ML19343B834

Testimony on Behalf of Util Re Tx Pirg Contention 2,Griffith Contention 4 & Mccorkle Contention 2 Concerning Cooling Lake Recreational Benefits.Resume & Calculations of Total Chlorine Residuals Encl

ML19343B834
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	12/18/1980
From:	Tischler L ENGINEERING SCIENCE
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DIRECT TESTIMONY OF L. F. TISCHLER ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY RE: TEX PIRG CONTENTION 2, GRIFFITH CONTENTION 4, AND McCORKLE CONTENTION 2 COOLING LAKE / RECREATIONAL BENEFITS 0012300&f

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DIRECT TESTIMONT OF L. F. TISCHLER RE COOLING LAKE / RECREATIONAL BENEFITS 1

Q. Please state your name and position.

2 A. My name is Lial F. Tischler and I am Vice President 3

and Manager of the Austin Office of Engineering-Science, 4 Inc.

5 Q. Please describe your educational and professional

6 background.

7 A. My educational qualifications include a Bachelor a of Science degree in Civil Engineering from the University 9 of Texas at El Paso and Master of Science and Ph.D. degrees

! 10 in Environmental Health Engineering from the University of y; Texas at Austin. Over the past thirteen years I have been g intimately involved in all aspects of water quality analysis 3

and water resources engineering. I have had extensive experience in research and systems engineering involving wastewater treatment, water-borne disease control, water quality measurement, computer and advanced statistical l .O analysis techniques, hydrology, and environmental assess-ment. A large amount of my work has been concerned with 13 water resources in the State of Texas. I am a registered 19 professional engineer in the State of Texas, a member of t 20 the American Society of Civil Engineers, the Water Pollu-21 tion Control Federation, and the American Geophysical 22 Union. A more detailed listing of my qualifications is 23 included as Attachment I to this testimony.

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1 Q. Would you explain why you have been retained by 2

Houston Lighting & Power Company and the purpose of your 3 testimony?

4 A. On December 21, 1976, Houston Lighting & Power 3 Company (HL&P) announced plans to reactivate the construc-6 tion permit application for a one-unit nuclear generating 7 station at a site located near the junction of Allens Creek 3 and the Brazos River. This nuclear generating station, 9 designated as Allens Creek Nuclear Generating Station l'0 (ACNGS) Unit 1, is a modification of an original proposal 1; to locate two units at this site.

12 The decrease in the size of the station from two 13 units to one resulted in a decrease in the size of the g associated cooling lake from the original 8,000 acres to 5,000 acres. Other project changes in addition to those

.o directly associated with the reduction in project scope

,, from a two-unit to a one-unit station were necessitated in order to comply with regulations which became effective subsequent to the initial environmental review (Ref.1) .

19 Consequently, HL&P submitted an Environmental Report 20 Supplement on August 1, 1977 (Ref. 2 ) . The NRC staff then 21 prepared the Final Supplement to the Final Environmental 22 Statement (FS-FES) for the ACNGS Unit 1 in August 1978 23 (Ref. 3 ) .

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1 I have been retained by HL&P to review the water-quality analyses in HL&P's Environmental Report Supplement 3

and the FS-FES with particular emphr. sis on the following 4

aspects associated with the operation of the 5,000-acre 3 cooling lake: (1) the persistence of residual chlorine 6 associated with the chlorination required to prevent accumu-7 lation of biological organisms on cooling condensers and 3 any potential resulting acute and chronic toxicity in the 9 cooling lake; (2) the potential for the concentration in 10 the cooling lake of heavy metals which are input from the 11 Plant, the Brazos River and Allens Creek and their possible.

12 impacts on water quality and the biota and (3) the potential 13 for the formation of nuisance algal blooms associated with 14 enrichment of the cooling lake by nutrients in the Brazos

_s River water and in Allens Creek, with particular emphasis on

_ :2 the sewage discharges from the towns of Sealy and Wallis.

, Q. How did you conduct this review of the various

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g water quality analyses?

A. With the assistance of the staff of Engineering-I 19 Science, Inc., I accumulated and evaluated the most recent 20 technical information on all aspects of water quality and 21 biology of cooling lakes with characteristics similar to 22 those expected for the ACNGS lake in order to provide the 23 s best possible prediction of future water quality in the 24

1 lake. Particular emphasis was given to collecting and evaluating water-quality and biological data taken from 3

power plant cooling lakes in Texas with heat loadings and ,

4 water-quality characteristics similar to the Allens Creek 5 cooling lake. Since many of these cooling lakes have been 6 operating for a number of years under conditions similar to 7 those which will occur at the ACNGS, they offer the best a possible predictors of water quality and aquatic biological 9 conditions.

10 In addition to these data, the recent technical 11 literature has been extensively reviewed so that any addi-12 tional information not available during the preparation of the original environmental reports and environmental state-13 g ments, and which are germane to the potential water-quality and aquatic biota of Allens Creek Lake, would be included

,, in this evaluation.

o Q. What is the scope and emphasis of your testimony?

A. It should be noted that this testimony is comple-mentary to that prepared by Dr. Frank Schlicht, Principal 19 Scientist, Environmental Protection Department, Houston 20 Lighting & Power Company. Dr. Schlicht's testimony 21 emphasizes the biological aspects of the Allens Creek 22 cooling pond operation while my testimony centers on water 23 quality. By necessity, however, certain aspects of aquatic 24

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3 biology will be referenced directly in this testimony and 2

likewise, nany water-quality considerations discussed 3

herein are referred to and elaborated on in Dr. Schlicht's 4 testimony.

5 Q. Would you explain the results of the study of the 6 chlorination program proposed for the ACNGS cooling lake?

7 A. Chlorination of the circulating cooling water is a practiced by most power plants to prevent biological fouling 9 in the cooling system. The Environmental Report Supplement 10 and the FS-FES describe the proposed chlorination procedure 11 for the ACNGS. It is briefly summarized as follows: the g chlorine dosage rate will be regulated by use of a controller a tua 13 d]y a free cMode residual modtor set to mdtab 0.2 mg/l free residual chlorine at the condenser discharge

,_ block during the chlorination process. EL&P estimates that

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two 15-minute doses per day at a concentration sufficient l o, 17 to maintain this concentration of free chlorine residual will provide the necessary biocidal treatment. This dosage rate will be controlled such that the EPA's chemical effluent 19 limitations guidelines (Ref. 4) will be met.

20 Because free chlorine is highly reactive, it is 21 not expected that the free chlorine residual present at the 22 condenser discharge block will be detectable as free chlorine 23 24

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1 at the end of the discharge canal where the cooling water 2

enters the lake. Rather, the chlorine will react with 3

various compounds in the cooling water, predominantly the 4 nitrogenous compounds, to form combined residual chlorine.

5 The sum of the free residual chlorine and the combined 6

residual chlorine is the total residual chlorino (TRC) in a 7 water sample. MrAP has estimated a maximum TRC discharge 3 of approximately 2.2 mg/l to the lake during the two 9 15-minute periods each day when chlorination is being 10 practiced. This assumes no loss of residual chlorine along 11 the discharge canal.

12 It should be recognized that the chlorine dosage l

13 rate described in the Environmental Report Supplement and g FS-FES represents the best estimate of the maximum chlori- .

-3 nation requirement; at many times during the year, particu-u larly during cooler weather, the dosage and frequency of chlorination probably will be reduced. I have evaluated

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l the proposed chlorination strategy for the ACNGS in compari-13 son with the chlorination practices at a number of similar 19 power plants in Texas and find it to be consistent with 20 these practices. Thus, the proposed chlorination strategy 21 represents a realistic and conservative chlorination require-22 ment for planning and can be better defined after operation 23 of the ACNGS begins.

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3 EPA has published chemical effluent limitations 2

guidelines for steem electric power generating at 40 CFR 3

423 (Ref. 4 ) . The guidelines for.. free available chlorine 4 (FAC) residual in once-through cooling water, including 5 water from cooling ponds, are a maximum allowable concentra-6 tion of 0.5 mg/l and an average c5ncentration of 0.2 mg/1.

7 The guidelines further require that neither FAC nor TRC may a be discharged from any unit at a steam electric generating 9 station for more than two hourn in any one day. The basis 10 for these guidelines is presented in the Development Document 11 which was prepared by EPA to support their rulemaking 12 (Ref. 5). The guidelines were based on an evaluation of 13 requirements of power plants to minimize biological fouling g of cooling condensers and the impacts of these practices on water quality. The ACNGS will be well within these limita-la, tions. As specified in the Environmental Report Supplement, i the maximum concentration is 0.2 mg/l FAC, while the duration 1 17 of discharge is 30 minutes per day, one-fourth of that allowed.

19 The FS-FES and the Environmental Report Supplement 20 l

for the ACNGS project state that the dispersion of TRC in 21 the cooling lake could not be estimated because of the 22 difficulty in predicting dispersion due to circulation 23 patterns in the lake, uncertainties in the water chemistry, 24 l

i and unknown amounts of atmospheric losses.

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l However, since 2

the preparation of these two documents, additional infor-3 mation has become available in the technical literature 4

which allows an approximation of the TRC decay rate and 5

thus the TRC concentration gradient in the cooling lake.

l 6 The most useful information is the result of a 7 study in California of four different power plant cooling a water discharges including both fresh and saline cooling 9 waters (Ref. 6). The data which are most applicable to the 10 ACNGS system are those taken at the Contra Costa Power Plant 11, which show a 48 percent decay in TRC concentrations after 12 60 minutes under dark conditions and a 61 percent decrease 13 in TRC concentrations during the same period of time under g light exposure conditions. These results, which indicate that TRC decays more quickly in the presence of light probably

,, due to a photocatalytic effect, are consistent with the data

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in Ref. 7 which was conducted on a power plant using sea l water for cooling.

Assuming a first-order reaction describes the decay of TRC in the cooling water, the data presented in 20 Ref.'6 can be used to calculate a TRC decay coefficient 21 which, in turn, can be used to estimate concentrations in 22 the receiving water. Since it is probable that chlorination 23 will occur during both daylight and evening hours, a composite 24

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decay rate coefficient was estimated. Using the contra 2

Costa Power Plant data, this decay rate coefficient was 3

estimated at 0.835 hours0.00966 days <br />0.232 hours <br />0.00138 weeks <br />3.177175e-4 months <br /> ~1 or 7,315 years ~1 This decay 4

rate is substantially higher than the first-order decay rate 5 constant of 600 years ~1 which was used in the Environmental 6 Report Supplement (page S5.4-2) to estimate the long-term 7 average TRC concentration in the cooling lake. These more a recent and substantially more comprehensive studies on TRC 9 decay in cooling waters provide sufficient information to 10 conservatively estimate the persistence of TRC in the Allens 31 Creek cooling lake, which can then be used to examine the 12 p tential acute and chronic toxicity of TRC to the aquatic l 33 organisms which will be present in the lake.

l g The Allens Creek cooling lake in the vicinity of

, the discharge canal is uniform in both width and depth for a distance of approximately 4,500 feet at which point the bend in the inner dike results in a widening of the lake. If it ir conservatively assumed that the water containing the TRC travels as " plug" flow through this area of the lake and 19 that no dispersion occurs (that is, no forward or backward 20 mixing), the concentrations of TRC at any time after injec-21 l tion can be calculated using the first-order decay equation 22 and the coefficient derived from the data in Ref. 6 as 23 described above.

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For purposes of this analysis, it is assumed that 2

the chlorinated water extends across the entire wid'h of 3

the cooling lake in the vicinity of the discharge canal.

4 It is recognized that in reality the plume would be shaped 5 more like the temperature gradients shown in the FS-FES and 6 Environmental Report Supplement. However, this approach 7 provides a suitable basis for estimating the persistence of 8 TRC and the distance that TRC travels in the cooling lake 9 after a chlorination event. A more detailed description of 10 the assumptions used in calculating the cooling lake chlorine il concentrations is presented in Attachment II to this testi-12 mony.

T 3 Applicant's Exhibit _ (LFT-1) through Exhibit g (LFT-5) show the calculated TRC concentration in the cooling g lake starting at selected time intervals after initiation

! lo, of chlorination. Evbihit (LFT-1) shows the TRC concentration .

in the cooling lake immediately after the chlorination process is stopped (15 minutes after initiation). Isopleths for TRC are then shown at four other selected time intervals 13 1 after the initiation of chlorination, ending when the I 20 )

calculated concentration is 0.01 mg/l TRC. This TRC concen-21 I

tration was selected as a reasonable estimate of the lower 22 level of detection attainable in the lake waters.

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1 Based on this analysis, the TRC from a single 2

chlorination event will decay to this concentration within 3

.6.45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> after the initiation of chlorination at a distance 4 of approximately 2,500 feet from the point at which the 5 discharge canal enters the lake. As mentioned earlier, the i

l 6 actual shape of the discharge plume would most likely be a 7 teardrop and the most downstream point in the cooling lake a for the occurrence of the 0.01 mg/l TRC concentration might 9 be somewhat more distant than 2,500 feet from the mouth of 10 the discharge canal described above. It should be noted, 11 however, that this analysis is very conservative since it 12 assumes that the water containing the TRC does not cix and 3

disperse with the lake water of essentially ::ero TRC concen-j ,4 tration bd it further assumes that there is no loss of TRC 1

to the atmosphere. Thus, it can be conservatively stated that the concentration levels shown in exhibits LFT-1 15 through LFI-5 represent a reasonable approximation of the maximum impact of TRC on Allens Creek cooling lake.

