FINAL
ENVIRONMENTAL STATEMENT
RUSH ISLAND POWER PLANT - UNITS 1 & 2
UNION ELECTRIC COMPANY
BASIC DATA SUBMITTED BY UNION ELECTRIC COMPANY IN CONSULTATION WITH BECHTEL CORPORATION, WESTINGHOUSE ENVIRONMENTAL SYSTEMS, SMITH - SINGER METEOROLOGISTS, AND HARLAN BARTHOLOMEW AND ASSOCIATES
PREPARED BY
U. S. ARMY ENGINEER DISTRICT, ST. LOUIS, MISSOURI
24 NOVEMBER 1972 o / FINAL ENVIRONMENTAL STATEMENT
PROPOSED FOSSIL-FUEL POKER PLANT AT RUSH ISLAND JEFFERSON COUNTY, MISSOURI
Prepared By
U. S. ARMY ENGINEER DISTRICT, ST. LOUIS, MISSOURI
24 NOVEMBER 1972 PROPOSED FOSSIL-FUEL POWER PLANT RUSH ISLAND, JEFFERSON COUNTY, MISSOURI
( ) Draft (X) Final Environmental Statement
Responsible Office; U. S. Army Engineer District, St. Louis, Missouri
1. Nare of Action: (X) Administrative ( ) Legislative
2. Description of Action; Processing of Department of the Army permit under 33 USC 403 for construction of a fossil-fuel power plant and appurtenant structures in and along the Mississippi River.
3a. Environmental Impacts: Conversion of approximately 150 acres o f flood plain land to industrial use, loss of public access route, release of products o f combustion and waste heat to the environment, consumption of approximately 2.5 million tons of coal per year. .
b. Adverse Environmental E ffects: Increase in concentrations of sulfur dioxide, nitrogen oxides and particulate matter in the atmosphere, loss of some fish on plant Intake screens, loss of fish eggs and larvae carried through cooling system.
4. Alternatives: No project, purchasing power, alternate sites, alternate fuels, other cooling systems.
5. Comments Requested:
Region VII, EPA, Kansas City, Mo. Mo. Water Resources Board Dept, of Interior, Washington, D.C. Mo. Clean Water Commission Dept, of Health, Education & Welfare, Mo. Dept, of Conservation Washington, D.C. Mo. Dept, of Community A ffairs, Dept, of Housing & Urban Development Jefferson City, Mo. Kansas City, Mo. 111. Dept, o f Business & Economic Federal Highway Administration, Development, Springfield, 111. Kansas City, Mo. 111. Dept, of Conservation Dept, of Agriculture, Washington, D.C. 111. EPA, Springfield, 111. Dept, of Commerce, Washington, D.C. Coalition for the Environment, Office of Economic Opportunity, St. Louis, Mo. Kansas City, Mo. League of Women Voters, Dept, of Interior, Field Rep., St. Louis, Mo. Denver, Colorado East-West Gateway Coordinating US Fish & Wildlife Service, Twin Cities Council, St. Louis, Mo. Minnesota Jefferson County Environmental US Forest Service, Rolla, Mo. Committee UMRCC, Davenport, Iowa Second Coast Guard D istrict, St. Louis, Mo.
6. Draft Statement to CEQ 10 August 1972 Final Statement to CEQ 9 MAR W71 TAbLli OF CONTENTS
FINAL ENVIRONMENTAL STATEMENT
RUSH ISLAND POWER PLANT
Page
1. PROJECT DESCRIPTION ...... 1-1
1.1 General Description L oca tion ...... 1-1 Purpose...... 1 1 Determination of project necessity ...... 1-1 1.2 General System Description Existing and planned generating capacity ...... 1-2 Predicted demands ...... 1-3 System reserve capacity ...... 1-3 1.3 Project Physical Description Plant s i t e ...... 1-6 Plant generation p roce s s ...... 1-7 Physical interfaces with the environment ...... 1-7
2. ENVIRONMENTAL SETTING WITHOUT THE PROJECT ...... 2-1
2.1 The Rush Island Plant Site and Surrounding Area . . . 2-1 2.2 Local and Regional Setting of Project Site Land use trends and p la n n in g ...... 2-2 Hydrological ...... 2-5 Climatological ...... 2-6 Ambient air quality ...... 2-7 Inversions ...... 2-9 Historical features ...... 2-11 Archeological features ...... 2-13 Topography and geology ...... 2-14 Present level of economic development ...... 2-16 Social and cultural customs ...... 2-19 Population trends...... 2-22 Agricultural and industrial trends ...... 2-23 Transportation ...... 2-25 Public access to the Mississippi River ...... 2-28 Transmission line rights-of-way ...... 2-28 2.3 Ecological Setting of Project Site Animal life and v e g e t a t io n ...... 2-29 Aquatic setting ...... 2-51 2.4 Interrelation of Projects in Operation by Others . . 2-41 2.5 Future Environmental Setting in Absence o f Project . 2-41
i i Page
3. ENVIRONMENTAL IMPACT OF THE PROPOSED ACTION ...... 3-1
3.1 Air Quality Considerations ...... 3-1 3.2 Land Loss and Land Use ChangesAt or Near the Project S i t e ...... 3-4 3.3 Impact on Economic and Social Conditions ...... 3-4 3.4 Transportation...... 3-5 3.5 Impact of the Plant on W ild life ...... 3-8 3.6 Water Quality Consideration Thermal effects ...... 3-12 Biological effects ...... 3-14 Chemical parameters ...... 3-24 Summary...... 3-26 3.7 N o i s e ...... 3-27 3.8' Scenic and Aesthetic Impact ...... 3-28 3.9 Hydrological Impact ...... 3-29 3.10 Impact on Projects in Operation by O th ers ...... 3-29 3.11 Site Preparation and Landscaping...... 3-30 3.12 Public Access to the Mississippi River ...... 3-30 3.13 Transmission Lines ...... 3-31
4. ADVERSE ENVIRONMENTAL EFFECTS MUCH CANNOT BE AVOIDED . . . 4-1
5. ALTERNATIVES TO THE PROPOSED ACTION ...... 5-1
5.1 Not Building the P la n t...... 5-1 5.2 Purchase Power...... 5-3 5.3 Alternate Means o f Generation Natural g a s ...... 5-4 Synthetic natural gas ...... 5-4 Fuel o i l ...... 5-4 Nuclear fueled u n it ...... 5-5 Combustion turbines ...... 5-5 Hydroelectric facility ...... 5-6 5.4 Alternate Sites ...... 5-6 5.5 Alternate Cooling Methods Cooling pond ...... 5-8 Spray c a n a ...... 5-8 Topping tower ...... 5-8 Closed cycle cooling tower ...... 5-9 Dry cooling tow e r ...... 5-10 5.6 Alternate Air Quality Controls ...... 5-10 5.7 Alternate Circulating Water Intake Arrangements . . . 5-10 Intake canal ...... 5-11 Offshore intake ...... 5-11 Fish s cr e e n s ...... 5-11
6. RELATIONSHIP BETWEEN LOCAL SHORT TERM USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY ...... 6-1
i i i Page
6.1 Cumulative and Long-Term e f f e c t s ...... 6.2 Short-Term Effects ......
7. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES WHICH WOULD BE INVOLVED IN THE PROPOSED ACTION SHOULD IT
BE IMPLEMENTED...... 7 l
8. COORDINATION WITH OTHERS...... 8' 1
8.1 Public Participation Prior to Draft Environmental Statement...... 8-1 8.2 Coordination with Government Agencies Prior to Draft Environmental Statement ...... 8_- Local l e v e l ...... 8~“ State l e v e ...... 8*'') Federal level ...... 8-3 8.3 Coordination with Citizen Groups Prior to Draft Environmental Statement ...... 8-4 8.4 Comment and Response on Draft Environmental Statemen ...... 8-3 FIGURES
Figure
1-1 Site Location - Rush Island Plant 1-2 Actual and Forecast Peak Demand - Union E lectric Company 1-3 Union E lectric Company - Peak Demands, Net Output, Load Factor, Losses and Sales - Years 1967 - 1976 1-4 Union E lectric Company - KWiI Sales - Years 1967 - 1976 1-5 Union E lectric Company - KWIi Sales - Years 1971 5 1972 1-6 Union E lectric Company - Number o f Customers - Years 1967 - 1976 1-7 Union E lectric Company - KlVil Output - Years 1907 - 1976 1-8 Capacity-Demand Relationships With 5 Without Rush Island Plant - Union E lectric Company 1-9 . Legal Description o f the Rush Island Plant Site 1-10 Aerial Photo, 12 September 1968 - Rush Island Plant Site and Surrounding Area 1-11 Site Plan - Rush Island Plant Unit 1-12 Plot Plan - Rush Island Plant Unit 1-13 Plant Arrangement - Rush Island Plant Unit 1-14 Rush Island Plant - Unit 1 5 2, Eastern Approach .'Iain Entrance View 1-15 Rush Island Circulating Water System 1-16 Proposed Intake and Discharge Structures 1-17 Proposed Intake Structure 1-18 Proposed Discharge Structures 1-19 Flue Gas System - Rush Island 1-20 Rush Island Coal Handling System 1-21 Aerial Photo - Rush Island Looking South, 16 Feb 72 1-22 Aerial Photo - Rush Island Looking East, 16 Feb 72 1-23 Aerial Photo - Rush Island Looking North, 16 Feb 72 1- 24Proposed Rush Island Unit No. 1 Schedule
2 - 1 Surrounding Counties of Rush Island Plant 2-2 P olitical Boundaries - Jefferson County 2-3 Rush Island Topographic Survey Map 2-4 City - County Remote Telemetry Stations 2-5 Wind Direction, All Hours, All V elocities, Ground Level and Stack Height Level 2-6 Historic Sites Location Map - Jefferson County 2-7 Location Map - Rush Island Plant 2-8 Population Trends - Rush Island Plant Site Vicinity 2-9 Mississippi River Water Quality Upstream and Downstream from the City of St. Louis 2-9-A Identification of Benthic Organisms, September and November 1971 2-9-6 Identification of Benthic Organisms, April 1972 2-9-C Holoplankton Data for Rush Island, November 1971
v Figure
2-9-D lioloplankton Data for Rush Island, November 1971, Water Samples 2-9-H lioloplankton Data for Rush Island, April 1972, Tow Samples 2-9-F lioloplankton Data for Rush Island, April 1972, Water Samples 2-9-G Chemical and Associated Physical Data for Water Samples Collected September 1971 - Rush Island Site 2-9-II Chemical and Physical and Associated Data for Water Samples Collected November 1971 - Rush Island Site 2-9-1 Chemical and Associated Physical Data for Water Samples Collected April 1972 - Rush Island Site 2-10 Ambient Air Quality Dustfall 2-11 .Ambient Air Quality - Sulfur Dioxide Concentration 2 - 12 .Ambient Air Quality - Suspended Particulates
3- 1 Mississippi River Flow Data - Rush Island 3-2 Mean Daily Flow Duration Curve for Mississippi River at St. Louis 3-3-A Mississippi River Temperature at Meramec Plant, J anuary 3-3-B Mississippi River Temperature at Meramec Plant, February 3-3-C Mississippi River Temperature at Meramec Plant, March 3-3-U Mississippi River Temperature at Meramec Plant, April 3-3-K Mississippi River Temperature at Meramec Plant, May 3-3-F Mississippi River Temperature at Meramec Plant, June 3-3-G Mississippi River Temperature at Meramec Plant, July 3-3-H Mississippi River Temperature at Meramec Plant, Augus t 3-3-1 Mississippi River Temperature at Meramec Plant, September 3-3-J Mississippi River Temperature at Meramec rian t, October 3-3-K Mississippi River Temperature at Meramec Plant, November 3-3-L Mississippi River Temperature at Meramec Plant, December 3-4-A Subsurface Isotherms near Single Point Discharge - Rush Island Units 152, May 3-4-15 Surface Isotherms - May - Single Point Discharge 3-4-C Vertical Isotherms - Rush Island Units 1 5 2 May 3-5-A Subsurface Isotherms near Single Point Discharge - Rush Island Units - July 3-5-B Surface Isotherms - July - Single Point Discharge 3-5-C Vertical Isotherms - Rush Island Units 1 5 2 - July 3-6-A Subsurface Isotherms near Single Point Discharge - Rush Island Units 1 5 2 - August 5-6-B Surface Isotherms - August - Single Point Discharge 3-6-C Vertical Isotherms - Rush Island Units 1 r, 2 - August 3-7 evaluation o f Water Temperature Standards and Water Temperatures Resulting from Rush Island Plant Operation 3-8 Schematic Illustrating Biological Sampling Stations for the Fall and Spring Study at the Sioux Power Plant 3-9 Benthic Organisms Identified in Samples Collected at the Sioux Site, August 1971
vi Figure
3-10 Benthic Organisms Identified in Samples Collected at the Sioux Plant, October 1970 at Station 2 3-11 Benthic Organisms Identified in Samples Collected at the Sioux Plant, October 1970 at Station 3 3-12 Data for Iloloplankton Analyses for Station 2 at the Sioux Plant, October 1970 3-13 Data for Holoplankton Analyses for Station 3 at the Sioux Plant, October 1970 3-14 Data for Holoplankton Analyses for Station 2 at the Sioux Plant, November 1970 3-15 Data for Holoplankton Analyses for Station 3 at the Sioux Plant, November 1970 3-16 Effluent Guidelines and Standards - Missouri and Illinois 3-17 Hourly Maximum Concentration of Sulfur Dioxide and Nitrogen Oxides - Rush Island Units 1 5 2 3-18 Estimated Concentrations o f SO2 along Radial to North of Plant, due to Respective Source Alone 3-19 Forecast o f High-Pollution-Potential Days in the United States
5-1 Rush Island and 29 Alternate Sites
Vll Appendix
A Union E lectric Company Letter to United States Environmental Protection Agency, and Response
li Rush Island Air Quality Study
C Thermal Discharge Criteria
D Mathematic Model for Predicting Thermal Discharge Dispersion
E Correspondence 1-1
SECTION 1
PROJECT DESCRIPTION
1.1 General Description
Union Electric Company (hereinafter referred to as the "company" or "utility") plans to construct two electrical generating units, each nominally rated at 600,000 kw, for initial service in 1975 and 1976. These units w ill produce e le ctricity through combustion of coal. The units are expected to provide service for a period of 35 to 40 years. The company proposes to withdraw and discharge water from the Mississippi River to operate a once through cooling system for its condensers.
