ML19331B284

Affidavit Re L Holcomb 720614 Testimony Re Plant Impact on Fish Losses in Tittabawassee River

ML19331B284
Person / Time
Site:	Midland
Issue date:	07/07/1972
From:	Seeburger D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML19331B279	List: ML19331B278 ML19331B281 ML19331B284 ML19331B285
References
NUDOCS 8007280885
Download: ML19331B284 (4)

Text

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N._ )

UNITED STATES OF AMERICA ATCMIC ENERGY C0!CIISSION In the Matter of )

)

Consu=ers Fever Company ) Docket No. 50-329

) Docket No. 50-330 (Midland Plant Units 1 and 2) )

STATE OF MICHIGA'i )

) SS.

COUITI"I 0F JACKSON )

Affidavit of Dexter James Seeburger Dexter James Seeburger being duly sworn deposes and says that he is an aquatic biologist with Applicant; that the statement attached hereto was prepared under his supervision and is true and correct to the best of his knowledge.

/s/ Dexter James Seeburger Dexter James Seeburger Subscribed and sworn to before me this 7th day of July,1972.

/s/ Iris C. Markeaski (SEAL) Iris C. Markovski Notary Public, Jackson County, Michigan My Commission Expires Mar. 12, 1974 8

soonso 886

s Statement of Dexter Jcmes Seeburger Regarding the Testimony of Dr. Larry Holcomb at the June 14, 1972 Session of the Midland Nuclear Plant Proceeding I have previously appeared as a vitness in this proceeding and have 'ceen sworn. I have reviewed the testimony of Dr. Larry Holcomb which appears in the transcript of the proceeding beginning on page 8517 and have the following connents to offer.

Dr. Holcomb in his analysis calculates fish losses in the Tittabavassee River as a result of destruction of phytoplankton and zoo-planhon by the operation of the Midland Plant to be $52,800/ year. Appar-ently his calculation is based on the methodolog proposed in the AEC 's draft Guide to Preparation of Cost-Benefit Analyses which was released in December 1971 and used by Applicant in preparation of its Supplemental En- j vironmental Report. His only deviation appears to be the use of a value of

$3,00 per pound of fish rather than the AEC's recommended $1.00 per pound.

The AEC, however, has abandoned this method as being unsupportable. The use of this method by Dr. Holcomb indicates his failure to pay attention to the testimony of Mr. Grube (Tr. 7369-72) and his lack of understanding of aquatic biota. '4hile it is true that some quantity of phytopinnkton l and zooplanktoa vill be killed by the operation of the Plant and that this amount may approximate five percent of the phytoplankton and zooplankton in the River at the point of intake during the period when withdrawals i

are being made, these losses cannot meaningfully be converted into pounds of fish. The nutritive value of these organisms vill be returned to the River where it can be utilized by the fish and other biota. Additionally, both phytoplankten and zooplankton reproduce very rapidly and it is to be

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expecte'd that the remaining organicms in the River vill have rapidly re-stored the concentration of phytoplankten and zooplankton to a level ap-approximating that previously in the River. Even during the pariods when there is no pond discharge, I would not expect to see the -destruction of this quantity of plankten affect the fish population. If the River is healthy there vill be an abundance of these organisms for plankton feeders and if the River is unhealthy to an extent that would affect this abundance the lack of plankton vill not be the controlling factor on fish populations.

It is not to be expected that any meaningful decrease in the quantity of fish in the River vill occur as a result of this relatively small destruction of these organisms. Even vere' there any likelihood of such loss, Dr. Holccmb's use of a $3 00/lb value is beyond comprehension. He, himself, states that the values he is using for fiah are these developed by the Southern Division of the American Fisheries Society (1970) cnd that such values range from

$.15 per pound for very undesirable species to $3 50 for several game species. Yet he uses $3.oo/lb as an average figure. He must be assuming that vastly disprcportionate numbers of game fish will be affected since his average is in the game fish range. I believe this to be an unreason-able assumption.

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-Dr. Holecmb assigns a cost of $26,k00 per year as a result of -l i

loss of benthic organisms. He, however, fails to allege any mechanism which would result in such a loss or any basis for his monetary figure. j Although sczne benthic organisms during certain times of the year may be- )

cczne entrained by the' intake structure, this will not occur with any fre-quency. Benthic organisms are by definition bottom dwelling organisms l l

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3 which exist in the sediment of the River. They will not nomally be con-tained in any significant quantity in the intake water. His figure is not supported by his testimony and is unreasonable.

Dr. Holcomb makes the non sequitur that since Hydropsyche in the Delaware River were either dead or sluggish when the river temperature reached 95 0 F, that a value of $98,100 should be assigned to the effects of Dov discharges within Michigan water quality standards that raise the ambient temperature to 850F. The quality standards set by the Water Re-sources Cocmission (WRC) are designed to permit intolerant fish - vann water variety. Tne composition of the fish population in the River in 1975 and beyond vill be that which has resulted from WRC plantings. Pre-sumably the WRC vill act reasonably and plant fish that are compatible with their standards. On that basis I can visualize no significant effect from the Dov discharges within the limits of the water quality standards and Dov's stipulation with the WRC.

It is my conclusien that Dr. Holcomb's values which I have dis-cussed above are unreasonable and unsupported by his testimony.

Dated: July 7, 1972