18 The long-term average TRC concentration in the 19 cooling lake using the TRC decay coefficient described 20 above is essentially zero. Although a first-order decay 21 reaction never truly results in a zero concentration since 22 it approaches zero asymptotically, it is only a theoretical 23 representation of the decay phenomenon and for all practical 24

1 purposes the expected long-term average concentration of 2

chlorine in the lake will be ::ero. In fact, as described 3

in Attachment III to this testimony, it is actually impossible 4

to distinguish between a concentration of zero mg/l TRC and 5 a concentration of 0.071 mg/l at the 99 percent confidence 5 level because of the inherent lack of precision and accuracy 7 of the available chlorine residual tests at extremely low i 3 concentrations. This point is even more important when 9 evaluating the potential acute and chronic toxicity of the 10 concentrations of TRC in the receiving water on the aquatic 11 biota.

12 The NRC Staff's analyses in the FS-FES rely 13 extensively on work of Mattice and Zittel (Ref. 8) to 14 evaluate potential acute and chronic toxicity of TRC on the 15 aquatic biota. Applicant's Exhibit (LFT-6) is the 16 riginal graph prepared by Mattice and Zittel and used by 17 the NRC in the FS-FES to evaluate the impacts of the pro-1g posed ACNGS chlorination program.

9 The Edison Electric Institute commissioned a Consultant to Conduct an in-depth review of the data base in the Mattice and Zittel paper to determine its validity for predicting the potential toxicity of chlorine to aquatic organisms (Ref. 9). The review evaluated both the scientific validity of the various research papers that were used by

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l 1 Mattice and Zittel to develop their relationships and the l 2 procedures used by Mattice and Zittel to establish their 3 toxicity criteria. The review concluded that over one-half 4 of the data points used in the Mattice and Zittel relation-5 ship were either unreliable and/or inappropriate because of i

6 the following reasons: (1) the authors of the research 7 paper did not report how chlorine measurements were made; 3 (2) inaccurate or inappropriate methods were used to measure 9 the chlorine in the toxicity studies; (3) some of the 10 studies were only observational in nature and provided only 11 qualitative data; and (4) suitable experimental procedures 12 were not used to develop accurate estimates of acute and 13 chronic toxicity. Using only those data which passed the 14 above tests, a new relationship was developed by the reviewers s for the Edison Electric Institute which indicates a higher i

,, acute toxicity threshold level for chlorine than that

.o g developed by Mattice and Zittel, as shown in Applicant's g

Exhibit (LFT-7). This study did not revise the chronic toxicity threshold of 0.0015 mg/l TRC proposed by Mattice

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20 a total of 14 data points at exposure durations of greater l than 10,000 minutes are less than a TRC concentration of

22 l 0.01 mg/1. Considering the potential sources of error in

! 23 the data base for the Mattice and Zittel paper, it is of 24 l

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i 1 dubious technical validity to establish a chronic toxicity 2 limit based on these two points.

3 A similar study was conducted for the Edison 4 Electric Institute to evaluate chlorine toxicity to marine 5 ecosystems (Ref. 10). The results of this evaluation 6 showed markedly higher acute lethal toxicity thresholds 7 than the relationship developed by Mattice and Zittel. The 3 chronic toxicity threshold for TRC is greater than 0.02 mg/1.

9 The chlorine toxicity relationships developed in this study 10 indicate that TRC is less toxic to marine organisms than to 11 freshwater organisms, but in any case the chlorine residuals 12 which have acute and chronic toxic effects on aquatic biota 13 are substantially higher than those used by the NRC in the l

l 14 impact analysis in the FS-FES.

,- In 1979, the Edison Electric Institute commissioned 2

a second study of the Mattice and Zittel approach for 16 defining the threshold toxicity of chlorine in freshwater 1

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1 l ecosystems, with the objective of devising an alternative g model (Ref. 11). The review of the Mattice and Zittel model identified essentially the same basic problems with 20 21 its data base as were described in the earlier review. The l

more recent review was more thorough, however, and specifi-cally identified certain inappropriate basic assumptions in the Mattice and Zittel mcdel. The most important of these

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1 questionable assumptions are the use of data points represent-2 ing both lethal and sublethal effects as if they were the 3 same and the use of marine organisms as well as freshwater 4 organisms to develop a conversion factor to change the 5 median response concentrations to threshold response levels.

6 In addition, the procedure used to derive the acute and 7 chronic toxicity threshold lines had no statistical basis 3 and was based only on the most conservative data, regardless 9 of its authenticity (Ref. 11).

10 The Edison Electric Institute contractor devised

an alternate model for freshwater chlorine toxicity thres-12 holds as shown in Exhibit (LFT-8). This model was l 13 developed to predict the threshold of lethal response of g freshwater organisms to TRC and is based on consistent 2

bicassay data reported in the technical literature through 1978. Only freshwater bioassay data limited to the LC50 6

response (lethal concentration to 50 percent of the test i organisms) to TRC as measured by the amperometric titration or ferrous-DPD analytical methods was used. These are the two analytical methods with the highest precision and accuracy (see Attachment III). A statistical procedure was used to establish the toxicity threshold for the "most-sensitive" species (Ref. 11).

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1 As can be seen by comparing Exhibits LFT-6 through 2 LFr-8, the threshold lethal toxicity levels predicted by 3 the alternative model are almost one order of magnitude 4 higher than those predicted by the Mattice and Zittel 1

5 model. Although no chronic toxicity level is predicted by 6 the alternata model, the threshold lethal level predicted 7 at 10,000 minutes of exposure (about 6.9 days), which a corresponds to the Mattice and Zittel model chronic effects 9 level, is 0.02 mg/1.

10 Again, it should be noted that all available I

11 information shows that the tests for determining chlorine 12 residual have relatively poor precision and accuracy at low 13 concentration levels. In evaluating the toxicity data in 14 Exhibit LFT-7, this lack of accuracy should be considered, 15 especially in view of the fact that the Mattice and Zittel 3

• Q chronic toxicity threshold appears to be based on only two 3

data points. It is possible that the actual chronic toxicity el threshold could be substantially higher than that shown.

g The TRC concentration distributions for Allens Creek cooling lake shown in Exhibits LFT-1 through LFT-5 l can be used in combination with the toxicity relationship in Exhibit LFT-8 to define the approximate extent of the 22 area in the cooling lake which could be toxic to the aquatic biota. With respect to acute lethal toxicity, the isopleths 24

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1 for TRC three hours after the initiation of chlorination 2 are the maximum extent for the potential of impacts on the 3 aquatic biota, based on the revised toxicity relationship 4 presented in Exhibit IJT-8.

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. In Exhibit IJT-8, it is shown that the acute 6 lethal toxicity threshold for aquatic biota at 180 minutes 7 (three hours) is approximately 0.2 mg/l of TRC, which 3 corresponds closely with the predicted concentrations in 9 the cooling lake three hours after chlorination ceases.

10 The front of the chlorinated water plume after three hours 11 is approximately 1,200 feet from the point of discharge of 12 the canal into the lake and this should be the approximate 13 extent of potentially acute toxic concentrations of TRC in 14 the cooling water. It should be reemphasized that the a method used to calculate chlorine concentrations in the l

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, cooling lake assumes that there is no mixing and dispersion of the chlorinated water with the lake waters, which results l e in a Conservatively high estimate of TRC concentration in the lake.

g The potential toxic impacts of chlorine in this zone are discussed in some depth in the FS-FES and Environ-l mental Report Supplement. Fish in the path of the plume l

22 normally will swim away from the high TRC concentrations.

It is likely, however, that the area within approximately 24

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1 1,200 feet of the point of discharge of the canal to the 2 lake will show some effects of chlorine toxicity on the 3

aquatic biota, particularly on some of the benthic popula-4 tions described in the FS-FES. Compared with the total 5 surface area of the lake, however, the area encompassed by 6 TRC concentrations that have potential acute toxicity is

, s small. Also, it should be recognized that these concentra-a tions are projected to persist in this area for only

, 9 approximately six nours out of every 24-hour period (three i 10 hours after each dose). Further, these estimates are based l 11 on the maximum expected dosage rate of chlorine even though l

12 it is probable that much lower doses of chlorine will be 13 applied during the cooler months of the year, resulting in 14 lower concentrations in the cooling lake.

l 13 In the Environmental Report Supplement and the l

16 FS-FES, it was predicted that the long-term average concen-17 tration of TRC in the cooling lake would be 0.001 mg/1. As g discussed above, the recent data on the decay rate of TRC in freshwater indicate that it is more probable that the 19 1 ng-term average concentration in the lake will be zero 20 j for all practical purposes. Further, it should be emphasized l

that the level which has been established as the threshold for potential chronic toxicity to aquatic biota is actually below the sensitivity of any of the available test procedures

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1 for measuring residual chlorine in natural waters. My 2 analysis indicates that the probability of chronic toxicity 3 due to residual chlorine in the Allens Creek cooling lake 4 is essentially zero with the possible exception of the area 5 of the cooling lake within about 2,500 to 3,000 feet from 6 the point of discharge of the canal into the lake.

7 Another approach which can be used for assessing 3 the potential impact of chlorination on power plant cooling 9 lakes is to review chlorination practices at existing 10 lakes. The advantage of using this approach is that many 11 lakes have been used for cooling power plants for long 12 peri ds of time and they should be particularly indicative 13 of the possible occurrence of acute and chronic chlorine toxicity. In addition, it is anticipated that any major 14 3

fish kill that occurred due to acute toxicity brought about by chlorination of the cooling water would have been observed 6

7 and recorded by the various pcwer plant operators.

g I have obtained chlorination data for power plant cooling lakes from the Lower Colorado River Authority, the City Public Service Board of San Antonio, Texas, and the Texas Electric Service Company. Their chlorination practices are smnmarized in Applicant's Exhibit (LFT-9). In addition to the chlorination data shown in LFT-9, the load 23 factor in megawatt capacity of the power plant per acre of 24 1

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1 1 surface area of cooling lake is also shown to serve as a 2 basis of comparison with the ACNGS. The ACNGS will have a 3 load factor of 0.23 megawatts per surface acre on the 4 proposed 5,000 acre lake.

5 As indicated in the summary in LFT-9, a wide 6 range of chlorination practices are used by power plants in 7 Texas having cooling lakes. The range in chlorination 3 frequency and residual at the condenser outlets can be 9 attributed to the differences in seasonal chlorine require-10 ments. In general, much lower and less frequent dosages of 11 chlorine are required during the winter months when biologi-12 cal growth is decreased by cold temperatures. Applicant's 13 Exhibit (LFT-10) shows the fish productivity as measured 14 by the Texas Parks and Wildlife Department in selected 15 Texas cooling lakes including five of those for which chlorination practices are shown in LFT-9.

16 g As a matter of reference, these fish productivity g estimates are based on rotenone studies conducted by the g Texas Parks and Wildlife Department as part of a federal 20

• ' * * * ' ' ' ' ' ' an - mpad ng the fish productivity for selected lakes in LFT-10 with chlorination practices shown for the same lakes in LFT-9, it can be seen that the highest fish productivity observed in these studies occurs in the lake that also received one 24

1 of the highest doses of chlorine: Lake Alcoa. Furthermore, 2 both lakes Braunig and Calaveras, which are operated by the 3 City Public Service Board of San Antonio, practice relatively 4 high rates of chlorination and have extremely high fish 5 productivity with a substantial proportion of these fish 6 being game fish. None of the power plant operators supplying 7 information had any evidence or observations of fish mortality a or distress which could be related to chlorination practices.

g This is not to say that acute or chronic toxicity due to 10 chlorine has never occurred in any of the lakes. However, 11 it is obvious from the fish productivity data that it is 12 not a significant problem and that there is no evidence of 13 any chronic toxicity of chlorine in these cooling lakes.

14 Q. What are your conclusions regarding the chlorina-tion of ACNGS cooling water?

_3a

,, A. Based on my evaluation of the available data on

.Q g the chlorination of cooling water in power plants utilizing g

cooling lakes, I conclude that the proposed chlorination program specified by HL&P will not result in significant toxicity to the aquatic biota of Allens Creek cooling lake.

Further, I believe that the potential for conditions acutely toxic to aquatic biota due to the chlorination practices in the ACNGS will be confined to a relatively small area of 23 the lake within approximately 1,200 to 1,500 feet of the 24

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1 point of discharge of the cooling water into the lake.

2 Information that I have been able to gather and evaluate

, 3 from utilities in Texas using cooling lakes and chlorination 4 practices similar to those proposed by E&P indicates i

2 either that higher organisms such as fish are generally 6 able to avoid acutely toxic concentrations of TRC, resulting 7 in no observed occurrences of fish kills due to chlorination, g or that the acutely toxic concentrations of chlorine shown 9 in the technical literature and described above are much 10 lower than those which would cause mortality in the fish 11 typically found in Texas cooling lakes.

12 Q. Are there other factors which will affect possible 13 chlorination impacts?

g A. Yes, E&P has agreed to conduct a chlorine minimi-

, a.