Location
The site chosen for the power plant is located in the State of Missouri, along the west bank o f the Mississippi River, in the southeast corner of Jefferson County. As shown in Fig. 1-1, the location selected is about 8.5 miles southeast of Crystal City, Missouri, and about 35 miles south of the City of St. Louis. The tract of land is comprised of approximately 500 acres of Mississippi River flood plain in an area known as Rush Island. The company has chosen the name "Rush Island Plant" to identify the proposed electrical generating fa c ility .
Purpose
The company is responsible for meeting the ele ctric power demands of consumers within its franchised service area. Figure 1-2 records the growth of this demand from 1956 to the present, and indicates the expected increase in demand for power through the year 1976. The company's planned addition of two 600-megawatt units is required to meet this increased demand for electric power. The installed generating capacity of the company must exceed the predicted demand to provide the degree of service reliability expected by the con sumers and by the regulatory agencies. This margin of reserve gen erating capacity allows units to be removed from service for periodic maintenance, provides a back-up for unexpected system problems, and alleviates the effect of deviations from the company's forecasted demand growth. Because of transmission interconnections with other electric utilities, the company is generally able to provide ex pected service-reliability with a minimum of reserve generating capacity.
Determination of project necessity
The planning and addition of generation facilities is accompanied by continuous studies of area ele ctric demand and growth. The forecasting techniques employed utilize statistical analyses along with computer-developed models defining service area power needs. Forecasting total electric demand involves estimates of base load growth plus a component attributable to local temperature and weather conditions. The base portion of the electrical power demand is projected using area population trends, historical demand records and business activity as reflected in change o f Cross National Pro duct. Consideration is also given to specific factors that in fluence this demand such as loss or gain of large industrial customers or possible new applications o f electric power. Tbo temperature- sensitive portion of the electric service demand utilizes service area weather patterns and the potential for additional air condi tioning load as principal input. Combining the base and weather- sensitive portions of the expected demand with an allowance for uncertainties has proved to be an effective forecasting method. Demand figures developed by these techniques are presented in sub section 1.2 which follows.
1.2 General System Description existing and planned generating capacity
The Company's net generating capability as o f 1 January 1972 totals 4600 MW; individual plant contributions to this total are as follows:
Labadie ...... 1100 MW S io u x ...... 952 Meramec ...... 882 Venice No. 2 ...... 486 Cahokia ...... 301 Ashley ...... 70 Venice No. 1 ...... 43 Venice Combustion Turbine . 26 Osage ♦ keokuk Hydro . . . 330 Taum Sauk Pumped Storage . 350
To bolster this generating capacity during periods of peak demand, the Company maintains contracts with other utilities so that power may be imported through transmission interconnections. Similar agreements also allow Union lilectric to assist adjoining utilities in time of need. ■>
1-3
The Company has two additional 580 MW generating units under con struction at Labadie Plant. These units are scheduled for comple tion in 1972 and 1973. Prior to the subject additions at the Rush Island Plant in 1975 and 1976, the Company plans to in sta ll a A3 MW combustion turbine in St. Louis County in 1973 and 150 MW of combustion turbine capacity in 1974. The location of this latter turbine has not yet been determined. This existing '.nd planned capacity, with the inclusion of contract agreements for j.jwer exchanges between connected utilities, is outlined in the following tabulation:
Capacity Source Capacity, MW 1972 1973 1974 1975 1976
Existing UE system 4600 5180 5803 5953 6553
UE planned additions (including Rush Inland) 580 623 150 600 600
Electric Energy Incorporated* 450 450 400 400 400
Unreserved purchases: O O f-i — —
Associated E lectric Co-op 130 1 i 1 Public Service of Oklahoma 125 —
Unreserved sales: Northern States Power Co. (-245) ---- Iowa Power and Light (-200) Iowa Southern U tilities (-100)
Adjusted total capacity 5640 6253 6353 6853 7553
* Electric Energy Incorporated operates the Joppa generating plant located near Paducah, Kentucky. Union E lectric is part-owner of this plant. **
** Negative numbers indicate firm capacity sales contracts with other u tilitie s that reduce available capacity.
Predicted demands for electric service
Based on the techniques described in subsection 1.1, the Company forecasts a peak electrica l demand of 5910 MW in 1975 and 6280 MW in 1976. Figures 1-3 through 1-7 treat h istorical and predicted demands in detail, giving statistics of peak demand, kilowatt-hour output and number of customers, and categorizing sales according to the type of consumer. Makeup of the overall peak demand expected during the 1972-76 period is illustrated in the following tabulation: 1-4
Demand Allocation Demand , MW 1972 1973 1974 1975 1976
UE expected peak * 4810 5170 5540 5910 6280
Electric Energy Incorporated 94 94 94 94 94
Reserved sales: Columbia, Mo. 12 12 16 — — Hannibal, Mo. 14 16 18 20 22
Reserved purchases: Associated E lectric Co-op (-18)** (-20) (-22) (-24) (-27) American E lectric Power Corp. (-114) (-114) — — — Tennessee Valley Authority —— (-130) (-130) (-130) (-130)
Adjusted total demand 4798 5028 5516“ 5870 6239
* This is forecast data from Figure 1-2.
** Negative numbers indicate firm capacity purchase contracts with other utilities which reduce effective demand.
Union Electric's forecast of percentage increase in demand over the 1972-76 period as compared with that of other nearby u tilitie s and with the predicted national growth rate, tabulated below, show that the Company's forecast of peak demand growth rate is comparable with rates o f other nearby mid-western u tilitie s and slightly less than the predicted national average.
FORECAST OF PEAK DEMAND GROWTH RATE, PERCENT (Based on expected normal severities of extreme hot weather)**
Union Illin o is Commonwealth Year E lectric Power Edison Nation*
1972 13.5** 9.5 9.7 11.3 1973 7.5 8.6 8.0 9.3 1974 7.2 8.4 8.0 8.3 1975 6.7 8.5 7.8 8.1 1976 6.3 8.6 7.8 7.9
Average 8.5 8.7 8.2 9.0 Over Period
* From the 50th Semi-Annual E lectric Power Survey October 1971 Edison E lectric Institute
** Because of unusually mild weather in 1971, this increase is greater than what would normally be expected. 1-5
System reserve capacity
Reserve capacity is defined as the excess of actual power generating capacity over the total demand of the consumers within the service area. Reserve capacity allows the Company to remove generating equipment from service for periodic maintenance, provides back-up for unexpected system problems, and mitigates the e ffect of uncer tainty in predicted electric power requirements. The amount of reserve capacity maintained by the Company is variable because equipment additions provide step increases in generating capacity, while actual demand growth follows a continuous curve. A margin of 15 to 18 percent is considered a minimum value to provide the degree of reliability expected by the regulatory agencies. Inter connections with other u tilitie s allows the reserve capacity to be kept at a minimum. It has been estimated that a reserve capa city of 40 to 50 percent would be necessary, to maintain the same degree of reliability without transmission interconnections.
The Company's current policy of 15-18 percent reserve capacity is supported by study results of the Mid-America Interpool Network (MAIN) Task Force on Load Forecasting and Reserve Requirements. An October 1971 Edison E lectric Institute survey reveals that the total electric utility industry reserve capacity will be approxi mately 21 percent through the year 1976. The Federal Power Com mission has suggested that reserve capacity be maintained at 25 percent. These figures indicate that reserve margins maintained and planned by the Company are not excessive.
The ratio of the adjusted total capacity to the adjusted peak demand as developed in the preceding paragraphs indicates the percentage of reserve capacity available to the Union Electric system. Accept ing the accuracy of forecasted demands, and assuming that construction plans and power contractual obligations are met, the Company's re serve capacity with and without the addition of Rush Island Plant w ill be as follows :
With Rush Island Units Without Rush Island Units
Adjusted Peak Adjus ted Reserve Adjusted Reserve Year Demand,MW Capacity,MW Capacity Capacity ,!tW Capacity MW % MW /o 1972 4798 5640 842 17.5 5640 842 17.5 1973 5028 6253 1225 24.4 6253 1225 24.4 1974 5516 6353 837 15.2 6353 837 15.2 1975 5870 6853 983 16.7 6253 383 6.5 1976 6239 7553 1214 21.1 6253 14 0.2
This information is depicted graphically in Figure 1-8. 1-6
If additional generating units are not operational in 1975 and 1976 and the low reserve capacities of 6.5% and 0.2% are realized, an unscheduled outage of any one of the Company's large generating units will severely jeopardize the ab ility to serve peak demands. Unless power could be imported from adjoining utilities, this situation would lead to inter ruption of electric service.
A reserve capacity of 200 MW is derived from units relegated to emer gency service because of air pollution restrictions. An additional 300 MW may soon be subject to restricted service because of pending regulations. Dependence on these units for serving peak demands w ill deter efforts to minimize air pollution.
l . 3 Project Physical Description
Plant site
Factors that governed selection of the Rush Island Plant site and alternates considered are covered in subsection 5.4. The site area consists of a half-mile-wide corridor of Mississippi River bottom land bounded on the east by the river and on the west by timber- covered bluffs. The legal description established for the property is Figure 1-9. The general area of the site and surrounding terri tory is shown in Figure 1-10. The preliminary site and plot plans are depicted in Figures 1-11 and 1-12.
Rail entry into the site will be provided by spurs from the St. Louis- San Francisco Railroad main line which parallels the west boundary of the property. Vehicle access from U. S. Highway 61 is gained using either Drury or Johnson Road, both of which intersect Big Hollow Road which in turn continues into the site. All of these connecting roads are maintained by Jefferson County. The Company will construct a two-lane concrete overpass on Big Hollow Road bridging the St. Louis-San Francisco Railroad right-of-way at the site entrance.
Areas of the Rush Island site occupied by the power plant plus cer tain critical equipment and structures will be protected against flooding of the Mississippi River. The area protected, defined in Figure 1-12, will be filled to an elevation of 410 feet above mean sea level (m .s.l.) using sand and clay dredged from the river and/or borrowed from the southern portion o f the tsite. F illing the plant area to elevation 410 m.s.l. affords two foot freeboard against the "200 year flood"—the hypothetical maximum flood that might occur once in 200 years. The 200-year flood as projected at the Rush Island site would reach elevation of 408 m .s.l.*
No flood of record has ever reached 400 m.s.l. at Rush Island. The tabulation below shows the elevations for Mississippi River floods of record at St. Louis and Rush Island. The elevations for the 1844 flood in parentheses are projected elevations. The actual elevation of 398 m. s .l. occurred before construction of the Mississippi River levee system and the Missouri River reservoirs. 1-7
St. Louis Elevation Rush Island Elevation Year (feet, mean sea level) (feet, mean sea level)
1844 421.2 (431.9) 398 (408) 1943 418.8 397 1944 418.9 397 1947 420.1 398 1951 420.1 398 1969 415.8 393
Plant generation process
Each of the proposed Rush Island Plant units will have an electrical generating capability of 600 MW, produced by a conventional, steam- driver turbine-generator. To produce 600 MW of electrica l power, 4,080,000 pounds of steam per hour at a pressure of 2400 pounds per square inch (psi) and a temperature of 1000 degrees Fahrenheit ( F) will be supplied to drive the turbine. The steam will be produced in a b oiler through combustion o f pulverized coal at a rate o f 260 tons per hour. After passing through the turbine, the spent steam w ill enter a heat exchanger and be condensed. This heat exchanger w ill be supplied with about 300,000 gallons o f river water per minute to carry away the waste heat of the spent steam. Water re sulting from this condensing process will subsequently be pumped back to the boiler and again be converted to steam. Each o f the 600-MW Rush Island units w ill operate independent of the other. The e le ctricity produced w ill be generated at 18,000 volts and immediately transformed to 345,000 volts for transmission through out the Company service area.
