Letter to Elkhorn Slough Docents and Friends by Carolyn Nielson, Co-Chair, Voices of the Wetlands


March 8, 2001


The State Water Resources Control Board (SWRCB) has decided to review the Moss Landing Power Plant (MLPP) Expansion Permit, specifically the once through water cooling system. Duke Energy and other interested agencies and individuals have until March 14th to respond to the issue discussed in the three petitions that were filed. After that, the SWRCB will analyze the responses and decide whether the Duke permit should be subject to a public hearing and a decision by the State Board. I think that this is unlikely because this conflict is such a sensitive issue and also because Duke has invested millions of dollars in getting to this point in the process. No agency will want to make an administrative decision and so I think that ultimately, we are headed for a lawsuit. Sierra Club continues to watch closely, but it is necessary that we exhaust all possible administrative relief before Sierra Club, or any other group can file a lawsuit. The other two petitioners and I are MIGHTILY ENCOURAGED that the Water Board concluded that out petitions had enough merit to justify a review.


Yesterday I attended a Water Board meeting in Sacramento. Duke received certification for their thermal discharge plan. I spoke briefly, protesting that it seemed backwards to certify discharges when the water cooling intakes were under review. They received the certification, nonetheless. One good result is the news coverage we received. Hopefully, it will reawaken interest in the power plant cooling system debate. I think most people thought that the expansion project was a Done Deal, not realizing that Duke has not received certification for their project because of the petitions that were filed objecting to the MLPP once through water cooling system.

Dr. David Mayor, the consultant in charge of the resource assessment studies, stated in his testimony at the committee hearing on July 17 that, 50% of the water in the Slough, by volume, gets passed through the intake system of the power plant. The new units will use about 10% of the water in the slough by volume. 1,200,000,000 gallons of water per day is difficult for me to comprehend, so I did some figuring, trying to find a way to make the proposed water intake volumes more meaningful. This is what I came up with:

Visualize a rectangular pond, the size of a football field. Put in 33 inches of water, about as deep as a pair of trousers is long. This is how much water The Power Plant uses every minute ! Then multiply that by 60 and you can see how much they use every hour. The football field would have to be dug 140 feet deep (deep enough to contain a 14 story building) to hold the water that Duke uses in an hour. Now think of 24 football field size ponds, each 140 feet deep. The water it would take to fill all 24 football size ponds, each of them 140 feet deep, is what Duke uses each day! Even worse that the quality of water used is the fact that it is super heated causing 100% mortality of all pelagic organisms contained in that volume of water. It's astounding !

If Duke is required to build a modern cooling system for the new Units, 1 and 2 the plant will require much less water. Instead of the 24 ponds, 140 feet deep, those 24 ponds would be 100 feet deep, a huge savings of water and organic life. In a single 24 hour day, the water saved would be enough to fill a 96 story building, the size of a football field. In other words, a rectangular cube with the dimensions of 300 ft x 160 ft x 960 ft. Unfortunately, it seems there is is nothing that can be done to revoke the permit that PG&E had to entrail 870,000,000 gallons of water a day. The power plant, built in the 1950s, is an unexamined, pre CEQA artifact. It would never be permitted today, but we are stuck with it for now. All we can do is to try to prevent the plant from doing even more damage than it has already done, by requiring Duke to build a modern cooling system for the new units, instead of expanding the old once through water cooling system.

As to where all the water comes from that is used by the power plant, the answer is not definitive. It seems self evident that when the tide is coming in, the water used by the MLPP is coming from the Monterey Bay. And when the tide is going out, the water used by the MLPP is obtained from the Elkhorn Slough. Duke argues that since the intake pipes are in the harbor, a lot of the water is coming from the harbor. But there isn't that much water in the harbor. And besides, since water knows no geographical jurisdictions, that defense is not supportable. No dye studies or radioisotope studies were done to determine exactly the source of the water used by the MLPP. But, looking at a map, knowing about the tides, and common sense al indicate that the water used by the MLPP is Monterey Bay water at flood tide and Elkhorn Slough water at ebb tide.

The team that did the biological resource assessment studies for the expansion project identified and enumerated fish and crab larvae only. As all Elkhorn Slough Docents know from our plankton tow experience, there are many other organism in the estaurine waters in addition to fish and crab larvae. The impingement screens covering the intake pipes, is a mesh having 3/8 inch diameter openings, so obviously, lots of eggs and copepods and diatoms can slide through a screen like that, in addition to fish and crab larvae. Nevertheless, only fish and crab larvae were identified and counted, primarily because fish and crab have commercial value.

Thank you so much for your support and encouragement. I miss the Slough a lot, but until this conflict is concluded, I don't feel good about volunteering in the visitor's center anymore. I continue to be outraged that the Elkhorn Slough Foundation did not oppose expanded intakes of water into the power plant, because now, I feel as if we docents are working at cross purposes with the Elkhorn Slough Foundation. Instead of participating in meaningful conservation and stewardship, in partnership with the Elkhorn Slough Foundation, their collaboration with Duke, enabling Duke's expansion plans to proceed unchallenged, has changed the docent program into an adult daycare program. It's meaningless to beaver away pulling weeds and planting acorns to preserve estaurine habitat while at he same time Duke expands its operations, turning the estuary into an industrial wasteland, completely unopposed by the Elkhorn Slough Foundation. Since the Foundation is not likely to change, I'm afraid that I wont be able to come back as a docent. That doesn't change my commitment. It's just that the nature of my volunteer work is different now. I'm still dedicated to conservation and stewardship, like all of you. But now I go to meetings and speak and read and write a lot of stuff. There have been some real rewards in the last 5 months. I have learned a lot, even though there have been some scary situations and some exhausting challenges. Pretty soon now, the things that I can do will be done, and then, we hope that we'll be handling the responsibility over to the Sierra Club or some other organization to finish the job.

Again, thank you for your care, and your encouragement.
And please keep in touch.

Carolyn Nielson


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