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(2) Dams or spillways, which we also do not have on the river below this plant;

(3) Wave action, which we do have, but only in the summer. Depending upon amount of open water in the winter, icing will cut down the lake surface; and

(4) Living organisms within the water which, in themselves, are very delicate, susceptible to temperature change, and can be killed. This drastically reduces the river's oxygen-recovery power.

Sewage plants along the river discharge their treated sewage into the St. Croix and other tributary rivers. The closest sewage treatment plant to the proposed generating plant is Stillwater. Heating of this partially treated sewage can cause many problems. Examples of these problems include the following:

Heating drastically increases bacterial action. Bacterial action is the prime decomposer of sewage which accounts for streams purifying themselves, provided the pollution level is not high. During this increased bacterial action, large demands are made on the oxygen within the streams and, at sometimes, to a point possibly using all the available

oxygen. There are numerous accounts, other than on the St. Croix as yet, where this heat has depleted the oxygen and mass fish kill has resulted. The clean bacteria, which does the work of decomposing the sewage, is very sensitive to heat changes. Heat can also kill these bacteria if the temperature change is too severe and then the sewage would not decompose at all; it would then pass on downstream unabated; and the stream would not purify itself.

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The river presumably would be partially ice free for a considerable distance downstream-approximately 3 miles or so—and, as stated by Mr. Hill of the Northern States water pollution, it would be clear possibly down to the Hudson Bridge. Warm water tends to remain on the top of the pool of water thus tending to render the mixing inefficient. This ice-free area would then affect the ice fishing, ice sailing, and the auto racing Now, some would presume that this increase in temperature during the winter would be beneficial, but we have to consider the foods upon which fish feed. Some eggs of a food chain called Daphnia have to be chilled or frozen before they hatch. Some of another food chain, called diatoms, abound only at temperatures below 50° F. If the river temperatures are affected enough, these fish foods may not be available. Yes, there are other foods, but can we risk the loss of these? Gentlemen, we cannot answer this question; we need biological studies by fisheries experts for this.

As water temperatures rise, aquatic organisms require more dissolved oxygen, yet temperature is the most important single factor affecting the solubility of oxygen.

We are not just concerned with the present changes, we are also concerned with what will happen in the future. We do not want to see the growth of the valley stagnated because we have used up all the resources of the river. Our residential and recreational population, as I have previously stated, has grown by leaps and bounds. All of the towns along the river have sewage treatment plants. These plants are presently doing the job of reducing the sewage to a point where the river is acceptable for all the uses we have described. But none of these sewage plants have complete treatment, so they must rely on the bacteria and oxygen in the river to completely purify this sewage.

When all studies on the river water's characteristics are completed, we may find that the biological oxygen demand is as high as it can presently be. We must, therefore, make every effort to require every water user to keep or return the water in as good a state as it was when taken from the river. At least, all technological ability must be used to insure that river quality will not be jeopardized.

There are many pollutant elements we cannot control, or do we eren know their source. In the St. Croix Valley we have an unusual situation where a certain amount of the drainage area contributing to the river is wooded. Rainfall water partially decays the fallen leaves and grasses, and then carries certain minute portions of decayed matter into the stream, creating an oxygen demand for further decay. Naturally, we do not wish to reduce the wooded area, so we live with nature's oxygen demand.

The counties abutting the river are heavily farmed, and, as such, fertilized. A certain portion of these fertilizers find their way to the stream, causing some effects on plant growth and many other yet un

With this area becoming a "suburbia," we are subject to some uncontrollable erosion which results in silt in the stream. Lake St. Croix is quite large and can, perhaps, stand a substantial amount of silting

known effects.

before it gets filled, but this is not the problem as much as the effect on plants, micro-organisms, and fish spawn which can be trapped or destroyed on the bottom of the river.

Many beneficial pesticides are now being used to great advantage to the farmer and homeowners, and must continue to be used, but a certain portion of these have found their way into streams, having harmful effects on fish and aquatic plants.

The St. Croix River is used very extensively by boats, as we all know, and this will continue and increase in the future. Although both the States of Minnesota and Wisconsin now have boat toilet laws, there will still be some uncontrollable pollution added to the waters from this source.