Physical i nterfaces with the environment
The process of electrical generation within the plant is dependent on an array of structures and external equipment which have im mediate contact with the environment. These major physical inter faces are described in succeeding paragraphs.
Powerhouse, service building and miscellaneous structures:
The turbine-generator, boiler and related auxiliary equipment will be housed in a steel-framed building inclosed with insulated metal siding. Foundations for the powerhouse w ill be reinforced concrete, supported on concrete friction pile driven to depths required for sustaining the expected loads. Roofs will consist of insulated metal decking finished with asphaltic material and gravel. A cross sectional view o f the plant is shown on Figure 1-13.
A separate, three-story service building will be erected north of the powerhouse. This structure w ill contain personnel o ffice s and service facilities. As depicted in Figure 1-14, the architectural treatment planned for the powerhouse and service building is de signed to minimize their visual impact on the surroundings. 1-8
A water treatment plant and auxiliary service center w ill be erected east of the powerhouse. These fa c ilitie s are planned so as to harmonize with the appearance o f the main structures.
Cooling water system:
Mississippi River water w ill be used as coolant for the plant con densers. A water intake structure w ill be located in the stream near the west bank of the river. This concrete structure will house pumps for circulating the water through the plant, plus a trash barrier and a revolving self-cleaning screen to remove debris from the water prior to its entry into the pumps. Water w ill be trans ported to the plant through a buried steel pipe of 114" diameter. After passing through the condensers and absorbing waste heat, the water w ill be returned to the river through a 114" diameter steel pipe to the seal well/weir structure and from the weir structure to the river through a 144" diameter steel pipe with a 132" diameter mass discharge exit. The discharge pipe will extend into the river at a point 100 feet downstream of the intake structure. Its single-port outlet w ill be located below the river surface, 40 feet west o f the channel centerline. The top o f the discharge pipe w ill be set at elevation 337 m .s .l., 19 feet below the low water level o f the river. During cold weather, a portion of the warm discharge water will be diverted to the intake structure through a 54" diameter pipe to prevent ice buildup on the equipment. A schematic diagram o f this system is included as Figure 1-15. Figures 1-16 through 1-18 show the location of the intake structure and provide additional details of the proposed cooling water system piping arrangement.
The water intake structure w ill contain two pumps for each of the Rush Island units having a combined capacity of 302,00U gallons per minute at Design Low Water (elevation 359', m .s .l.). With both generating units in service at full load, approximately 600,000 gallons of river water per minute w ill be circulated through the plant condensers. This water wj11 absorb about 140 btu o f waste heat per gallon, resulting in a water temperature rise o f approximately 20°F. The intake entrance w ill be sized so that the river water in let velocity at the trash barrier is held, to 0.5 foot per second. An analysis of the effects of warm water discharge in the Mississippi River is included in section 3 of this report.
The proposed Rush Island Plant cooling water intake structure will be located on a free-flowing section of the Mississippi River. In contrast to an intake located on an impoundment behind a dam, or one located on an auxiliary canal, river flow sweeping past an intake structure emplaced in the stream w ill minimize the number o f fish entering the outer portion of the structure. Furthermore, the structure w ill be designed with an intake velocity o f 0.5 foot per second. This low flow rate should permit fish to escape from the inlet area. 1-9
No chemical additives w ill be introduced into the cooling water as i t passes through the plant condensers and is returned to the river. If operational cleaning of condenser surface is required, it w ill be accomplished through mechanical means. Sponge rubber balls would be recirculated, or brushes with synthetic bristles would shuttle back and forth, through the condenser tubes.
Combustion gas system:
The combustion process in the boiler requires a controlled mixing of pulverized coal and air for efficient heat release. Over 2,000,000 pounds of air per hour will be forced into each boiler by means of two parallel 2000 horsepower fans which take suction from the atmosphere. Hot gas generated by the combustion process leaves the boiler and passes through a heat exchanger, giving up some of its heat to the air entering the b oiler for combustion. Leaving this air preheater, the gas enters an electrostatic pre cipitator which removes 99.5 percent of the entrained particulate matter (fly ash). After passing through two additional 4500 horse power fans arranged in pa ra llel, the gas enters a 700-foot high stack and is dispersed to the atmosphere with an upward emission velocity of 90 feet per second, about 60 miles per hour. A sche matic diagram of the combustion gas (or ,:flue gas") system is in cluded on Figure 1-19.
It should be noted that a single concrete stack w ill serve both Rush Island units. The stack shell will contain a separate in sulated steel duct for each unit. Aircraft warning lights w ill be installed according to Federal Aviation Agency regulations and the stack will be protected against lightning.
The arrangement of the combustion gas handling system w ill allow future addition of sulfur dioxide (SO2) removal equipment. At present, the Company believes that no commercially reliable sulfur dioxide removal system is available. Pending development of proven equipment, air quality standards w ill be satisfied by use of low sulfur coal.
Coal handling system:
Coal for the Rush Island Plant will be delivered by railroad via the bridge near Chester, I llin o is , from mines in the DeSoto, Illin o is , area approximately 110 miles southeast of the site. The train will follow a precise daily schedule in making deliveries from the mines to the plant.
Coal cars w ill be emptied by means of compressed air operated bottom dump gates. The coal will pass through the track rails into an underground hopper designed to receive 3000 to 4000 tons per hour. A water spray dust suppression system w ill be installed at this un loading hopper. Coal w ill be conveyed from the unloading hopper to a storage p ile which eventually w ill occupy about 16 acres, stacked to a height of 60 feet. This amount of storage will supply coal requirements of Rush Island units for about two months. Coal re covery (or reclaim) hoppers w ill be located beneath a portion of the storage area for automated transfer of fuel into the boilers. This active portion of the coal storage area w ill cover about one acre and w ill be fille d to a height o f 100 feet. The boom-type conveyor used to build the coal p ile w ill also be equipped with dust suppression water sprays. All coal conveyors will be covered and w ill be equipped with automatic water deluge systems for fire protection. The coal unloading, storage and reclaim system is shown diagrammatically in Figure 1-20.
Coal supplied to the Rush Island units will have a typical analysis as follows :
Constituent % of Weight Moisture 9.8 Carbon 57.5 Hydrogen 3.9 Nitrogen 1.2 Chlorine 0.1 Sulfur 1.0 Ash 18.7 Oxygen 7.3 Remainder 0.5
The plant w ill consume about 2.5 m illion tons of coal per year.
Delivery of coal to the Rush Island Plant by barge on the Mississippi River is not presently contemplated. However, the plant design will not preclude the addition of a barge receiving and unloading system in the future. I f such a system is in stalled, its design would pre vent coal spillage into the river.
The quantity of low sulfur (1%) coal for the Rush Island Plant is limited. It is expected that the sulfur content would begin to in crease after ten years of operation and may reach approximately 2.6% in twenty years. As the sulfur content increases the coal analysis indicates a decrease in ash content. No information is available at this time concerning the analysis of coal for the Rush Island Plant beyond the fir s t twenty years of operation.
The coal w ill be mined in a manner that conforms to a ll applicable Illinois State regulations. These regulations include a plan for reclamation of the strip mine area that must be approved by the State.
I f the increased sulfur content of the coal results in substandard ambient air quality and a commercially available sulfur dioxide removal system is available, Union E lectric would in sta ll such equipment. At the present time, work is being done by Union Electric and others to develop a commercially acceptable sulfur dioxide removal system, and the Rush Island Plant is being designed to include space for installati of such equipment. 1-11
Some of the chemical processes for sulfur dioxide renoval presently known but not commercially develop will result in a substantial increase in solid waste. If such a system was installed at the Rush Island Plant, it will be necessary to implement one or all of the actions outlined below in order to provide adequate ash disposal methods.
Ash collection and disposition:
The typical coal to be burned in the Rush Island Plant boilers will contain about 18.7% ash. When operating at full load, ash will accumulate in each unit at a rate of about 50 tons per hour. 80% of this ash is entrained in the combustion gas and w ill be collected in the electrosta tic precipitator. The remaining 20% — consisting of heavier ash particles — will remain in the boiler and be col lected in hoppers located below the furnace area.
The ash from coal used at Rush Island will have a typical analysis as follows :
Constituent % ot Weight
Silica (Si02) 52.2 Ferric Oxide (Fe203) 9.8 Alumina (AI2O3) 24.A Lime (CaO) 3.6 Magnesia (MgO) 0.8 Sulfur Trioxide (SO3) 2.1 Potassium Oxide (K02) 3.7 Sodium Oxide (Na20) 0.7 Undetermined 2.7
Both the flyash (collected in the precipitator) and the bottom ash (collected at the furnace bottom) w ill be piped to a common ash storage area by means of hydraulic jet pumps utilizing river water for transport. The planned ash storage area, located south of the plant as shown in Figure 1-12, is in reality a pond formed by ex cavation and/or dredging to an elevation of about 330 m.s.l. The area will be contained by an earth dike built to elevation 410 m.s.l. The pond w ill cover approximately 1A0 acres and have a capacity of about 8.8 m illion cubic yards of ash, a volume su fficien t to handle plant ash disposal needs for about ten years. After the in itia l ash pond is filled, other ponds will be developed on the cite, or the height of dikes around the original pond will be increased. Pond areas will not infringe on the 150 acres of site property intended to remain in a natural state.
There are two sp ecific items, however, that may bend to increase the in itia l l i f e of the ash pond beyond 10 years. F irst, Union Electric has sold substantial amounts < Tly and bottom ash from existing fa c ilitie s for use in the manufacture of cement and as an additive for concrete. This use is actively promoted and a market for the ash from □
1-12
Rush Island Is expected to develop. Second, as the li f e of the plant O increases, the load factor (percent of time in operation) decreases. That is, as newer generating stations are developed the older plants are not operated to fu ll capacity. This program is currently being carried on with the older plants in the metropolitan St. Louis area. Both of the items w ill decrease the need for ash disposal area on the job s ite .
The rate of ash disposal w ill be monitored by the company. I f the need for additional disposal area arises, there are at least three alter natives open for disposing of ash. Existing areas on the plant site to the north and west could be enclosed by dikes to elevation 410.0 feet, m.s.l. The initial ash pond dike could be raised to a higher elevation. Or the ash could be handled from the site to some other disposal area. There are, however, no plans for any of these alter natives at this time.
After leaving the transport pipe, ash w ill settle to the bottom of the pond and excess water will be returned to the river. This run off will be controlled by a stand pipe. Water returned to the river will be clear, containing a limited amount of dissolved solids, as described in section 3.
Recycling ash for use in the manufacture of cement and as an addi tive for concrete would reduce the amount of ash to be disposed of on the site . This use is being actively promoted by the Company.
Water treatment f a c i lit ie s :
Mississippi River water will be treated and purified in varying degrees for use as equipment cooling water, boiler water and potable (sanitary and drinking) water. Total maximum demand for these services w ill be under 5000 gallons per minute. The primary water treatment plant w ill be located east of the powerhouse. It w ill contain tanks and equipment for clarifying, softening and filtering raw water taken from the river. Waste material from the treatment fa cility w ill be piped to the ash pond.
Highly purified boiler water w ill be prepared from the effluent of the primary water treating plant by means of demineralizers. This equipment w ill remove dissolved mineral salts from the water by chemical action. Waste water and materials from the demineralizers will be essentially self-neutralized before being discharged to the ash pond.
Potable water will be prepared by chlorinating the effluent of the primary water treatment plant. This water w ill comply with a ll re quirements of the U. S. Public Health Service and the State of Missouri. 1-13
Fuel o il storage:
A 66,000-gallon tank will be erected for storage of No. 2 fuel oil. The tank w ill be surrounded by a concrete block wall capable of re taining the tank contents in the event of rupture. The fuel oil w ill be used to start the main plant b oilers, to fire the auxiliary boiler used for plant heating, and to operate a diesel-driven emergency electric generator. Oil will be delivered to the site by truck or rail.