=ation study after startup of the ACNGS. The objective of this study would be to determine the minimum dosage and lo, l

,., frequency of chlorination required to control biofouling of ,

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the main condensers. The proposed chlorine minimization study details are discussed by Dr. Frank Schlicht in his testimony. In general, the approach is to operate under certain chlorination regimes for sufficiently long periods of time to determine their effectiveness in preventing biofouling. This must be done under both summer and winter 23 conditions and for a sufficiently long period of time to 24 i

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1 give confidence in the results. I have every reason to .

2 believe that this study will be effective, particularly in 3 minimizing chlorine dosages during the cooler months of the 4 year. As indicated above, this is common practice for 5 power plants using cooling lakes. There is an incentive 6 for E&P to reduce chlorine usage because of the relatively 7 high cost of this chemical and thus I anticipate that the 3 projected concentrations used in the evaluations of the 3 impact of chlorination presented above probably will be the 10 maximum ever required and will occur for only short periods 11 of time, if ever. Even if they are not, I am confident 12 that the impact of the chlorination procedure proposed by 13 E&P f r the ACNGS will be substantially less than that I

predicted in the FS-FES.

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_a Q. Would you explain your study of the heavy metals inputs to the cooling lake?

6 g A. The FS-FES indicates that certain heavy metals

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• 13 Allens Creek inflow into the proposed cooling lake which l

could result in the accumulation of toxic heavy metals in the lake with subsequent potential for bicaccumulation and biomagnification. The primary basis for this concern was one year's worth of data collected in 1974 as part of a biological monitoring survey conducted for BL&P (Ref.19) .

24 l

1 The Brazos River data are presented in Table S.2.6 on 2 page S.2-9 of the FS-FES.

3 In April 1978, EL&P conducted a special Brazos 4 River heavy metal bioaccumulation field study to develop 5 additional information on the possible presence of poten-6 tially toxic elements in the cooling lake (Ref. 20). In 7 this study, samples of Brazos River water, sediment taken 8 from the Brazos River in the vicinity of the proposed 9 intake structure, and samples of fish collected from the 10 Brancs River near the site were analyzed to ' determine the 11 concentrations of selected heavy metals in each of the 12 samples to provide additional information for the environ-13 mental evaluation. This study showed very low levels of 14 potentially toxic heavy metals in all samples, which is 15 mentioned on page 2.5-20 of the FS-FES. The sediment and 16 fish samples, in particular, should be reasonably good 17 indicators of long-term trends of heavy metals concentrations 18 in the river, although, as is recognized in the FS-FES, a g relatively few number of such samples were tested. With the exception of the few samples collected during HL&P's 20 biological monitoring program, there appears to be little evidence of elevated heavy metals concentrations in the makeup water and natural inflow to the proposed cooling lake.

24

1 I was requested, as a part of this testimony, to 2 re-evaluate the situation with respect to heavy metals 3 concentrations in the makeup and inflow to the Allens Creek 4 cooling lake and the possible'effect of these metals, if I

5 any, on the water quality and biota of the lake. The first l

6 step in such an analysis is to gain an understanding of the 7 precision and accuracy of the analytical tests used to a measure the heavy metals. The analytical methods for the 9 major heavy metals of concern in the FS-FES (cadmium, 10 copper, lead, mercury, nickel, and sinc), are all based on 11 atomic absorption technology and are described in detail in 73 Reference 21.

13 Applicant's Exhibit __ (LFT-11) summarizes the g precision and accuracy at low concentrations of the analytical

.2 methods which are recommended by EPA for the heavy metals cf interest (Ref. 21). If the concentration levels shown in LFT-11 are compared with EPA's Water Quality Criteria (Ref. 22) for these same metals, two facts immediately become obvious. First, the EPA-recommended water-quality criteria for the protection of aquatic biota in fresh water are below the stated level of detection of EPA's analytical methodology for mercury, copper, and lead. Second, the 22 accuracy and precision of these tests at extremely low con-23 centrations -- those near the level of detection -- is very 24 poor.

1 Mercury is probably the best example, notable 2 particularly because it is one of the metals which is of 3

concern in terms of the Brazos River and Allens Creek 4 inflows to the proposed cooling lake. The precision and i

5 accuracy levels shown in LFT-11 for mercury were based on 6 analyses by 76 different laboratories of standard samples 7 sent to them by EPA. At a true value of mercury in the 3 standard sample of 0.21 micrograms per liter, which is over 9 four times greater than EPA's recommended water-quality 10 criteria for freshwater aquatic organisms of 0.05 micrograms l

11 per liter, the 76 laboratories reported a mean mercury 12 concentration of 0.349 micrograms per liter with a standard 13 deviation of 0.276 micrograms per liter. This represents a 14 very high potential analytical error and, in fact, the 13 measured mean concentration of 0.349 micrograms per liter 16 could not be shown to be any different from zero at the 90 l percent confidence level.

17 The same holds true for the 18 ther analytical tests for the heavy metals of concern at gg these low concentration levels. Note particularly that the 20 analyses all overpredicted the quantity of metals present in the standard sample.

g This means that the water-quality data collected for Allens Creek and the Brazos River must be evaluated carefully in the context of the analytical accuracy of the

tests used. If the data in EL&P's biological monitoring 2

program for Station A-5 on Allens Creek are examined in 3

this way, it is found that six out of 12 mercury samples,

( 4 eight out of 12 nickel samples, 10 out of 12 cadmium samples, 5 and all of the lead samples were below the level of detection 6 of the analytical techniques. This means that estimates of 7 heavy metal concentrations that might occur in the cooling 3 lake as a result of inputs from Allens Creek and the 3razos 9 River must be evaluated in the context of the potentially l 10 high analytical variability resulting in probable overesti-1; mation of metal concentrations based on historical data.

12 Although, as mentioned in the FS-FES, the heavy 13 metal water chemistry in the proposed cooling lake cannot 4

be completely defined at this time, it is possible to gain

, _o some insight into the potential heavy metals loadings and

,. o, resulting metals accumulations in the cooling lake by 3 ., reviewing the long-term historical data for the Brazos

/

River rather than the one year of record used in the FS-FES.

Applicant's Exhibit (LFT-12) presents heavy i metals data collected by the U. S. Geological Survey at the l 20 Richmond station on the Brazos River during the period from 21

, September 1973 through June 1978. These data were obtained

( 22 from the Texas Department of Water Resources' Statewide 23 Monitoring Network selective data reporting system. Also 24 t

l

. . . - . . . - _ . . - . . . .27 _ _.__,-- -- - . . _ . . - . . . - - . _ . _ -- -

t shown in LFT-12, for comparison, are records of heavy 2

metals concentrations at three sampling stations in other '

3 Texas rivers. Concentrations shown in LFT-12 represent the 4 long-term averages and maximum observed concentrations in I

l 5 each of these rivers and show that the concentrations l

5 measured in the Braros River are not significantly different 7 from those in the other rivers, particularly when the 3 precision and accuracy of the analytical tests at the low 9 concentrations measured are considered.

10 Another point which should be made when considering t1 water-quality data at these extremely low concentrations is 12 that the mean or arithmetic average is usually a poor 13 indicator of the statistical distribution of concentrations 3 ,. for a given constituent. The reason for this is that the z concentration of any of the heavy metals is bounded by zero 1

i ,, at the lower end but is essentially unbounded at the upper 1 .o 3

/

levels, resulting in a skewed statistical distribution g

which is logarithmically normal or of even higher order.

g In this type of distribution, the arithmetic average is heavily biased by a very few high concentrations and the median of a particular set of data is a more realistic estimate of the concentration for the purposes of estimat-22 '

ing the concentration of a constituent in the waters in the 23 rivers over a long period of time, such as the life of the 24 ACNGS.

. _ __ -.____._-28

9 In order to make a prediction of the loading of 2

selected heavy metals to the Allens Creek cooling lake over 3

its life, the Brazos River water-quality data measured at 4

the Richmond U. S. Geological Survey station were analy=ed 5 to determine the median concentrations for each heavy metal 5 which occurred during only the three or six months during 7 which water will be withdrawn from the river for cooling 3 lake makeup. The months of the year when water will be 9 withdrawn are, in general, the months with the highest flows la in the Brazos River, which coincide with the lower concentra-11 tion ranges of the measured heavy metals. Concentrations 12 f r each heavy metal of concern which are obtained in this 13 manner for the Brazos River water are summarized in Applicant's

.4 Exhibit (LFT-13).

la Even when the median concentrations are selected

,, for a set of data, it is possible to overestimate the actual

.o i

.i concentration if there are a number of "less than" values l

reported in the data and the less than values are used in the calculations. If the median of a data set is a "less 19 than" value, one approach which can be used is to average the "less than" value and zero and use this value as the l 21 concentration of the median. Another approach is to use 22

=ero as the median concentration but this is a less conser-23 vative approach. The heavy metal water-quality data collected 24

_ _.-29 _ . _-

I during the biological monitoring program (Ref. 19) at 2

station A-5 on Allens Creek fit the pattern of having 3

median concentrations which are "less than" values for most 4 of the constituents for which analyses were performed. The 5 approach described above, that is averaging the "less than" 6 value with zero when the "less than" value was the median 7 and using the calculated concentration as the median for 5 loading calculations, was used in my analysis and the 3 resulting concentrations are shown in LFT-13.

c One important point to note in the Allens Creek 11 data is that the median concentration for mercury calculated 1; using this method is 10 t.imes greater than the EPA water-l 13 quality criteria mentioned earlier. The reason for this is t

,4 not that the concentration of mercury in the Allens Creek

.._ waters is high, but rather that the level of sensitivity of Aa

,, the analytical procedure used was rather high for this o

g particular metal. Thus, use of the conservatively high

,, estimates of median concentrations for heavy metals contri-1 a l

, buted from Allens Creek to the cooling lake, as shown in 13 l LFT-13, will substantially overpredict the long-term average l 20 annual quantities of metals contributed by this source.

21 Also shown in Exhibit LFT-13 are contributions of 22 heavy metals associated with ACNGS operation, other than 1

23 24

t condenser cooling water makeup. Groundwater will be deminer-2 alized and used as makeup for the nuclear steam supply 3 system. The damineralization system will remove heavy 4 metals frem'the groundwater, and when the system is regener-5 ated, these metals will be discharged to the lake after 6 treatment as shown in Figure 5.3.8 of the FS-FES. The 7 content of heavy metals in the groundwater is based on 3 three samples collected in 1978 by Dames and Moore and -

3 reported to HL&P by a letter to R. W. Lawhn, dated May 25,  ;

10 1978. The concentration of heavy metals in the groundwater

was treated the same as those in the other sources as 12 described above. It is conservatively assumed that all l

t

,3 metals are removed from the groundwater and are subsequently.

,4 discharged to the lake. No removal by the treatment system is assumed, since the metals concentration is low in the l_a regenerant wastewater.

,, A second source of heavy metals from plant opera-el tion is the annual cleaning of the auxiliary boiler.

Approximately 30,000 gallons per year of wastewater is 9

generated by this operation. This wastewater is treated in the demineralizer regenerant waste treatment system and 21 then discharged to the lake. After treatment, this waste-22 water is expected to contain 1 mg/l of nickel and 1 mg/l of 23 copper, which results in the quantities shown in LFT-13 for 24 this source.

31-- , - - - . ...- - , - - - - - - - - - -

Other potential sources of heavy metals are corro-2 sien products from the condenser cooling system. These 3

heavy metals are represented by the radionuclides shown in 4 Table 5.5.2-1 of the Report Supplement (Ref. 2) . The 5 quantities of these metals are extremely small; the total 6 loss to the lake for all six metals listed in LF'-13 is 7 less than 1 microgram per year. This source of metals was, 3 therefore, appropriately neglected in the analysis.

9 The summary of the cooling lake operating charac-10 teristics presented in Table S.S.I. of the FS-FES present l 11 the annual average inflow and outflow from the cooling lake 12 over the long term. The water balance information given in 13 the Environmental Report Supplement and the FS-FES, combined.

g with the estimates of heavy metals concentrations and 3._ loadings presented in LFT-13, can be used to estimate the 2

g long-term annual average heavy metals loading on the cooling

,. lake for both the three-month and six-month pumping modes.

l

.I 1

i g

These estimates are shown in Applicant's Exhibit (LFT-14) with the total representing the total amount of heavy metals calculated as input during the year l from these sources and the accumulated loadings shown in the table representing the amount of metals remaining in 22 the lake water, assuming that the outflow from the reservoir 23 contains the mean concentration of metals in the total 24

l l

t Using this approach and assuming that all annual inflow.

2 of the heavy met.is entering the lake are in the dissolved 3

form and remain soluble, the long-term average concentrations 4 expected in the water in the cooling lake can be calculated 5 given an average volume of water in the lake.

l LFT-14 shows 6 the concentrations of heavy metals calculated in this 7 manner assuming an average lake capacity of about 65,000 3 acre-feet.

9 With the exception of mercury, all of the calcu-to lated long-term average concentrations of heavy metals in 11 the cooling lake are below EPA's water-quality criteria.

12 In the case of mercury, the contribution from Allens Creek,

.13 which represents, on the average, two-thirds of the amount

.g of makeup water pumped from the Brazos River, contributes g over three times the quantity of this metal contributed by the Brazos River. The probable reason for this is the use g of the high median concentration for mercury in the Allens

,, Creek runoff in the estimation of these annual loadings.

.c l

In all probability, the actual mercury contributions from the Allens Creek watershed will be substantially lower than the estimates, resulting in a much lower annual loading and 21 long-term average concentration of this metal in the cooling 22 lake.

