ILLINOIS POLLUTION CONTROL BOARD

December

2,

1971

MISSISSIPPI THERMAL STANDARDS

)

R70-16

Supplemental Statement

(by Mr. Dumelle)

While

I agree with

the standard adopted

here. and with

the bulk

of the Board opinion

I am not certain that

the maximum temperatures

established

in the standard are correct.

These maximum temperatures

may have been set too low.

Dr.

Robert Morris of Iowa has

stated,

at a joint Federal—Iowa—

Illinois meeting in Chicago on November

12,

1971 that Iowa tempera-

ture monitoring stations have detected

a maximum 2°Frise in daily

temperatures on the Mississippi

River.

The hottest portion of this

daily cycle comes as would be expected in late afternoon according to

Dr. Morris.

The Alton data, received late

in the proceedings of this matter,

are the basis

for the revision now adopted.

But these are

8:00 a.m.

data and thus

on the ~coo1~

side.

It

is

thus possible that we may be

setting these temperature maxima

as much as 2°Ftoo low with conse-

quent great and unnecessary economic effects

to those who might

legitimately want to use the Mississippi River for cooling purposes.

However,

the only answer would be

to obtain better temperature

data

for

other

hours

of

the

day.

This

obviously

must

be

acquired

starting

now

since

it

does

not

now

exist.

I

would

hope

that

the

Federal

Environmental

Protection

Agency

through

its

monitoring

by

the

U.S.

~o1ogicai

Survey

would

begin

to

acquire

such

data.

When

such data are available

the Board should re—examine the maximum

temperatures

set

herein.

I

do

not

agree

with

the

portion

of

the opinion

(p.7)

which

accepts

the

diffuser

as

a

safe

way

in

which

to

discharge

heated

water

to the ~ississippi

River,

See my dissent on Quad-Cities Nuclear

Plant

(PCB

71-20)

of November

15, 1971

(p.3-4).

Justbecause

there

are interstices

of

cool water in the cross section of

the stream

does

not mean that fish will

in fact use the plume as

a zone of

passage,

What is lacking in the record and what

is still needed are

actual experiments with diffusers and

fish

to prove that passage

will occur.

I am also disturbed

by

the failure of the Board

to obtain and

examine

the

transcript

of

the

Iowa

Water

Pollution

Control

Commission

meeting

of

November

2,

1971

after

which

Iowa

rejected

the

permit

app1i~

3— 189

---

cation by Commonwealth Edison Company and Iowa-Illinois Electric

Company for

a diffuser.

The temperature

standards here enacted

can stand without an opinion either way on the merits of

a

jet

diffuser which are more properly the subject of the permit proceeding.

I feel that it was not necessary in these temperature standards

proceedings

to endorse the diffuser as

a satisfactory method of heat

dissipation.

Our rules state:

the Hearing Officer may receive material, re-

levant evidence which would be relied upon by

a

reasonably prudent person in the conduct of

serious affairs which is reasonably reliable and

reasonably necessary

to resolution of the issue

for

which it is offered.. .(Procedural Rules Sec.

320(a))

Our sister state,

Iowa,

relied on some evidence which we do not

now have that was evidently highly persuasive to

them.

We ought to

have delayed

a favorable diffuser opinion in this proceeding until

we had received and looked at the

Iowa evidence,

/

/1

/

/ / Jacob

D. Dumefle

//

3

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190