been reported In numerous
scientific  journal article* that In many case* when multiple stresses are
applied  t» planu,  the  efftcts are often compounding rather thun additive.
In  a ooro slnpla  statement. * plant suffering from boron toxlclty 1* In
poor condition /*» contend  with the effect* of excestlve TOS.  Thus,
since  It  wa» not  possible for the preparer*  to Include the very complex
and  cocq>oy e n'.ilvu le'cls  of  tioran,  TDS and SAR «r« likely tu result In algnlf-
 li.imly  gruAter  yield reductions.   Tlie limited resource* provided tor
 tills study procluded thu prediction of actual yield reduction* which
would  result  frui* the complex Interaction* of lh*s* multiple stresses."

      krlitlv,-  tu Item 8 In my oral comment,  the draft EIS should be
modified  to convey tha proven phenomenon of  a soil and boron-containing
 I rrlf.it Ion water  reaching an equilibrium  Involving n point of maximum
jdsorptlon ol  boron by thu soil it wine point In  tine; and furthermore.
at th.it  point  In tin:,  the lysten  1* known tu acquire the boron concentra-
 tion of  thu lrrlj.it Ion water a* the mlnlnuu horon concentration of tho
 •oil wlutlin.  If the bor>,n concentration 1*  Increased such a* by oper-
ntlng rh<> power plant, thu soil will adsorb more boron and new, higher
 concent r it Ion of  bo ion In  thu soil solution will develop.  Alto, It linu
bean shown that  about I or 2 orders of magnitude more water 1* required
                                                                                                                                            Responses to Sins

                                                                                                            198)       The effects of the three individual parameters, boron.  IDS,and SAR.
                                                                                                                  were not considered to be additive.  Rather the Interactive  effect  was
                                                                                                                  considered of TDS and SAR (effect a) and boron (effect  b) separately.
                                                                                                                  Effects a and b were then considered to be additive.  As stated In
                                                                                                                  responses to comments of Caneron. no quantitative data  were  found describ-
                                                                                                                  ing the Interactive effects of boron and other substances on crop response.
199)       This paragraph discusses the phenomenon of boron  by  stating that at
      some point In time the boron adsorption will reach « maximum.   At that
      point the boron concentration In the soil solution will be equal to the   *
      boron concentration of the Irrigation water.

           Theoretically, this maximum value cannot be  reached.   However, by
      using Langmuir's theory 1t can bt approximated.   We have  estimated Langmuir
      K and Q to be on the order of SO and 0.02 for Poplar River soils.   Assuming
      99 percent saturation of the exchange sites for boron  the  equilibrium
      concentration required would be 1990 ng-B/1.  A solution  concentration of
      200 ng-B/1 would be required to saturate half of  the sites. Concentrations
      of this magnitude  and hence, saturation of all boron  adsorption sites are
      unrealistic.  It Is true, however, that higher Irrigation  water values
      will result In higher boron soil solution concentrations.   This Is accounted
      for by our boron miss balance approach.
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IN}
<*>
              Mr. Con* Taylor
              October e. 1*60
              rage i
       to leclalm A bo run polluted iinll than wn>i need to anka it.  The expenao
       of tbia type of redemption should be mantlonod in the 118.  That la, It
       vlli tike 10. 20 or more tlmae the nuabar of irrigations to reclaim the
       •oil end the development of the boroa polluted soil could bo over *
       period of e few to oovorel peer*.

200)        Tho Irrigation refillremente of alfalfa calculated by the preperere
       on pofe 10). baaed oo the tleney-Crtddle equation and the invalid eeeump-
       tlae that oo Irrigation lo required In Nay end the letter port of Septem-
       ber, aunt bo repleced by • oore retlonel derivetloe.  Tho irrigation .
       requirement* of alfalfa end other crop* Irrigated in the Beelo ehould~b«
       baaod oo a tried and proven eyoteO), If one aatata.  I nalnteln thet euch
       a tried and proven ayetem ail ate.  SpecifIcelly, the U.S.D.A. loll Conaar-
       vatlon Service 1974 publication entitled "Irrigation Culdo for Montana"
       haa boon devuloped, in part, through actual practice through the aervlce
       ectlvily of SCS In dealgnlng Irrigation syatome for Hontana fermere over
       the paat few decade*.  Since SO ho* a record of auccoaefully dealgnlng
       Irrigation ayafeme for Montana farmers uelng their guide •* • baals, It
       ahould bo viewed aa a hotter baa I a for determining irrigation requtnmenta.
       Alao. alncc alfalfa la a perennial crop, irrigation in let* September
       and/or during October lo neceeaary to fill the eoll profile with water to
       hoop the alfalfa allva over winter.  Tho Ileney-Crlddle eyatem need la
       the draft IIS dooa not account for thla over-winter need for water by
       alfalfa.

201)        further to the fact that alfalfa ia a perennial crop,  the Manner in
       which the draft BIS la written auggeate that the conclualona In the
       summary, wliich atatoa that no elgoiflcent damage la predicted, were baaed
       on average yoare.  Theao pa"* °* the draft BIS ahould bo rewritten to
       incorporate the fact that some of the greatest hitarda from having to
       irrigate with low quality water cornea la years with below-average precipi-
       tation, auch aa was experienced by the Scobey area in 1979 and again In
       1980.  One of the primary effocta of high aallnlty Irrigation water on
       alfalfa !• arand reduction.  Stand reduction ia a form of damage which
       muat be Integretod over eevorel yeare succeeding the year of damage.  If
       the aallnlty level becumaa high enough or la maintained for aucceaeive
       seasons complete failure of the crop reaulta.  Thla type of reaponae to
       Increasing anllnlty of  the Popular River mult be Included in the CIS.

            It  la prciMMptloiia of  Ilia preparera who, at beat, have eitremely
       limited eaperlence In irrigated farming and mlalmel training In the
       agronomic  nclrncea, to recommend Irrigation farming praetleea for Poplar
       •Ivor Beala irrlgatora,  many of which are ualng Irrigation ayetame designed
       by eaporlenced  U.S.D.A. Soil Conaervatloo Service Irrigation apeciallata
       
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     Hr . r.rnu  T.I y I or
     October  S.  I1)SO
     Page  4



202)       Tli-:  .Ilitciis-jlona and concluulona regarding the effects nf SO  deposi-
     tion  mi  Ljlli  in the Poplar River Basin on p.ig«s 167 to 174 are not
     entirely  i.urcct.  On page 174, the mlJille paragraph concludes that thure
     will  be  iu> problems with acidification of the soil on the basis that
     these soils ne dll highly buffered by CaCCK   This conclusion is not
     i»m.-ct.   Although sum* of the soils In the Basin are buffered by CaCO.,
     nany  .ire noi .   The use of the alternate crop-fallow aanagenent system on
     ilr; upl.mil lolls of the Basin has had the same leaching affect as would
     b<* found In tones of higher rainfall.  After several yearn, the net
     etlect  Ins been to leach the soils to the extant that nany soils have
      loat the Cii'O  in their Ap horizons, soeie of which have actually developed
      acl.llt.  Ap hoii£oni.  Increased SO. coul.l hasten the development of acidic
      coii'Jl tlots.  A c.raain observation of similarly leached soils nlscuhere  In
     •Ionian i It the levelopmant of surface crusts which Imped* crop emergence
      mJ root penetration.  A soil pH of 8.0 or above Is an indication of the
      prci.r.c.- of CaCO   lower pH value Indicates Its absence.  Out of 212 Ap
      h.irljou-i In Daniels County tested by the HSU Soil Testing l-.it>. 22Z had  a
      pll aSuve I, 57Z luJ a pH between 7 and 8 and 211 had n pll bo low 7, with
      soie .is l(w a» 6.0   Increased SO. enlsalons would constitute a damage  to
      these soils
                                                                                                                                            Res ponies  to Sims
                                                                                                            202)       Soil pH Is not the best  Indicator of  the capacity of a  soil  to
                                                                                                                  buffer strong acid.  Alkalinity  Is the best direct measure.   The
                                                                                                                  carbonate 1on(CO»* ")1s a component of alkalinity but  In the pH range
                                                                                                                  fro* 6 to 10 the bicarbonate  Ion (HCOV) controls the  buffering capacity
                                                                                                                  (StUM and Horgan 1981).  Therefore,  the presence of calcium carbonate
                                                                                                                  is not a necessary condition  for soil buffering ability.   Use of  only
                                                                                                                  one conponent of alkalinity (COi1') (i.e.  41 C« CO,) Indicated no pH
                                                                                                                  change when soil was exposed  to  acid  deposition (Saietana, 1979)


                                                                                                            203)       We have attempted to correct the deficiencies In  the draft E1S
                                                                                                                  and to present It In a »re concise and readable manner via  this  final
                                                                                                                  EIS.  The purpose of a draft  EIS Is to foster review and critique of
                                                                                                                  Its preliminary conclusions and  all comments are accepted In this
                                                                                                                  context.  The Impacts on irrigation have been stressed.   It  should be
                                                                                                                  realized that the severe impacts predicted are after operation of four
                                                                                                                  300 Ml units.  SPC does not presently plan to build  more than two 300 PW
                                                                                                                  units.
ro
  203)     In ilutlng, I sincerely hop*  that  these comments and  suggestions
      will htflp I P,\ and Tetra Tech Inc.  to  revise this  draft EIS  Into a more
      useful .loc.ian.-tt.  Hy luruli  criticism  of  the draft EIS at the  public
      hearing In Scob«y was justified by the  poor manner in which It was wittten
      jnl it* technical deficiencies.  Although  they had  to deal  with some
      OEtiuccly complex envlronment.il interactions, the preparers did not
      express the  limitations of  their evaluations and  suggest that the actual
      J.m ifiln.j effects nf further degradation of the Poplar River water could
      be nuch ;runtcr than Indicated In  the draft HIS.   The data  generated by
      the prennrers of this draft EIS and the manner In which It  Is presented
      lend me i > bellove that If  the U.S. Government utilizes the conclusions
      In  the EIS to enter Into  an agreement with Canada,  nil Irrigation farming
      In  t'le Poplar Rlvar Basin will be  precluded.  The draft BIS must be
      nitructui.J and rewritten  to emphttslse (he severe Impacts  on Irrigation
      farming.

                                         Kespectfully.
                                                 James R. Sim*
                                                 Professor of Soil Science
               JKi/1.
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CO
ro
ui
        Mjic-M-iii  of  Oi .  Jaous R. $!•». C.P.S S , C.H .AH. Research Soll'Sclentlst,
        llotii mi ,\i;i l«.uliur jl Cjtpui Incut Station. Rnrca.ni, ri^aldlng the Jr.ift
        • iivlroi.nnt.il Impact statement (KPA 908/5-SO-OOJ). "UfMict of Canadian
        Power  Pl.int  Dcvelopisunt and Flow Apportionment an Hie Poplar River Basin",
        pruaantej  it  (he  public hoarIng held In Seoboy. Montana on Tuesday,
        Sopteriuu  23. 1930.

        Upon  inltl.il  iM.t.»lr.ntlon "f tin: draft unvjrunmunt.il iifstunent, "Impact of
        C.iiijiJl.in P.^.-i  I'l.mi Dcvxlopspnt nnd Flow Apportlonwrnt on the Poplar
        Rlvar  Basin" (EPA 908/5-80-003). I found a number of deeply dlnturblnt
        fenturcx.  -.t.iicacntit. and prediction!.  Soae of these disturbing aspect*
        ul  ihu di:ift  rib  are outlined below:

204)    1.    Irrcvelant auicrlal «hould be moved.  For exaieple, on page 2 end
             again on page 4. FPA point! out $269.000 expenditures In the U.S. by
             Canadian worker* plus sane secondary benefit* yet fells to Mention
             the U.S. chare of approxloately J7JO.OOO spent by taxpayers to
             f limner  the  "fin emit lonal Poplar River Wnter Quality Study", eon-
            duitPd  by (he IJC anil /Alls to nunllon the taxpayer expanse for tills
            X1S which Is estinstiit to be 8175,000, ell of wlilch results In a nsc
             )>j. .  to  thf  U.S. tarjiayurs of a feu ImndroJ thousand dollars.

        2     I:i'"l on tlic Hot of propnrcrs, this draft CIS uas prepared without
            th« be-iff It  of » professional soil scientist, crop physiologist, or
            •gronoalst on the staff.

205)    3.   The EPA. on  pegs* 17-18 and elsewhere In this drsft EIS, with various
            scenario*, predict* B concentrations frosi 0.8 to 5.5 sig/l with sest
            of  the  preJlctlonn around 2.0 »g/l.  RPA and U.S. Geological Survey
            persunnel, working with their Canadian ten* members, predicted B
            concentritlon* Iron 5.4 to 11.S ag/1 with nost of the predictions
            • round 6.0 ng/1 or *bovc.  This oxtrmne variance In predicted B
            concentration* Is not  acceptable and mist bo resolved.  Diffurences
            of  ^  few percunt would be understandable, but differences of 300X
            are not!

206)    ->.   The EPA, on  page 2 .ind elsruhere In this draft EIS. ststes that
            operation of','»*• single 300 HUe units will not lead to significant
            di-griJatlon  of water quality for irrigation; and yet. on page 1)1  it
            prclients rc-iiri-k^lon o^uotlonj which Indicate that Increasing the B
            level by even 1 ng/1 will result In yield roductlons fro* 2 It to
            B 7t  for tli<: various crops, anJ on P*RC 140 present yield reJuctliins
            of  39: to 75Z (10Z leaching fraction)  and 71 to 2Vt (JOZ leaching
            fraction) due to i.ilinlty and/or sodlclty for ths various crops.
            The EPA  need* to uxnnlnu the swaning of the word "significant".

207)    J    Thu Irrigation requlrucwntA of alfalfa whlrh wore calculated hy EPA
            on  page  107  wtrc based  an tlM aosuBptlmi that  no Irrigation Is
            required during the conrh of Hay.   That jssun|>tlun Is not valid.
            The EPA  calculated  net  requirement  of  11.8 Inches and, with a convey-
            ance efficiency of  63X,  a  gross diversion requirement of 18.7 inchiis
            prr acre.  This I*.  .is  F.PA gays, roughly tvilf  of the Irrigation
                         i:.ilculatej  by  Horrlson-Mnlerle  lar the Fort  Peck Renerva-
                                                                                                                                           Rcsponses to S1sa
                                                                                                            204)
                                                                                                            205)
                                                                                                            206)
                                                                                                            20?)
     SM response 196.
     Boron concentrations for scenarios 23 through 27 did not Include
ash lagoon seepage.  The maximum concentration predicted with no seepage
and 4 300 NU units Is 8 mg/1 (Table 6-2.1).  The naxlMM concentration
predicted with the ash lagoon seepage (scenario 8A) and 2 units Is 20ng/l.
Differences are due to assumption used to develop scenarios.  The EIS
analyzes both wrst case and conditions expected based on SPC's present
plans.

     The change In concentration of the Modeled constituents fro*
scenario 3 (Cookson Reservoir) to scenario 28 (Cookson Reservoir and
1 unit operating) Is small as shorn by examlng Tables 6-2.1 through
6-2.16.  The decreases In crop yields were computed from the present
yield using average soil properties and not from the yield using Poplar
River Mater for Irrigation.  The large yield decreases are due to the
lack of dilution and larger applications In low rainfall years.