23 24 l

l l

i l

1 Although the analysis presented above greatly l 2 simplifies the complex water chemistry phenomena which

! 3 actually will occur in the cooling lake, it does provide a 4 perspective on the potential for the accumulation of toxic 5 quantities of heavy metals in the lake water during the l

6 life of the plant. Since the contribution of direct preci-7 pitation on the lake represents a substantial amount of 3 total annual average inflow and it can be assumed that this 9 precipitation contains essentially no heavy metals, simple to multiplication of the highest actual concentration of heavy t; metals ever observed in the Brazos River by the maximum 12 concentration factor estimated for the cooling lake greatly 13 overestimates the metals concentration. In addition, the impact of heavy metals on the biota and the potential for 3

bicaccumulation are long-term effects and evaluation of a

expected long-term average loadings provides a more reason-

, able assessment of the potential toxicity of metals to the

, .7 l

aquatic biota and the possible bicaccumulation of these 13 metals to a level which would be hazardous for humans 19 eating fish taken from the lake.

i 20 The above analysis assumes that all of the metals 21 which actually enter the cooling lake are dissolved in the 22 water and remain dissolved even as they are concentrated by 23 evaporation. The predicted concentration levels shown in 24

- - - y- y ,. -i--a-  % *-m - ,e-- - y--g-- --s--g ---

---wi4 - -- --w-, + o y,y+ gy,-m-- - g Mg--i-y - - ee^-

)

T LFT-14 were compared with the solubility of the compounds of 2

these metals most likely to be found in natural waters 3 including carbonates, chlorides, sulfates, nitrates, and 4 bydroxides. These comparisons indicate that the predicted 5 concentrations of heavy metals are sufficiently low to 6 assume that chemical precipitation would not occur. If this 7 is true, then the major potential for accumulation of heavy 3 metals in the lake over the long term would be the accumula-9 tion of suspended material containing these metals from the 10 Brazos River and Allens Creek makeup sources and from the 11 death of any aquatic biota which have bicaccumulated metals 12 directly from solution. In the former case, it can be 33 anticipated that most of the heavy metals associated with suspended materials in the Brazos River water will be removed with these materials in the sedimentation basins which are l_a g

designed to operate for the life of the project. Sediments which accumulate in the cooling lake are expected to have 7

the same low levels of heavy metals as the Brazos River g

and Allens Creek sediments, as demonstrated by the sediment samples collected during the bioaccumulation field study l conducted for EL&P (Ref. 20).

21 Q. What are your final conclusions regarding heavy 22 metal inputs?

l 23 A. Based on available information, there is no reason 24 to believe that these accumulations of heavy metals in the t

sediment will be any more substantial or toxic than similar 2

heavy metals accumulations in other lakes, both cooling 3

lakes and lakes designed for conservation storage, through-4 out the State of Texas. Contacts with the various power 3

plant cooling lake operators throughout the State of Texas 6 and data acquired from the Texas Department of Water 7 Resources have not indicated any observed problems with the 3 accumulation of heavy metals in cooling lakes. My evaluation 9 of the existing information and the calculations performed 10 above indicate no reason to believe that the potential for 1; accumulation of heavy metals in the Allens Creek cooling 12 lake will be any greater than in similar cooling lakes 13 throughout the State of Texas.

4 The only question which remains to be answered is 32 the reason for the two high concentrations of mercury g measured in 1974 in the Brazos River samples during the t- initial HL&P study cited in Table S.2.6. of the FS-FES.

I 13 ese data, along with certain data points measured for the g other metals of interest, are inconsistent with the long-term data records at the U. S. Geological Survey station at Richmond, Texas. This USGS Station does, however, show 21 high mercury concentrations during the time period of the 22 EL&P study. This difference could be due in part to sampling 23 and analytical error. Another possibility in the case of 24 t

mercury is the intermittent discharge of mercurial-based fungicides which were, at the time that survey was conducted, 3

still acceptable for use. Intermittent industrial discharges 4

j are also possible, although there are relatively few major l

5 industrial discharges upstream. Whatever the reason for 6 the few high concentrations of heavy metals is, I believe 7 that the approach used above for estimating the possible 3 impact of heavy metals on the cooling lake is a more realistic 9 approach than using the highest values ever measured.

10 Q. Please describe your review of the impacts assoc-11 iated with nutrient loading of the lake.

12 A. The FES for the original project, the FS-FES, and 13 the environmental reports prepared by HL&P all discuss the 34 potential for nutrient enrichment and the associated growth 3-2 of algae and higher aquatic plants (eutrophication) in the 16 proposed cooling pond. The Environmental Report Supplement l 3 i

and the FES for the two-station ACNGS evaluate a number of 1

references on algal growth in nutrient-enriched Cooling g

lakes and other lakes in Texas which have high nutrient loads. As discussed in these reports, direct calculations I

of the total amount of plant matter which will be produced at a given level of nutrient loading and under a particular 22 water quality and temperature regime is not possible.

23 However, there are many Texas lakes in which algal growth 24 l

__.._ _ _-37 _ ._ ._ ,_________.,._._.____

and growth of other aquatic plants is well-documented and 2

these can be used to extrapolate the future condition of 3

ACNGS cooling lake.

4 As a part of my review, I evaluated the studies 3 cited in the above-named reports and have developed additional 6 information which can be used to estimate, with a reasonable 7 level of confidence, the probable condition of the cooling 3 lake in terms of the growth of aquatic plants. The primary 9 consideration in this evaluation is the potential for 10 development of " nuisance" algae which possibly could limit 11 the recreational use of the cooling reservoir during certain 12 times of the year. As I will show in the following para-13 graphs, there is ample available information on existing 34 cooling ponds with nutrient loadings equal to or higher i

32 than projected for the ACNGS cooling lake which show that 3g nuisance conditions which could have an impact on the

_37 recreational use of the lake will not occur.

g Before proceeding with an analysis of the potential g levh of algae and other aquatic plant growth in Allens Creek cooling lake, it is desirable to briefly discuss the t

concept of eutrophication and particularly its significance 21 to a " managed" ecosystem such as a cooling pond as opposed 22 to a natural lake. A eutrophic lake is one that has an 23 extremely high level of biological productivity, particularly 24

l i

l l

t with respect to the growth of aquatic plants (primary 2

production) as a result of elevated loadings of plant 3

nutrients, primarily nitrogen and phosphorus. In general, 4 especially in natural lakes, eutrophic conditions are 5 considered undesirable inasmuch as the high quantity of 5 algae present decreases the clarity of the water and these t

! 7 lakes often develop fish populations which may be dominated 3 by bottom feeders (catfish, for example) and rough fish 9 (carp). Nuisance planktonic species such as certain types 10 of blue-green algae can form surface scums which have an 1; undesirable appearance and may cause odors. Eutrophication 12 also is considered to be the trophic state which is the 13 last stage in the life of a lake inasmuch as with time, 4

albeit very long, the lake will slowly fill with sediment

,_ resulting from the high rates of biological production and

? 3 subsequent death and sedimentation.

l 3 ,/

It should be emphasized, however, that the conven-tional interpretations of a eutrophic lake and the ultimate consequences of this on the life of the lake and its viability as a recreational source are based on natural lakes, many 20 of which have extremely low hydraulic turn-over rates (that 21 l is, displacement of water volume). Cooling lakes, such as l 22 l

the one proposed for the ACNGS, are managed ecosystems with 23 a relatively high rate of turnover and a great degree of 24 mixing compared to that present in most natural lakes.

l

t These conditions are highly conducive to enhancing primary 2

productivity with the result that large quantities of algal l 3 biomass are present. The condition of eutrophication is 4

not necessarily bad and can, in fact, improve the recreational 3 viability of a particular body of water. The issue then 5 becomes one of whether the degree of eutrophication present 7 will be a nuisance or a benefit since high primary produc-3 tivity is beneficial in supporting high populations of 9 fish.

10 The best way to evaluate the _ recreational viability 11 of the Allens Creek cooling pond as related to the potential 12 for eutrophication is to compare its water chemistry and 13 morphology with those of similar Texas cooling lakes which 14 have been in operation for long periods of time. This has 3 been done to some extent in the environmental reports and FES'S prepared for the ACNGS project. The information 5

i 37 presented in the remainder of this testimony allows a more g

direct comparison of the Allens Creek cooling lake with similar Texas cooling lakes than did the earlier information g

presented in the environmental reports.

The FS-FES and the original FES for the ACNGS l

project based the estimated concentrations of nitrogen and 22 phosphorus in the cooling lake on the maximum projected 23 concentration cycle in the lake and the concentrations of 24

-4 0 ;- _ , _ _ _ . _ _ _ _ _ _ _ _ _ _

r t

nitrogen and phosphorus in the Brazos River water. It is 2

difficult to use this approach for making any comparison of 3

the cooling lake with existing lakes inasmuch as the relation-4 ship which develops between the nutrient supply and the l

primary producers often results in extremely low concentra-5 6 tions of both nitrogen and phosphorus during periods when 7 algal growth is the highest. A more effective way of esti-3 mating the nutrients available for algal growth in the 3 ACNGS cooling lake is to use the mass balance approach 10 originally suggested by Vollenweider, as described by Tapp 11 (Ref. 23 ) . This approach uses an estimated nutrient budget 12 for nitrogen and phosphorus, based on all known sources of 13 these nutrients to a specific lake, taking into account the A ,. outflow of nutrients from the lake, if any. This method 3_2 has been used by EPA in their National Eutrophication Survey which was initiated in 1972 in response to the 6

requirements of Public Law 92-500, the Federal Water Pollu-77 g

tion Control Act Amendments of 1972.

l The nutrient budget for the Allens Creek cooling lake was calculated using the nitrogen and phosphorus data for Allens Creek which were collected during the HL&P bio-logical monitoring program (Ref. 19) and the data from the 22 Brazos River taken from long-term historical records from 23 the USGS station at Richmond. The expected long-term 24 f

-w-

i t

t average hydrologic characteristics of the cooling lake are i 7 based on the estimates in Table 5.5.1 in the FS-FES. The 3

quantity of nitrogen and phosphorus in the precipitation on 4 the lake is estimated using the concentrations that EPA has 5

used in their reports on four Texas power plant cooling i lakes which were studied by EPA during their national I

7 eutrophication survey (Ref. 24, 25, 26, and 27). The exact 3 procedure used by EPA to calculate nutrient budgets for 9 their eutrophication survey was used to prepare the 10 estimated nutrient loading.on Allens Creek cooling lake and 11 the detailed calculations are presented in Attachment IV to 12 this testimony. The nitrogen and phosphorus concentrations 13 used for Allens Creek runoff and Brazos River contributions -

34 were calculated in the same manner as described above for 13 long-term average heavy metals contributions to the cooling g lake.

37 The predicted nutrient loadings on the proposed 13 c ling lake are shown in Applicant's Exhibit _ (LFT-15) and compare directly with measured loadings on four Texas power plant cooling lakes which were studied by EPA during the National Eutrophication Survey and one power plant coolin<J lake in Illinois which also has been the subject of 22 extensive ecological evaluation (Ref. 28). Also presented 23 in LFT-15 are data on mean chlorophyll-a concentrations in 24

. -tm - -- - __ --

the existing cooling lakes which provide a basis for assess-2 ing the relative algal biomass in each lake. As expected, 3

the lakes with the highest total and accumulated nutrient 4

loadings also have the highest primary productivity. It 5

can be anticipated that the ACNGS project will be likely to 6 behave in a manner similar to Lakes Calaveras, Sangchris, 7 and Braunig, all of which support a relatively high level 3 of algae. The next question is whether these levels of 9 algae have had any adverse effect on recreation or fish 10 productivity of these particular lakes.

11 In addition to evaluating the reports prepared by 12 EPA and the Illinois Natural History Survey on the five 13 example lakes shown in LFT-15, ES directly contacted the

,4 owners and operators of the four Texas cooling lakes to 3

.a determine if there had been significant instances of nuisance 5

algae gr wth which would have an impact on the recreational 17 use of these lakes. The technical references and these g direct contacts have indicated that the levels of algae which have occurred year after year in these lakes have not caused any adverse impact on recreational use of the lake waters or on biological productivity, in terms of fish 21 populations. The fish productivity data for Lakes Braunig 22 and Calaveras, two of the most highly nutrient loaded lakes 23 and those with the highest algae populations, have previously 24

-nu-

1 1

been shown in LFT-10 of this testimony. Referring to this i

j 2 exhibit, it can be seen that these two lakes are highly 3 productive of fish with a substantial proportion of the 4 fish being sport species.

5 Lake Braunig near San Antonio, Texas, is a parti-l 6 cularly interesting case in the context of nutrient loading 7 and fish' productivity. A detailed technical report on this 3 lake and its eutrophic characteristics has been presented 9 in the technical literature (Ref. 29) . Lake Braunig has a

g very small drainage area and thus requires considerable i~

t; makeup water to be taken from the San Antonio River. The 12 location at which the makeup water is taken is downstream 13 fr m the point of discharge of all of the major wastewater 4

, discharges from the city of San Antonio. During low-flow

.4 g conditions, most of the water pumped to Lake Braunig is

,, treated effluent, which results in the very high nutrient

.o g loadings shown in LFT-14. This nutrient loading is far above that projected for the Allens Creek cooling lake.