I reiterate that we must extend a herculean effort to preserve what water quality we now have with the realization that with "progress" comes some uncontrollable pollution; but, if we overuse our natural resources, we will destroy those resources and pay much too much for the march of progress.

We now come to the control of this resource by legal means. As such, no written standards of water quality have been set for the St. Croix River, nor have any hearings been set to search out people's desires and needs as guide in establishing standards.

We have been told that there is not time to establish standards pravious to consideration of this plant, the proposed Allan S. King steamelectric generating plant.

If we had Federal standards, talked of as provided in S. 619, then we would have guidelines to protect our resources. I am convinced that no equitable evaluation of powerplant effects on this valley can be made without such standards, even if they do require consider able study.

To the best of our knowledge, there are only a few scattered water test results available and a short, 2-week study made recently by the Department of Health, Education, and Welfare. I don't believe these are sufficient to make a proper assessment of our present situation, much less project the future effects of this proposed plant.

There are those who would object to evaluation of the future of our natural resources by the Federal Government, and, as stated previously, there are many, many groups who would like to use the Government, the Federal Government, to be the "big bad wolf" in this situation so they could make the determination, so they would thus be influenced by local pressure, lobbys, and other efforts and could make a judgment more equitable to all concerned than any other governmental unit.

So we submit, Mr. Chairman, that we are in favor of S. 619, at least in its provisions to provide Federal standards which would not duplicate necessarily the State standards but supplement if the State standards were not available. [Applause.]

Senator NELSON. Thank you very much.
Senator Metcalf, did you have any questions?
Senator METCALF. No.
Senator Nelson. Thank you.

(The full text of Mr. Mertes follows:)

PREPARED STATEMENT OF FRANCIS T. MERTES, PE., ON STREAMFLOW AND THE

NEED FOR STANDARDS

Mr. Chairman, members of the committee, I hope our testimony here today, which was preceded by many months of study and opinion seeking can be of some value in pointing the need for a strong Federal water pollution preventative act as proposed in Senate bill 619 and authored by Senator Muskie.

The subject resource for these hearings, the St. Croix River and abutting valley have been described very aptly by Mr. Dunn. I would like to add more detail to some of the aspects of usage and a presumption as to why these usages occur.

Many persons have used the St. Croix Valley for residential purposes for many years. The trend has more recently become intestified to a point where the St. Croix Valley might be called a valley of commuters-from work to a beautiful clean valley. The river is the focal point. These people have located their homes here, as I have, so we can view the river and its valley, relieve worldly tensions and enjoy the river and valley for fishing, boating, swimming, and hunt. ing. All of these residents have established a claim on its cleanliness. It would be folly for anyone to say that most of these residents would have located here regardless of the cleanliness.

Boaters by the thousands swarm to the river on weekends and many take advantage of this resource during the week. They come here because the river is clean, cool, and of quality acceptable to health standards. These people lay claim to their portion of the river. The rapidly growing marina industry which serves and adds to the economic structure of our valley also have their claim to a continuing clean, recreational river.

Many species of fish abound the river due to its cool temperature, lack of pollution, and adequate oxygen supply. Commercial and recreational fishermen alike derive income and pleasure from these fish. They also have claim to their part of this resource.

Then what of the many people who neither fish nor own boats but who derive great pleasure, relief, and a feeling of general satisfaction from just driving to and through the parks and roads adjacent to the river? They, too, have justifiable claim to recreational use of the valley. And what would the valley be without pure water?

We must also consider the thousands of YMCA youngsters who use the camp 3 miles south of Hudson. In addition to excellent swimming and canoeing, the valley provides them with many nature trails for hiking and camping. They have used these resources for many years and they have a right to continue to do so.

And what of the St. Croix Valley Rod & Gun Club who derive their major income from a large ice-fishing contest every year? A sizable portion of these funds are used to develop and foster good hunting and fishing habits in our youth. Both of these groups, to, lay claim to a portion of the river.

What of the Hudson Boosters who sponsor auto racing on the river's ice each winter? Their income from this annual event is used to support little league baseball during the summer. Their right to continue this program should be protected.

Many more groups could be listed. Each day, more and more citizen organizations, conservation groups, and various communities lay claim to their share of this resource. For too long we have been unaware that it needed active protection but now we face an impending desire by the few to take what is not rightfully theirs alone.