Waste liquid effluents:
All roof drains and yard drains w ill be collected in a storm water drainage system and discharged into the Mississippi River. Where contamination of storm water is possible — at collection points near equipment, for example — drains w ill be directed to the ash pond.
An oil and grease separator will be installed on these lines before entering the ash pond if the separator is necessary for the effluent to comply with Federal or State regulations. This could take the form of an o il skimmer or some other device.
A combined primary and secondary sewage treatment system w ill be installed to serve the plant. The treatment fa cility w ill have a capacity of 20,000 gallons per day and w ill be in operation during the construction period. The system w ill be designed to meet the requirements of the Missouri Clean Water Commission. Wastes generated on site prior to installation of the sewage system w ill be hauled away for disposal.
Electrical transmission system:
The Rush Island Plant site is located near the southern perimeter of the Company's electrica l transmission grid surrounding the St. Louis metropolitan area. Compared to transmission requirements at alternate site locations, overhead line connections to the Rush Island area w ill be minimal.
Electric power will be generated at 18,000 volts and will be trans formed to 345,000 volts prior to entering the plant switchyard. Be cause of the distances to feasible points of connection to existing transmission systems and loads, the relative availability of trans mission technology, overhead transmission w ill be used.
Two 345 kv overhead transmission lines w ill connect the switchyard with existing Company electric distribution facilities at Tyson Substation, located in the northern part of Jefferson County, and at St. Francois Substation, located near the center of St. Francois County. A third transmission lin e (138 kv) w ill be routed to the plant switchyard from an existing 138 kv line located about six miles northwest o f the plant and this line w ill furnish firm start-up electrical power to the Rush Island units. 1-14
The Rush Island-St. Francois 345 kv line will run from the plant 15.5 miles southwest to the St. Francois Substation near Bonne Terre. The structures for the line w ill be of the wood "II"-frame type because this type of construction blends in well with wooded terrain and, since this line carries only a single circuit, this type of construction w ill f i t on a minimum width of right-of-way (150 fe e t). The average spacing of structures w ill be about 850 feet; the average height of structures w ill be about 85 feet; and the normal clearance under conductors will be 32 feet.
The Rush Island-Tyson 345 kv line w ill run from the plant 34 1/2 miles north-northwest to the Tyson Substation in Jefferson County, just south of Valley Park. The 138 kv transmission line w ill be on a join t right-of-way with a width of about 250 feet from the plant to a point (approximately six miles) where the right-of-way intersects an existing 138 kv transmission line. The remaining 28 1/2 miles of right-of-way will be 150 feet wide. In order to minimize the widths of rights-of-way noted above and the impact on the environment of these two transmission lin es, the 345 kv line will consist of double circuit steel structures with vertical configuration and the 138 kv line will consist of wood "ir'-frame type structures. 2-1
SIXTIOJ 2
Ej^rvrri^.TAL srjtiho urmouT tt;i: pi^ ihct
'flic Rush Island plant site is located in the southeast corner of Jefferson County, Missouri, in Plattin Township. The development of the Rush Island plant is in agreement with the General Land Use Plan 1985 which was part of The Comprehensive Hater and Sewer Plan for Jefferson County. " This plan shows the site is suited for in dustrial development.
Parts of three additional counties are also located within ten miles of the s ite . Jackson Township of Ste. Genevieve County, Missouri, lies to the south, Mitchie and Renault Precincts of Monroe County, Illinois, lie to the east: and Prairie du Rocher Precinct in Randolph County, Illin o is , lies to the southeast. The influence of the Rush Island plant on the Illin o is areas w ill be very limited because these areas are completely separated from the site by the Mississippi River and the river bottom flood plain delta which is approximately four miles wide in the vicin ity of the s ite . The nearest bridges are the Chester, I llin o is , Bridge located 3u miles to the south, and the Jefferson Barracks, Missouri, Bridge which is 32 miles to the north. Since there are no nearby bridges, these Illin o is areas w ill be b riefly considered in this statement.
2.1 The Rush Is_land Plant Site and Surrounding Area
The area surrounding the plant site consists o f a relatively un developed, sparsely populated region. A map showing the location of the power plant and those parts of Jefferson County within ten miles of the plant are shown on Figure 2-7. The Festus-Crystal City urban area is located to the northwest of the site, approxi mately 8 1/2 miles. The City of DeSoto is located 15 miles to the west. Significant growth and development is taking place in the Festus-Crystal City urban area, with considerable residential ex pansion to the west and north. The rugged terrain has precluded any development south of this area. Considerable commercial growth has taken place in the southern sector of this urban area, generally along U. S. 61-67. However, the growth of this area has not expanded or caused any significant growth in the surrounding area of the Rush Island plant site . The developments along U. S. 61, from Festus-Crystal City to the Isle de Bois Creek (the south Jefferson County line), is characterized by scattered rural resi dences. The area between U. S. 61 and U. S. 67 is very sparsely populated and is characterized by residences scattered along the county roads lacing this area. Similarly, residences are scattered along U. S. 67 from the Festus-Crystal City area to the south 2-2
Jefferson County lin e. Of the few scattered commercial uses, all are oriented to highway activities and a limited number o f farm service establishments. There are no industrial uses within this surrounding area other than several quarries. This area has not been affected by the extremely rapid urbanization of the northern part o f the county, nor by the growth and development o f the Festus- Crystal City urban area. Essentially, it has remained relatively unchanged during the past several decades. Growth has consisted primarily o f the development o f additional residences along the highways. The community o f Selma, located on U. S. 61 approximately two miles west of the Rush Island plant site, is the only community in the area.
The main track of the St. Louis-San Francisco Railway Company is located on the western edge o f the s ite , adjacent to the b lu ffs.
The topography of the surrounding area is best described as rugged terrain with rolling hills, traversed by small creeks and intermittent streams. The terrain becomes more rugged east o f U. S. 61 and 1-35 as the watercourses travel through the bluffs to the Mississippi River. The area between U. S. 61 and U. S. 67 is a large v a lley , drained by Plattin Creek, which runs north through Crystal City. The Mississippi River bluffs vary in elevation from 500 to 800 feet mean sea level (m .s.l.).
2.2 Local and Regional Setting of Project Site
Land use trends and planning
Significant changes in the land use pattern in Jefferson County have taken place under the impact of the growing St. Louis metropolitan area. Urban growth has formed sprawling groupings of buildings and people along the main thoroughfares which lead into the St. Louis area, particularly along Missouri Routes 21, 30, 141, and U. S. Route 61-67. Older, relatively small communities, such as High Ridge, House Springs, Arnold, Otto, Imperial, and Kimmswick began to grow and spread, and subdivisions sprang up sporadically, especially in the general area bounded on the north by the county boundary and on the south by county roads M, MM, and W. Seasonal dwellings, weekend retreats and resort subdivisions have developed along the Meramec River and around lakes. A comparatively dense population center has developed in the DeSoto area, sprawling along all of the secondary routes in the area. 2-3
Another cluster of urbanization is in the area between Barnhart- Sulphur Springs and Festus-Crystal City. Pittsburgh Plate Glass Company and St. Joe Minerals Corp. are the major industries in this area. Haphazard residential growth occurred, especially after 1960, in the h illy countryside west o f Pevely, north and south o f County Road Z. Lake Louise, for example, platted and promoted for a long time as a resort development, s t i ll has about 70 lots vacant out of a total o f approximately 75.
Throughout this area o f growth the random placement o f individual mobile homes and tra ile r courts, small commeicial establishments, industrial fa c ilit ie s , dumps and junkyards o f a ll sizes and abandoned automobiles occurred because o f the absence o f county zoning controls. A major problem o f Jefferson County is the mixture of incompatible land uses along U. S. Route 61-67 from the St. Louis County line to just south of Crystal City. Numerous businesses, residenc6s and small industries are clustered along this major thoroughfare, forming even larger clusters at almost every in ter section. New urban sprawl has begun along the recently completed Interstate 55. Hillsboro is developing into a more inportant busi ness center as the county seat, with Big River and Central Townships becoming new areas o f residential growth.
Of the 21,857 single-family residences surveyed in Jefferson County in 1967, approximately 9,300 were located north of County Road MM. The largest density was located along U. S. Route 61-67 from the north county line to the Imperial-Kimmswick area.
Fifty-four trailer courts with 944 trailers plus 671 individual mobile homes were counted, representing a total of 1,615 mobile homes. Thirty-six of the trailer courts were located in Rock Township with the balance scattered throughout the rest o f the county. Many in dividual trailers occupied lots in residential subdivisions. Nearly 5,400 seasonal dwellings were counted along the Meramec River, Big River, and around the many lakes in Valle Township.
New residential subdivisions have been laid out in the northern por tions of Jefferson County which have accessibility into St. Louis City and its employment centers. These subdivisions are scattered throughout the northern section and have varied in size from ten houses per subdivision to over 300. Most of these subdivisions were developed in the absence o f proper sewage and water systems, and it has been only in recent years that they have been added.
In 1967, a total o f 1,325 commercial establishments were scattered throughout Jefferson County, concentrated in areas o f high population density. Of this to ta l, 624 were engaged in "trade" and 701 were offering "services." Fifty-nine manufacturing establishments were 2-4
recorded in the 1967 land use survey, a ll being located in areas of nigh population densities, such as Herculaneum, Festus, Crystal City, DeScto and areas along U. S. Route 61-67.
Considerable commercial development has taken place in this area to support the population growth. These commercial developments have generally taken the form of strip commercial sections along the major highways and in the smaller communities. In the past ten years the Festus-Crystal City commercial area has expanded sign ificantly. A very minor amount of industrial development has occurred, and the basic employment is s t i l l provided in St. Louis and St. Louis County. Most of the older established industrial uses in Jefferson County are located in the Herculaneum-Festus-Crystal City area and in the DeSoto area. There is a very low level o f industrial development in Jefferson County in relation to the population growth.
Agricultural activities in Jefferson County have been primarily relegated to the limited number of fertile flood plains throughout the county. The topography of the county is rugged, characterized by narrow ridges and deep ravines, particularly in the northern portion. The southern half has a more rolling topography, with flatter crests and shallower valleys.
The General Land Use Plan 1985 for Jefferson County, Missouri, estimates that an excess of 28 square miles of land w ill be needed to provide living space for an estimated population increase of 140,000. While most existing communities in the county w ill share in this increase, this plan proposes that the vast bulk of addi tional population will be located in the northcentral and north eastern portions.
The Jefferson County General Land Use Plan divides residential development into two general density categories, urban residential having one to two dwellings per acre and suburban residential having one-half dwelling per acre. The urban residential area would be located primarily on a narrow strip of the eastern border along the Mississippi River and extend in a narrow strip along half of the northcentral border. Five other small areas are distributed through out the remainder of the county. The suburban residential area would occupy a large area extending from the northcentral part of the county to the southeast.
The General Land Use Plan estimates that approximately 1,300 acres of commercial land divided into many commercial centers throughout the county w ill be needed by 1985. Many of the existing commercial areas probably w ill expand and commercial services of a roadside nature w ill be encouraged to concentrate in planned commercial dis tricts . Another 1,500 acres of land are designed for industrial pur poses. Most of this needed land w ill have to be found along the 2-5
eastern traffic corridor of the county. This corridor offers the greatest potential for industry because of such assets as level available land and orientation to community centers, highways, ra il roads and the Mississippi River.
Approximately 96,000 acres of land in Jefferson County is designated for rural resource. Some of this undeveloped land has problems of water supply, severe topography, unsuitable soils, and poor orienta tion to facilities and employment. With such limitations, these reserve areas adapt well to watershed protection, extensive agricul tural, recreational and large residential acreage developments.
Despite the limited area available for such activity, the agricultural pursuits of Jefferson County have had the greatest influence upon the county's image in the past. The preservation o f such an important asset has been of great concern for some time and the plan encourages this land use by designating 130,000 acres as agricultural. The acreage with the greatest potential for exclusive agricultural use is designated on the basis of present land use, s o ils , topography and related agricultural studies.
The plan also depicts, in a general way, those areas of Jefferson County having the greatest potential to provide a balanced and diver sified recreation program. This is a reflection of studies conducted in the past, and further surveys w ill be necessary to determine the exact locations and number of necessary recreation activities to meet the demands. The major proposals for future recreational uses are based on the premise that a ll levels of Government should reserve both large and small areas as potential sites for park and recrea tional uses, and other open space uses. The nlan recognizes the proposed Lower Meramec River National Recreational Area. Pine Tore Reservoir and a proposed riverside easement, running adiacent to the bank line of the Mississippi River.
A land use plan has not been dove]once1 for Ste. Genevieve Count” , Missouri. However, topographic characteristics and terrain are similar to that found in the Southern portion of Jefferson County and the area is even more sparsely developed.
