March 8, 2001
GOOD NEWS !!
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.
HIP ! HIP ! HOORAY
!
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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