Despite this extremely high nutrient loading and high degree of eutrophication, Lake Braunig has maintained its ,

20 i l usefulness for recreation and power plant operations (Ref. ,

21 '

25, 29). Lake Calaveras, to a lesser extent because of its 1 22 greater drainage area and smaller requirement for makeup 23 water, confirms the example provided by Lake Braunig in 24 that it also receives the city's treated effluent.

l l

t

. - - - . - - , , + . . - . , - - - . - . "W

l EPA's National Eutrophication Survey listed Lake n

Calaveras as fourteenth out of 39 Texas lakes examined, 3

with the lowest numbers representing the least degree of 4 eutrophication. This is true even at the relatively high 3 nutrient loadings to Lake Calaveras shown in LFT-15 and the 6 fact that many of the lakes in the survey are not used for 7 power plant cooling. These studies done for the National 3 Eutrophication Survey and additional technical information 3 which has been developed for Texas cooling lakes have shown 10 no relationship between degree of eutrophication, the 11 potential for nuisance algae blooms, and the use of lakes 12 for power plant cooling (Ref. 30, 31).

13 One of the issues which has been raised in the 34 FES and FS-FES was the potential impact of nutrient loadings i

from the towns of Sealy and Wallis, whose treated waste-3 g

waters could eventually drain into the proposed cooling 77 lake since they are in the Upper Allens Creek watershed.

g To define their potential contributions of nitrogen and l ~g phosphorus to the cooling lake, potential annual loadings l

of these two nutrients were calculated using projected 1985 20 populations and typical wastewater nitrogen and phosphorus loadings from domestic wastewater treatment plants (Ref.

22 32). No nitrogen and phosphorus removal is assumed in 23 these calculations so the loadings calculated in this 24 manner represent conservative maximum estimates of potential 2

loadings on the cooling lake. Also, it must be recognized 3

that the long distance from the point of discharge of these 4 wastewaters to the cooling lake probably means that most of 5 the time no effluent would reach the cooling lake.

6 The calculations for these nutrient loadings are 7 shown in Attachment V to this testimony. When compared 3 with the calculated Allens Creek nutrient loadings from all 9 sources (see Attachment IV & LFT-15) the effluent represents 10 eight percent of the projected total nitrogen and two 1; percent of the projected total phosphorus loading to the 12 Allens Creek cooling lake. Thus, even if all of the nitrogen 13 and phosphorus discharged from these two towns entered the

4 cooling lake, it would represent an insignificant part of the total nutrient loading.

3

,. o, A connection between thermal loading and algal 7

blooms and other factors affecting fishery resources also 1

! has been suggested. Extensive analysis of the thermal g

loadings on the proposed Allens Creek cooling lake have been made by HL&P and the Nuclear Regulatory Commission and I

are summarized in both the Environmental Report Supplement 21 and FS-FES. I have carefully reviewed the mathematical 22 approach, the assumptions, and the results of these tempera-23 ture analyses and believe that they represent state-of-the-art 24 l

I

-4s.

3 prediction of temperature in a cooling lake such as that 2 designed for HL&P. The fact that the Allens Creek cooling 3

lake is shallow and will be well-mixed because of the .

4 relatively high circulation rate of water makes the hydraulic 5 calculations involved in the temperature cnalysis simpler 6

than would be the case for a stratified lake and increases 7 the confidence in the temperature predictions. Based on my 9 evaluation, I conclude that the predicted thermal conditions g under both normal and maximum loading conditions, as shown 10 in the Environmental Report Supplement and FS-FES, will be 11 a good representation of the actual conditions in the 12 cooling lake.

3 a As stated in the original FES for the ACNGS 4 project and the FS-FES on the single generator project, the l

projected maximum temperatures and the average temperatures in the cooling lake are consistent with temperatures in l 7 other power plant cooling lakes in Texas. Extensive discus-g sien is provided in those two documents, which I have reviewed and found to be a reasonable representation of the expected situation.

20 To provide an additional basis of comparison, Appli-

! 21 cant's Exhibit (LFT-16) shows the observed peak tempera-l 22 tures in the discharge canals of selected Texas power 23 plants using cooling lakes and compares these temperatures

24 1

47

l t

with those predicted for the ACNGS. It can be seen that 2

the ACNGS worst-case prediction (100 percent capacity, 3

five-day critical meteorology) is nct as high as the highest ,

~

4 temperature that has been observed in the operating cooling 5 lakes shown in LFT-16. In addition, although temperature 6 data were not available for Lakes Braunig, Calaveras, and 7 Alcoa Lake, it is known that these lakes operate at high 3 temperatures during the summer months. All of these lakes 9 are shown in LFT-10 of this testimony and demonstrate high 10 fish productivity and high percentages of sports fish as 11 compared to the total fish populations. This is consistent 12 with the literature source cited in the FES which indicated 13 that experience in Texas has been that power plant cooling 3

4 lakes tended to maintain higher proportions of sports fish in their fisheries than did the unheated lakes. There are 3

,, also substantial additional data showing higher productivity

.o 3

in heated lakes, as cited in one of the references used in 7

~ "' '

13 l Q. What conclusions have you reached concerning .

nutrient loadings and related impacts?

A. Based on the comparison of the projected nutrient 21 loadings, thermal and physical characteristics of the 22 proposed cooling lake with existing cooling ponds and data 23 in the technical literature, I conclude that there is a 24 48- _ _.__. _ . _ .

l

~

3 I very low probability of algal blooms in the new cooling lake which would be significant enough to impair recreational 3

use. In fact, I believe that the data from existing lakes 4

in Texas documents quite effectively that the Allens Creek 3 cooling lake will be a valueble recreational resource in 6 terns of both fishing and contact recreation, as have been 7 similar power plant cooling lakes throughout the State.

3 Q. Based on the incensive reviews you have just 9 described, and your own professional expertise, do you 10 expect the ACNGS cooling lake to be a viable sport fishery?

11 A. The comparisons shown in this testimony regarding 12 chlorination, heavy metal concentrations, algal growth, and 13 other water-quality factors have clearly demonstrated that 14 the Allens Creek cooling lake can be expected to support a 35 productive sports fishery resource and will have a high 3, recreational potential. The data from a number of existing

=

17 Power plant cooling p'onds which are exposed to similar l

13 conditions and which have been in operation for many years

,g have shown that the projected conditions in the proposed cooling lake are consistent with current practice and will result in an excellent recreational opportunity for surround-i ing areas. Freshwater-based recreation is very popular in

! 22 Texas and, as discussed in the various environmental reports

23 l on the ACNGS project, is in relatively short supply in the 24 Houston metropolitan area. My evaluation of available w%

t technical information and ccmparison with existing cooling 2

lakes indicates that the water quality and biological pro-ductivity of this lake will be an attractive additional 4

recreational resource for this area.

5 6

7 3

9 10 11 12 13 14 l'5 16 17 18 19 (

i 20 21 22 23 24

.sn.

l l

REFERENCES

1. U.S. Atomic Energy Commission, Directorate of Licensing,

" Final Environmental Statement related to the proposed Allens Creek Nuclear Generating Station Units 1 and 2, Houston Lighting and Power Company,"

November 1974.

2. Houston Lighting & Power Company, "Allens Creek Nuclear Generating Station Unit 1 Environmental Report Supplement, Volumes 1 and 2," undated.

3. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, " Final Supplement to the Final Environmental Statement Related to the Construction of Allens Creek Nuclear Generating Station Unit No. 1, Houston Lighting and Power Company, Docket No. 50-466," Washington, D.C., August 1978.

4. U.S. Environmental Protection Agency, " Environmental Protection Agency Effluent Guidelines and Standards for Steam Electric Power Generating," 40 CFR 423; 39 FR 36186; 40 FR 7095; 40 FR 23987; 42 FR 15690; 43 FR 43025; 43 FR 44848.

5. U.S. Environmental Protection Agency, " Development Document for Effluent Limitations Guidelines and New Source Performance Standards for the Steam

, Electric Power Generating Point Source Category,"

t U.S. EPA, Washington, D.C., October 1974.

6. Hergott, Steven J.; Jenkins, David; and Thomas, Jerome F.; " Power Plant Cooling Water Chlorination in l Northern California," Journal Water Pollution l Control Federation, Vol. 50, No. 11, pp 2590-2601,

! November 1978.

7. Hostgaard-Jensen, P.; Klitgaard, J.; and Pedersen, K.M.;

" Chlorine Decay in Cooling Water and Discharge into Seawater," Journal of the Water Pollution Control Federation, Vol. 49, No. 8, pp 1832-1841, August 1977.

._.-51 ._._, __ . _ . _ _ . _ . _ _ __ _ -

8. Mattice, J.S. and Zittel, H.E., " Site-Specific Evaluation '

of Power Plant Chlorination," Journal Water Pollution Control Federation, 4B_, 2284-2308 (1976).

9. Seegert, G.; Bogardus, R.B.; and Horvath, F.; " Review of the Mattice and Zittel Paper, Site-Specific Evaluation of Power Plant Chlorination", Prepared for Edison Electric Institute, Washington, D.C. ,

(Project 218), June 1978.

10. Thayer, T.A.; Chang, S.Y.; Turner, A.; and Astor, P.H.;

" Chlorine Toxicity in Marine Ecosystems, an Evaluation of the Mattice and Zittel Model for Deriving Toxicity Thresholds and a Proposed Alternative,"

Prepared by Edison Electric Institute, Washington, D.C., August 1978.

11. Turner, A., and Thayer, T. A., " Chlorine Toxicity in l Freshwater Ecosystems - An evaluation of the Mattice l and Zittel Model for Deriving Toxicity Thresholds t

and a Proposed Alternative Model," prepared for Edison Electric Institute, Washington, D.C.,

March 1979.

12. Texas Parks and Wildlife Department, " Performance Report as Required by Federal Aid in Fisheries Restoration Act, Federal Aid Project F-30-R-1, Statewide Fishery Management Recommendations, Job A: Existing Reservoir and Stream Management st ex s kp 1 19 6 l

13. Texas Parks and Wildlife Department, " Performance Report as Required by Federal Aid in Fisheries Restoration Act, Federal Project F-30-R-2, Statewide Fishery Management Recommendations, Job A: Existing Reservoir and Stream Management Recommendations, Colorado City Reservoir, 1976," Austin, Texas, l June 1977.

l l 14. Texas Parks and Wildlife Department, " Performance

, Report as Required by Federal Aid in Fisheries i

Restoration Act, Federal Aid Project F-30-R-2,

, Statewide Fishery Management Recommendations, Job l A: Existing Reservoir and Stream Management l Recommendations, Blundell Reservoir, 1976," Austin, l Texas, June 1977.

I l

n i

l

15. Texas Parks and Wildlife Department, " Performance Report as Required by Federal Aid in Fisheries Restoration Act, Federal Aid Project F-30-R-1, Statewide Fishery Management Recommendations, Job A: Existing Reservoir and Stream Management Recommendations, North Lake," Austin, Texas, April 1976.-

16. Texas Parks and Wildlife Department, " Performance Report as Required by Federal Aid in Fisheries Restoration Act, Federal Aid Project F-30-R-2, Statewide Fishery Management Recommendations, Job A: Existing Reservcir and Stream Management Recommendations, Fairfield Reservoir, 1976."

Austin, Texas, January 1977.

17. Texas Parks and Wildlife Department, " Final Report as Required by Federal Aid in Fisheries Restoration Act, Texas, Federal Aid Project F-31-R-4, State-Wide Fisheries Research, Objective XVI: Evaluation of Predator Fish Introduction, Research Leader: Paul S. Crandall," Austin, Texas, December 1978.

18. Texas Parks and Wildlife Department, " Job Final Report as Required by Federal Aid in Fisheries Restoration Act, Texas, Federal Aid Project No. F-12-R-18, Region 4-A Fisheries Studies, Job No. 6a: Lake Bastrop Channel Catfish Stocking Study," Austin, Texas, December 1973.

19. Dames & Moore, " Biological Monitoring Program - Allens Creek Nuclear Generating Station," Houston, Texas, February 1975.

20. Dames & Moore, "Brazos River Heavy Metal Bioaccumulation Field Study, Allens Creek Nuclear Generating Station, for Houston Lighting & Power Company,"

Houston, Texas, April 1978.

21. U.S. Environmental Protection Agency. " Methods for Chemical Analysis of Water and Wastes, EPA-625-16-74-003," Office of Technical Transfer, Washington, 1974.

22. U.S. Environmental Protection Agency, " Quality Criteria for Water," U.S. Environmental Protection Agency, Washington, D.C., July 1976.

'" 5 7 -- - - - - - - - - - - - - - - - - - - --

23. Tapp, John S., " Eutrophication Analysis with Simple and Complex Models," Journal of the Water Pollution Control Federation Vol. 50, No. 3, pp. 484-492, March 1978.

24. U.S. Environmental Protection Agency, " Report on Lake Bastrop, Bastrop County, Texas, EPA Region VI,"

Working Paper No. 632, Corvallis Environmental Research Laboratory - Corvallis, Oregon and Environ-mental Monitoring and Support Laboratory - Las Vegas, Nevada, September 1977.

25. U.S. Environmental Protection Agency, " Report on Braunig Lake, Bexar County, Texas, EPA Region VI," Working Paper No. 634, Corvallis Environmental Research j Laboratory - Corvallis, Oregon and Environmental l Monitoring and Support Laboratory - Las Vegas, l

Nevada, April 1977.