Hydrological
The Mississippi River at R-jsh Island, approximate mile 140.3, L'pner Mississippi River mile, has a total drainage area of 705.000 square miles. The Missouri -liver which enters the Mississippi at mile 195.0, comprises about 534.300 square miles of the total drainage area above Rush Island. Although flow frequency data are not avail able specifically for Rush Island, this information can he approxi mated from gage records at St. Louis (upstream drainage, area equal to 701,013 square m iles). 2-6
Average flow past St. Louis is about 175,000 c .f .s . (elevation 371 feet m .s.l. at Rush Island) based on 108 years o f record. Flow at flood stage is equal to approximately 500,000 c .f .s . The river dis charge exceeds this flow about 1.5% (5.5 days per year) of the time. This discharge would reach an elevation o f about 389 feet m .s.l. at Rush Island. Maximum and minimum discharges at St. Louis have been measured as 1,300,000 c .f .s . on 27 June 1844 and 18,000 c .f .s . on 21-23 December 1863, respectively. A recurrence of the 1844 flood would reach an elevation of about 408 feet m .s.l. at Rush Island, while the low flow elevation would equal about 356 feet m .s.l. (see page 1-6).
Climatolo g ical
The climatological information for St. Louis can also be equally applied to the Rush Island area. The proposed site is part of the same geographic area, and offers no unusual features that would affect the information on record at the St. Louis Weather Bureau.
Rush Island is approximately 55 miles below the confluence of the Missouri and Mississippi Rivers, and 140 miles above the confluence of the Ohio and Mississippi Rivers. It is very near the geographical center o f the United States. Thus, with a somewhat modified con tinental climate, it is in the enviable position of being able to enjoy the vicissitude of a four-season climate without the undue hardship o f prolonged periods o f extreme cold, extreme heat, or high humidity. To the south is the warm, moist air o f the Gulf o f Mexico, and to the north in Canada is a favored region o f cold air masses. The alternate invasion of St. Louis by air masses from these sources, and the con flict along the frontal zones where they come together, produce a variety o f weather conditions, none o f which are likely to persist to the point of monotony.
Winters are brisk and stimulating, seldom severe. Records, since 1871, show that temperatures drop to zero or below an average o f two to three days per year. Maximum temperatures remain as cold as 32° or lower less than 20 to 25 days in most years. The record low temperature recorded by the Weather Bureau was -14° on 19 January 1940, but the a ll time record low for St. Louis was a -23° back in 1864.
Snowfall has averaged less than 20 inches per winter season since 1930 and has varied from a mere 0.7 indies in 1931-32 to 55.2 inches in 1959-60. Snowfall of one inch or more is received between 5 to 10 days in most winters, but there have been seasons when less than an inch f e l l , as in 1931-32 and other years when there were 15 days or more with one inch or more snowfall. Snowfall o f an inch or more has occurred as late as 11-12 April, and as early as 5 November. It was at this early date, 5-6 November 1951, that the second heaviest snowfall of record occurred at the airport, with a fall of 10.3 indies. The greatest snowfall at the airport was 11.2 inches re ceived on 31 January 1958. The greatest snowfall of record at St. Louis was 20.4 inches and this occurred 30-31 Mardi 1890. The winter of 1911-12 had the greatest total snowfall of record with 67.6 inches. 2-7
The long-term record for St. Louis (since 1871) indicates that maximum temperatures of 90° or higher occur an average of 35 to 40 days per year. Extremely hot days o f 100° or more are expected on no more than 5 days per year. The highest temperature on record is 115° read at the airport on 14 July 1954. On the same day 112° was recorded at the city office location on top of the ten-story Federal Building.
The last temperature as low as 32° in the spring has occurred as early as 8 March, and as late as 10 May, while the first occurrence of a freezing temperature in the fa ll has been as early as 6 October, and as late as 27 November. There is an average o f approximately 190 days between the last freezing temperature in the spring and fir s t such temperature in the fa ll, but this can vary from 150 days to around 230 days. The average date of the last freeze in the spring, is 15 A pril, and the average date o f the fir s t freeze in the fall is 20 October.
Normal annual precipitation for the St. Louis area, based on the average for the period 1931-1960, is a l i t t l e over 35 inches, but 68.83 inches was recorded in 1858, and as lit t le as 20.59 inches in 1953. The three winter months are the driest, with an average total of about 6 inches of precipitation. The spring months of April to June are normally the wettest with normal total precipi tation of nearly 12 inches. From the middle of summer in July into the fa ll, it is not unusual to have extended periods of 1 to 2 weeks or more without appreciable rainfall.
Thunderstorms occur on the average between 40 to 50 per year. During any year there are usually a few o f these that can be cla ssi fied as severe storms with hail and damaging winds. During the entire period of record there have been only four tornadoes which produced extensive damage and loss of life in St. Louis: 27 May 1896, 29 September 1927, 10 February 1959, and 24 January 1967.
Amjbient air quality
The Rush Island plant site is located within Jefferson County and, therefore, is included in the St. Louis Metropolitan Air Pollution Control Region. Although the immediate area is sparsely populated, there are a few relatively major industrial operations in the area. A fertilizer plant is located about four miles north of the Rush Island plant site and a cement production plant is in operation about six miles north of the site : both are on the Missouri side of the Mississippi River. In addition, there is a smelting operation at Herculaneum, some 13 miles to the north.
Dustfall measurements taken in the general area o f the plant site are shown in Figure 2-10. In addition, data from a sampling station located at St. Louis University, in the heart of the St. Louis metropolitan area, are presented for comparison. 2-8
It is of interest to note that dustfall measurenents in Jefferson County do not d iffe r significantly from samples taken at St. Louis University, which is somewhat contrary to what one might exnect. However, dustfall measurements are highly sensitive to local ac tivities. It is reasonable to conclude that a major portion of the settlable particle matter cantured at these locations repre sents a background concentration generated, in part, by natural means.
Sulfur dioxide.concentrations in the immediate vicinity of the plant site have not been measured either by regulatory bodies or by Union E lectric Company. However, a great deal of sampling has been done in an area not too different in population density and location rela tive to the metropolitan area than that of the power plant site. These data would be somewhat representative of what one would expect to find at Rush Island. Figure 2-4 is a location map showing con tinuous ambient air monitoring stations maintained by Union E lectric Company, the City of St. Louis, and St. Louis County air quality control agencies. Tabulated in Figure 2-11 is monthly sulfur dioxide data obtained from Station No. 15 which is located west of the St. Louis metropolitan area, Station No. 22 which is located south of St. Louis near the Mississippi River at approximate river mile 162, and Station No. 12 which is located at Gray Summit, Missouri. Station No. 12 data are expected to be most representative of the Rush Island plant area. Although Station No. 22 has a major power station, the Meramec Plant, located nearby, the concentrations of sulfur dioxide do not vary greatly from that measured at Station No. 15 which is not located near a significant source of sulfur dioxide emission.
Based on what is known about concentrations of sulfur dioxide in the metropolitan region the background concentration of sulfur dioxide near the Rush Island plant site is expected to be 0.01 ppm.
Suspended particulate measurements at these stations are shown in Figure 2-12. Data in this tabulation should be quite representative of the suspended particulate burden in the ambient air in the vicinity of the Rush Island plant site. The data Indicate an in crease in suspended particulate concentration in 1971 over the pre vious year. In reviewing data published by the Missouri Air Con servation Commission, six out of seven sampling sites in St. Louis County showed increases in suspended particulate loading during the fir s t six months of 1971 over the corresponding six-month period in 1970, and seven out of eight stations in Springfield, Missouri, showed increases in particulate concentrations over a similar period. This indicates that an overall increase in natural background of suspended particulates occurred during that period. 2-9
Inve rsions
Inversion conditions of the atmosphere occur frequently in the St. Louis region and inversions can result in a buildun of pollutants in the lower atmosphere.
,\ major study was undertaken in the St. Louis metropolitan region in 1966 by the U. S. Department of Health, Education and Welfare, Division of Air Pollution, to better define the atmospheric regime in a major metropolitan area and to study the effects of urban pollutants. In the Phase II Project Report, Volume V - Meteorology and Topography, it is stated that:
"Frequency of temperature inversions is another useful clim atological parameter for describing atmospheric dilution. Jlolsher's data in Table 3 shows seasonal percent frequency of inversion at or below 500 feet above ground. The percent of total time during which inversions occur is highest in the fall; therefore, the time during which pollutants can mix freely into a deep layer is a minimum during the fa ll . . . “
Information referred to in the preceeding paragranh as 'Table 3' is presented be low:
PERCENT FREQUENCY OF INVERSION OCCURRENCE ...... ______
(Central Standard Time) Total3 Season 9p_.m. 9a.m. 6p .m. 6a.m. Time Maximum
Winter 53 38 27 52 31 61 Summer 54 4 1 67 31 62 Spring 84 5 5 78 35 86 Fall 80 24 20 66 43 85
percent total time.
^percent of dates on which at least one observation showed an inversion.
The high frequency of inversions occurring in this area are in the lower 500 feet of the atmosphere. These inversions can have a very pronounced e ffe ct on the buildup of pollutant concentrations from low level emissions. However, emissions from tall stacks penetrate these inversions and the inversion will often act to reduce the ground level concentration of emissions released from such sources.
The proposed Rush Island Plant stack w ill have a single shell con taining two separate inner flues. This stack design takes advantage of combining the heated mass of gases from both generating units to JL
2-10
increase the buoyancy of the plume which results in an increase in plume rise over that which could be obtained by using separate stacks for each unit. This should result in improved dispersion of stack effluent and minimize ground level concentration of pollutants. The plume from the Rush Island Plant stack will rise approximately 800 to 1,000 feet above the discharge point under unstable atmospheric conditions with moderate wind speeds and can rise much higher under light wind conditions. Therefore, the gas plume from the subject plant will be well above most inversions.
Inversions based at high levels in the atmosphere that could trap the plume do not occur with the frequency or duration in this region of the United States necessary to produce a significant pollution potential. This conclusion is based on the "Interstate Air Pollution Study" report published by the Department of Health, Education and Welfare,* which states that:
"Air pollution potential is defined as a set of weather conditions conducive to the accumulation of air pollutants in the atmosphere over a period of time. It is a condition that can be forecast with reasonable confidence when applied to large areas and a reasonable persistence. Miller and Niemeyer indicate that 2 high air pollution potential days occurred in St. Louis from August 1960 through July 1961. Their criteria for high air pollution potential are: (1) surface wind speeds less than 8 knots, (2) winds at no level below 500 mb**(about 18,000 feet) greater than 25 knots, (3) the existence of subsidence below 600 mb**(about 14,000 fe e t), and (4) persistence of these conditions for 36 hours or more over a minimum area equivalent to a 4-degree latitude-longitude square. Since July 1961, these criteria were met only for a 3-day period, November 30-December 2, 1962, and for 1 day in October 1964, when St. Louis was on the boundary of such an area on the 15th and 16th."
The study also states that:
"Interpolation from Korshover's work, indicates that St. Louis experienced nine cases when high pressure systems with very low wind speeds stagnated over the area for 4 or more consecutive days during the period 1936-1956. These cases resulted in 40 stagnation days, which occurred from April through October."
in te r s ta te Air Pollution Study, Phase II Project Report. Department of Health, Education and Welfare; U. S. Public Health Service; Division of Air Pollution, Technical Assistance Branch, Robert A. Taft Sanitary Engineering Center, Cincinnati, Ohio, dated May 1966.
**mb. m illibar, approximately one thousandth of an atmosphere, 1000 mb = 29.53 inches of mercury. 2-11
Figure 5-19 shows the areas o f the United States most subjected to high air pollution potential conditions. It can be seen that the St. Louis region lies in a sector having a probability o f high air pollution potential occurrence of from 0 to 10 days per year, which is very low as compared with other parts of the United States. Korshover's work as interpreted in the "Interstate Air Pollution Study1' report indicates a frequency for the St. Louis region o f two days per year.
There have been three occasions of high air pollution material in the St. Louis area since forecasting of such conditions have been under taken. The fir s t occurrence was in August 1909. The air pollution watch began at 11 a .n ., 25 August, and ended at 12 noon on 28 August. A review of the data taken from nine continuous air monitoring stations showed the maximum 24-hour average concentration of sulfur dioxide recorded at any station during the period was 0.08 PPM. The 24-hour average at that location the day prior to the stagnation period was 0.07 PPM and was 0.06 PPM the day following the termination o f the stagnation period. In summary, the data from the nine monitoring stations showed only normal concentrations of sulfur dioxide occurred during this high air pollution potential period.