     The discussion of diversion requirement has been deleted from the
•aln text.  The month of Nay has been Included In calculation of crop
consumptive use.
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209)
210)
                                       -J-
           llon.   l(  U>.\  wuulj luv.-  cnnnultc.l tin  U.S.D.A. Soil  Conservation
           i^rvU-.- 1«74 publication  tntllluil "tri iRJt Inn Uuldo for Montana".
           Hi.i umil.i  hive  found th.il  lrrle.nfi.1 nlf.ilfi In thli  area hi* in
           «VIM.I-,.I i •ui'.iiMiiilvi- ii!..i.  In M.iy, nf J./fl lin-liuN, an nvoruH'i offi'crlvo
           r.id!,ill nl  I.U liiL-he*.  and thue, en avern&a not Irrigation requlre-
           nu-iir .if 1.1) iiiclii-i,

           ruriliermorii. the USD\-ttS guide I lets rho rural consumptive uae of
           w.i.-i  by .ilfilfj In ihM  .iro.i jn 21.48 Inchus tin* Hay 1 In 'juni.
           2«.  Dm uM active rilnfnll  ax *.61 Inchon, which lonve* • nit Irriga-
           tion ruqulrimwnt of 19.1} inch**.  Ultli a conveyance  efficiency of
           6K.  thli |iv«i n grata divan Inn requirement of 10.7 Inches, which
           It eucti closer to the Horrlson-Hfllurlu rui|iJlranant.  Alia,  EPA did
           not  Include tin water required fur affecting a 0.) leaching fraction.

      •    furiliorrore. on Dago 107. E?A u».-d the precipitation  probabilities
208)       for Havre. Hontena, which le about 220 ml lee to the wett.  There are
           publunnl precipitation probability data for wather  ttatlona In
           Northeaelern Montana.  Also, according to my collague. Dr. Joaaph
           Caprn, Agricultural Cllutologlat and Hetaurologtat  for the Hontana
           Agricultural Bxparlnent Station, aueh probability data could have
           bdon easily computed for Scobay by aupplying tbo computer with about
           tO bite of date from the local weather •teflon.  With ao much hard
           data fro* the lew-dials area available. It la difficult to justify
           uelng weather date fro* a station 220 miles away.

      7,   Concluvlona In the suawry that no •Igniflcant dauga we a predicted
           were appnrently based on the "average yeare"; EPA nuede to bo raejlnded
           Hint the graetssc haierd from having to  Irrigate with low quality
           Irrigation water comae In yeere with below average precipitation.
           Aa I tuld the U.S.-Canada IJC laet fall. 197* precipitation waa
           considerably below average, 1980 has turned out evin woree - we have
           hardly received an inch during  the growing eeaaon ihle year,  the
           statoMnt by EPA on  page 108 that  their  design quantity, for alfalfa
           le realistic Ignores the fact that dry year* occur and that half the
           tl.x- precipitation will be below average.

       S    In inputting  the Impede of boron  on crops end the aoll chamiatry of
           boron.  tf\  cites thu work of Hatcher end othere. end  etatee ih.it
           when wetere containing boron era applied to aolla. eome of the boron
           le *1»'iilM'«l.  Furthermore. EPA ut«i»  ititi as juellflcotIon to eaiumc
           thet Scobey area Irrigated eolls can remove sufficient axcemi boron
           from the cmuimlnatod  Irrigation water  to prevent crop damage.   TMe
           Is not  the  rin.il end point  in the  raactlunu between boron-containing
           Irrigation  wetera  and aolla.  Hatcher, at nl., want on to apply  the
         . Thonda-lltualer-Vermouleit uquntlona  showing  that  tho volume of walur
           containing  lioron required  to reach  equilibrium with the eoll decraeeea
           as lie boron concentration  increases, and thnt  the elutlon of boron
           from aalurated  eoll* always requires a  larger volume of walur thin
           tli.it required to effect  eaturetlon.  In  lay  term*. Ihle mem* the
           higher the  Boron content of the  wntar.  the  quicker the soil become*
                                                                                                                               Responses to S1e»

                                                                                                208)       The Scobey precipitation data were not used when irrigation requlre-
                                                                                                      amts were originally calculated.  Subsequently, Scobey temperature and
                                                                                                      precipitation data have been used In our crop consumptive use estimates.
                                                                                                      He note that the precipitation probabilities obtained originally fro*
                                                                                                      Havre and adjusted for Scobey coincide with those obtained fro* the Scobey
                                                                                                      data.

                                                                                                209)       Precipitation probability was taken into account using dilution
                                                                                                      factors (see Appendix G) to simulate soil water quality degradation in
                                                                                                      below- and above- average years.  The design diversion quantity was
                                                                                                      based on rainfall of a I In 10 year drought.
                                                                                                                          our statement on the conclusions of the work of
                                                                                                      Hatcher, and Bower (1956).  Even though their conclusion was that desorp-
                                                                                                      tlon required greater voliates than adsorption, they also concluded that
210)       Me agree with you
                   -     J,g
                                                                                                      either of these processes was adequately described by Langwlr theory
                                                                                                      In the concentration range of Poplar River water*.  Rhoades. et al.
                                                                                                      (1974)conc1uded that Langjwlr theory did not describe the desorpTTbn of
                                                                                                      native boron.  In both studies soils with native boron were used althouoh
                                                                                                      Hatcher and Bower used soil with low Initial boron whereas Rhoades et al.
                                                                                                      used soils with widely varying Initial boron.  The boron added In Ir-
                                                                                                      rigation water will be associated with the fast reaction referred to
                                                                                                      by Griffin and Buran (1974) and therefore subject to rapid desorptlon.
                                                                                                      Thus our approach Is valid since we consider only boron held by adsorp-
                                                                                                      tion and not native boron.  Leaching of native boron Is not an issue
                                                                                                      associated with power plant developMnt.
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                                         -J-

             • iiuratAl wlili baron, nml  it  (hat  pnlnt.  th« loll  solution ha a tho
             • .unit It cuniunt Ji» tha li rlp.nt Inn wo tor.   Ic  nlnn •oani that It taken,
             auvfi.il i Im-a rare v»tat to raclnln a horon-pollulad loll than it
             4 III  In ui.ikn It .

             Thus.  M'\'» contention  ilui tha aolla In  Ilia Poplar River Baa In can
             peri-iii>-iii ly MI •• t acrubber  to roonvii I fro* the Irrigation water
             <•  Invill.l.

211)   9.    Tli*  it.tiiMMiit on page J Hint  iliu lupunndiaent  of  inter In Conkimn
             Rimorvolr lue ratullod  in  Improved water  quality on the Eaat Kork at
             I ho  International burtlor In all nu.ieona axcont aprlng, It not a
             aliiiuaani of fjet. but  rathar  ia an aaauaptlon.   It la an taeunptlon
             bused  nn another aaauaptlon thiit onu yaar'a  data,  197). represent
             rlio  |u !„ turn average.

             An i"iuill>  vjlld aaauaption la that lha preeant  uatar quality of tha
             Entt i.jrlr at tho lnteriuiilon.il bordar reflect* tha trua avarag*
             w.itor  .|iij|lty of) lha taal  Fork for lha parted of Inpoundaant (197J-
             lli'l).  .md  that thaaa TOS  and boron lovaln would ha a «ora valid
             b.i .11 tin* which to ju4c« futxru jj.T.itiun of lha 300 MWo unit  will lower tha quality of
             llu-  uii.r jn tlio tat I Fork.  Ttilii  la con-il»tent  with KPA'a atateawnl
             on i it," 126 llul thti omflov nu.illty tram tho raaarvolr li dufurnlnad
             by eonpluia •!«!»( o( tha  raaarvolr and aiaa* balanca of all raaarvolr
             Illflitv. ind out f low i .

212)   iO.   ,M«o,  nn fan* !">. "A  mntua  thai  tlu- qmllty of  Kirfnco lrrlc.itIon
             ri'iurn flow waa c.ilculatuij .11  IOZ lilnluT  Ihiin lha  quality of lha
             dlvorrud watar.  Tha quality of tha return flow  will ba imich lowar
             tltnn that of  rim dlvartml  Irrlgiillnn wntor.   Croialy Invalid atala-
             awnta  auch  na lha on* by EPA abovo eaat doubt on tha validity of tha
             r ipud .

       »•   t' there la any validity to any of lha prediction* in Ihla raport,
             th>  pn-dUtvJ ylulil roduetlona on pugoii 132,  1*0 and Ul, whlcli ara
             anbtliint I il, would ha very algnl f Ic.int jnd la In norloun conflict
             with EFA'a  ktaioneiii on page 2, which tuya that  operation or a
             ul nn la Mi/o  unit  will not le.id  to elgnlfleant  degradation nf uatar
             quill t/ for Irrlp.iflnn and olhnr porpn-icn.

214)   II.   M.iiiuf ictui Inn tin- yield reduction eatlKiia /ie n  function of CAR and
             K'' .19  .1 logiltlmlc functlun of SAR and KC, »nd applying II  without
             vrrlf Uat ion by o«p"rl«ent  la aclant If Ically  unaccaplahla.   I don't
            hullcvp tliai  lha Scubny area Irrlx-iinrit ahnuld ba  aakod to bacoatt
             /out axporlnnni  to leal  Ihli cuflrlcnl functlun.  Alao, by l!iu
             ui.iiumcnt un P.IU» H^,  Ihla unui I r I c 11 function If  aup|iO*ud  lu hava
             i MI...J  b.irl.y,  wli.i.ii  ,itiJ ii.iIu in Imvo i>K|it.>rt. 11 ahvd,  why ara limy nut cludf
            Al'.i,  Ion "itjrv.il l.'il" ihoulil bu Jet 1m-.I.
                                         to S
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                                             -4-

            I3-  0" P«S* 1*1. EPA states that they considered  the  effects of boron,
                 salinity and sodicity to be additive.   The report doesn't cite any
                 reference as a basis for making this'assumption.   In  many cases,
                 when multiple stresses are applied to  plants, the effects are often
                 compounding rather than additive.  This area  of  the report needs  to
                 be raore thoroughly done.  Boron has A  roxicity effect;  SAR has
                 indirect effects on soil physical properties, aeration, reduced
                 availability of calcium, phosphorus and other plant essential
                 elements; and salinity has osrairlc effects on water uptake and
                 sometimes specific ion effects including toxicities and interference
                 with the uptake of plant essential elements by plants.  Such complex
                 soil-plant-water relationships and interactions should  not be treated
                 so lightly and simply glossed over with unproven, empirical treatments
                 such as EPA has done in this report.

    216)    14.  Nowhere in this draft EIS is there an  indication  that EPA considered
                 the extra expense to Scobey area irrigators that  would  be required
                 to effect leaching of the high salt levels that will  develop in
                 their soils.  Also, no consideration was given to the expense for
                 additional fertilizer to replace the plant nutrients  which would be
                 leached out along with the harmful salts.  There  was  no mention of
                 other increased production costs to the irrigators to use the high
                 TDS,  high boron water and the new on-farm management  practices
                 proposed.

                                     Concluding Remarks

            This draft EIS^contains an excess of irrevelant material.  It contains a
            great number of contradictions within itself.  It  utilizes a large number
            of invalid assumptions.  It relies heavily  on untested empirical solutions.
            It and the Poplar River Water Quality Report have  such wide  discrepancies
            in their predictions concerning irrigation  water quality and the effects
            of high TDS and boron on crops that the effect of  the  Draft  EIS slnply
            further clouds the issues rather than to help clear them up.  Even though
            it would be an additional cost to the taxpayer, I  call for it to be
            redone.  This concludes my testimony.


                               Responses to Sims
215)        This issue has  been treated in response  to the   comments
      of Cameron.

216)        See response 201.
                                     328
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 7
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 •I
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       211J .'I
            I
making this request.
           1 have (one questions  I  would like eo direct to the
people that filed thin, if I may,  and I may have to refer to
•ouioonr bac!: In the audience 1C  thnt'n permissible.
           HEARING OrriCER McCLAVE:   And could the—we don't
hnv« a f.  A. system, so the people In the audience—If you can
Identify yourself for the court  reporter then we would be sure
                                                     i
to get your name in the record.                      ' . ;
           MR. HATIIEj  There seems  to bo some discrepancy with
regards to water quality or quantity In the apportionment.
Tl.«t's the flr«t Item I would like to—I would like to address
If you look at the water apportionment report, the first one,
th« yellow one, you don't have one up here,  the IJC's water
apportionment report. It seems like you people took that
Information and that information was baited on one plant, and
you hive included two—two and up  to four In thu—there seams
to be  some conflict there.
           I  mean can 1 direct anything}  Can I get a response
back from  the board on that?
           HEARING OFFICER McCLAVE:   Yes.
           MR.  NATHE:   It seems like  your—the four arena that
you  look at  vary from eight to twenty-one percent that we will
gel oo  the east fork of the Poplar and  then  you have plugged
In more  power  plants,  anil this first recommended apportionment
r>nly wos on  nut- power plant,  And you don't have anything
           spills.
                               Response to Mr. Ha the
    217)      Hodellng and 1*p«ct  analysis have been done for up to four power
         plant units.  The additional evaporation and Inflows to Coofcson Reservoir
         were added to the model.   Spring runoff Is Included when the reservoir
         was full.   This occurred at the I In 10 year high flow cases on the East
         Fork.  A rmnnaH'nn of th« n»»iir»l 'MM «•»»« •>"•< «•««»' r««« ..-•«-- *• • .
    i
    a
    4
    A
    a
    T
    *
    n
    III
    II
    IS
218) It
    II
    15
    1«
    IT
    IN
    II
    20
    *i|
    X!
    Si
    21
     I
side of. the border, have went through I^>... jcura of testimony  1
in trying to stay up  with the experts, actually from both
sides of the line.  We are not scientists.  All we are primar-
ily concerned about is protecting our environment and our
overall I would  say economic well-being, and I feel free to
make the comment I don't care whether Saskatchewan Power puts
in twenty power  plants up there just as long as they don't
harm us on this  side  of the border.  That's been our prlnary
drive down here  is making sure that we are not harmed.
          My question la is there unyona here that is from the
EPA?  What happened to—in the Draft BIS to the infrared
photos that had  been  Uiken over this area since 1971?  I can
remember sitting in 1977 with Alba (sic) Pond (sic) of the
EPA and Lieutenant Governor Ted Schwindcn end myself, State
Representative Art Lund, State Senator Smith, in a conference
room in Helena when a decision was mado to use those infrared
photos as a baseline  data to make for sure that in the future
we were not being harmed, and I have never seen any of that
information come out  anyplace.
          Those  were  supposed to be reinterpreted at Las Vegas
and In Wheeling, Wast Virginia, I believe, and whnt has
happened to that Information?  That never shows up, because
those infrared photos would give us a base lino for those
years prior to the establishment of that plant as to the
the kind of  information that we want  for our own economic
protection in  the  future.
                                                                                                            Response to hY. Maths
                                                                                 218)      The Infrared surveys were used by Tetra Tech as explained at the
                                                                                      (waring (see Figures 4.3-1 and 4.3-2 of the EIS). The original photos
-------
         i


         4
    219)
        11


        12


        18


        14


        15


        1(5


        17


        18


        I'l


        •20


        •Jl


        22


        23


        24
           Secondly,  on this air quality thing, is going

through it I see where you make reference to the study done

out  in Corvallis, Oregon.  Now, that  study was--I don't know

how  I get ahold—I  must apologize  to  you because I haven't

really spent that much time myself on this thing, but it's  my

understanding that  on those plant  species which again I was

involved with with  Dr. Alba (sic)  Fond (sic), who is no

longer with the EPA,  and also Dr.  Francis Sitoway (sic) from

the  USDA, Northern  Agricultural or the Northern Plains

Research Center at  Sidney, Montana, Ed Weiss (sic), when the

EPA  wanted information as to the varieties that should be sub-

jected to the effects of S02 and I guess nitrous oxides and

stuff and that I see  some of those plant varieties were tested

out  at Corvallis, but it's my understanding that there was  a

lot  of question on  the validity of those tests.  They were  not

done especially with  wheat for some reason during the--I don't

know if it was the blossom stage or the heading stage, when

wheat is supposedly the most susceptible,  and I sec that that

data in turn is poured in here as substantiating the con-

clusions that are coming to or that you  have come to with

regards to air quality.