26. U.S. Environmental Protection Agency, " Report on Calaveras l

l Lake, Bexar County, Texas, EPA Region VI," Working Paper No. 638, Corvallis Environmental Research I Laboratory - Corvallis, Oregon and Environmental Monitoring and Support Laboratory - Las Vegas, Nevada, February 1977.

27. U.S. Environmental Protection Agency, " Report on Lake Colorado City, Mitchell County, Texas, EPA Region VI, " Workinc' ' tper No . 640, U.S. Environmental Protection 1 y, Corvallis Environmental Research-Laboratory - milis, Oregon and Environmental Monitoring an, nort Laboratory - Las Vegas, Nevada, Februar, .77.

28. Illinois Natural History Survey, " Annual Report for Fiscal Year 1976 - Lake Sangchris Project," R.

Weldon Larimore, Principal Investigator; John A.

Tranquill, Project Coordinator, February 1977.

29. Taylor, Ronald D., Dailey, James E., and Rohlich, l

Gerald A., " Wastewater Effluent Discharge to Cooling Lakes," Journal of the Environmental Engineering Division, ASCE, Volume 103, No. EES, pp. 907-918, October 1977.

I 1

30. Espey, Huston & Associates, Inc. " Review of Phytoplankton Studies Conducted on Five Texas Reservoirs,"

Prepared for Texas Electric Service Company, Austin, Texas, February 1974.

31. Becker, C.D.; Cushing, C.E.; and Gore, K.L.; " Synthesis 1

i and Analysis of Ecological Information from Cooling Impoundments," Battelle, Pacific Northwest Laboratories.

Prepared for the Electric Power Research Institute, Inc. Undated draft.

t

32. Engineering Science, Inc., " Water Quality Management Planning Methodology for Municipal Waste Treatment Needs Assessment," Administration Operators Division, Texas Water Quality Board, Austin, 1978.

33. Radian Corporation, " Review of Surface Water Temperatures and Associated Biological Data as Related to the Temperature Standards in Texas," Austin, Texas, l April 1973.

l l

l l

1

REFERENCES USED BUT NOT CITE IN TESTIMONY

' Crumley, S.C.; Stober, Q.J.; and Dinnel, P.A.; " Evaluation of Factors Affecting the Toxicity of Chlorine to Aquatic Organisms," Prepared for U.S. Nuclear Regulatory Commis-sion, NUREG/CR-1350, March 1980 Houston Lighting &. Power Company, "Allens Creek Nuclear Generating Station Units 1 and 2 Environmental Report,"

August 24, 1973-May 15, 1974.

Johnson, Allyn G.; Williams, Theodore D.; and Arnold, Connie R. ; " Chlorine-Induced Mortality of Eggs and Larvae of Spotted Seatrout (Cynoscion nebulosus)," Transactions of che American Fish Society 106 (5), pp 466-469, 1977.

Jolley, R.L., Gorchev, H., Hamilton, D.H., eds., " Water Chlorination - Environmental Impact and Health Effects,"

Volume 2, Ann Arbor Science Publishers, Inc., Ann Arbor, 1978.

Katz, Bernice M., " Chlorine Dissipation and Toxicity Presence of Nitrogenous Compounds," Journal of the Water Pollution Control Federation , Vol. 49, No. 7, pp. 1627-1635, July 1977.

Morgan, Raymond P. II and Prince, Robert D., " Chlorine Toxicity to Eggs and Larvae of Five Chesapeake Bay Fishes," Transactions of the American Fish Society 106 (4), pp 380-385, 1977.

NUS Corporation, " Chlorination Practices of Nuclear Plants,"

submitted to Utility Water Act Group, Chemical Committee, Pittsburgh, January 1980.

Opresko, D.M., " Review of Open Literature on Effects of Chlorine on Acquatic Organisms," Prepared by Oak Ridge National Laboratory for Electric Power Research Institute, EPRI EA - 1941, Interim Report, August 1980.

Rubin, A.J., ed., " Aqueous - Environmental Chemistry of Metals," Ann Arbor Science Publishers, Inc., Ann Arbor, 1974.

Walsh Engineering, Inc., " City of Wallis, Austin County, Texas, Wastewater Collection and Treat:nent System, EPA Project No. C-481625-01-0, Public Participation Work Plan,"

November, 1979 Winklehaus, Ph.D., P.E., " Chlorination: Assessing Its Impact," Journal of the Water Pollution Control Federation Vol. 49, No. 12, pp 2354-2537, December 1977.

I i

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i l

ENGINEERING-SCIENCE ES-1 ATTACHMENT I Biographical Data LIAL F. TISCHLER. Ph.D.

Environmental Engineer Personal Informacion i

Date of Birth: 22 August 1942 Education B.S. in Civil Engineering, University of Texas at El Paso, 1964 l

M.S. in Environmental Health Engineering, University of Texas at Austin, 1966 Ph.D. in Civil Engineering (Environmental Health), University of

! Texas at Austin, 1968 Honors and Awards -

Sigma Xi Outstanding Senior Military Engineering Student, University of Texas

! at El Paso, 1964 Professional Affiliations Registered Professional Engineer (Texas No. 32768)

American Society of Civil Engineers (National and Texas Section)

Water Pollution Control Federation Experience Record 1967 W. Wesley Eckenfelder, Consulting Engineer. Project En-gineer on report to Federal Water Pollution Control Admin-istration on industrial wastewater treatment loads and costs for a broad spectrum of industry.

1967-68 University of Texas at Austin. Research Engineer for Center for Research in Water Resources preparing first draft for a report to the Federal Water Pollutien Control Administration (now the U.S. Environmental Protection Agency) on the state-of-the-art of waste treatment in the petrochemical industry.

1968-69 U.S. Army, Medical Service Corps. Sanitary Engineer for j the 2nd Infantry Division in the Republic of Korea.

Complete responsibility for water supply, waste treatment (water-borne and solid wastes), water-borne disease con-trol, and industrial hygiene for a population of 15,000 in a semi permanent military region of over 250 square miles and more than 20 separate installations.

1969-70 U.S. Army, Medical Service Corps . Sanitary Engineer in the Sanitary Engineering Division of the U.S. Army Environ-mental Hygiene Agency, Edgewood Arsenal, Maryland.

09/80

ENGINEERING-SCIENCE ES --

t Lial F. Tischler, Ph.D. (Continued) t Planned, supervised, and prepared reports on two industrial wastewater treatability investigations for Army instal-lations and a comprehensive field investigation of Fort Knox, Kentucky , wastewater treatment plant designed to determine treatment efficiency and design changes. De-signed experiments to determine the biodegradability of TNT wastewater and the suitability of a manometric BOD unit for Army-wide use.

1970-73 Texas Water Development Board. Systems Engineer (1970-71) on the application of computer-applied analytical tech-niques to water resources and environmental problems, including preparation of reports on stream water quality models and their application to several Texas rivers.

Applied advanced statistical techniques to the analysis of water quality data to determine various environmental i

relationships.

Office of Director of Planning. Hydrologist (1971) working on the application of advanced =athematical techniques to water resources and water quality problems. Supervisor of project to provide refined natural stream flow for all river basins in Texas.

Director of Systems Engineering Division (1971-73). Su-pervisor for three Office of Water Resources Research Grants valued at more than S500,000. Principal inves-cigator on project designed to evaluate the effects on an estuarine environ =ent of upstream water resources devel-opment. Secretary of the Water Oriented Data Programs Section composed of eight State of Texas natural resources agencies and designed to develop a state hydrologic data bank and a natural resources information system.

1970-73 Engineering-Science, Inc. Consultant on a number of projects including: computerized cost allocation of wastewater treatment costs for a regional treatment plant; computer program for statistical analyses of waste treat-ability data; review of industrial wastewater treatment plant design and design of treatability studies for ARADMAC, Corpus Christi Naval Air Station; hydraulic de-signs for two petroleum / petrochemical waste treatment plants; and development of computer model to predict precipitation probabilities for any area of the United States.

1971-73 Earnest P. Gloyna, Consulting Engineer. Review of several refinery and petrochemical industrial waste treatment plant designs. Also reviewed Environmental Protection Agency's petrochemical waste treatment research program for the General Accounting Office.

_2

ENGINEERING-SCIENCE ES -

Lial F. Tischler (Continued) 1973-77 Engineering-Science, Inc. Project Manager and Program Director of major environmental engineering projects, including regional water resources and water quality pro-grams, industrial waste management, environmental assess-ment, and other environmental protection and enhancement projects. Specific major projects directed included:

study for the National Commission on Water Quality on the technology and costs of wastewater treatment for the l petroleum refining industry; water quality / wastewater man-

! agement plan for the lower Rio Panuco basin in Mexico l

l (Tampico); baseline water quality study of Lake Maracaibo, Venezuela; negotiation of revisions in the EPA ' Organic Chemicals Guidelines for butadiene; zero discharge plan for the Rocky Flats, Colorado plant of the U.S. Atomic Energy Commission; and five environmental assessments for new petrochemical plants on the Texas Gulf Coast.

1977-Date Vice President and Deputy Manager of Southwest Region .

Project Manager and Technical Director for major en-vironmental engineering projects. Specific major projects

! include: project management and technical direction, air, l water and solid and hazardous waste permit applications /

negotiations and environmental assessments for major in-dustrial projects in the pulp and paper business, petroleum i

refining, phosphate industries, and chemical industries.

Direction of environmental assessment and permitting for a regional hazardous waste management center.

l l Presentations / Teaching University of Texas at Austin. Lectures on statistical analysis of water quality data and application of modeling techniques to en-vironmental and water resources problems. (1970-73).

Civil Engineering Programs Applications Society. Speaker at annual meetings in Pittsburg, Pennsylvania, to discuss application of advanced techniques to water resources and water quality problems.

(1972).

National Water Resources Meeting, American Society of Civil En-gineers. Presented paper on new techniques to evaluate the economic, environmental, and social effects of water resources projects.,

(1973).

American Geophysical Union. Panelist and speaker for a session of the Hydrology Sectica, on the application of surface water models to planning probless. (1973).

Water for Texas - Annual Conference. Coauthored paper on stream water quality simulation with computer models. (1973).

First World Congress on Water Resources. Presented paper on integrated surface / groundwater development on a regional basis for San Antonio, Texas . (1973).

01c --

ENGINEERING-SCIENCE ES --

Lial F. Tischler, Ph.D. (Continued )

American Chemical Society. Presented paper on biological treatment of petrochemical wastewaters at 168th meeting. (1974).

University of Texas at Austin. Lecturer in continuing education courses on biological and - physical / chemical vastewater treatment processes. (Spring and Fall Semesters, 1975-80).

University of Tulsa. Presented paper on " Effluent Variability in Wastewater Treatment" at the Open Forum on Petroleum Refining Wastes which was cosponsored by EPA, the American Petroleum Institute, and the National Association of Petroleum Refiners. (1976).

University of Tulsa. Presented paper on " Treatment Cos t-Ef fec tive-ness as a Function of Effluent Quality" at the Open Forum on Petroleum Refining Wastes which was cosponsored by EPA, the American Petroleum Institute, and the National Association of Petroleum Refiners.

(1977).

University of Texas at Austin. Adjunct Associate Professor of Civil Engineering. Teaching graduate course on industrial wastewater treatment. (Spring Semesters, 1976-80).

Water Pollution Control Federation Conference. Coauthored paper on

" Evaluation of the Potential for Air Stripping of Hydrocarbons During Activated Sludge Wastewater Treatment." (1979).

l l National Council on Air and Stream Improvement Conference. Presented j paper on " Evaluation of the Potential for Air Stripping of Hydro-carbons During Activated Sludge Wastewater Treatment."

(1979).

Consultantshios l

Consultant to Pan American Health Organization /World Health Organi-zation. Prepared work program for monitoring and reduction of pollution in the coastal zones for the Secretaria de Recursos l

I Hidraulicos, Mexico. (1975).

Consultant to Pan American Health Organization /World Health Organi-zation. Presented lectures on industrial waste treatment at the University of Mexico, Mexico City, for a special short course.

(1976).

Publications Engineering reports and papers in Journals of the American Water Resources Association, American Society of Civil Engineers, and International Association on Water Pollution Research (refer to separate list for publications).

l ATTACHMENT II CALCULATIONS OF TOTAL CHLORINE RESIDUALS ALLENS CREEK NUCLEAR GENERATING STATION l

SASIS:

Assume that TRC residual decays as a first order reaction. The selected rate is based on the data cited by Hergott, Jenkins, and Thomas (JWPCF, _50, 2590) for Contra Costa plant ir. California - rate used will be an average of day and night decay rates.

l l ASSUMPTIONS:

(1) The TRC decay follows a unit step response of the following form:

k

. x

= "

s(x,t) e where:

s = concentration of TRC, u = average velocity in lake, l x = oistance measured from point of exit of canal to lake, I

I W = mass discharge of TRC, Q = flow rate through condensors and,

-1 k = 0.835 hr (2) The lake channel is rectangular in cross-section with an average depth of 8 ft. (lake at lowest level), and a width of 2,300 feet in the area immediately downstream from the canal. This shape continues for a distance of about 4,500 feet until the bend in the diversion dike occurs.

(3) There is no dispersion and plug flow conditions occur in the lake.