I speak not entirely of the power company, but, also, of those proponents of extensive valley industrialization at the expense of dissipating a public resource for their own profit without due recourse to proper democratic or corporate practice.

In a corporation, as we know, all of the owners of their representatives must agree to sell before ownership can transfer. We submit that the resources of this valley are also public property so all who share in these resources should also have a voice in its impending sale.

We are obliged to preserve the recreational aspects of this river, not only for the present but also for future generations. In addition to its recreational

values, we must also consider the industrial potential of the St. Croix Valley. Sound long-range planning dictates that we do not abandon our clean, cool water to one industry who would spoil it and jeopardize our present favorable position to future industries that could locate here without destroying the recreational values of our river.

The problems we face in this valley have been explained in a general way so I will turn to the specifics of heat pollution.

First, I would stress the fact that the amount of heat pollution is dependent upon the flow for heat dilution. As General Wilson, Chief of Engineers, U.S. Army Corps of Engineers, has said, “Dilution is not the solution to pollution."

The riverflow data we have used for our calculations has been collected from flow records published by the U.S. Geological Survey. We have added the recorded flow of the St. Croix at Taylors, Minn., to the Apple River at Somerset, Wis., to arrive at an estimated flow at the proposed powerplant site, so we feel this method is quite accurate.

Lowest flow at the plant site was 80 cubic feet per second in 1910. The average flow of the river is 4,328 cubic feet per second. According to the Northern States fact sheet, and their permit request to the Minnesota Water Pollution Control Commission, the plant will need 660 cubic feet per second, or 300,000 gallons per minute. This represents 825 percent, or more than eight times, the low flow. I would also stress the fact that this is 15.3 percent of the total average flow.

Before going on, I would like to emphasize the fact that the technology of thermal transfer or heat exchange in rivers is not an exact science. It is an approximate science. It is not hard to delineate the problem but the magnitude is more difficult to ascertain. The point is that we have a potential problem. In law, the rule is innocent until proven guilty but, when health hazards are concerned, we should reverse the rule to read "Guilty until proven innocent."

Now let's consider some of the facts concerning the amount of riverflow the proposed plant will ultimately use:

The data presented by NSP states an anticipated rise of 10° to 17° of the water passing through the plant for cooling. If the riverflow equals the plant needs, the whole river will be heated approximately 15°. If the riverflows are less than plant needs, recirculation will raise the temperature in excess of 15°. If, for example, the water temperature was 70° F., as it is many times during our summers, and the plant needs dictated recirculation four times, this could mean that the water temperature could reach 100° F. in the discharge area if the proper distribution did not take place or the transfer within the pool did not result rapidly.

As an example of flows, I have tabulated in the form of a bar graph the lowest average daily flow for the years 1910–50 and, of these low days, plant needs exceeded the lowest daily flow 18 of these years. If, according to NSP's announced plans, a second plant is built, this low-flow day would have been exceeded in 37 of the 40 years in this record.

The other chart I display is a typical low-flow year plotted by riverflow any day. It can be easily seen that plant needs exceeded the flow provided by the river many times during this year.

At this time, I would like to point out the proposed plant orientation with relation to the surrounding topography. The Stillwater sewage plant, like most sewage plants, does not give complete treatment and it is located just upstream from the plant on the same side of Lake St. Croix. The proposed location of the power plant is approximately 1,000 feet above the north end of what is called Andersen's Bay, which also will be used as a discharge channel to the river. Along the bay is the village of Bayport which also has its beach at the mouth of the bay.

This illustration shows possible mixing with river water that would occur in the river before intake to the plant would occur. This means that the sewage effluent would not be effectively mixed with the river or purified before it is pulled into the plant and heated 17° F. If we assume a temperature of 83° F. for the river water, which it could easily be, add 17° F. to it and we have a resultant outflow of 100° F. water from the plant, mixed with sewage. It has been stated, by NSP officials, that about a 10-hour retention would result in the bay with about 3° F. loss of heat here. This means that the water would be discharged into the river at 97° F. and, then, would depend completely on mixing for residual river temperature.

Water, which has a large amount of oxygen within it, dissolved or free, has a maximum capability to carry or hold oxygen based on the temperature of the water. If water is heated, some oxygen will be driven off. The carrying capacity reduces quite sharply. This, then, means that, as the plant heats

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