           HEARING OFFICER McCLAVE:   Are  you talking about the

study that was done around Colstrip?  Corvallis also did--
                            Response to Mr. Nathe
219)       The varieties of crops tested from planting through harvest 1n
     field experiments at EPA Corvallis Included  spring wheat, durum wheat,
     barley, crested wheatgrass, and alfalfa.  In addition native grasses
     studied from seedling stage through harvest  included western wheatgrass,
     Russian wild ryegrass, blue gramma grass, and needle and thread grass
     (Wilhour ert aj_. 1977).  Plant health Including foliar damage and crop
     yield v/ere examined during these studies. Results from other studies
     on the effects of S02 and NO* are outlined 1n Table 5.6-1 of the EIS.
     These results were used in addition to the EPA studies 1n Corvallis.
                                 330
-------
       I


       X


       3


       4


       n


       r,


       7


       ft


       u


      111


      11


      IX


      13


      14


      15


      IB


      17


      1ft


      19


      •J»


      81
  220) -'
      S5
                                                             40



Again, my name is Hal Robbins.   I  am the Chief of the Air .


Quality Bureau in Helena for  the State of Montana.


          I just have a couple  of  short things I want to say.


One, we will be submitting written testimony to EPA for our


final comments.  Our comments will be incorporated in the


Final EIS.


          As was already mentioned, tfce Air Quality Bureau is


playing a major role in the analysis  of the air quality


impacts.  Our chief concern among  many other things concerning


the Draft EIS was essentially the  use of the meteorological


data in that air pollution nodel.   The meteorological data in


any air pollution model is extremely critical to tha output of


that model and it's extremely critical to the accuracy of that


model.


          The Air Quality Bureau since approximately 1977 had


been conducting extensive meteorological monitoring and air


monitoring in the Scobey area and  will continue to do so.  The


Air*Quality Bureau, therefore,  is  taking the exact same model


that Tetra Tech ran and we believe to be a reasonable model,


and we are inserting our data that we spent such long, hard


hours on into that model.


          That model, by the  way,  has been run.  We now have


the data for that.  Unfortunately, it just came out about two


Jays ago.  We have not had a  chance yet to analyze the dif-


ference between Tetra Tech's  results  and ours, but those
                         Response to Hr. Robbins
220)     The results of tht air quality modeling by the State of Montana
    have bean Incorporated Into tne final EIS.  Their report Is Included
    In Appendix I.
                                  331
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                        Response to Air Quality Modeling


220) Air Quality Modeling
Cont.
          The Montana Air Quality Bureau performed additional air quality
     modeling (Gelhaus, 1980) using the CRSTER model and meterological data
     collected at Scobey for the period November 1, 1978 through October 31,
     1979.  This model was also used for the air quality modeling in the EIS
     using Glasgow data since the Scobey data were not available at the time
     of the DEIS preparation.  Emissions data and stack parameters used in
     two modeling studies are compared 1n Table 1.  The emission rates used
     are identical.  Some of the stack parameters differ but not by a signi-
     ficant amount.

          Table 2 compares the predicted maximum concentrations in the U.S.
     of the two modeling studies for a 600 and 1200 MW power plant.  The
     predicted values for NOX and particulates 1n the two studies are closer
     than the predicted values for SO*.  Detailed tables showing concentra-
     tion at a given distance and direction are included in the Gelhaus
     report only for 1 hour maximum SOz concentrations.  The  performance of
     the model cannot be evaluated fully because tables showing predicted
     values on a given day were not included.  However, the table (repro-
     duced here as Table 3) for the 1-hour S02 concentrations does not show
     consistent results.  For example, the occurence of single high values
     along a particular azimuth is not consistent with the Gaussian disper-
     sion formulation which uses horizontal and vertical dispersion parameters
     to determine the spread of the plume and adjusts the dispersion-versus-
     distance curves based on the stability class  (Budiansky, 1980).  A con-
     centration of 216 pg/m* appears to be a more realistic estimate of the
     maximum concentration based on the direction and other predicted values.
     This would be very close to the maximum concentration predicted by the
     EIS of 214 ug/m3.  Table 2 shows that even the maximum predicted values
     do not exceed the federal or Montana ambient air quality standards.
     The PSD Class II standards are exceeded only for the maximum 24 hour
     standard and then by 1 ug/m3 for a 1200 MW plant but not for other cases.

          The CRSTER model predictions were also used to determine whether
     violations of the PSD Class I standards could occur at the Medicine Lake
     Wildlife Refuge located about 105 km  (65 miles) southeast of the plant
     and at the Fort Peck Indian Reservation boundary located 48 km (30 miles)
     directly south of the power plant at  its closest point.  The predictive
     capability of the CRSTER model falls off very rapidly at distances over
     48 km  (30 miles) but it can be used to provide an upper limit concentra-
     tion.  The predictions at these distances would be very conservative
     due to the use of average wind speeds and directions which are not a
     function of distance, the lack of vertical variation of dispersion
     coefficients, and the lack of loss with distance due to chemical pro-
     cesses and deposition.

          The maximum 24-hour S02 concentration for a  1200 MW plant with no
     S02 control at the wildlife refuge was predicted to be  9.2 ug/m3 by
     Gelhaus and 7.1 ug/m3 in the EIS.  Both concentrations are above the
     PSD Class  I standard (for S02 of  5 yg/m3 ).   Predictions with 60  and 90
                                      332
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                           Table 1

             EMISSION DATA AND STACK PARAMETERS
        Parameter          AQB 1980*            EIS


Emission Rate g/sec

     S02                    1352.2            1352.2

     Particulates             56.7              56.7

     NOX                     453.6             453.6


Additional Pollution Control
     SO*, percent control    Zero            Zero, 60, 90

     Particulates,
     percent control           99              99, 99.5

     NOX                    Zero                Zero


Stack Parameters0

     Stack height, m         121.9              122d

     Exit Gas Velocity,                              ,,
     m/sec                    24.2               24.4°

     Stack Diameter,  m         7.1                7.4

     Exit Gas Temperature,                         H
     °K                      425.2              424°
aData are from the modeling report (Gelhaus, 1980).

 The derivation of these rates 1s discussed In Section 5.1.2 of
 the EIS.

cStack parameters 1n the EIS were supplied by EPA Region VIII
 personnel 1n Denver.  The Gel nous report states that the stack
 data were derived from EPA Region VIII data but does not state
 why different values were used.

 These values agree with Appendix E:  Plant, Mine and Reservoir
 Operations International Poplar River Water Quality Study 1979
 p. 5-75.  The stack diameter given in Appendix E 1s 7.11 m.
                           333
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                                    Table 2
             ESTIMATED MAXIMUM POLLUTANT CONCENTRATIONS IN  MONTANA
                          FROM THE POPLAR RIVER POWER PLANT

                (Concentrations in micrograms  per cubic meter)3
Pollutant
Sulfur Dioxide



Nitrogen Oxides

Particulates

Time
Period
1-hour
3-hour
24-hour
Annual
1-hour
Annual
24-hour
Annual
Power Plant Size
600 Mw
400 (214f
166 (96)
46 (28)
1.6 (2.4)
134 (74)
0.6 (.79)
2.0 (2.6)
0.06 (.2)
1200 Mw
800 (428)
332 (192)
92 (56)
3.2 (4.8)
268 (148)
1.2 (1.6)
4.0 (5.2)
0.12 (.4)
NAAQSb
—
1300
365
80
—
100
150d
60d
Montana
AAQS
1300
—
265
55
564
94
200
75
PSD
Class II
—
512
91
20
—
—
37
- 19
aNote - higher concentrations have been predicted  using  a  fumigation model.
 However the duration time remains uncertain.

National  Ambient Air Quality Standards.

Sumbers in parentheses are predicted concentrations  in  the  EIS.

 Secondary Standard.
                                  334
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                         Table 3

POPLAR RIVER AREA ESTIMATED SULFUR DIOXIDE CONCENTRATIONS
             600 Mw FACILITY (Gelhaus,  1980)
Direction
100
110
120
130
140
150
160
170
180
190
200
210
220
230
240
250
260
1-Hour Maximum Concentration9
(Values in nricrograms per cubic meter)
Distance Downwind (km
10
176
158
196
176
176
198
196
168
176
166
138
196
196
178
196
182
148
18
140
112.
400
138
118
130
118
128
118
102
112
112
112
112
94
112
108
30
90
86
76
80
216
216
164
84
76
84
158
110
84
76
76
314C
314C
42
68
86
64
68
146
186
156
80
64
146
146
182
128
114
252
252
252
50
64
82
64
64
64
168
146
106
70
86
152
152
118
134
224
220
236
      Note - Higher concentrations have  been  predicted
      using a fumigation model; however, the  duration
      time remains uncertain.

      Direction  in degrees, 0  or  360 = North.

    **These values would occur in Canada as the border
      is about 35 km  (22 miles) from the power plant site
      in this direction.
                      335
-------
                                                                      Table 4


                                 PREDICTED MAXIMUM S02  CONCENTRATIONS AT THE FORT PECK  INDIAN  RESERVATION
                                                             BOUNDARY-POWER PLANT SIZE
to
CO



Time Period
3 Hour
24 Hour
Annual
Allowable
PSO
Increment
Class 1
25
5
2
300 MW
Percent Centre
(
A
49
11
0.4

B
12.5
5
0.5
60
A
20
4.4
0.16
B
5
1.8
0.2
1
90
A
5
1.1
0.04
B
1.2
0.5
0.05
600 HM
L_ Percent Control
i
A
98
22
0.6

B
25
10
1
60
A
39
8.8
0.3
B
10
4
0.4
90
A
9.8
2.2
0.08
B
2.5
1
0.01
1200 MH
Percent Control
0
A
196
44
1.6
B
50
20
2
60
A
78
17.6
0.6
B
20
a
0.8
90
A
2.0
4.4
0.2
6
5
2
0.2
                 Note:  All values are  in u9/*'.  Values under A are fro* Gelhaus, 1980.  The values under A for 60 and 90 percent control are
                       calculated values.  Values under B are from the EIS.
-------
220) Continued

     Air Quality Modeling (Continued)

     percent SO* control 1n the EIS {Table 3.1-2 1n  the EIS)   show that 90
     percent control would be required to meet the PSD Class  I standards
     for SO2 for a 1200 MW plant at both the wildlife refuge  and the Fort
     Peck Indian Reservation.  For a 600 MW plant the EIS predictions indi-
     cate that PSD Class I standards for S02 at the  Fort Peck Indian Reserva-
     tion could be met with 60 percent control, although the  predicted values
     are within 1 yg/m3 of the standard (Table 4).  The predictions by Gelhaus
     indicate that 60 percent control  is Insufficient.   For a 300 MW plant,
     the EIS predictions are equal to  the maximum 24-hour SO2 standard while
     the Gelhaus predictions exceed both the maximum 3-hour and 24-hour SO2
     standards.  Using 60 percent control would meet the standards based on
     Gelhaus1 predictions.  Participate PSD Class I  standards are not exceeded
     by either prediction with 99 percent control (Table 5).
                                      Table 5

                PREDICTED MAXIMUM PARTICULATE CONCENTRATION AT THE
                       FORT  PECK  INDIAN  RESERVATION BOUNDARY
Time Period
24 Hour
Annual
PSD
Class I
Increment
10
5
Power Plant Si 2
30C
A
0.46
0.02
MW
B
0.4
0.04
60C
A
0.92
0.04
MW
B
0.8
0.08
e
1200MW
A
1.84
0.08
B
1.6
0.16
        Note:  All values are in ug/ms with 99 percent control.  Values
               under A are from Gelhaus, 1980.  Values under B are from
               EIS.
                                       337
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220) Continued

     Fumigation Estimates

          The Montana Air Quality Bureau also made calculations of S02 con-
     centrations during fumigation (Gelhaus, 1980).  Both Gelhaus and the
     EIS used Turner's equation (Turner, 1969) as shown below:
                           cf
                            I            VC.II UVJ x II*
where C  (x, 0, 0, H) = the ground-level, plume

                         centerline pollutant concentration,  ug/m3

     Q = the pollutant emission rate, ug/m

     U = the mean wind velocity, m /sec

   Of = the spread of the plume in the  "y"  direction

         during fumigation conditions, which is given  by

         oy (stable) + H/8 (where H is the total  plume rise),  >n

    ni = the inversion height, approximated  as H  +  2<
                                                              m
     As shov/n for January conditions 1n Table 6, the meteorological  conditions
     used in the two fumigation calculations were similar.   In addition,  the
     EIS included fumigation calculations under typical  meteorological  condi-
     tions for April, July, and October and more severe meteorological  condi-
     tions with light winds and a very strong surface inversion.

          A key parameter, plume rise, was not given in the Gelhaus  1980
     report.  Both investigations used Briggs equation to calculate  the
     plume rise (Briggs 1969, 1970, 1972).  The EPA used a  value  of  216 m
     for the typical January case.  A value of 200 m was apparently  used  in
     the Gelhaus report (Personal communication 1981).  Sensitivity  analyses
     were conducted to show the variation in results due to differences in
     plume rise.  The SOz concentration was computed for a  plume  rise 25  per-
     cent lower (150 meters) and 25 percent higher (250 meters).   Results  of
     these calculations (Table 7) indicate a higher percent change in concen-
     trations closer to the plant.  Varying the plume rise  between 150 and 250 m
     does not explain the difference between the EIS and Gelhaus  calculations.