(4) There is no decay of TRC in the discharge canal.

(5) TRC spreads across the entire cross-section of the lake at point l

of discharge (actual plume would be more like the temperature plume but this assumption is within reasonable limits).

CALCULATIONS:

(1) Cross-sectional area of lake at point of discharge 2,300(8) = 18,400 ft 2 (2) Condensor flow and TRC mass loading 3 6 l Q = 1.940 ft /sec =

6.984 x 10 ft3/hr I

= 239.6 lb TRC/15 min (2.2 mg/1)

W = 958.57 lb/hr W/Q = 2.2 (3) Velocity u = 6.984 x 10 6 = 380 ft/hr 18,400 (4) Concentrations of TRC under various conditions I

(a) at t = 15 min, x = 95 ft (front of plume) s(95,0.25) = 2.2 e-0.00220(95) = 1.78 mg/l s(0,0.25) = 2.2 (rear of plume)

(b) at t = 1 hr front of plume x = 380 ft s(380,1) = 0.95 mg/l rear of plume x = 285 ft s(285,1) = 1.17 mg/l l (c) at t = 3 hr front of plume x = 1,140 ft s(1,140,3) = 0.179 mg/l rear of plume x = 1,045 ft s(1,045,3)

= 0.22 mg/l (d) at t = 6 hr front of plume x = 2,280 ft s(2,280,6) = 0.015 mg/l rear of plume x = 2,190 ft s(2,190,6) = 0.018 mg/l 1 l

I (e) at t = 6.45 hr front of plume x = 2,451 ft l

l s(2,451,6.45) = 0.01 mg/l rear of plume x = 2,356 ft s(2,356,6.45) = 0.012 mg/l l

l l

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ATTACHMENT III ACCURACY OF ANALYTICAL TESTS FOR CHLORINE RESIDUAL An accurate analysis of the persistence and effect of chlorination on water quality and the aquatic biota requires an underst-Hng of the analytical methods available for the measurement of free available chlorine and TRC in cooling waters. Basic knowledge of the precision and accuracy of the tests for chlorine residual is important to the understanding of the impacts of chlorine on water quality and the aquatic biota since the chlorine concentrations of interest in the Allens Creek Cooling lake are at extremely low levels.

Standard Methods for the Analysis of Water and Wastewater (Ref. III-1) discusses in depth nine analytical techniques for measuring chlorine residuals. This reference describes interlaboratory studies of the precision and accuracy of these nine methods. The detailed discussion and comparison of the precision and accuracy of the various tests for chlorine residual will not be repeated here, but the most important aspects with respect to the effects of chlorine on the Allens Creek cooling lake are as follows:

(1) the orthotolidine (OT) procedures which have been the most widely used for determining chlorine residual have been

__ ._ - ._ __ . . _ . _ ~ _ _ _ _ , - _ , - _ . .

deleted as standard methods because of poor accuracy and precision and'a high overall (average) total error in comparison i

with the other available methods; (2) the methyl orange procedure has also been deleted because of poor precision (3 ) the iodometric methods are only suitable for measuring chlorine concentrations greater than one mg/l and are inaccurate at lower concentrations or in the presence of interferences; (4) the amperometric titration method is the standard of comparison for the determination of free or combined chlorine (TRC) and is affected little by common oxidizing agents, temperature variations, turbidity, and color but is more difficult to perform than the colorimetric methods and requires greater operator skill to obtain maximum reliability; (5) the titrametric DPD is an acceptable procedure for determining free available chlorine and estimating free and combined chlorine fractions which are present together; (6) the stabilized neutral orthotolidine and the DPD colorometric methods are applicable only to the determination of free available chlorine and are not generally recommended for measuring combined residuals due to interferences; (7) the leuco-crystal-violet (LCV) method allows the determination of free available chlorine, total chlorine, and combined chlorine by difference. Like all of the other methods, however, there are interferences in the LCV procedure which

are particularly important at low concentrations due to various compounds which might be present in the water.

A recent study done for the Utility Water Act Group (UWAG) was designed to establish the precision and

accuracy of the amperometric titration method for the deter-mination of residual chlorine in power plant main condenser cooling waters (Ref. III-2). The amperometric titration procedures were chosen for careful evaluation because the forward titration procedure is approved by EPA and is widely used by the power industry, particularly for determining free residual chlorine. This comprehensive evaluation included testing of cooling water from four different types of sources

" clean" fresh water, " dirty" fresh water, brackish water, and sea water. Investigations were conducted at four power plants. Individual operators at each of the plants or chemists from the plant laboratories ran the tests. The results of this evaluation which are pertinent to the question of the persistence and effect of chlorine on the water quality of the Allens Creek cooling lake can be summarized as follows:

(1) Over the range of 0.0 to 0.2 mg/l TRC and free available chlorine (FAC) the average overall precision (standard deviation) of the method is 0.0275 mg/l for TRC and 0.333 mg/l for FAC.

(2) The amperometric titration method, over the range of 0.00 to 0.20 mg/l chlorine, has a single operator precision of 0.012 mg/l for both the free and total residuals.

l (3) The back amperometric titration method (ASTM D1253, Method C) does not work as specified in the official instructions.

The UWAG report succinctly presents the consequences of the observed precision and accuracy of the amperometric titration method which is identified in Standard Methods as one of the most acceptable of the chlorine residual analytical procedures. For example, any measured TRC concentration less than 0.071 mg/l is not distinguishable from zero at a 99 percent confidence level. Similarly, if the mean FAC concentration in the cooling water at the condenser outlet is 0.085 mg/1, then the results of the TRC analysis in the plant discharge would range from 0.014 mg/l to 0.156 mg/l simply as a result of the inherent variations in the analytical method.

The implication of the variability in the analytical procedures for measuring residual chlorine is twofold. ,

i First, measurements taken to determine compliance with a chlorine residual standard such as the EPA chemical effluent limitations guidelines could easily show violations of the l

1

l standard due to the inherent inaccuracy of the test if the standard is set at very low concentrations of residual chlorine such as the proposed 0.1 mg/l TRC specified by the NRC in the FS-FES. Secondly, the data on toxicity of FAC and TRC on aquatic biota must be scrutinized very carefully in terms of the analytical procedures used to define toxic concentrations. In sum, potential analytical inaccuracy raises serious questions about available toxicity data, particularly when it is compared with observed effects of chlorination of power plant cooling water on aquatic biota of cooling lakes.

References 1

III-l American Public Health Association, " Standard Methods for the Examination of Water and Wastewater," 14th edition, Washington, D.C., 1975.

III-2 The Utility Water Act Group, The Edison Electric Institute, and the National Rural Electric Coopera-tive Association, " Collaborative Test Results for Chlorine Analysis by Amperometric Titration," NUS Corporation, Pittsburgh, Pennsylvania, March 1979.

ATTACHMENT IV CALCULATION OF ALLENS CREEK LAKE NUTRIENT LOADINGS Inflow Concentration Loading (1) (mg/1) (kg/yr)

Nitrogen loading Inouts:

1. Allens Creek 2.54x1010 1.20 3.05x104

2. Brazos River 3.70x1010 1.02 4.42x104

3. Precipitation 2.05x1010 2.16 3.76x104 TOTAL 8.29x1010 1.35 1.12x105 Outouts:

1. Seenage 7.4x10s 1.35 9.99x102

2. Spillage 3.1 x1010 1.35 4.15x104

3. Controlled Releases 1.6x109 __

1.35 2.16x103 l TOTAL 3.33x1010 1.35 4.47x104 Accumulated Loading = 6.73x104 kg/yr 3.25 gm/m2/yr Total Leading = 1.12x105 5.4 gm/m2/yr Phoschorous Loading Inputs:

1. Allens Creek 2.54x1010 0.54 1.37x104

2. Brazos River 3.70x101 0 0.26 9.62x103

3. Precipitation 2.05x1010 0.04 7.23x102 TOTAL 8.29x1010 0.29 2.40x104 Outputs:

l 1. Seepage 7.4x108 0.29 2.15x102 l

2. Spillage 3.1x1010 0.29 8.99x103

3. Controlled Releases 1.5x109 0.29 4.64x102 TOTAL 3.33x1010 0.29 9.67x103 l Accumulated Loading = 1.43x104 kg/yr 0.69 gm/m2/yr Total Loading = 2.40x104 1.16 gm/m2/yr

ATTACHMENT V ESTIMATED NUTRIENT LOADINGS FROM THE TOWNS OF SEALY AND WALLIS l

Sealy Pooulation: Use 3200 - 3500 35~00 (1975) (1985)

Wallis Pooulation:

1108 - 1130 1150 (1975) (1985)

Phoschorous Loadings Sealy: .0008 (3500) = 2.8 lb/ day l = 1.27 kg/ day

= 463.5 kg/yr Wallis: .0008 (1150) = 0.92 lb/ day

= 0.417 kg/ day

= 152.31 kg/yr NH3 - Nitrogen Loading l Sealy: .012 (3500) = 42 lb/ day

= 6953.5 kg/yr Wallis: .012 (1150) = 13.8 lb/ day

= 2314.9 kg/yr Equations for N and P loadings obtained from: Water Quality Management Planning Methodology for Municioal Waste Treatment Needs Assessment for the Administrative Operations Division of the Texas Water Quality Board by Engineering Science, Inc. , Austin, Texas.

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A I N A T _

- A C

U -

- RN A '

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G I -

- TR S

E

- FO AL H *

- A A

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l

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_ L . UO he

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• m T I T n.

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T t

. f A T C

Y R

H I A l R D T TAN U

_ S 5MO MAS ejmi E

. , e l!-  ! l

gn0e nMh e P4g T

S E

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t aR CA F

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t i sp K E

g 1

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a

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N A I T A

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.- L L A A N U

D I T

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y.

R SO I -

C 5

1 RT 0 L EA A T N FI - /l T AR s O O e m T RL S 0a l S 7 8

0C O D t 1 E I F T 1 0 0 A =

1 T V l

H t C

I A

A .! * . .I R 0 T TAh St u S Eno E SAB

i l

ESTIMATED TOTAL RESIDUAL CllLORINE C0t4CENTRAT10llS - ACHGS - 3 il00RS g . 3 tt00RS AFTER START f OF Cil10RINAT10N ll i

,, , j runraus 5 "802 *-

AZOS v

( .!s 2

Attens Caste StelNNIAf ton SA5IM A

i f // stoim urArson sAllN "8

i -

m stAit rAns (gAv USE AAEA)

At1Taltite A4(A I "

• p -t I

o.i7s men

,1 m

>4 I :x:

gl$CHAAGE CANAL O ~

u m*f .

w. 8

==- uer-I

,. a A'

l i s

ESTlHATED TOTAL RESIDUAL CllLORINE CONCENTRATIONS - ACNGS - 61100RS 1

j t . 6 nouns Anta siant \

0F CHLORINATION mu-ur runt ME SIAil08

• b

)

20S N

~ $

E_ "

r j at M> tarts

• gggggggggAf ggg 3433g **g* 1141C rAAs f/

l i '-

' (DAT ggt AntA)

S(0fMENTAll0N SAilu "S'*

s St31Siciit AREA b

'O D

....o

. .. . . .a

.i "

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, .,c-cA9 w N

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5

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- f .$

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( F i"

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1 ' ,,

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_ 41, 1'

1 Ay 8

~

S R

U 61 $ -

/#0 0

l 5

l S

- 4 O E t

6 Z ig ta A (A

- H l F

p hE g

S !I G !A

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i C

A PAE g

s-g S 4 l 0 l 1 0 i A

I I

T &

n A l R

rG 4 ul _ -

- a T /

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tP kn A e.

g

,. i Au -

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l i

tr a

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g 0

3 .

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o A s A C

E o i

s 0

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H r il A e l

R O

r N

r n

T M

f t

l

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l t

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/ ~

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A

(/

4 L sN m m 0 A nI uR 08 l

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i 5C l

D f.i F E 6O T = 8 M

l t

i I

C f

A i 1 A el* . .I T A D TAN S S( U E ERO SAS m

ORIGINAL DRAWING FROM MATTICE AND ZlTIEL (REF. 8)

Sil0 WING DATA POINTS USED TO DERIVE T0XICITY TilRESil0LDS (REF. 9) i i . . . .. . . i i ii ii 10 i . i i s iir .. , i . . . ..

I iii.

5 5 -

l' 2 ,

. _. .  := .g.

e, n .

p ty " ** .

s i  ;. >

.: ..i e

. . .. . .,w. ... , , . e. ... ....w... . ,

O., = .. .

,m -

g:

.....e,. '..,

r- >

,.. .c y 0.05 2

'0/7 e

e ,,, **.

.o ',' #, ass! H 0.02 ~ ..

.... 9-

1. 8 '

2.,

0.01 _ o , ,.

.r, m

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.  %, :I:

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o o -

0.0 01 I I IIIIU I I I I!IN I I IIIIU I I I!IIU 10 2 S 10' 2 5 10' 2 O 8 s 80 2 5 IO 2 5 10' 2 8 10 8 2 -

DURATION OF EXPOSURE (ml.)

S Y

m w

! i

{ h HtH4 u o 8

n - )4 -

r 2

0, e  : _

s 3 s

s* ~~

s 3 og a ~

s t

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s s

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0 0 0 O O 0 0 0 0 0 0 ojm g 8m2 : 3 "

!  ;)  !