Two succeeding high air pollution potential periods have occurred in the St. Louis area since 1969. One began at 12 noon on 17 August 1971 and ended at 9 a.n. on 29 August. The second began at 4 p.m. on 20 December 1971 and ended at 10 a.m. on 21 December. During both occurrences only normal concentrations of sulfur dioxide were re corded at the company's monitoring stations.
Historical features
The h istorical sites o f Jefferson County are important assets and reflect its history and cultural traditions. The 138 historical sites that have been identified include over 70 sites associated with im portant persons, events and activities: over 13 unique naturalistic and archeological sites: and over 50 sites of historic cultural value and buildings representative of a period as noted.in Figure 2-6.
John Hildebrand, a man o f French descent, is known as the firs t white settler in what now constitutes Jefferson County. In 1774, or possibly earlier, he settled on Saline Creek in the northeastern part o f the county and founded what was afterward called the Meranee settlement. The first town in the county, N'ew Hartford, was laid out in 1806 by Christian IVilt and John K. Honey. The exact location of the town is unknown, but is was on the Mississippi River, near the present location of Herculaneum. 2-12
Jefferson County attracted early settlers, and prior to them, tribes o f Indians and various wild animals, because o f its rich s o ils , mineral deposits, and its rivers and springs. In 1798, just before the close o f the Spanish period, a Connecticut Yankee by the name o f Moses Austin became so impressed with the richness o f the mineral deposits in the county that he obtained a Spanish grant of one square league o f land. He introduced improved mining and smelting methods and began operations, bringing workmen and equipment from Virginia. Permanent settlements at the mines grew rapidly, despite the constant threat o f Osage Indian raids.
On 8 December 1818, Jefferson County along with seven other counties was formed from parts o f St. Louis and Ste. Genevieve counties by an Act of the Territory." The county, named ’Jefferson" in honor o f the third President o f the United States and father o f tiie Louisiana Purchase, grew slowly during its early years. Herculaneum, named the county seat by the Act of the Territory, had a population of just 200 in 1S21. On 22 March 1819, the fir s t Circuit Court for the Northern Circuit o f Missouri Territory was held in Herculaneum with Nathaniel B. Tucker, presiding as Judge of the Northern Circuit.
Jefferson County has abundant buildings representing different periods and styles which arc of architectural interest. Kennet's Castle, located in tiie town o f Selma, was built in 1854 for the prominent Rennet family and patterned after North Italian Rennaissance county houses by St. Louis architect George J. Barnett. Although i t suffered the effects of Civil War battles, its original elegance has been re stored. More typical structures such as the Miner's Cabin from 1840 at Valle Mines, the Slave Cabin from 1S40, old general stores and taverns recreate the past. The variety of origins of tiie settlers is evidenced by homes such as Greystone Manor, an English Victorian home; Franzyn A. Hermann home, a German-style home; and by planta tion-styled homes such as Old Red Brick Plantation House, the old est existing brick home in the county.
Jefferson County is rich in naturalistic sites such as the natural land formation of Cliffdale Tunnels and limestone in La Barque Hills and Shelter Cave. Sulphur Springs, once believed to possess healing virtues, and Big Springs, at the site o f one o f the earliest h is torical settlements in the county, continue to attract as much in terest today as they have in the past.
There are no historic sites in the immediate vicinity of Rush Island plant site. The closest historic sites are identified as Funk House built in the 1870's and Sterling Bailey House, a covered log structure bu ilt in 1835, indicated as 46 and 47 on Figure 2-6. These h istoric 2-13
sites arc about two miles west o f the Rush Island plant site and are not along any road that normally could be used for access to and from the plant site. The National Register of Historic Places has been consulted, and no National Register properties will be affected by the proposed project. The State Liaison Officers for Historic Preservation in Missouri and Illinois were invited to comment on the project, and voiced no objections to the proposal as presented.
Along the southern end of Interstate 55, in the general vicinity of the Rush Island plant site but more than two miles away from the site are 11 historic sites in addition to two mentioned in the previous paragraph.
At the northern end, these include Rennet's Castle, an elegant Italian Rennaissance period home bu ilt in 1854; Selma Road, previously men tioned; Canepa House built in 1883; C liffdale Natural Tunnel; heaven House, bu ilt in 1844 o f rock and wood materials; McCreary House, built in 1835 o f white pine lumber; and Captain Kagener's Place, a covered log house bu ilt in 1839 by Captain Wagener, a p ilo t on one of the firs t Mississippi River steamboats. In the extreme southern area exist the remaining six h istorical sites. To the west o f 1-55 are the William Boyce Home, bu ilt in 1851; Carson House bu ilt in 1861; Bailey Cabin, possibly the oldest existing residential structure in Jefferson County, built in 1821. Brooks Place, the mansion o f the river captain James M. Brooks built in 1837 is located to the east o f 1-55 along with Funk House and Sterling Bailey House.
Archeological features
Several archeological features in Jefferson County record the areas history from over 20,000 years ago and its earliest settlements by Indian tribes. The remains o f mastodons, believed to have disap peared over 20,000 years ago, and over 1,000 prehistoric bones have been unearthed near Imperial. Many o f these remains were found among those o f the Indian culture described as Liarly Middle Mis sissippi (1,000 AD), suggesting the coexistence of man and mastodon. Petrographs, the graphic remains of Indian cultures, such as the l,0 60year old site o f the Great Stone Face, have been found through out the county; and the recent discovery of “Moder Mounds,' west of House Springs, are reconstructing the area's habitation by Osage, Shawnee and Cherokee tribes.
Prehistoric Indian villages and campsites o f these types are very common along the Mississippi River, especially on old river terraces. Many prehistoric sites occur on river islands, including some islands which today flood almost annually. 2-14
The Missouri State Historical Survey and Planning Office made no comment when informed of the permit application. It is therefore not certain whether or not there are archeological remains on the island or the nature o f their significance i f they do exist.
Topography and jjeolopy
The county lias varied Ozark topography with narrow valleys, steep hillsides and rolling uplands. Jefferson County contains an area of 667 square miles, or 426,880 acres. Of the 115 counties in Missouri, it is the fortieth in land size. The county is slightly on the large side compared to the otiier United States counties, whose median area is 620 square ’..dies. F ifty-five percent o f the 3,155 counties are smaller than Jefferson County in land area. The average land area of tiie 115 counties in the State o f Missouri is 606 square miles.
Generally the topography o f the County is rugged, especially in the northern half where very narrow ridges and deep ravines are common. The southern part of the county has a more rolling topography with fla tter crests and more shallow vallcvs. liven through the southern half is not as rugged, the major part of the county has a predominance o f stecn slones and the general surface is h illy . Rather than heinn a d e fic it to the county's development, however, these slopes can con tribute to the scenery and beauty o f all new development.
The highest elevation, 1,060 feet, is located in the south central section o f the county approximately one-half mile north of the St. Francois County boundary, north of Hart County Road, and two miles southwest of Valle Mines. The lowest elevation, 380 feet, is in the extreme southeastern section o f the county at the confluence o f the Isle du Hois Creek and the Mississippi River; this is the location of Rush Island.
The interior of the county has its own north-south continental divide which generally follows Missouri Highway 21. The waters in the eastern half of the county run easterly into the M ississippi. In the western h a lf, the streams flow north to the Big River, then into the Meran.ec. 'Ihe western half is part of the northeastern tip of the Ozark u p lift, having tyoical Ozark surface characteris tics. The eastern half of Jefferson County is a scries of east- west ridges and valleys which have a tendency to converge as they near the Mississippi. The five main streams which drain the eastern part of the county include Plattin. Joachim, Sandy, Glaizc, and Rocks Creeks. The highest ridge in the countv attains an elevation o f about 450 feet above the Mississippi River, and between two and three hundred feet above the general level of the neighboring water courses . a
2-15
The three rivers in Jefferson County are the Mississippi , Meramec, and Big Rivers. The Meramec River, forming most o f the northern boundary o f Jefferson County, and the southern boundary o f St. Louis County, meanders in an east-west direction. Its approximately one- mile wide flood plain is 'sometimes north and sometimes south o f the river itself. A tributary of the Meramec River is the Dip. River. After forming part of the southwest boundary o f the county, it flows approximately 60 miles northward through the county and cuts through h ills forming scenic bluffs 150 to 250 feet high. The four main streams which drain the western part o f the county, and flow into the dig River include Dry Creek, Belew Creek, Bourne Creek, and ileads Creek. The M ississippi, forming the eastern boundary, cuts into the county in an arc o f approximately 22 miles.
Rush Island is located in the alluvial valley of the Mississippi River, approximately 139 to 141.5 river miles above the confluence o f the Ohio River. The Mississippi River flows from St. Louis south to a point close to Ste. Genevieve, a distance of about 50 miles, through a flood plain which is from 2 to 5 miles wide. A few miles south o f Crystal City, a series o f islands have been formed along the escarpment on the Missouri side o f the river. Three islands form a continuous chain from north to south; ilarlow, Rush, and Lee Islands. The flood plain on the Illinois side east of Rush Island is between 2 1/2 and 5 miles wide. The area of Rush Island and vicin ity lies near the eastern boundary of the Ozark Plateau Physiographic Province, near the junction of the Interior Low Plateau Province. The Ozark Plateau Province is characterized as an uplifted peneplain, deeply incised by streams which developed high (up to 400 feet) bluffs along the Mississippi Paver. The area west o f the bluffs is characterized by ridge and valley topography approximately parallel to the river. The entire western escarpment consists of marine deposits of late Ordovician Age. Rock out crop pings in the escarpment belong sp ecifica lly to the Plattin Formation, which is characterized by dense, massive limestone overlain by the Kiua'.iswick Formation. The Kir.uiswick linestone is a light pray, coarsely crystalline, which, when weatiiered, gives a ‘honeycombed’' apnearance. The east escarpment and area consist of marine deposits of Missis sippi limestones belonging to the Salem and St. Louis Formations. The island is approximately a half mile wide and 2-3/4 riles long, and bounded on the east by the river and on the west by limestone bluffs. The steep bluff formation begins close to Crystal Citv, Missouri, and continues as a uniform wall south to the Isle du Rois Creek, which forms the southern boundary of Rush Island. The sur face elevation of Rush Island varies from about elevation 580 to 338 feet m .s.l., over 400 feet above the flood plain. The bluffs grade into h illy country to the west witli decreasing elevation to near U. 3. Highway 61. The flood plain on the Illinois side east of Rush Island is between 2 1/2 to 5 miles wide. The eastern escarp ment area is 720 feet m .s .l., with the bluffs grading into h illy o country with numerous sink holes. 2-16
'liio site is drained bv two creeks and a slou::!i whidi flow into the Mississippi River at the site . Muddy Creek, carrying runoff water from a catchment area of approximately 1100 acres, flows southward along the western edge of s ite , and then crosses the site diagonally and discharges into the Mississippi River. Isle du Bois Creek runs along the southern end of the site, and is the dividing line lie- tween Jefferson and Ste. Genevieve Counties. A number of snail creeks flow into a wide slough at the northeast corner o f the site.
The foundation soils at the site can be basically divided into an upper stratum of clays and silts 10 to 30 feet thick, underlain by fine to coarse sand about SO to 120 feet thick. Some gravel exists in the lower part o f the sand stratum. Dolomitic limestone o f Joachim formation of Ordovician Age underlies the sand formation at a depth o f about 120 to 140 feet at the river, decreasing rapid ly to a depth o f only 30 to 40 feet at the western edge of the Island.. Reference Soil and Foundation Report,' Rush Island Plant, Volumes I, II, and III, by McClelland engineers, Inc. The ground water table is primarily controlled by the stage o f the Mississippi River, because the sand formation underlying the site is exposed at the bank of the river, and the relatively high coefficient of permeability o f the sand permits it to transmit seepage and hydro static pressure under the Island with relatively little lag behind changes in the river stages.
Rush Island lies within the Ste. Genevieve fault region, and is about SO miles north o f the New Madrid Area. The Ste. Genevieve fault region is confined to the following counties: Perry, Ste. Genevieve, St. Francois, and part of Iron, Washington, Franklin, and Jefferson. This area lies on the northwestern flank o f the Ozark u p lift, and a belt of faulting extends from i.'ittenburg in Perry County through Ste. Genevieve County where the belt of faulting divides. One brand', extends across St. Francois County, and the other trends northward into Franklin County, approaching within 20 miles of the Island. The MSCOS seismic risk man places Rush Island in zone 2 (expected moderate damage from earthquakes). Historic and dynamic analysis indicates that the strongest horizontal acceleration that might possibly occur at or near Rush Island is 0.20r. This horizontal acceleration has been interpreted to be in the range of 6 to 7 on the Richter scale. This information on acceleration was incorporated into plant design. Reference Soil and Foundation Investigation, Rusli Island Plant Renort, to Bechtel Corporation, by McClelland Engineers, Inc., Volume III.