          The SOz concentrations from both studies are shown in Table 8.  Direct
     comparisons are hindered since Gelhaus' calculations were made  for 6 km
     and EPA calculations were made for 10, 20,  30 and 40 km.  The input  data
                                     338
-------
                                    TABLE 6
                    CONDITIONS FOR FUMIGATION CALCULATIONS
Parameter
Wind speed (m/s)
Ambient temperature (°K)
Ambient lapse rate (°C/M)
Plume rise (m)
S0£ emission rate (g/sec)
EPA
"Typical" January
6.3
256
0.013
216
1352.2
Montana
January 1978
7
258
0.02
200*
1352.2
January 1979
8.2
260
0.009
200*
1352.2
Assumed in this memorandum
                                     339
-------
                                    TABLE 7

                       SENSITIVITY  OF PLUME  RISE  ESTIMATE
Distance Downwind
(km)
1
3
6
10
20
Computed S02 Concentration3 (ug/m3)
Plume Rise=150 m
8190 (+30)b
3446 (+24)
1778 (+26)
1086 (+23)
541 (+17)
Plume Rise=200m
5744
2620
1410
882
451
Plume Rise=250 m
4276 (-25)
2080 (-20)
1158 (-18)
738 (-16)
386 (-14)
'Values  are computed using Gel haus'  data  for January  1978.

Parentheses denote percent difference  of S0«  concentration at stated
 plume rise from SO^ concentration at plume rise equal  to 200 meters.
                                     340
-------
                                TABLE 8
                       COMPARISON OF CALCULATED S02
                    DUE TO FUMIGATION, FOR 600 MW PLANT
Month
"Typical" January
"Typical" January
January 1978
January 1979
"Typical" April
"Typical" April
April 1978
April 1979
•Typical" July
"Typical" July
July 1978
July 1979
"Typical" October
"Typical" October
October 1978
October 1979
Severe Meteorological Conditions
Downwi nd
Distance (KM)
10
20
6
6
10
20
6
6
10
20
6
6
10
20
6
6
10
20
S09 Concentration?
ug/m3
EPAD
912
484
—

863
457
—
—
822
484
—
—
568
301
—
2,016
1.301
Montana0
.....
	
7,580
5,918

	
7,424
No. calc.
	
	
5,882
6,060
	
	
5,962
4,860


dGround-level, plume centerline concentrations
bEPA=DEIS Table 5.1-5
^n tana-Gel ha us, 1980
                                341
-------
                                                             TABLE  9

                                          COMPUTED SO-  FUMIGATION CONCENTRATIONS  (ug/m3)
                                                         FOR  600 MW  PLANT
Downwind (km)
1
3
6
10
20
(1)
Typical Jan.
(EPA
Assumptions)
5,767
2,625
1,465 (0.5)
922
476
(2)
Jan. 1978
(Montana
Assumptions)
5,774
2,620
1,410 (0.5)
882
451
(3)
Jan. 1979
(Montana
Assumptions)
4,903
2,237
1.204
753
385
(4)
Typical Jan.
EPA
___
—
—
912
484
(5)
Severe Jan.
EPA
___
—
—
2,016
1.301
(6)
Jan. 1978
Montana
__ _
—
7,580 (2.84)
—
—
(7)
Jan. 1979
Montana
___
—
5,918 (2.22)
—
—
U)

IN)
        NOTE:  Columns  1,  2, and  3  are  recomputed  values.  Columns 4 and 5 are from the DEIS.  Columns 6 and 7
              are  from Gelhaus,  1980.   Values  in  parentheses  are in ppm.
-------
Fumigation Estimates (Continued)

for January from the two studies were used to verify the previous cal-
culations as shown in Table 9.   Several  conclusions can be drawn from
these comparisons:

     t    S02 concentrations computed 1n this memorandum using
          January meteorological conditions from the EPA and
          Gelhaus reports are of the same magnitude at a parti-
          cular distance downwind.   For  example, computed S02
          concentrations at 6 Ion downwind are from 1,204 to
          1,465 ug/m3.

     t    SCh concentrations computed In this memorandum at 10
          and 20 km downwind using  EPA's January assumptions are
          very close to values  from the  EIS (e.g.  912 vs. 922 ug/m3
          at 10 km).

     t    SO2 concentrations computed in this memorandum at 6 km
          downwind using Gelhaus1 assumptions (Table III, columns 2
          and 3) are a  factor of 5  lower than values presented in
          Gelhaus's report (Table III, columns 6 and 7).

To show the change in concentration with distance, the results in Table 9
are plotted 1n Figure 1.  The EPA severe meteorological conditions are
close to estimated values for January 1979 of Gelhaus.   The values at 10 km
are based on the percent change with distance.

     Most of the experimental tests have been made for exposures of
longer durations than one hour.  It 1s difficult to relate long and
short term exposure effects. In addition, fumigation occurs over a
small area at any one time and  the  frequency of multiple exposures at
the same site cannot be predicted.

     Gelhaus points out that 1f fumigation occurred for 15 minutes,
ambient standards can be violated for short time periods.  Using the
EPA fumigation estimates under  typical meteorological conditions and
estimated ambient concentrations at 6 km ambient standards are violated
for a 1200 MW plant but not for a 600 MW plant.  Using Gelhaus1 estimates
for fumigation and ambient concentrations, violations occur for a 600
and 1200 MW plant.  While this  Is true under certain conditions, the
area involved would be  small.  It is also not clear that short-term
fumigations events should be compared to ambient air quality standards.
                                 343
-------
     8000-1
                                                                        B (3.0 ppm)
     7000-
     6000-
     5000-
rr>
     4000 -
     3000-
                         D  calculated value
                  o

                  A
     2000-
D  calculated value
                                A - Lower threshold
                                limit—no Injury to
                                plants below line at
                                1 hr exposure
                                (EPA 1973)

                                B - Upper threshold
                                limit—damage likely
                                above line at 1  hr
                                exposure (EPA 1973)
                                D  EPA Severe Cond.
                                   Typical Jan.  EPA
                                O  Jan.  1978 \
                                A  Jan.  1978)
                                                                                 calculated
                                   Jan.
                                   Jan.
                           1978
                           1979
                                                                                 Gelhaus
                        O
                        -A-
                        •  calculated  value
                        •D	 A (0.5 ppm)
     1000-
                                                          £
                       T
                       5
10
i
15
20
                              Distance Downwind, km
                   Figure  1.  Comparison of Fumigation Estimates
                              for a 600 MW Plant along the Plume
                              Centerli ne
                                           344
-------
CJ
4*
cn
          t;
          IH
           -•I
      221)  '•*
           in
          HEARING OFFICER NcClAVE:  We have been going for an
hour and a half.   Why don't wo take about a ten-minute break.
          (A  recess was then taken.)
          Let's get star tec' agnin.  The next  speaker will be
Mr. bill Tande, Daniel* County Conmlssloner.
          MR.  TANDF.:  I am Bill Tande, Daniels  County
Cionisstoncr,  spokesmen for Commissioners of  Daniels County.
I would like  to first say th:.t T don't think  Lhc- Notice of
this hearing  was  advertised at all to the public.   There was
no notification in any paper or  anything by tho EPA.
           HEARING OFFICER McCLAVE:   It was published  In your
 local  newspaper.
           tm. TANDC:  Did you—did  the EPA publish this?
           HEARING OFFICER McCLAVE:   Yes,  sir, in your local
newspaper.   We had a—someone  go down and check it.
           MR. TANDE:  There was  an  article in our local news-
paper  but not put in by the EPA.
           HEARING OFFICER McCLAVE:   About a month ago there
was a  legal  notice put in your paper.
                              Response to Mr.  Tande
    221)     See response 135.  The hearing MBS  advertised 1n the local paper.
, «J
 I
 1
                                                                                                222)
                 n
                 in
                 M
                 W
                 n
                 14
                 IS
                 It
                 IT
                 W
                 It
                 Li)
deal with  eh*  sentence.   It snys, "Alternative  Clow apportion-
ments wore considered but the SO/SO division of flow between
Canada and the I).  S.  with the specifications above," this
paragraph, "la the beat  from a wntor quality viewpoint—water
quantity," excuse  me, "water quantity."  Can you  go a little
farther along?  I  an not sure If Z understand this  whole
statement  there made there.  That seen* to me that  it's an
assumption.  There Is no fact In this book I can  find to back
that up.
           MS.  SUMMERS:   There was a series of apportionments
which wore models.   Not  all the modeling results  are included
in this book.   The other types of apportlonac-nts--there was
one which  gave the U. S. only thirty percent of the  water and
Canada seventy.
           MR.  TANDEi   This is dealing strictly with  the 50/50
division of water  on the East Fork then.
           MS.  SUMMERS:   No.  It's the 50/50 division of tho
total flow of  the  Poplar River between Canada and the U.  S.,
and then it's  divided up according to a schedule  among the
different  forks, but we  also considered a 70/30 split between
Canada and the U.  S., which is clearly nut as good as the
50/50.
                                                                                                                       Response to Mr. Tande
                                                                                              222)      Hie SO/SO division mentioned here and described In detail In the
                                                                                                  MMMry ind Chapter 2 refers to the division of the total flow across
                                                                                                  Uie border of the Poplar River and tributaries.  This apportionment
                                                                                                  Is estimated to result In the least adverse Impacts throughout the
                                                                                                  basin based on the present and projected water uses and Impact analysis
                                                                                                  given In Chapter S.
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22J)
     III


     II


     12


     II


     14


     IS


     IK


     II

     It


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     21
                                                              51


          MR.  TAN Oh:   Is thai uhrro Lh(. 50/50 split will  bo

nude—at the  international border?


          MS.  SUMMEHS:   The split is debcrlberl on  Page  14.

          MR.  TANDF:   Yos, I ontli -.-stand that, but  1L  still

doesn't  really say whjt I want to know.


          MS.  SUMNtttS:   Yes, it  says the International  border

of  the  total  flow of--


          MR.  TANDE:   It soys in the book only thirty-two

percent of  total Poplar River Basin rlaea out of Canada.


Fifty percent  of thirty-two is only sixteen.

          MS.  SUMMERS:   No, fifty percent of the total  flow—

          MR.  TAHDE:   Right.

          MS.  SWWERS:   --not Just the thirty-two  percent.


          MR.  TANDE:   1 just wanted to clear that  up, and then

on  P.-igo 2,  beginning with Paragraph 5, It says,'"The  Impound-

ment of w/itcr In Cookson Reservoir has resulted In Improved

water quolily on the East Fork at the International border In

all seasons except spring."  Where Is the data to  back  that

up?


          MS.  SUWERS:   Host of  the dot*, the actual  modeling

results, are given in the Appendix, and there is discussion  of

water quality In Chapter  5.

          m.  TAHDl.:   Yes, but I don't have the Appendix,  but

that  Is quite a broad—that Is an assumption.  You haven't got

the dm.i for the years—you use  in here mostly one or two
                         Response to NT. Tande


223)      The statement is based on water quality daU for 1974-1977 and
    and Modeling results which are dtscusssed  in Chapter 3 and the Appendix.
                                                                                             16

                                                                                          •   10
                                                                                         224)
                                                                                             IB


                                                                                             19


                                                                                             JO


                                                                                             21
                                                                                             li


                                                                                             7


                                                                                             8


                                                                                             0


                                                                                             10


                                                                                             11
          At  the  lout  paragraph, the last line,  I read  In this

BIS I think about four or five times It says, "Thus, no Impacts

were predicted on any  rare and endangered species," and I ask

the question.  Arc there any In this area except maybe  the

farmer, but Is there any endangered species In this area?

          HEARING OFFICER McCLAVEi   Docs anybody know If

there are any endangered species In this area?

          MR. CRIEB:   There were no rare and endangered

species Identified In  tho state reports that were conducted  by

Montana Parks and Came Department--Fish and Game Department.

          MR. TANDE:   Just reading  this one sunmary here,  It's


                                                              53


In the book about three or four tines,  and I always wondered

if there la something  hera,  because It's referred back  to

about three or four tines in the book.

          HEARING OFFICER McCLAVE:   It says there were no

impacts predicted.

          MR. TANDE:   That's right.  How can there be any

Impacts If there  are none here?

          HEARING OFFICER McCLAVE:   Therefore, none were

predicted—because It's a requirement of the law.  Are  there

any impacts on the rare and endangered species?  That's why

the thing was written.   _                    _
                                                                                                                Response to Nr. Tandy
                                                                                       224)     Rare and endangered species which could Inhabit or pass through the
                                                                                           area are listed In Appendix A-6.
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t*>
      225)
12
M
II
16
Ifi
17
I*
IV
          MR. TANDE:  To return  to  the one we  first  started
here, we talked about management of irrigation.  This  valley
Is a natural polluted valley, because this whole river
system—you show me a number of  trees, and I got aa  many
fingers on my hand as the number of trees growing along this
rivc-r basin, and to Irrigate in  this valley and most of our
Innd we have to have a  flushing  effect.  You have fco have a
                                                      . i
flushing effect in the  East Poplar  to wash away the  TDS,  total
dissolved solids, the boron.  Otherwise  it becomes saturated,
so when the HtlNO
                        •Dl 0 «lf •••• MUVft IM
                                                                               I
                              Response to Mr. Tsnde
     225)     The reaovtl of channel sedtMnts by high flows and the reanval of
          MlU,  sodlusi, and boron by leaching are discussed In the EIS.
                                                                                  226)10
                                                                                      11
                                                                                      It
                                                                                      It
                                                                                      14
                                                                                      It
                                                                                      16
                                                                                    y
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                                                                                      11
                                                                                      if
                                                                                      to
                                                                                      ti
                                                                                      SI
                                                                                      S3
                                                                                      M
                                                                                      IS
where a layman can understand this,  this book, and 1 think the
book la put vary poorly across.   I think everything In her*
la—it seems to ae somebody Bade all the tables up and then
somebody elaa wrote  the summary, but the summary doesn't  even
really go with all the  tables.  I will get back to the tables
in juat a minute and I  would like to point out just a few
mistakes that I have found or other people have found and
brought to my attention.
          First of all,  in hare  it says there are only two
schools, elementary  and high achoola, in this county.  There
are three.  Peerless, Montana, has an elementary school and
high school, so that makes three.
     **
          HEARING OFFICER McCLAVEr  Where}
          MR. TANDE:  Peerless,  yet, and that in here you  have
got—your land acres are completely wrong aa far as the data
I could find.  You have got the  total acres in Daniels County
la about two thousand acres off, and I would think that a
simple thing like that  could be  done right, and the irrigated
acres in this county are off.
          HEARING OFFICER McCLAVE:  How far—what direction
are they off?  This  is  the Draft.  We are trying to correct
It.  You say it's two thousand acre* off?
          MX. TANDE:  It's about two thousand acres off.
          HEARING OFFICER KcCLAVE:  I mean is It too large or-
          MR. TANDEt  Total acres In this county are 910.080
                                                                                                                     Response to Hr. Tanda
                                                                                             226)     Appendix p. 130 changed to Include schools In Peerless. Montana.
-------
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227)
      i


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           21
                                                                   ib


acres.   I believe the  book said waa it  nine hundred eleven

thousand some acres, and on Table 4.3-3,  Page  34,  you have got

the  total Irrigated acres in  Daniels County in 1975 as

twenty-five  hundred acres.  It  says all hay.   The IJC had

3912.5 acres, and if we go Into our county assessor's office

there Is over ten thousand acres.


           You refer here—in  this Irrigated acres  you go  back

to wild hay,  producing wild and alfalfa hay.   I  think the main

mistake was  made here—the wild hay classification of land.