1 :t. [,i {1i ,:'i .

ALTERNATIVE FRESilVATER H0 DEL OF CitLORINE T0XICITY (REF. II) l PHOCEDURE U$EO 8N CONSIHUCI8NG ALTERNAleVE A400EL SitP 9.

Data Possess ebaat teampto to watuss assasunac ef satstam aanranomattmec i

100 0 - 1 i nat iose ca P a nnous - pro. sa conoes.s v ac anno nat asuname tese ntstonut star a.

att sche vatuas want cosevaasto 30 t(Inat sesmasseoto alvats ef TH4 e massavalan conavansione e actua escsk Inassanoto Comcaminateosas m atcset so sta Ins Cosevaassoas f aCioa mas pe navt o s mona t at ssamav a m asoassays nuncas pa rom ss o a cse amo g 3 snatuar,6o cosecastmaisons twata anrosuma cuaa rsons consrust.

_d 102 -

3 g #ce . Econcantaaraose gnnassem o"O*'C8"'#^'80" acte 8'

[ 1 g

I

. e so z

at we aai as asuaae4a ce naraos avaatasta enote 3na O 1 tattaaruna p 2 2 u 1 2 1 sitt i 3 2 innasesoa Imamucansio c contamina so soo watuas s aose assois s asso ouma rmene ensemus a sa vat ua s wa na

$ 1.C -

1 2 snam pto Isooes a canessuswes tos 5

3 o 4 3 ounationsmaso aoccdantnassoes as1na a ANf V AMas.asstaCfewatV.

g g s Le 4.

N 3 set aasnassaose aama eose 3na iNgBAa onIa saI was OatCuLasaoutspsG u O ouantions as seta amoartanotaer vansasta amo concamraarenas as vees 6

1 carasmism vansaats. 'O d 3 11 M

< 2 4 "'' ' "' * ' I'"***'"***0' ' ' ' ' H h 3 e

,- .1 -

1 E s'"tia"na ta'c"co"'sta"asin"a seo'ss as oa mews o e'no"a n

was Cat caft als o eose 6 acte na a Posse 5. We8 0 EMa+G a te I Esf pt sepeant E.

43

• 5 tantsatanat . m,.i won as a -anema nyaocon caasanaesuas, d .cas g 2 4 cassinatuisecasa am aisse s sJees i.e as c.sia ssma.4 s i.es ma ssoone s wa na g

9 7 paa sesnoadu ay sea ce s ano a su am na sasuas nas cat cut.aIa o e on set on s 2 2 & emasceawa as sot tons. na narnasanssu mV saus asuma rneuts ase vasa nata amatertssato U d,

g N

• g g

6

.assoscava cea nvao b

.01 -

too tI3 1

CD'*ctast mas soas

• masotis as saconoso us H ele sua tasaantuna eon 8 g

-46

\  %

scacats a vna assam os na pounts - a e. e e s. - a4 eg atr.n assoas ano . 3 e . - e s-tems x

.O 84UnaERALS PLOilED INDICA 1E NuuGER OF 08sf RVAT60N5 AT Tile CONCENIHAI8ON AND DUMAllON "" "I'""

.000

• I I -- I led naama ssanse t ems set gemes semee ss was se s mas neowau eT bha anos$

to 100 sa msateva arttaa s. team s srs caa s meessa ant ase ses seuuat mas teet Gas atts 1.000 10.000 aessativa vatuta aso incais a tua nueosoa A assass ma ssovat . 4 aa

$na taakt 4 5 DullAi40N OF EXPOSURE lMINUIE$)

f-Q) w

~

APPLICANT EXh1DIT NO. (LFT-9) 4 CHLORINATION PRACTICES AT TYPICAL TEXAS COOLING LAKES i

Load Surface Factor Chlorine Residual Lake Acres at Condenser Outlet Years (MW/ acre) Chlorination Frequency

' (mg/l) Chlorinated Bastrop* 906 0.73 1 hr/24 hour period 0.2 Braunig** 1,340 0.66 1 hr/ day, 3 daysl or 5 days 3/wk 0.5 - 1.0 j Calaveras** 3,550 0.92 1 hr/ day, 31 or 53 days /wk 0.5 - 1.0 Colorado City *** 1,612 0.51 l Once daily for 30 mini Twice daily for 30 min each2 0.54 3 times daily for 30 min each3 24 Alcoa*** 800 0.35 3-14 hrs /wk 0.5 - 1.04 Arl ing ton * *

• 2,200 19 0.24 3.5-10.5 hrs /wk Graham *** 0.54 16 2,500 0.24 3.5-10.5 hrs /wk 0.54 Nasworthy*** 1,600 0.05 14 2.3-8.0 hrs /wk 0.754 Oak Creek *** 2,300 9 0.03 2.3-8.0 hrs /wk i

Eagle 0.754 12 Moun ta i n* *

• 8,500 0.08 3.5-10.5 hrs /wk 0.504

Trinidad *** 750 0.59 20 3-14 hrs /wk 0.5 - 0.754 10 1

NOTE:

- winter, 2 - spring, 3 - summer, 4 - colorimetric.

• Data obtained from Lower Colorado River Authority.

• • Data obtained from City Public Service Board of San Antonio, Texas.

• • • Data obtained from Texas Electric Service Company.

-f l APPLICANT EX11IBIT NO. (LFT-10)

FISH PRODUCTIVITY IN SELECTED TEXAS COOLING LAKES Average Fish Load Factor Productivity Lake Name Game Fish Fishing Pressure (MW/ acre) (lb/ acre) (percent)

(manhours / acre)

Alcoa 0.35 796.88 66.4 34.98 Colorado City 0.51 3

141.90 45.2 -

Blundell 0.59 325.01 68.6 -

Braunig 0.66 657.27 77.9 -

Calaveras 0.92 720.93 50.8 -

North 0.88 178.6 29.3 -

Bastrop 0.73 149.42 63.4 29.68 ACNGS 0.23 -

i 4

. ~ _ _ . _ _ . _ . . __ -

APPLICANT EXHIBIT NO. (LFT-11)

PRECISION AND ACCURACY OF ANALYTICAL METHODS FOR SELECTED HEAVY METALS

• Low level Accuracy / Precision Level of Detection True Value Mean Metal ug/l ug/l Std. Deviation 1

ug/l ug/l Nickel 20 -

200 11 Zinc 5 7 22 26 Mercury 0.2 .

0.21 0.349 0.276 i Cadmium 2 1.4 3.3 5 Copper 10 7.5 9.7 6.1  !

Lead 50 25 31 22

• Reference 21.

e l

l l

. _ - _ __ .- - - - - . . - -------- - ---- -- - ' " ~ ~ ~ ' ~ ' ~~ ~

e NN 4 N N NN l

O N e

m. %N e  %%

% N ee u .= %e  % NN e  % eN O  %%

5

.N  %%

WN

== WW

=  %

h e OO O O OO ** *e en se en O 9 *e M O M io M. m.

m

.o. m. NN ist  %%

b  %% N e .%

=

.O=- O

% .e= =e=

e.  % e  %%

O  %%  %

- eN N .O =-O

.s .=. .s e . O >= C D= O e=

g 88 OO at O MC

, 3 e$ "O C "O t w ~

I M . .,,.

E 4 e .s=ah sha ==aD 2 W

i M

-J -

>= en M

e C. O.p .en.=

,E mwe

.=. E =

N Ge

.=

M D O.

g b) 4 .= 2 4

Ea. $

w a w - .=.

. e >= >= N s=

Q ne O. O N. O N. O -O w g e - - e= Oe e m w w w w 3

m E.a .=

u-N. N t

g <

> Og-2 O. % as N.

O

-5 2

• m 0 a 2 2 -

e m 4 SE 25 35 35

t w 5 a 2 C C "O 't  ?.=

O w

H e

O

- - .=

0%

- r l

>C a 4

> ohs ODA nm%

.O v 2

,a m v a a

g M Sy j w e b >

1. • w - - 3 M > O e= O >= C D=

aC =

80 mc so ao a U M 2 *C C 'O 'O e w o W O -

M b . - .= - .= $

% o C* aC w <

=

m%

mm u2 us ba OD OD N

v 2 N

v 2 aC < 3 E

m - - ,

. O e= 0N O n= O >= e at -O =O -O -O >

p g am w

>=

w

>= w >=

w w e=

w O

1 a W =

==

. - ==

> m O% O Of Og M ag" .ii ~T~f 2 2 72 b e

W *

."".= a C

C O O =*

C b ed O e e

== 3 On b '

• e N. 4 P W's .id ed 90 u Cg g

.u 4A % M

. ** e e ch.

6 en -

9-e C e

W as O *O

• C

-4 3 3 g .= De O b . .a =e. 3'N. u eC

> O

• • he

• • C M=

y W-e -

• ==== M en M O OO -

M +a T CL 9 4 e ee

- Os au de O bb 9M e ed O a.= b m.

en ** 93 ad M O ed Om

=5 am m.

W O v2 OK um i

-, -, , . - - - , . - , e -gs e ,- ,

-n--r-m- -

g- ~- -m-- , - - ev-- --- --m,-

AIPLICANT EXHIBIT NO. (LFT-13)

ESTIMATED MEDIAN CONCENTRATIONS OF HEAVY METALS' IN INFLOWS TO ALLENS CREEK RESERVOIR Brazos River ncentr ion gj Allens Creek Constituent 3-Month Pumping Concentration 6-Month Pumping (ag/1)

Nickel 0 0 0.5 Zinc 10 10 18 Mercury 0.15

~

0.10 0.5 Cadmium 0 0 0.5 Copper 3.0 3.0 8 Lead 1 1 1 HEAVY METALS FROM ACNGS OPERATIONS Metals from Metals from Groundwater Supply Boiler Cleaning Constituent (kg/ year) (kg/ year)

Nickel 7.6 l 0.1 Copper 1.5 0.1 Lead 7.6 -

1 Mercury 0.03 -

! Cadmium 1.5 -

Ifnc 35.7 -

~~'

_ _ _ - - . -- -- - - ---- - ----- ' - -~-~~~~~ ~ '~~ ~ ~~ '

o APPLICANT 1;XHIBI'r HO. .

(LFT-14)

ESTIMATED HEAVY METALS LOADING ON ALLENS CREEK COOLING LAKE 3-Month Pumping Mode 6-Month Pumping Mode Total Accumulated Concen-Loading Loading ** Total Accumulated Constituent tra t ion **

• Loading Concen-(kg/ year) (kg/ year) Loading ** tra t ion * * *

(99/1) (kg/ year) (kg/ year) (99/1)

Nickel 20.3 12.1 0.15 20.3 12.1 Zinc 0.15 74 6.9 447 5.6 746.9 447 Mercury 5.6 13.5 8.1 0.1 12.2 7.3 0.09 Cadmium 26.9 i 16.1 0.2 26.9 16.1 Copper 0.2 268.2 160.5 2.0 280.9 168.1 Lead 2.1 58.4 34.9 0.4 44.2 26.4 _

0.3

• Basis:

- Richmond USGS Station Records for the period 9/10/73 to 6/6/78. . 20) andMedianfrom concentr is taken from the ER supplement (Ref. 3). Avsrage projected inflow to the lake

• • Calculated by assuming the concentration in the sOther sources of heavy metals are concentration of metals in all inflow during the year. pillage from the lake is equal to the mean

• • • Assuming a volume of water in the lake of approximately 65,000 acre-feet.

t 9

k APPLICANT EXlilBIT NO. _ (LPT-15)

COMPARIS0N OF NUTRIENT LOADINGS ON THE PROPOSED COOLING LAKE WITil SELECTED EXISTING LAKES Lake Phosphorous 1.oading Nitrogen Loading Hean Chlorophyll-A (g/m/yr) 2 (9/m/yr) 2 Bastrop*

Total 0.27 3.3 12.392 Accunnlated 0.24 2.5 Braunig**

Total 4.17 2.98 22.762 Colorado City

• Total 0.21 4.0 12.675 Accumulated <0.01 1.4 Sangchris t Total 0.45 28.8 19.292 Accumulated 0.16 14.1 Calaveras*

Total 0.76 4.00 22.500 Accumulated 0.74 3.70 ti ACNGS Total 1.16 5.40 N/A Accumulated 0.69 3.25

• Data obtained from National Eutrophication Survey Reports for these lakes unless otherwise noted. (References 26,27,28,29)

• • Data obtained from Journal of the Environmental Engineering Division, Proceedings of the American Society of Civil Engineers, Voi! Td3, Oct.1977, p. 913. (Reference 29 )

IData obtained from Annual Report for Fiscal Year 1976t Lake Sangchris Project, by lilinois Natural History Survey, Urbana, Illinois Feb.1977. (Reference 28) ttCalculated values

.. e I

APPLICANT EXHIBIT NO. (LFT-16)

COMPARISON OF PEAX TEMPERATURES IN DISCHARGE CANALS 0F SELECTED TEXAS POWER PLANTS Peak Temperature in Loading Factor Discharge Canal Cooling Lake (MW/ acre) ('C) Reference Lake Colorado City 0.51 44.5 31 North Lake 0.88 42.2 31 Lake Bastrop 0.73 36.8 31 l

ACNGS (Predicted) 0.23 43 -

l l

I C

- .-. - . . . - . . . . - - . . - . - - - . . . . . . . _ . . - - . . . - . . _ -