Present level o f economic develop:.ent
Because the economy o f Jefferson County is a part o f the overall St. Louis metropolitan area economic structure, growth is dependent upon the metropolitan economic situation. It is estimated that over 5U percent of the employees in Jefferson County commute to places o f employment within the metropolitan region. Various surveys that have been made at various times within the past decade 2-17
in individual communities and on a county-wide basis indicate a high nercentape of commuters. Not only are persons in the northern portion of the county commuting to places outside the county, but residents of Festus, Crystal City, and DeSoto have a high number o f commuters. Within the rural areas in the southern part of the county, a number o f persons are commuting to employment also.
The present economic activities within Jefferson Countv include a limited number of manufacturing establisbnents, service centers, highway oriented commercial a ctiv itie s, and a lin t ted amount of agricultural production. However, all of these activities are outweighed by the number of persons commuting to a ll tvpes of em ployment in the St. Louis metropolitan area.
The maioritv of manufacturing employment is orovided by three of the larger and older companies in the county. The Pittsburg Plate .Glass Company emnlovs over 1.500 persons, and the fluctuating em ployment of the Missouri P acific R.R. shops at times has numbered 1,200 persons. The St. Joe Minerals Coro, in Herculaneum employs nearly 500 persons. Five other firms employ from 100 to 300 persons, and the remaining plants employ less than 100 persons each. None of these manufacturing establishments are located in the surrounding, area of the Rush Island Plant site.
Agricultural production in Jefferson County is of a lower volume in comparison with many other counties in the state. Similar to many of the Ozark region areas, the so ils and terrain are not well- suited to agricultural activities. However, agricultural production amounts to 5 million dollars in total farm products sold. Crops in the county include com , hay, wheat, soy beans and oats, and the principal animals are poultry, dairy cattle, beef cattle, hogs and sheep. In recent years, agricultural activity has shifted away from the field crops to grazing and livestock production. Generally, the river valleys are used for crop production, although a limited number o f acres is available for this use throughout the county. The southern part of the county, particularly the area surrounding the Rush Island s ite , is used primarily for the grazing of beef cattle. The declining role of agriculture is indicated by the fact that the number of farms has decreased from 2,600 in 1940 to less than 1,000 in 1970.
Retail trade, services, wholesale trade, banking, business and financing activities have increased considerably due to the signi ficant growth of population. Total retail sales increased from $49,020,000 in 1960 to $96,250,000 in 1970. However, the develop ment of supporting retail and service establishments has not kept pace with the population growth and it is anticipated that a sig nificant growth in these areas w ill occur in the near future. 2-18
The area surrounding the Rush Island Plant site has witnessed very lit t le of the economic development in the county. In fa ct, there has been a slight decline in agricultural activities in this area. Several new highway-oriented commercial establishments have developed along U. S. 61-67.
Employment by place o f residence is listed by the Missouri Employ ment Security Commission through data provided by the Social Security Administration. This information reports "covered employment’ with in the St. Louis Standard Metropolitan S ta tistical Area (' S .M.S.A. ') . A total of 983,000 employees was reported under this procedure, of which only 8,533 of the 'covered employees' actually worked in Jefferson County. Jefferson County's 1970 population of 105,248 represented 4.45 percent of the St. Louis metropolitan area popu lation. Yet, the covered employment" figure of 8,533 working in Jefferson County is less than 1 percent of the total employment in the St. Louis metropolitan area. This is sign ifican t and indicates that out of five employees in Jefferson County, four of them com mute to jobs in locations outside of the county. There was consid erable variation in the number of "covered employees ‘ working in the county and the percent of total St. Louis metropolitan area employment, as seen in the following tabulation:
Number Employed in Percent of Total Type of Employment Jj^ffers_oji Cojuntv S.M._S.A. Employment
Agriculture, Mining and Construction 605 1.22
Manufacturing 3,597 1.31
Transportation, Utilities, etc. 667 0.99
Commercial, etc. 2,423 1.26
Finance, etc. 322 0.68
Services, etc. 813 0.54
Total 8,533 0.86
The foregoing v erifies the high number of commuters, as ideally, the percentage in each category would be 4.45 percent i f Jefferson County had fu ll comparable employment to population. Construction, manufacturing and commercial employment were the highest employment categories. However, they do not represent nearly the 4.45 percent 2-19
of the St. Louis metropolitan area population. While these sta tistics have limited absolute application, they are probably the most ap propriate figures available that indicate the fact that li t t le em ployment exists within Jefferson County and that most of the labor force is commuting to other locations within the St. Louis metro politan area - primarily St. Louis and St. Louis County - for em ployment.
Social and cultural customs
Prior to the expansion of the St. Louis metropolitan area into .Jefferson County, the residents of the county consisted of a pre dominantly rural population, with a small percentage o f persons living in the cities of Festus, Crystal City, DeSoto, and in smaller communities. Festus and Crystal City were basically dependent upon the Pittsburg Plate Glass Company and, to some extent, upon the St. Joe Minerals Corp. plant in Herculaneum. Similarly, much of the economic base of DeSoto was dependent upon the Missouri P acific R.R. yards. The remainder of the county primarily consisted of rural households. Thus, prior to 1950, a majority of the residents of the county were oriented to the social and cultural customs of a rural society.
During the past two decades, Jefferson County has changed to an urban population. According to the 1970 Census, some 70 percent of the population is classified as 'rural non-farm'' (living either in the citie s or in the rural areas), with only about 6 percent considered as "rural - farm," indicating the current nonagricul tural status in Jefferson County. This is attributed to the sizeable area devoted to forests and the creation of rural households without farming operations. A cross section of the people occupying the county can be attained from the 1970 Census data. A total of 105,248 persons reside in Jefferson County, occupying a total of 23,677 households, or an average of 4.4 persons per household. This figure is somewhat higher than both the state and national averages.
Studies of characteristics of the population indicate a progressive change in representative trends as distance to the St. Louis - St. Louis County urban area decreases. Characteristics of the popula tion nearer the St. Louis - St. Louis County urban area are smaller households, higher median income, higher level of education, higher percent enrolled in school, larger percent of females in the labor force, larger percent of white collar jobs, all indicative of a more urban population. Since Jefferson County is located between urban St. Louis and rural areas to the south and southeast, the area contains a gradual change from an urban to rural population. This distinction is readily identifiable in the northern areas of 2-20
Jefferson Countv. which are urban in character and the oo.onle livin' in tills northern area have the socia l anc! cultural custor’s of an urbanized area. Conversely, the peonle In the southern nnrt of the county reflect rural characteristics. With a few executions, those persons in the vicinitv of the Kush island Plant site repre sent rural population, i.e ., larger households, a generally lower median income and a lower level of education.
Persons 65 years and older are a smaller percentage of the popula tion in the northern tovmshins of Rock and Meramec, with 4.1 and 5.6 respectively. In Plattin Township, the. percentage is 7.6 per cent of the population and is even higher in severe] of the other rural townships. A greater proportion of the. population ir. the northern parts of the county are in the 20-25 age groun, whereas in the vicinity of the Rush Island Plant site, this percentage is considerably lower. A great majority of the residents live in single-fam ily houses, according to the 1067 Land Use Survey. Recent studies on mobile homes (1060) indicate that there are now in excess of 3,500 mobile hones throughout the countv, with nearlv one-third of this total being placed on individual lots. Verv l i t t l e multiple-family housing existed at the time of the 1967 Land Use Survey, as only 100 such structures were noted.
Lousing conditions were also observed in the 1067 survev, which indicated that 86 percent of all units were, sound and onlv 14 ncr- cent were rated as substandard. Of the 4.528 substandard units, nearly one-half of these were located in Rock Township, an area of significant growth in recent years.
The median income for the population of Jefferson County in 1060 was $5,767 per year, slightly above the national average of $5,620. This was achieved primarily by having fewer persons in the lowest income bracket (below $3,000 ner year) and more in the lower-middle income bracket ($3,0Q0-$6,999) than nationally.
The I960 income of the 16,033 families living in the county at that time was as follow s:
Yearlv Income Jefferson Countv United States
Below $3,000 16.8 21.7
$3,000-$6,999 52.7 43.9
$7,000-$9 ,999 21.7 20.0
$10,000 and over 3.8 14,4 2-21
Private estimates generally indicate that "bracketing” of income similar to 1960 continued to occur. In 1968, Jefferson County continued to have fewer incomes in the lowest brackets (below $5,000), more in the middle brackets ($5,000 to $9,999), and fewer in the highest bracket (over $10,000) than nationally, as shown by the following (from Sales Management, June, 1969):
Yearly Income Jefferson County United States
Below $3,000 15.0 18.9
$3,000-$4,999 11.1 13.2
$5,000-$7,999 29.4 24.7
$8,000-$9,999 20.8 15.0
$10,000 and over 23.7 28.2
The o ffic ia l U. S. Census data for 1970 show the median income for the population of Jefferson County was $9,742, slightly below the national average o f $9,867. The same "bracketing” of incomes is evident again. The 1970 income o f the 29,777 families living in Jefferson County at the time o f the census was as follow s:
Yearly Income Jefferson County United States
Below the poverty 7.2 8.9 level* $15,000 and over 14.3 22.3
* Poverty level is a function of the local cost of living, and is approximately $3,000.
The buying habits of Jefferson County residents, in comparison to the U. S. averages, indicate that a higher percentage of total income is spent for food, while a lower percentage is expended on household appliances and general merchandise. Purchases o f auto motive and drug items are approximately the same as the national average, as shown in the following data on reta il sales as a per centage of total income from 1968 (from Sales Management, June, 1969): 2-22
Item Jefferson County United States
Food 27.5 21.7
General Merchandise 8.0 17.0
Furniture, Household Appliances 2.8 4.7
Automotive 19.5 18.7
Drug 3.4 3.6
_Population Trends
Jefferson County has experienced ranid growth during the last several decades, due to the expansion of the St. Louis metropol itan area. From 1900 to 1930, the population in the county re mained at approximately 26,000 persons. The population increased to approximately 32,000 in 1940, and 38,000 in 1950.
It was in the early 1950's that rapid growth bepan to take place and by 1960, the population increased to 66,377. This represented an increase of 75 percent during that decade. This upward trend continued and, by 1970, the countv had a total population of 105,248, an increase of 58.6 percent during that decade. During, this same period, many of the surrounding counties in Missouri experienced a stable population or an actual decline of population.
As could be expected, the ponulation changes in Jefferson Countv were not uniform throughout the county. Generally, there were two types of population change. All of the rural areas had been ex periencing a decrease from 1900 to 1930. During this same period, the urban areas were, for the most part, experiencing increases because of their manufacturing operations.
Population growth in the county since 1950 has also taken a very distinct trend. In the 1950's and 1960's, Rock Township and Meramec Township had significant numerical increases. Rock Township grew from about 7,000 to 35,000 persons and Meramec Township increased from 4,000 to 14,000. Joachim Township increased only from 14,000 to 20,000 during, this same period of time. The remaining townships had increases of about 1,000 to 2,000 persons. Plattin Township had a relatively minor increase from 1,844 to 4,487, a numerical increase of 2,643, or approximately 700 families. 2-23
The population density in the vicinity of the Rush Island Plant is very low and has shown very li t t le growth in the past 20 years. In Plattin Township, Jefferson County there are about 11.8 families per square mile and there is even a substantially lower population density in the areas of Ste. Genevieve County, Missouri, and Monroe and Randolph Counties in Illin o is that are within about ten miles of the Rush Island Plant s ite . Population trends in the p o litica l subdivisions that have part of their area within ten miles of the Rush Island Plant site are shown on Figure 2-8.
Agricultural and industria l trends
The terrain and soil conditions in Jefferson County are a severe limiting factor on agricultural activities. The total 426,888 acres In Jefferson County contains considerable rugged terrain and many areas where rock or gravel soils are near the surface. There were only 72,456 acres in croplands in 1969, and only 27,506 were actually harvested. This is extremely low for this part of the county.
Agricultural activity is on the general decline in Jefferson County, as is evidenced by comparisons of the 1964 and 1969 Census of Agri culture. Harvested croplands decreased from 33,946 acres to 27,506 acres. The number of large farms decreased slightly and small farms (of 1 to 9 acres) increased. This is all part of the trend of the conversion of the area from large full-time farmers to small part-time farming and absentee farming. The number of acres of land for pasture or grazing actually increased. The de crease in full-tim e farming is evidenced by the fact that farms of 500 to 1,000 acres decreased from 47 to 44: farms of 260 to 499 acres decreased from 126 to 122; farms of 220 to 259 acres decreased from 50 to 40; and farms of 180 to 219 acres decreased from 80 to 59. The number of farms actually increased during this same period: however, this is a result of the division of land and not an in crease in activity. The farm incomes and market values of products increased during the five-year period, as would be exnected. The number of farms with livestock increased from 258 to 309 during this same survey period.