There are three different classifications of irrigated hay

land In the  State of Montana.   Daniels  County  has  three of

them, which  they classified as  irrigated, wild hay and C2B

type land.   The wild hay land Is—number of acres  Is 9,476

acres.  This Is irrigated land, but it  has not—it's been

Irrigated, changed the species  of the grass, it's  produced

more tonnage and It has not been converted to  alfalfa, seeded

back to alfalfa, but  It still Is irrigated land, and the  C2B

land there  Is 33,760 acres, which is sub-irrigated,  and It's

flood irrigated by natural flow, and this is not even con-

sidered in here.


           As I stated  before, the IJC said there was 3912.5

ncres, mid  1 pointed out to them that this Is  wrong, so this

makes nil—all your economic  impact tables in  this EIS are in

error.  They don't mean a thing, because  you use twenty-five

hundred acres where you aren't  even close, so  I not  only  say


                       •OUCH •HONfHAHO KirOHONO
                                                                                                                              Responses to Mr.  Tande
227)      OiU on  irrigated acres fn Daniels County vary by source  selected.
     The Census of Agriculture reports 2,016 acres Irrigated In 1974.  The
     Montana State Department of Revenue  reports Irrigated acreage  as 610
     acres In 1974 and 2.029 acres In 1978.  The Montana Department of Agri-
     culture reports Irrigated acreage as 2,500 acres In 197S, 2,900 acres
     In 1976 and 1.700 acres In 1977.

         Apparently there Is a conflict  In the definition of what  consti-
     tutes Irrigated land.  Wild hay lands are not reported as Irrigated
     1n other sources.

         Grazing  land Is classified according to its carrying capacity.
     G2B is slightly better thin average  grazing land In Daniels County.
     Land Is classified as 628 based on a combination of soil and other
     factors.  It  Is generally not a cropland and My or nay not be affected
     by flow* In the Poplar River.  So there Is a possibility that  the
     animal units  supported by G2B lands  could be reduced by the apportion-
     ment.

         It Is not possible to estimate  accurately Impacts on grazing lands
     without a detailed study of soils and sources of aoisture.  However,
     we can indicate the limits of the problem.  If G2B lands amount to
     33,760 acres, they constitute approximately 10 percent of the 325,000
     acres of pasture and range lands in  Daniels County.  G3 lands require
     28 to 37 acres per animal unit and 626 lands require 22 to 27 acres
     per aniMl unit.  The 33,760 acres of G2B lands will carry approximately
     1400 animal units.  If all are affected by the apportionment and reduced
     to G3. they could carry approximately 1050 animal units, a reduction  of
     360 animal units.

         Using 63 lands as the average for grazing lands,  the total animal
     unit capacity in Daniels County is approximately 10,000 animal units.
     Therefore, the maximum impact on carrying capacity Is approximately 31.


228)      Paragraph Inserted in Economic  Impact Section to discuss possible
     yield losses on naturally irrigated  lands.


229)      The economic Impacts of decreased irrigation witer are based on
     existing and  projected Irrigated acres which use Poplar River water.
     Other land irrigated with other sources 1s not Included.  The tables
     In Uie DEIS are correct.
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230)
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16


16


17


18


19


20


21


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24
                                                             57


we will .in no way support this  Draft for final apportionment


of water, because it doesn't tall  the truth.  It isn't right.


          HEARING OFFICER McCLAVE:   Can I ask you where you


got these figures, sir?

          MR. TANDE:  The local—

          HEARING OFFICER McCLAVE:   The tax assessor?


          MR. TANDE:  Yes.

          MR. DEAN:  What year  does  that deal with?  With the

 •-                                    '"
current?

          HEARING OFFICER McCLAVE:   Last year probably?

          MR. TANDE:  1973.  Also  in this book there is no


impacts.  We are talking about  quite a few acres of irrigated
   ,.  ~    v   .....

lands, but there is no impact on loss of tax base.  I would

like to know why that isn-'t here,  because being a county


commissioner the people have got to  make up the taxes and if


there is a' loss of tax base somebody else has got to pay for

it, and it's going to be the people  in this county, and that's

a very important impact, and it's  been completely left out of


here.

          About all I can say again  is we cannot support this

Draft in any way until the changes are made which will make

it—with the tax base put in here, the loss of tax base and

the right irrigated acres in this  county, which would in turn


make the economic impact tables different, and it will show

a greater loss.
                        Response to Mr. Tande
230)      Impacts on tax base and effect on county budget have been added
     to Section 5.5 of final EIS.
                                349
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  231)
       •j




      iw




      11




      12




      13




      H




      13




      1C
      S3
Apportionment on  the  Poplar River Basin," I found a number of i



deeply disturbing features,  statements and predictions.   Soxe ;



of these disturbing aspects of the Draft EIS are outlined



below:



          The Draft EIS  contains considerable irrelevant



material which  should be removed.  For example,  on Pa^s 2 and



again on Page 4 EPA points  out $269,000 expenditures in the



U. i. by Canadian workers plus some secondary benefits and yet



fails to mention  the  U.  S.  share of approximately $750,000



spent by taxpayers to finance the "International Poplar River



Water Quality Study"  conducted by the IJC and fails to mention



the taxpayer expense  for this EIS which is estimated to be



$175,000 all of which results in a net loss to the U.  S.



taxpayers of a  few hundred  thousand dollars.  This is



irrelevant to the main issues of the Impact—Environmental



Impact Statement  and  this should be removed from this



Statement.



          HEARING OFFICER MeCLAVE:   We are required, sir,  to



see •what the socio-economic inpacts are.   In othar words,  if



we spend money  we are required by law to put it  in.



          DR. SIMS:   Okay.   If it's required by  law to puc ic



in all the numbers should be put in.



          HEARING OFFICER McCLAVE:   If you would like  us to



calculate the cost of the $170,000  apportioned to the  tax-



pay ers--
                             Response to Or. Sli
231)      This Mtertal  is retained as required by law.  See response 196.
                                   350
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 232)
233)
234)
 is


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 14


 is


 16


 17


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 20
      SJ


      24



      »


      1


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      3


      4


      5


      6
           The statement on Page 2 that  the iapoundcent of

water  In Cookson Reservoir has resulted in la-proved Meter


quality  on the East Fork at the international border in all

seasons  except spring is not a statement of fact but rather  is

an assumption.  It is an assumption based on another assump-

tion that one year's data, 1975, represents the long-term


average.

           An equally valid assumption is that the present

water  quality of the East Fork at the international border


reflects  the true average water quality of the East Fork for

the period of iapoundnont, 1975 lo 1980,  and that these TDS

and boron levels would be a core valid  base from which to


judge  future degradation than is the 1975 data.

           The actual operation of the three hundred megawatt


unit will lower the quality of the water in the East Fork.


This is  consistent with EPA's statcnent on Page 126 that the

outflow  quality fro* the reservoir is determined by complete


mixing of the reservoir and mass balance of all reservoir

inflows  and outflows.

           Also on Page 126 EPA states that the quality of


surface  irrigation return flow was calculated at ten percent

higher than the quality of the diverted water.  The quality  of

the return flow will be touch lower than that of the diverted


irrigation water.  Grossly invalid statements such as the one

by EPA above cast doubt on the validity of the report.


           If there is any validity to any of the predictions

in this  report, the predicted yield reductions on Pages 132,

140 and  141, which are substantial, would be very significant


and is in serious conflict with EPA's statement on Page 2


which  says that operation of a single megawatt unit will not

lead to  significant degradation of water quality for irriga-

tion and other purposes.	

               Responses to  Dr. Sims
232)      Die 197S 'baseline year' MS chosen as * reference point, primarily
    for a description of pre-resenrolr conditions and development.  The 197S
    year was not modeled and thus Is not the comparison point for the pro-
    jected Impacts • after Impoundment and historical conditions are the
        arlson points.
  s



 ID


 1)


 IS



 13



 14






 IS


 IT
233)
    Substitute •concentration*  for •quality*.
234)      This statement referred to the difference between the concentrations
    of parameters for the Impoundment only and one power plant case.  The
    crop yields were compared to yields with estimated soil solution concen-
    trations.
                                351
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Z35)  >'

     I.'.


     if.

     17


     IS
               HEARING  OFril-.Ett McCLAVK:   Milt Gunderson.

               HR. CUNOERSON:  I urn Milton Gunderson.   I  live on a

     small family  farm  about twenty-three miles downwind  from where

     thn plant Is, and  1 work here  In Scobcy at the  newspaper.

               A portion of this Draft that was devoted to air

     pollution Impacts  on crops and  land indicated  little or no

     v/c0jiit!on soil  damage from two  three hundred megawatt plants.

     1)>. re In conflicting evidence  on this.  I refer you  to a paper

   i; ruMUrted in  March, 1979, by the Air Quality Bureau
   i
111  \\ Environmental Science Division of the Montana Deportment of

''   ! H._  :lili .it'tor  a  study of the Scientific and Engineering

''-'  ,j Ad\ isory Panel  on  the Poplar River air quality.  I believe you

     reLerred to it  in  some places  in your Draft.

               This  report states that there would  be a one to two

     percent crop  loss, both grasses and grains,  In-a forty-

     kiloncter radius around the plant.

               Now,  perhaps Tetra Tech feels two  percent is too

     small to consider, but to an area that is completely dependent

     on agriculture  this is very  important.

               Using present production records and  prices, a one

     and  n K-ilf percent loss in  just the part of  this Forly-

     kllurGtcr radius circle which  lies in Daniels  County would

     Amount  to over  $400,000 a ycur.  Tliis lost* to  farmers would
             |M  'I

                I

                  MIII-J llvui offset the economic  gnl.n predicted  In  Lhc Draft for

                  area business  places,  tarmors would have $400,000 less to
                                                                                                                         Response to Mr. Cunderson
                                                                                                235)     The statement that the deposition of sulfur pollutants would result
                                                                                                     In • 1 to 2 percent crop yield  loss MIS «de In t report by the Air
                                                                                                     Quality Bureau Environmental Science Division of the Montana Department
                                                                                                     of Health (Gelhaus and Roach. 1979).  The effects of SO, deposition on
                                                                                                     vegetation are site-specific and Mist be evaluated on a case-by-case
                                                                                                     basis.  Our analysis which considered acute, chronic, and long-term
                                                                                                     exposures to projected ambient  concentrations of SO, as well as the
                                                                                                     potential effects of sulfur accumulation In the soils, does not support
                                                                                                     the conclusion reached by the Air Quality Bureau.  The assessment of
                                                                                                     the Impacts of gaseous emissions on vegetation Is presented In Section
                                                                                                     5.6.1.1.  of the E1S.
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Ul
       236)  *

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-.11
       237)
            .•'i
spend, and  this is not nearly all the projected loss.   It most


probably would be wall over double that figure.

           Quoting from Page 22 of the Department of Health

paper, "It  does not Include the  effect of pollutants other

than sulfur dioxide and its derivatives."  Another quote,

"This estimate doesn't consider  decreases in crop productivity

and fertility loss of  the soil caused by radical application
                                                       * V.

of  sulfur pollution."   This, I believe, could be drastic  as

the years progress.  I would hope that some  considerable  part

of  the Final Impact Statement would be directed to the  long-

range effects of the land.

           The study mentioned about only for one year.  There

Is  strong evidence that the problem would multiply as the

years go by, and how many years  after they estimate the thirty


fivt years  life of the plant will production from the surround

ing land be towered?

           During 1977,  and this  report has been mentioned

before, researchers from the Terrestrial Division of the  EPA

CorvnHis Environmental Research Laboratory  studied potential

effects of  sulfur dioxide on crops and native grasses grown in

our area.   I quote one of the conclusions.   "Prolonged  low-


love 1 sulfur dioxide exposure appeared to be more of a  throat

to  crop yield* than short episodes of high exposure."   Yet in


this Draft  the only dumngc even  hinted «t was fumigation  under


very stable  conditions  for short perlods--noclilng adverse
                                        MUCH iHOITtMANO Ot»OBTIN»

                                           •••••II ••••»1bt««M

                                           KK>M«n «OkMft«»MI
                                                                                                                             Responses to Sanderson
236)     The long-term effects of elevated SO, concentrations Including
     the buildup of sulfur In soils and soil acidification have been addres-
     sed In the E1S (Section 5.6.1.1).


237)     The statement—prolonged low-level sulfur dioxide exposure appeared
     to be more of a threat to crop yields than short episodes of high ex-
     posure—was not presented as a conclusion 1n the report published by
     the Terrestrial Division of the EPA Corvallls Environmental Research
     Laboratory (Response of selected smell grains, native range grasses
     and alfalfa to sulfur dioxide. Hllhour at al. 1979).  Rather, this
     statement represents the Scientific andTngTneerlng Advisory Panel's
     (Air Quality Bureau Environmental Science Division of the Montana
     Department of Health) interpretation of the remits of the afore-
     mentioned study.  The study conducted by the Corvallls Environmental
     Research Laboratory (CERL) did indicate that yields of Duram wheat
     and barley decreased when treated weekly for 12 weeks with 72-hour ex-
     posures to SO, concentrations as low as .10-.IS ppm (270-400 pg/m').
     However, predicted maximum SO, concentrations during any 72-hour
     period In the Poplar River Basin are substantially below 0.10 ppm
     (270 ug/n').

         One of the authors of the CERL report (Mllhour et al* 1979). 6. E.
     Heely, was contacted concerning this statement of prolonged low-level
     sulfur dioxide exposure.  He Indicated that If one considered weekly
     exposure to SOs treatments of 0.10 and 0.15 ppm for 72 continuous
     hours as prolonged lew-level sulfur dioxide exposure, then the state-
     ment In question has some merit since the CERL study also showed that
     exposure to 1.2 ppm or 3240 tig/m1 (short episode of a relatively high
     exposure) had no effect on yields of the small  grains and alfalfa.
     However, It must be emphasiied that the exposure durations and concen-
     trations, which resulted In loss In plant yield in the CERL studies.
     are substantially greater than predicted SOi levels associated with
     the operation of two 300 MM power plants by Saskatchewan Power Corpora-
     tion.  Moreover, the results of the CERL studies cannot be used to
     predict the effects of long-term exposure of crops to the predicted
     Increases In ambient S0» concentrations.
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238)  ,
239)
    I •

    II
           In (.ontltiftlun, 1  found the  rfpot t very  technical and


th'/:<»u,;|i to th« point white  it  !• hard  to understand.   It was


diftlt'ili t.> 'io'(  down one  subject. becau«« the material was


!•» ator'il i hrou^hmit the report.  On*  172-word paragraph was


priritnl twlcu  In  the soiae ••ctlon on  two different  pages--


l'i, c  ?0), thi  last p«rnj,rnph,  and Pnge  204, the third para-


v,ri"  report etatee  on Page 125 that I ho  winter flow


uf  the  neper Middle Pork !•  absolutely  zero fifty percent of


ill*  time.  I find UiJa statement untruo.  I hnve  been tip and

10,11  ihli river  In I ho dead  of winter many time*  In th* last


l..in>/  yir.ii nnJ  1 have yet  to flnil a time when we  didn't have

i<>,i>-  gtteam  Clou.  1 have nlio talked with many of  tliu oldor


-incl.L"-! •.,!i') |),iv« vlnti-rtd  tattle and ihocp on thn  Mldille Fork


lit  yi/n» ujlng imly untur  from l.hn rlvr-r for their stock.  1C


it  W
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       -  I
       .  I
  241)
 242)
                                                                81


  have  in  this  report.   I would recommend,  gentleaen, that

  before you sake a final decision on stream flow apportionment

  and Mater  quality standards that you take a closer look ac the

  real  problems.

             Thank you.   Would you like a copy of that?

             HEARING OFFICER McCLAVC:  Lee Humbert.

             MR. HUMBERT:  My name is Lee Humbert.   I live north-

  vest  of  Scobey  near the eiddle fork of the Poplar River.  I

  would like to begin by making some general comments about the

  Statement  followed by some comments about ground water, which

  is an area of specific concern to myself  and others living

  near  the international boundary.    ,'

             The Statement which is purported to  address several

  flow  apportionment alternatives on the Poplar  fails to mention

  Boundary Waters Treaty of 1909, specifically the articles

  pertinent  to downstream users.  This treaty should be central

  to any discussion of  apportionment or use.

             The language of the Statenent is  very technical and

  difficult  for the layman to understand.   This  is contrary to

  the EPA regulations for compiling such a  document.  An example

  of this are the wind-rose charts on Pages  148  to  151 of the

  Appendix.  These apparently simple graphs can  be  a nightmare

  for a layman to decipher.   There is no keys for  the explanatio:

  of their proper interpretations.

             There are a number of obvious inaccuracies in the
                        Responses to Hr. Humbert
241)
See response 240.
242)      The detailed air and water quality Modeling and analyses of impacts
    are complex technical subjects and need to be treated thoroughly. Changes
    have been cade to mimt the EIS man understandable.  These Include adding
    an expanded sumury in non-technical language, and a description of the
    scenarios in the sumary; saving the map of river stations to the summry;
    and adding sore detailed keys or footnotes to tables and figures
                                 355
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243)  I

     i

     •I


244)  4
245)
    I'J

    II

    II

    m

    III

    n

    IX
246) _t  Iniludlui; tlrst  the m.ip on Pugo  11  of the Appendix


\,hli'n h.is  countlud misnamed and geography  misrepresented;


•uHorul,  thr itnumrnt  on Pago 130 of the Appendix which  reads,


"Ilie only  sch'jols In U.inli'ls (.uuuty nro  locnlud	


ScoU-y."  rin.- people in Puerlcss would lake exception to this


ul..it • [iirnt.  Iliird, the atalimrnc on Page 125 of tho Iinp.ict


Si itiMM'iu  ill.i ling with the wlntei flows  which states, "The


winter  conditions on the upper Middle lurk, Station 4, are

slmll.u- with .'do flows fifty percent of the time."  I have


livid .n the upper Mld'le  Fork nearly all  my life and I  have


ytt i.n  sea the river with  icro flow fifty  percent of the time


in  the  winter.  My father, who has lived there for nearly


si:, ty- live ycavs--hu also  states this statement le obviously


false.


           My point In  taking those obvious Inaccuracies  Is  If


they  ate so apparent to •  layman how many Inaccuracies In the


tcclniii.il  uvuerlola gathering and Interpretation would also be

obvious to nn expert?

           1 take  exception to Sections  5.3.5.1. and S.3.S.2.  01


Pa^os 14) and 149 of  the main report.  These sect lone state


potuiLliil Impacts ani  attempt to give  forming Ictsons to the


rovli-vior.   They do not state who will pay the cost of imple-

menting llu-se pnicil-.os, however.


           Mine do. itorinr, nnd the effective lowering of  tho


\Titer t.-itlo hus bit-n predicted by the Ground Water Committee

                      MAUCM tMOKIM4NO 1IPOMIINO
                          •O. * «'* •'••* -•- «i !»•
                              «<• 111 IM«
                                                                                                                  Retponsei  to Mr.  Humbert


                                                                                         243)      The swp nasws hsve been corrected.


                                                                                         244)      Sentence his been changed adding the schools  In Peerless.


                                                                                         245)      The zero flows ire sodel results and mein less thin 0.004 cubic
                                                                                             hectometers per eonth (3.2 ic-ft).  See  response 240.


                                                                                         246)      NEPA regulations require that mitigating Measures for Impacts be
                                                                                             discussed In the EIS.  A discussion on costs has been added to Section
                                                                                             5.5.4.
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           i'l
 of the IJC.  They  any It will lower tho wnter table at  the
 Inienmtioail boundary 2.3 fuet  in  thirty-five years.   I think
 tho jo flgurus con  be ilinputed.   A prediction of even a
 greater lowering of thu wnter hna been anticipated.  This is
 not,  however, even discussed in  the Impact Statement.   This
 lax.irln^ of tho water table would have an obvious impact on
 tho farmers and ranch* ra near the boundary who depend on
 springs und sub-irrigated pastures  for livestock production.
           There has been an increase of saline seep from rais-
 ing of the water table below tho reservoir.  This Impact has
 n»t been discussed In tho Statement.  I would like to know If
 mining water and surface water quality has been addressed.
 Thu underground water contain* a much higher volume of  IDS
 Including mercury  as wall as other  constituents thnn the
 surface water it pumps into.  It may also contain hydrocarbons
 which are dangerous to health from  its rapid depletion  from
 •.ho coal-bearing aquifer.  Another  question is will the
 •url.-itc water bo centum! iwteO in Lhe recharged ground-water
aquifer .\nd be polluted by precipitation run-off, tho mine
«|Kille  and open profiles?
           In closing,  1 think thiu  Statement should be
ru-tvalimtod to lotemlnn the extent of the Inaccuracies  it
contains u.ttl then be  rovlsod before  any final approval.   Tliore
II.IN 1'ccn a groat volume of 
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   'I
         • turiiob  .ire  gutieratud and completed  in the loc il area  rathor

         I'un  in  in nvur or Oillfurnla It would  Improve the credibility

         of the  r> ports.

                    Thank you.

                    IlLAKKiG OFFICER HtCLAVE:   Eddie Lund, Scobey.

                    MR. LUND:  Plrtt of oil, my  nnmo 1* Eddie  Lund,  and

          I  live  on 4i .ranch ncnr  Scobey, end I am here to addre*s  the
       |l
249)  ' ,| mercury contamination  issue.   The Draft EIS has done  every-

          tiiinf Lut overlook  It.

                    Page 46  In the EIS points  out that mercury level* in

          w.illcy.  i.il;en from  the  CooLjon Reservoir exceeds the Canadian

          .in.)  U.  s. standards.  The report noted level* of up  to l.S

          pu.-ts per million.  However, the Saskatchewan Power  Corporatloij

          rtf/ort  on mercury contamination showed a maximum of  1.7l--over

          three Limes the Canadian standard and  well over .the  U. S.

          •tjndard of one part per million.

                    The CIS goes  on to aay that  mercuric acetone le

          widely used as a  fungicide for treatment of wheat seed

          thrut>;iiaiit the basin.   EPA, of all |»oplu, should know that

          Mercury sued treatment  ha; been banned in the U. S.  end

          CIIUK'J since the  early  Seventies.  The seed treatment  theory

          \MS  firal proposed  1>y  the SPC, and  It's disappointing  that Che

          Lraft bis 1*3 echoed  thts lane encuse.

                    On the  following page of the EIS, It it noted  that

          mcrruiy levels In oil  but the main stem have exceeded  the

                               "AUC'I •MOMT.KMO KCPOKTlMa
II


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                                                                                                              Response toNr. t.  lund
                                                                                     249)      Mith regard to Mercury problems, the EPA and USGS are pursuing
                                                                                         thts problesi.   The text of the DEIS ha* been changed adding other
                                                                                         possible sources.  Hercurlc acetone Is still being used—see response
                                                                                         102.  A detailed field Investigation would be required to determine
                                                                                         the sources of e*rcury. Such a study Is outside the scope of this
                                                                                         project but Is strongly recamended.  In addition, a long-tern *K>n1tor>
                                                                                         Ing prograo Is recoMiendad which would determine Mater quality and
                                                                                         concentrations of selected toxics In fish tissue.  These recmunda-
                                                                                         tlons have been added to the EIS Sujsury.
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250)
    31


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252)
dun ulr for naxinua productivity.  Air quality lam, both

federal and state,  ara written to protect liumm haalth, not

agriculture.  The long-tern effect of low levels of air

pollution on agricultural crop lovols tliat mc-ot the law ar&

not ouay to document.  It Is  known, though,  that the affects

can ciuse yield reductions.

           Ona study,  Cor example,  snowed reduction in wheat

ylolds of tip  to fifteen  percent from sulfur dioxidaVlevals

about half  the present federal standard.   The EIS, however,

cortulns only simplistic and unsupported statements on this


question.

           On  Paje 10  the EIS says,  "The predict ad Maxima


concentrations and duration of exposures ara also below

acute and chronic threshold limits  Cor the most sensitive

plant species."  The  EIS fails to say  what those threshold*

are and what  plant species.   The fact  is that there am no

known thresholds for  damage from long-ten low-level pollution

           The EIS say* there will be finlgatlon near the

ucuto threshold* without saying how close the fumigations


will  be or how they will  affect the agriculture.

           There Is nothing  in the BIS about the affects  or


possible effects  of acid  rain on crops  or  on water quality.

Sulfur dioxide Mission can cause acid  rain hundreds of miles

from  the source.   It  is conceivable that acid precipitation


cflunod by the  Poplar River Power Plant  could affect farming

operations even farther from  th* plant  than our farm noar

Circle.  No ono can be aure  thnt It will but neither can any-


nnr assure ova  that  It won't.   The EIS simply does not  address


th.it  question .ind the risk Is ours.
                         Responses to Mrs.  Mailer


250)     Acute threshold exposure Halts (concentrations and short-tern
     exposures below which no visible Injury is observed) wire presented
     In the EIS for three categories of SOi sensitivity In plant species
     (Figure 6.6-1).  Reported acute and chronic threshold Units to gas-
     eous exposures of Important  native plant and cultivated species In
     the Impact area ware also presented (Table 5.6-1).

         It Is correct that there are no known thresholds for daaage
     fraa long-ten low-level exposures to gaseous emissions.  For this
     reason, the analysis of long-tare) effects of SO* Missions presented
     In the EIS concentrated on the secondary effects of elevated eablent
     SOt concentrations such as toll acidification.


261)     Fumigation concentrations are presented In Section 5.1.5.4 and
     tapacts on crops are discussed In Section 5.6.


252)     The tepact of primary concern associated with the acid rain Is
     not daaage to aerial  portions of plants,  but the acidification of
     soils and the subsequent deterioration In the soil  quality.  Soil
     acidification, as was pointed out in the  EIS, can occur through both
     dry and wet (acid rain) deposition of sulfur.  However, based on the
     calculated buffering  capacity of soils in the input area. It MS
     concluded that no significant change In soil pH would occur.  The
     potential for deterioration In water quality resulting from atmospheric
     emissions was addressed In Section 5.6.2  of the EIS.  Based on the
     alkaline nature of soils and surface waters, it was concluded that
     thare Is an extremely IOM potential  for surface water acidification
     In tht inpact area.
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yields  of up to fifteen percent from sulfur dioxide  levels

about half the present federal standard.  The EIS, however,

contains only simplistic and unsupported statements  on this

question.

           On Page  10 the EIS says,  "The predicted maximum

concentrations and duration of exposures are also below

acute and chronic  threshold limits  for the most  sensitive

plant species."  The EIS fails to say what those thresholds

are and what plant species.  The  fact is that there  are no

known thresholds  for damage from  long-tern low-level pollution

           The  EIS  says there will be fumigation  near the

acute thresholds without saying how closa the  fumigations

will be or  how they will affect  the agriculture.

           There is nothing in  the EIS about  the  effects or

possible  effects of acid rain  on crops  or on water quality.

 Sulfur  dioxide emission can cause acid  rain  hundreds of miles

 from the source.   It  is conceivable  that acid precipitation

 caused by the Poplar  River Power Plant  could affect farming

 operations  even farther  from the plant  than  our farm near

 Circle.   No one can be sure that it  will but neither can any-

 one assure  me that  it won't.   The EIS  simply does not address

 that question and the risk is ours.

            Similarly,  the EIS neglects  the  potential problem of

 radioactivity.  Studies  of power plants burning lignite  in

 Texas  show they emit  the same level of radioactivity as  a

                                  MD MFO"I>NO
                                                                                                                         Responses to Mrs. Mailer


                                                                                                253)     The DEIS presented • detailed discussion of SO, effects on
                                                                                                     p. 171-175 Including • summary of experimental data on threshold
                                                                                                     levels In Table 5.6-1 plant species.


                                                                                                254)     Estimated S0> concentrations during fumigation at between 10
                                                                                                     and 40 tat from the plant are shown In Tables 5.1-4 through 5.1-7.
                                                                                                     The maxlmi* concentration using very conservative assumptions Is
                                                                                                     estimated as between 1.0 and 1.5 ppm as discussed on p. 174 of the
                                                                                                     DEIS.  This level could cause some foliar damage to very sensitive
                                                                                                     species 1f exposed for more than 1 hour.  Fumigations are of short
                                                                                                     duration (Portelll. 1975) and thus are not expected to cause damage
                                                                                                     to crops. Prediction of when and how often fumigation will occur
                                                                                                     at the same location Is subject to changes in nieteorlogical condi-
                                                                                                     tions.  In addition estimates of funigatlon concentrations depend
                                                                                                     on meterological conditions and thus change with time and location.
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            Similarly, the EIS neglects the potential problem of


 radioactivity.   Studies of power plants burning lignite  in


 Texas show they emit the sane  level  of radioactivity as  a


 normally-operating nuclear plant of  the  tamo megawatt capacity


 The  «ura<» study says  the problem would be worse with North


 Dakota  lignite, because it contains more radioactive material.


 The  lignite in Saskatchewan at Coronach is even higher in


 radioactivity than North Dakota lignite.


            Again, I can only wake a guess at the magnitude of


 this problem, because the  EIS  does not address that concern


 elthef.


            It Is also silent on the effects of the existing


 reservoir and strip mine on ground water and saline seep.


            Although the EIS  is  difficult to digest, one con-


 clusion  seems safe to me.  The proposed apportionment will


 seriously damage downstream water users.


            The EIS makes no mention of the Boundary waters


 Trenty which prohibits the degradation of trans-boundary


 waters to  the detriment of users  across  the border.   Canada


 violated  that treaty by constructing Morrison Dam and Cookson


 Reservoir  in  the  first place.


           Now,  the State Department  seems to  be  trying to


 ratify the violation of  that treaty.  This  EIS merely glosses


 over  the impact of the Poplar  River  Power Project  on agricul-


 ture  in  WonUinu in order  to excuse violation  of  that treaty.


 If the EPA and the State Department will not protect


Northeastern Montana  interests  through the Boundary  Haters


Treaty then who will?


                      MUCH »MOHf«A«O NIPOMTIHa
                         •a> ••«>• ••«• Mvll •>"
                         •K*, W.f KOMI**' MJtt
                                                                                                                 Responses to Mrs. Miller
                                                                                            * .-.  Bflssjons of radioactivity from nuclear power plants wist sect
                                                                                             federal and state standards.  The Missions froithis power plant
                                                                                             are not expected to exceed these standards.
                                                                                         256) .K  J*t EIS,"" *1r«M»P«*««eilly «° 1lBiet» 1" "e U-S. Part of
                                                                                             the basin only, of f>°" apportlonaent and power plant operation not
                                                                                             ~"~	5*S£t1on, Tdliowl., oo 5ro^dP«t«. ind saline
reservoir
                                                                                             Ms been
                                                                                                          to Chapter S for the U.S.  part of the basin.
                                                                                           } « A .T£J°2?-"Py ?•*•!! l!^ 1s dlscu"«' <» the revised Chapter 2.
                                                                                             Si^fS11^ d'scussl0" •* *"•*««» on agriculture Is given In Chapter 5.
                                                                                             Whether the treaty has been violated Is a decision of the courts not
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       24
                                                               91


           Thank you.

           HEARING OFFICER McCLAVE:  Thank you.

           Gerry Farver.

           MR. FARVER:  My name is Gerry  Farver.   I live six

 miles below the confluence of che east fork and  middle fork of

 Che Poplar River  in Che  Poplar River Basin.   I represent Che

 irrigators along  the Poplar River above  the Fore Peck Indian

 Reservation.

           My comments  are going to be directed towards the

 water quality as  it affects the irrigators  in Daniels County.

 On Page 139 of the Environmental Impact  Statement Draft the

 maximum yield reduction  for Scenarios 4A and 8A  for present

 yield for alfalfa  is forty-eight percent,  wheat  thirty-five

 percent,  barley fifty-one percent and oats  eighty-seven percent

 The Draft does not make  it clear if this  yield reduction is foi

 one year or five years or is,  in fact, a  geometric progression.

 Regardless,  the loss in  income is more than  enough to put most

 farmers or ranchers out  of business.

           In the summary on Page 2 of the Draft  it states that

 the operation of a  single three hundred megawatt  unit will not

 lead to significant degradation of water quality  for irriga-

 tion and  other purposes.   Is a forty-eight percent reduction

in  alfalfa yield and a thirty-five percent reduction in wheat

yield not significant?

           I  refer to Article IV of the 1909 Boundary I.'aters
                         Response to Mr. Farver
258}      Crop yields  given are for one year only.  However, scenarios 4A
    and 8A Included the ash lagoon decant and thus are severe.  SPC has
    stated that the decant will be reclrculated.  Clay linings of several
    ash lagoons are already In place.  Thus, these severe conditions will
    not occur.  The statement 1n the summary referred to the difference
    1n water quality  for one 300 MM unit with decant reclrculatlon and
    post Impoundment  conditions (scenarios 28 and 3, respectively).
                          362
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Treaty between the United States and Canada,  tha last para-
graph of which read* as follows:  "It  la  further agreed that
the Miters herein we find as boundary  waters  and waters flow-
ing ut 1-038 the boundary shall not be polluted on either side
to the injury of health or property on the other."  The above
yield reduction would certainly be a violation of the Boundary
Waters Treaty.  It is definitely an injury to my property.
          On November 1st of 1979 I started taking monthly
water samples for standard analysis from  five different sites
along the east fork anJ middle fork of the Poplar River and
also below the confluence of these two rivers.  The samples
were and are being sent to the testing laboratory at Montana
State University, Bozenun, and the results are sent back to
the Daniels  County extension agent and myself.
          I  tried to compare boron concentrations from my
water sample results with the results  that appear on Page 128
.imi 130 of the Draft.  This Draft Is supposed to be written so
that a layman could road and understand its contents.  The
graphs arc very confusing and they lack the labeling so that
a lay person cannot understand It.  The whole Draft In general
is poorly written.
                              Responses to Mr. Ferver
     259)     The Boundary Haters Treaty fi discussed In the revised Chapter 2.
          A detailed discussion of Impacts on agriculture Is given In Chapter 5.
          Mhether the treaty has been violated Is a decision of the courts not
          the EIS.
     260      The problem any have been the units of Mr. Farver's data.  At low
          levels •pp»" It approximately equal to lag/I*.
                                                                                    li
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                           -a	'•>	-w
           On Pago 131 of the Draft it states and I quota,
"The  seasonal water requireuwnt for alfalfa from June to
September,  assuming that in the months of April and May the
soil  retains sufficient moisture from snow melt requiring no
irrigation, is 18.5 incites."  Title statement  Is misleading and
Incorrect.  The irrigation season in Daniels  County  is  from
April through September.  The early April irrigation with its
low TDS content is necessary to flush out the salts and boron
accumulated from the previous year's irrigation.  The Draft is
giving a misleading assumption saying tliat the snow molt is
sufficient moisture.   It is not.  The ground is usually frosen
when  the snow melts so that between the actual run-off and
evaporation little if any moisture is actually being utilized
as a  flushing action  which is  badly needed.
          I would  like to  conclude my remarks  by saying  that
if both  countries  would recognize and abide  by the 1909
Boundary Waters Treaty we  would  not have a problem today or in
the future.
          In  cross-examination before the International Joint
Commission here in Scobey  a Canadian  testified that the
technology now exists  that they  could release  cleaner water
than now flows in  the  Poplar River but  the process would cost
a lot of money.
          When the automobile Industry  had to  put  seat belts
In every automobile they turned  out they merely passed the
cost on  to the consumer.   Why can't Saskatchewan Power
Corporation use tha available technology to  put scrubbers  in
the stack and whatever else  is required to clean up the  air
•«\ll the  water and  n*j«ii th«> cost  on  to the consumer?
                                                                                                                       Response to Mr. Farver
                                                                                               261)     The Irrigation season has been changed to Include Nay In our
                                                                                                   calculations.
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       262)
          :i
           14
River project each spend approximately $100 per  week when they

spend a weekend  in Scobey or Daniels County there  are no

precise estimates as to the amount really  spent.   There are

perhaps some businesses which would benefit from these few

construction workers but It Is Interesting to note that the

$100 spent  has  been broken down In this way:   Seventy dollars

for hotel  room and entertainment and the remaining thirty

dollars on other purchases.

           Now,  it's quite possible that there are greater

numbers of the workers going on to Plentyvood In Sheridan

County because they do have a twenty-four-hour border crossing

They have  substantially more retail stores and services avail-

able  than Scobey and entertainment which  la not available in

Scobey.   Our border north of Scobey Is  limited in hours being

open from nine a.m. to six p.m. from October  the 1st to May

the 14th and from May the 15th to September  the 30th the

border is open trom 'eight a.m. to nine  p.m.,  so that is very

 limiting.

           Now, an  Influx of  single men  always necessitates

 added services of  the community such as law enforcement,

 sanitation services and  et cetera.  These services in turn are

 paid for by the  taxpayers of Daniels County.   These added

 costs' would negate any  of the minor  increase in sales from

 these workers.

            It has been  found  that  sales  vary considerably from
                              Response to Mrs. Oanlelson


      262)     Reports of additional service costs were not uncovered by the
           DEIS prepares.  Such costs are difficult to estimate even when they
           were known to occur.
                                                                                            261)
                                                                                            264)
 *

 *

 «

 *

 6

 1

 8

 •

10

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14

16

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17

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20

21

22

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24

25
                                                                              263)
year  to  year in Daniels County and that  is  mainly due to the

farm  income  which is subject to weather  conditions and prices

for farm products.  Therefore, the impact of  dollars spent by

these workers is far less significant to Daniels County than

the incoma of fanners of the county.

          Because the main source of Income in  Daniels County

is from  the  sale of farm products and related businesses it

should be noted that probable results of the  Poplar River

project  will be acres taken out of production.

          One of the most dramatic effects  can  be seen today

on several farms bordering the United States-Canadian border

just  south of the project—mainly saline seep.   It is

directly affecting hundreds of acres already.   This means less

production from this land, less income from the land for ttie

land  user and will result in the land being declared unpro-

ductive 'and  would, have to result in the  tax base for this land

being lowered.   This would be a chain result  from the land

user  income  down to our county revenues  all being drastically

lowered.

          There has been projection of an intent of a large

increase in  the number of acres to be irrigated  in the next

ten years.   An increase in demand for farm  seasonal workers is

likely to occur if the growth In irrigated  land  takes place as

projected.

          Apportionment would have a tremendous  effect on the



               Responses to Mrs. Oanlelson


Possible Impacts on the tax base have been added.
                                                                              264)     The Irrigation systems contemplated are largely automatic and
                                                                                   require little later.  A change to Irrlgataed agriculture My only
                                                                                   serve to slow the historical decrease In local farm eaployMent.
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265)
 8


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                                                             100


most of  the  original settlements in this area were on the
                                                                 !
Poplar River.   Hence, I think you can understand the concern,  j

          Also what I would like to relay  to you that our

argument is  not with our good friends to the norch, the

Canadian citizens.   Our argument has always  been with the

Saskatchewan Power.

          Many of ray questions have been answered by listening

to this  testimony here this evening, but the gentleman on the

end who  stated there would be no impact of dry-land agricul-

ture, dry-land farming, from fumigation or from S02 build-ups

that appears to me  to be a dichotomy, because just to the

south of us,  the Knife River down here by Sidney.; it is
                    •       ,                    *
required of  that plant with sixty megawatts  to- have scrubbers

to protect the environment.   I think that's—something isn't

quite right  there.

          I  have visions and I have feelings that the Poplar

River is  a marginal river in the first place and to take out

half the  water and  you come to twelve hundred aeg&watts is

there going  to be enough water for anything?  I am still con-

vinced that  you have pre-empted all the irrigation that is

planned  on the Fort Peck Reservation in Roosevelt County and I

think that this project will pre-empt any  future development

and anything yet to come in this area.  The  negative impacts

that you  have  stated here in the EIS and in  this study is just

about exactly  what  we here in this area have been telling the
                          Response to A. Lund
265)     Air quality controls may be required to meet the U.S. and/or
    State of Montana air quality standards.  The standards are designed
    to prevent damage to human health, agriculture, and biota.  The dif-
    ference 1n the Poplar River case Is that the U.S. and Montana standards
    do not apply to the Canadian power plant. There are violations of
    these standards 1n the U.S., for a power plant of 600 MW's or more.
                      365
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       266)
       267)
                                                                             101
                IJC  toe  the  last five years.  You are right  on.
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          Tli£nk you.


          HEARING  OIKICER McCLAVE:  Thonk you.


          Dili  Cromwell.


          MR. CROMWELL:   Members of the panel, my name  is  Bill


Cronwcll.   I am Vice  Chairman of Three Corners Boundary


Association and Chairman of tho Daniels County Planning Board,


and I  live  about twenty-nine miles from the power plant right


about  the end of one  of those lines that you have drawn on the


isoplats.


          My main area of concern in the Draft EIS on the


impact of Canadian power plant development and flow apportion-


ment on  the Poplar River Basin is the air quality segment.


          As Milt  Gunderson mentioned, there is no mention of


the issue paper by the Scientific and Engineering Advisory


Panel  on Poplar River air quality.  This paper raised questions


.->bout  the coal  test burns, sulfur retention, meteorological


diLa,  emission  rates  and also calculated higher negative


ccononlc impacts to agriculture.


          Monitoring  and modeling of the emission rates are


critical Instruments  In determining the air quality Impacts.


In-stack monitoring of the emissions continuously Is the only


sure way of determining the point source air pollution  of  the


Poolar River Power Plant.  Additional monitors In the main


pU'tiie  areas >lowr>wind  are also esscnti >1 to show the hourly and




              Response to Mr. Cromwell
      266)     The Issue Paper by Gelhaus and Roach WAS discussed on p. 173 of
           the CIS.



      267)     The agreement between Saskatchewan and Montana covering water and
           air quality monitoring and Joint transfer of data was set up In September.
                                                                                               268)
                                                                                              268)
 •j



1U



II



12



IS



14



16



1C



IT



If)
daily SO2 concentrations.


          Modeling wu» done using meteorological data from tho


Glasgow area, 1 believe  some  from Scobey,  but it was indicated


in this Draft that the modeling would  have to be rerun using


the Scobey meteorological equipment  which  was Just installed


about a year ago.  The meteorological  transportation of


emissions from the power plant may bo  different than that used


with the Glasgow data.   The diffusion  of the plume may be


changed due to different air  dispersion.   The emission rates


of sulfur dioxide nay also vary widely due to differences in


cool analysis.


          The second set of coal samples received from Canada--


I bcllevo that was the one received  in March or May of '77--I


would have to check that—was different coal thin the first


sat according to the Scientific and  Engineering Panel.  This


raised the question of how much other  coal analysis will vary


and how It can be averaged.   Monitoring time limits because of


these variations should  be extended.


          More sampling  of area vegetation should be taken


more frequently such us  the beginning  of the growing season,


during development of bud and blossom  stage,  seed production


stage and at near maturity of the plant.   Notice should be


taken of any changes which might occur In  plant species due to


additional stresses.  Different varieties  of plant species may


appear which arc more tolerant of nitrovis  oxide and sulfur
                  Response to Hr. Cromwell



   See response 220 for comparison of modeling results.
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      269)
«*>
o>
-J
HI




II




I'




13




U




15




1C




17




IH
entitled  to prevention controls as other Montanuns.
                               •

           At Colstrip Montana Power coal-fired power plants


burning sub-bituminous coal with almost twice  the Btu's,  that


is ten thousand as compared to fifty-eight hundred at


Coronach,  with the best available technology is releasing


about 3317 tons of sulfur dioxide per year.  That's  a comparab


sized unit of seven hundred megawatts, I believe,  and this

                                                    >x

project at Coronach was held or this project at Colstrip  was


held up by the EPA to install better emissions controls.


OH.6 percent.  However, ETA seems to be giving the okay for


sulfur dioxide emissions for a plant producing over  ten times


greater.   Without the sulfur dioxide emissions control the


Poplar River six hundred megawatt plant will emit  about


39,900 tons per year based on coal consumption of  495,000


pounds per hour per three hundred megawatt unit.-  Montana's


new source emissions standerd of 1.2 pounds  of sulfur dioxide


per million Btu's is violated also by the Poplar River Power


Plants emitting 1.94 pounds of sulfur dioxide  per  million



Btu's.


           Evidence clearly shows that Montana  has  written good


air pollution laws.  We in Northeast Montana feel  that we are


entitled  to the rame clean air that we have  enjoyed  in the


past and  sincerely hops that our CnnndiMi neighbors  will  honor



our air standards.
                             Response to Mr.
     269)      The emissions levels of sever* 1 HontiM and North Dakota plants
         are cospared In the revised air quality section.  The Impacts of the
         Poplar River power plant and Mitigating effects of air quality controls

         have been Identified In the EIS.
                                                                                                   I


                                                                                                   x


                                                                                                   .1


                                                                                                   4



                                                                                              270)  *


                                                                                                   A
                                                                                                  10



                                                                                                  II



                                                                                                  IS
 detail at a later data.



           Also on behalf of the Daniels County Planning  Board


 I would like to provide you with a portion of our county


 comprehensive plan.  I guesa I have the wrong book.  It  has


 data which should be included in the Final Onrlrocawatal
                                                      I

 Impact Statement.  There are some errors in the Draft EIS on


 the  inventories as other people have or will note in their


 testimonies.


           This portion of the comprehensive plan was completed


 June 30,  1980,  and Includes  inventories or analyses of  land


use,  transportation, public  facilities,  housing and population


and economic studies, and we hope to have  a  whole plan


completed by June 30, 1981.
                                                                                                                     Response to Hr. Croawell
                                                                                             270)     The Daniels County Planning Board report MS reviewed and the
                                                                                                  pertinent Information Incorporated Into the EIS.
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     1


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     3


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 271)13


     14


     IS


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     23


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     23
                                                             106


work apparently has not been done  on the agriculture, live-

stock and the things that deal with the land that all these

people have  talked about previously,  and we don't went to be

weighing  vhat the possible good  effects may be against the

bad because  that has been our bread and butter and it con-

tinues to be our bread and butter.   This is what happens when

the agricultural land surrounding  our area is not but the

short-term effects that you people have stuck in here that

construction workers are going to  spend in our motels and our

bars.

           There are a couple of  things that I would like

answered—one,  a definition of direct and secondary impacts.

I wish that  I could operate my business with a margin of

error from 216,000 to 324,000.   That leaves you an awful lot

of area to work with.  If I could  budget my small insurance

business  on  those type of margins  of error, you know, I would

have lots of room to play with,  and I wish that I could do it

but, unfortunately, I can't and  I  don't think you people shoul<

be allowed to play any bigger games than anybody else when it

comes to  those things,  and when  I  look in the sections about

the multiplier factors, and so on,  and look at the figures

that are  given there they just don't  add up.

           I  wonder, as  has been  pointed out several tines

previously,  at  some of  the inaccuracies that were found in the

Tetra Tech report whether these  figures came from some
                         Response to Mr. Wolfe
271)      Expenditures by Canadian workers In Daniels County could not be
    measured directly but had to be estimated using some crude but reasonable
    assumptions.  To demonstrate the level of uncertainty we present an upper
    and a lower Unit for possible impacts.  The point to be made Is that  the
    Impact was probably less than 10% of retail sales in 1975.  NO change
    was made to text of DEIS.
                               368
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   1
   2
   8
   4
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   8
  .. »
   10
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=   13
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:   is
•   17
   18
   19
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.   22
   28
   24
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                                                                     107

         computer model that somebody came up with or Whether they were
         gathered with the type of data that they should have been
         gathered with,  because I did some gathering and talking with
         local businesses. ,       ;               :"
          •' *''  .    I  went to the local bank where I would have  to say
         probably ninety percent or better of the funds from the
         businesses In the impact area are deposited, and they  gave  me
         the .figures  from '77 to '78.  Their total Canadian deposited
         ''• \ -'•'•••••.-''     '    '' '           ,   *~' '           •
         funds had  decreased by fifteen percent and in  '78  and  '79 they
         had decreased by seven percent and—'77 to '78 they had
         decreased  by fifteen percent.  That's all the  checks,  cash,
         any type of  Canadian funds that come into the  Citizens State
         Bank.  Those were supplied by the vice-presidents  at  the bank.
                   I  have heard some comment earlier  tonight that,
         unfortunately,  I guess, we have got the  people here who we are
         supposed to  have, but you guys got a crutch.   You go out and
         hire private individuals, contract or  service people that are
       |  supposed to  do the Job.  You guys are  only the suppliers.   If
         you are  only supposed to supply  the people who are supposed to
         do the job then we lost there.
                   Again, I have dealt with consulting firms,  I have
         been on  the County Planning Board that deals with solid wastes
         and work with them—these people.  They all—what they do  they
         don't go out and gather raw data.  They go through all the
         other reports they can find in  the  libraries and  pull  all  the
                         Response to Mr. Wolfe
272)      It Is always difficult to trace expenditure patterns In a local
    economy because there are few published figures.  Host financial data
    are confidential, and publishing  data for small regions may reveal
    Information on a single firm.
                                369
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273) 18
     19
     20
     23
     24
     25
                                                               110
 income he then  spends,  you think of  it almost as a pyramid
 type thing.  You  spend a dollar at the top and it starts
 spreading out.
           MR. WOLFE:   So using the information you have given
 here and a multiplier effect of 1.85 and an average  figure in
 that gross range  you have to play with,  two sixteen  and three
 twenty-four, whatever,  two sixteen and three twenty-four,  and
 you are saying  roughly round the 1.8 up to two and say that
 the impacts have  been a hundred thousand dollars spent in  the
 area times two, which would be the multiplier comes  up to  the
 two hundred thousand dollars, then actually the report is
 saying the impacts have been the construction workers have
 spent a hundred thousand dollars in  this area.  Is that—
           MS. SUMMERS:   I believe it gives a specific amount
 they spent.  I  still  have to check on the page.
           MR. WOLFE:   On Page 155, and I hope, because it's
 all contradictory, if this is the case,  I tried to overlook it
 it  says,  "Using this  methodology secondary impacts can be
 calculated.  Daniels  County receives  approximately sixteen to
 twenty-four thousand  dollars annually in secondary impacts."
Well,  then that's telling us that if  we  only use a mean or
very,  very low figure,  I  mean very,  very low,  two hundred
thousand,  even below  the  two sixteen,  your lowest figure,   if
you are telling me the  secondary factor,  the sixteen to
twenty-four thousand, then the actual  primary impacts are  in
                         Response  to Mr. Holfe
273)       Daniels County does not receive all the secondary impact*.  The
          secondary impacts are allocated'to counties throughout the local
          trading area.  The  allocation of direct and secondary impacts is
          aa  follows:                          Low      High
        Direct Expenditures
          Multiplier 1.85
        Total Impacts
        Secondary Impacts
          Daniels Co.
          Roosevelt Co.
          Other counties
                                  $200,000 $300,000
                                  370.000  SSS.OOO
                                   170.000
                                   16,000
                                   53,000
                                   101,000
255.000
 24.000
 79,000
152.000
        Because of limic«4 wholesale facilities in Daniels and Roosevelt
        Counties. «uch of the secondary ivpact occurs in places such as
        Glasgow and Clendlve, Montana; and Minor, Korf.i Dakota.
                                ~ 370~"
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 274)
       u


      10


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      IS


      W


      JO


      31


      82
      35
                                                             11 Jj


forty-five minutes.   Now,  I believe that no  one could actually


make a statement as  to  how long a fumigation effect can work.

          The problem that I would like to address this panel

on is the effects  that  have been found with  some power

generating plants, coal-fired generating plants, in North

Dakota.around the  Bismarck area by a practicing veterinarian

over there, Dr. Don  Hastings, and what happens is that he has

concluded and found  and in our own little ways of practicing

people, fanners and  such,  we have proven to  the fact that when

y.,u have an inversion in the air it causes a concentration of
                                       f
the sulfur to be taken  up by the alfalfa plant in such a great

level that it will interfere with the usage  of the—the proper

usage of salinium  in the body.

          Okay.  Now, when this happens in—just to digress

Just a little bit, in a salinium-deficient area we have a

problem called  the weak-calf syndrome.  I  don't like  that

word because it's  just a panacea of a big  problem, but they

have it in certain areas, and we have found out it's  a lack of

salinium.

          Okay.   In  North Dakota and  likewise  in our  area  we

are in areas that  are known  to have adequate supplies of

salinium, but these  power plants have created  what we call

necrogenic problem,  disease.  It's a manmade problem, and what

happens with these calves in this Bismarck area  is  that  the

salinium was not properly used by the dame,   the mother,  during
                          Response to Mr. tec
274)      A detailed discussion of the Impacts of fumigation  1s given In
    Section 5.6.1.3 of the final EIS.  The Increased trace elanent concen-
    trations due to fuolgation are shown In Table 5.6-2.  Selenium Is
    required by livestock at levels between 0.04 and 0.2 ppm.  High levels
    of selenium have been found when soil 1s amended with 8  percent fly ash
    (Adriano et al. I960).  The percent increase in the soil due to fumiga-
    tion is estimated as 0.03 percent.  The estimated Increase in the aerial
    plant parts is 0.0007 ug/g dry weight. Selenium deficiency Is not ex-
    pected to be a problem in Montana.
                                     371
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        REFERENCES CITED IN RESPONSES TO PUBLIC HEARING
The references listed below were cited in the responses to the letters
and Public Hearing only.  Other references are listed in the Main
Report or the Appendix.


Adriano, O.C., A.L. Page, A.A. Elseewi, A.C. Chang, and I. Straughan,
1980.  Utilization and Disposal of Fly Ash and Other Coal Residues in
Terrestrial Ecosystems:  A Review, 0. of Environmental Quality, v.9
no. 3 p. 333-344.

Williams, J.R., 1975. Sediment-Yield Prediction With Universal Equation
Using Runoff Energy Factor in Proceedings of Sediment-Yield Workshop,
USDA Sedimentation Laboratory, Oxford, Mississippi, November 28-30,
1972.  Report No. ARS-S-40 p. 244-252.

Tanji, K.K., 1970.  A Computer Analysis on the Leaching of Boron from
Stratified Soil Columns, Soil Science 110(1):44-51.
                             372
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                         a   LIST OF PREPARERS
Thomas C. Ginn.  Ph.D.   Dr. G1nn served as project manager for the first
phase of the project and was responsible for part of the biological impacts
analyses.  Dr.  Ginn  is  an aquatic ecologist specializing in the effects of
environmental pollutants on the distribution and physiology of freshwater
and marine organisms.

Karen V. Summers.  M.S.  Ms. Summers served as project manager for,the
second phase of  the project and conducted most of the surface water quantity
evaluations, water use  analyses and part of the water quality impacts.  She
1s an environmental scientist specializing in modeling studies of ground
water and rivers,  design of field monitoring programs and water quality
evaluations.

Stanley W. Zison,  Ph.D.  Dr.  Zison  conducted the analyses of  baseline
water quality.Dr.  Zison is  an environmental chemist and statistician
specializing in waste  treatment management and mathematical modeling of
the  fate of pollutants.

William B. Morel and. M.A.   Mr. Morel and was responsible  for the  air qual-
ity modeling and prediction of air  quality impacts.  He  is a  meteorolog-
ical specialist in diffusion  analyses, clinatological analyses and effects
of atmospheric turbulence.

Thomas Grieb. M.A.  Mr. Grieb conducted terrestrial  biological effects
analyses for both air  quality and water quantity considerations.  Mr.
Grieb specializes in the impacts  of energy-related  operations on biologi-
cal  systems.

J. David Dean, M.S.  Mr.  Dean  conducted parts of the water quality impacts
analyses, especially as they  realted  to agricultural use of water and
determined the Impacts  of boron and salinity on crops.   He is an agricultural
engineer with experience in the use of stochastic/deterministic  models for
analyzing water demand by irrigated crops and predicting the  fate of  pollutants
moving through soil.

John M. Ryan, MBA.  Mr. Ryan was  responsible  for partial development of
the  socioeconomic methodology and impact  assessment. He Is  a specialist
in the modeling of complex socioeconomic  systems  in the public and private
sectors.

Daniel T. Dick, Ph.D.   Dr. Dick  also contributed  to the socioeconomic
methodology.  He  is an environmental  economist with considerable experi-
ence in regional  impact analysis  of energy development.

Mary E. Gray, B.A.  Ms. Gray collected and described information concern-
1 no  the baseline  socioeconomic conditions.   She has experience  in resource
planning, impact  assessment and energy development analysis.
                                   373
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Susan Mara, M.A.  Ms. Mara is a hydro!ogist and served as a consultant
on water-related natters in the socioeconomic analyses.

Leslie A. Young. M.S.  Ms. Young analyzed the direct socioeconomic
impacts.  She specializes in economic analyses and the development of
interview and survey techniques.
                               374
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                                    TECHNICAL REPORT DATA
                             (Heat nod Imttntctioni OH the nvene be fan compltting)
 , REPORT NO.
  EPA 908/5-81-003
             3. RECIPIENT'S ACCESSION>NO.
4. TITLE AND SUBTITLE
  Final  Environmental  Impact Statement
  Impact of Canadian Power Plant  Development  and Flow
  Apportionment on  the Poplar River Basin	
             S. REPORT DATE
              June, 1981
             B. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
  U. S.  EPA with assistance from  Tetra-Tech,  Inc
             B. PERFORMING ORGANIZATION REPORT NO.
J9. PERFORMING ORGtNIZATION NAME AND ADDRESS
1  EPA,  Montana Office
  Federal  Building,  Drawer 10096
  301 South  Park
  Helena,  Montana  59626
              10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.

               EPA Contract No.  68-01-4873
12. SPONSORING AGENCY NAME AND ADDRESS
  EPA, Montana Office
  Federal  Building,  Drawer 10096
  301 South Park
  Helena,  Montana  59626
              13. TYPE OF REPORT AND PERIOD COVERED
               Final EIS
              14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
  Prepared in cooperation with U.  S. Department of State
1O. ABSTRACT
  (See Attached Copy)
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS |c. COSATI Field/Group
18. DISTRIBUTION STATEMENT

  As described in  Chapter 7
19. SECURITY CLASS
                             21. NO. OF PAGES
                                   360
20. SECURITY CLASS (THItfUgt)
                                                                             22. PRICE
EPA Form 1120-1 (»-73)
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Attachment to Report No. EPA  908/5-81-003

                                       ABSTRACT


A  300 megawatt  coal-fired power  plant has  been constructed  by Saskatchewan Power
Corporation  on  the East  Fork  of  the  Poplar  River  about 4  miles  north  of  the
International Boundary,  another 300 megawatt  unit  is  under construction.  The power
plant  and associated  reservoir  will  result  in  a. water  use  and  will  modify  the
transboundary flow of  the Poplar  River.   A flow apportionment agreement  between the
U.  S.  and Canada  will  be  established.   This EIS  addresses the  impacts of  several
flow  apportionment alternatives in addition to  other  potential  impacts of the power
plant on  the  U.  S. part of the Poplar River  Basin.   The  Poplar  River flows will be
reduced  under  conditions   of the  recommended  apportionment.   These  reduced flows
result  in less  water  available  for  irrigation  expansion.   Lower  flows  may   also
impact  furbearers, waterfowl,  fish  and  other  organisms.   Water  quality  will be
degraded  with  total disolved  solids  levels increasing.   The  highest concentrations
of  airborne  pollutants will  occur in the  U.  S. southeast  of  the power plant.  The
predicted  concentrations  were  less  than   the U.  S.  National  Ambient  Air  Quality
Standards  and  the  Montana   Ambient  Air  Quality  Standards  for   1-hour,   3-hour,
24-hours, and the  annual mean.  Fumigation under very stable conditions could result
in  elevated  SO? concentrations.   The impact  of fumigation events  would be  minimal
because of the  small area  affected by one event, the  short  time  period, and the low
frequency of  occurrence.  The  S02 concentrations predicted by the  EIS with two 300
MWe  units and  no  S02  control  would  exceed  Class  I  PSO  regulations  at  Fort  Peck
Indian Reservation  (not  presently  desginated), but not at the Medicine  Lake  National
Wildlife  Area.  Comparison  of  the  predicted  concentrations   of  S02,   NOX  and
particulates  with   acute  and  chronic  threshold limits  for selected  plant  species
indicated  no  detectable  impacts  on  the  terrestrial   vegetation.   No  impacts   were
predicted due to accumulation  of trace metals  in soils.
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