Agricultural activities in Jefferson Countv have played a relatively limited role in recent years and will probably have a lesser role as urbanization continues. Most of these agricultural activities have been in the river valleys, such as those level areas found along the Big River. There is very little farming of significance in the immediate vicin ity of the Rush Island Plant s ite . u
2-24
Three larye industries have historically provided a greater part of the total employment in the county and have retained constant in tlici r operations. Tire Pittsbur^ Plate Glass Company plant in Crystal City is one o f the early industries in the St. Louis metro politan area and has provided continuous employment over a period of many years for from 500 to 1,500 persons. The Tssouri Pacific R.R. shops in UcSoto .have provided employment for up to 1,200 persons for many years. Total employment of the shoos has fluctuated over the years. The St. Joe '.'incrals Com. is also one of the oldest industrial operations in the area and has provided employment for nearly 500 persons for many years.
There has been no significant new industrial development in Jefferson Countv. Onlv two industrial operations o f anv significance have been developed and they have provided only a limited amount o f em ployment - less than 200 employees each. The l;estus-Crystal City area has had no new industrial development and the city of HeSoto, while haviny an industrial park, has only attracted several small operations. This is to be expected in view of the extreme topo graphy o f the county and the lack o f suitable industrial sites pro viding level land combined with rail and hi dway access.
The only industrial activities within the vicinity of the >’ush Island Plant site include the United States Steel Com. ( l!SS ) A/jri-Chemicals Plant at Selma Station, which is in the same delta area .-is the proposed power plant. This is a lony, low area ex- tendinp. from Selma Station, over Harlow Island and Push Island. The l)SG plant is located in the north end o f tins low area at the end of Doolin Hollow. It is served by a ra il smir from the main line of tiie St. Louis-San Francisco Railway Company (Frisco) which runs alony the face of the bluffs. The other industry within the vicin ity of Rush Island Plant site is the River Cerent Company, which is located approximately two idles north of the USS plant on the Mississippi River, also adjacent to the Frisco tracks. This plant, a subsidiary’ of the Mississippi River Corp., is located at the end of Selma Hollow.
The Rush Island Plant site is located in an area that was designated as a potential industrial site in a report on Economy and Population prepared by liarland Bartholomew and Associates in 1064. In fact, only three locations in Jefferson County were pointed out as suit able sites with highway, ra il and baryc access. The most northerly area was located just south of the lerar.ee River's confluence with tiie Mississippi River. The second site was the low area east of Crystal City. Hie third and largest area was tiie site of tiie proposed Rush Island Plant, and embraced a larye area extending alony the Mississippi River east of the bluffs and the Frisco tracks, includin'.- Selr.ia Station, Harlow Island, and Rush Island - an area approximately one-half to one mile wide and six miles lone. 2-25
Other areas were designated in the 1R6-1 renort as secondary in dustrial sites with either rail or highway access. There has been virtually no industrial development in Jefferson County in tiie last 20 years due to many factors, including the lack of suitable sites. As pointed out in previous sections, most of the employment is provided in other areas within the bt. Louis metro politan area. One of the disadvantages of the industrial sites in Jefferson County along the Mississippi River is tiie remoteness and lack o f rood highway access. Chile they have excellent rail and x'ivcr access, they are extremely remote fx'om tiie standpoint of highway access and, in the case of the areas on Harlow and Rush Islands, they are remote from even the present working popu lation and urbanized areas of the county. Conversely, these factors make this an ideal location for an industrial operation such as the Kush Island Plant.
Transportation
Jefferson County is served by four major north-south routes; these being 1-55, U. S. 61-07, and Missouri Routes 21 and 50. The cast- west routes are county roads, tiie majority of which are inadequate to serve the present population. Two railroad lines . the St. Louis San Francisco Railwav Company (Frisco) and the Missouri P acific R.R., parallel the Mississippi River alone the eastern side of the county. The Festus-Crystal City aimort and a privately owned airport at DeSoto provide the only air fa cilitie s in the county. Cater transpox’tation is available along the entire eastern boundary o f the county on the Mississippi River and to a limited extent along the northern boundary of the county on the ’eramec River.
The Rush Island Plant site is located approximately halfway bctiveen County Route AA and the Jefferson County-.5te.Cencvieve County line. The Mississippi River provides a harrier to vehicular access from tiie east on the Illinois side. A ferry currentlv operates at Ste. Genevieve, approximately in miles downstream. This is the nearest means of vehicular access across the river. The nearest bridge to the south is located at Chester, Illin ois approximately 56 miles by road from the site. The nearest bridge north o f ttie site is the Jefferson barracks bridge approximately 52 miles by road fx'om. the site.
Direct access to the Rush Islam! Plant site is over minor roads connecting the site to IJ. S. Route 61 (see Figure 2-7). Access to and from the nortli is over Jig Hollow Road (County maintained) to Drury Road (County maintained) to Route AA (State maintained) to Route 61. Approximately three miles north of Route AA, Route 61 connects to Interstate Route 1-55 by means of a diamond interchange. Access to and from the south is over Johnson Road (County maintained) to Route 61. Approximately five miles south on Route 61, Interstate Route 1-55 can be reached over Route K (State maintained) from. Route 61 (in Stc. Genevieve County). A diamond interchange connects Route K to Route 1-55.
77 2-26
Interstate .'onto I-'35 is constructed of duel 24-foot Portland Cadent (P.C.) concrete pavement senarated hv 6D-Coot Median. The route is constructed to interstate standards and this 3R-nile section south of the Route 67 interchan.ee was opened to tra ffic late, in 1971.
V. h. .Route 61 has two 11-foot lanes and is constructed of P. C. concrete. Six to eight-foot aggregate shoulders and open ditches are on each side of roadway surface.
Route AA has 22-foot wide macadam surface with onen ditches on each side.
Big hollow Road consists of 20 to 22-foot wide aggregate surface with open ditches on each side. A low water crossing at Saline Creek con sists of a P. C. concrete pad with a corrugated netal nine through it and becomes ir.nassable during high water. The maximum vertical grade is approximately 10 percent and horizontal alignment provides for 25 to 30 miles ner hour driving sneeds.
Johnson Road also has 20 to 22 feet of aggregate surfacing with open ditches on each side. The naximun vertical grade is approximately eight percent and the horizontal alignment w ill allow 25 to 30 miles per hour driving speeds. There is one small P. C. concrete culvert over a tributary to Big. liollow Creek. existing tra ffic volumes on access roads
The Traffic Han of Missouri'' prepared bv the Missouri State Hiphway Department provides the following Average Dailv T raffic (ADT) for various locations in the proximity of the plant site: *
Year -_ ADT Route Location 1961 ' 1970 1971
U. S. 61 South of Rt. AA *NA 6,100 7,420
U. S. 61 North of Rt. K *NA 6,320 7,740
U. S. 61 South of Rt. 67 Jet. 8,280 8,530 9,730
Rt. AA East of U. S. 61 95 98 *NA
Rt. 1-55 North of Crystal City 11,715 12,065 23,110
Mo. 110 DeSoto to Rt. 67 3,990 4,110 3,930
Mo. 32 West of Ste. Genevieve 1,890 1,955 2,690
*NA - Not Available 2-27
Drury Road, Big Hollow Road and Johnson Road am on the Jefferson County Road System and no tr a ffic volumes are available: however, it is assumed that ADT, prior to development of the plant s ite , would not exceed 100 vehicles per day, of which approximately 25 would be trucks due to current quarry operations.
In addition, the ADT was investigated for the years 1968 through 1971 on Route 61 north of the Festus-Crystal City area to determine the t effect on traffic on Route 61 due to the opening of Interstate Route 1-55.
For the four years following the opening of Route 1-55, north of the Route 67 interchange, the tra ffic on Route 61-67 averaged only 35 percent of its volume for the year 1^67. It is expected that the recent opening of Route 1-55 south of the 61 interchange will have a comparable e ffe ct on Route 61 tra ffic in the vicin ity of the plant site, exclusive of plant-generated traffic.
Based on the above analysis, the anticipated ADT on Route 61 for the next four uears, exclusive of plant-eenerated traffic, would be as follows :
Route Location 1972 JL973 __19_7_4 19_7_5
U. S. 61 South of AA 2,600 2,445 2,520 2,845
U. s. 61 North of Rt. K 2,710 2,545 2,620 2,960
U. s. 61 South of 67 Jet. 3,405 3,200 3,295 3,725
An experimental surface treatment is currently being conducted on Big Hollow Road immediately east of Drury Road. The experiment Section is apnrosimately 0.7 mile in length and the tests are beinv• conducted bv the Jefferson County Highway Department. This experiment currently consists of using Lignin Sulfanite, a by-product of the wood pulp industry, as a binder or stabilizing agent for the aggregate surface. The treatment supposedly w ill provide a 95 percent effective dustfree surface.
River Traffic The Mississippi River carried 5C.34 million tons of cargo past Push Island in 1970. During 1960 the tonnage past the proposed site was 30.02 m illion tons. Mot only has waterborne commerce increased more than 94 percent in the past ten years, but there has been a definite rise in the popularity of small pleasure craft. The rise in commercial and pleasure craft over the past ten years is one indication that the Mississippi River will carry even more traffic past the proposed plant site in the coming years. 2-28
Public access to the Mississippi River
No truly public access to the Mississippi River existed over the Rush Island Plant site when the real estate was acquired by the Company. Field roadways and tra ils on the plant site did exist which extended from the public road crossing over the Frisco Rail road right-of-way near the north west comer of the Rush Island Plant site. The roadways and trails on the plant site served the agricultural fields, one cabin, and four farm sheds. All such fields and buildings were acquired for the plant site.
The roadway along the north boundary of the site may have been considered public because some county maintenance had been per formed on this roadway. The southerly extension of the north boundary roadway, which paralled the river, also may have been public at one time for access to the river, but interviews with the Jefferson County court, former owners and tenants who fanned the land, and others indicated that it had long since lost its public identity at the time that the Rush Island Plant site was acquired by the Company. This roadway paralleling the river deteriorated to a trail and its course was changed bv floods and the growth of timber and it was regarded eventually as private and was used by farmers for access to the fie ld s , but at times i t served as access to the cabin mentioned above, when weather and river conditions permitted.
Eecause this north-south trail was not adjacent to the river bank and because there were no defined branching trails leading to the river bank, i t would have, been necessarv to denart from the north- south tra il and traverse private prooertv to reach the river.
Transmission line rights-of-wav
The first 13.5 miles of the proposed right of •••'av for the 15.5 .l i e lire fro- the Kush Island Plant to the ft. Francois Substation Ls rou'-h , extreno.lv hillv and h**avi!'» ’./coded. The land along this part of the right-of- way is very lightly populated and the agricultural use of the land is generally limited to isolated pastures. The last two miles of the right-of-way cross through an area that is being, used for pasture and: for some field crons. Along the entire 15.5 riles of the proposed line, there is no evidence of subdivision develop; .cut, nobile home narks . or cor‘— uerci al cons truction.
the. right-of way for the proposed 138 kv line and first six riles of the proposed line from Rush Island Plant to Tyson, the tonogran’iv changes from a very rough and heavi.lv wooded land to rolling farm land used primarily for pasture, and the commercial and residential land use. in the vicinity of the right-of-way is limited to that which borders the highways. For the next ten miles of the right-of-way for the Tyson line the land is rolling, wooded and almost completely undeveloped except for very limited con- 2-2')
nercial and residential development alonn the highways. At a point west o f Festus the line changes from running northwesterly to northerly and this 18 1/2 miles of line avoids intrusion upon communities although the land along the route changes from pre dominantly farm land at the southern end to the more heavily de veloped commercial and residential areas at the northern end o f the line.
2.3 ideological Setting o f Project Site
Animal life and vegetation
Rush Island has been farmed for many years and for this reason the natural botanical and zoological associations of an island in a flood plain do not exist. A few small trees remain scattered along the Mississippi River shoreline. The wooded area of the escarpment and the h ills to the west o f it are covered with the typical oak- hickory type forest of central Missouri. Due to the in accessibil ity of the area many old trees have been preserved. The valleys present the typical bottomland tree habitat, rich in hackberry; locust, intermingled with ash, chinquapin oak and other trees. A few unusually fine persimmon trees have been observed in the valley areas. The ton o f the escarpment orovides dense growth o f juniper wherever rock outcroppings occur.
The area in the general vicin ity o f Rush Island is rich in deer, and also supports turkey, wildcat, fox, squirrels, raccoons, and opossum who inhabit the wooded areas; cottontails are common in and near the river bottom. The well drained open forest habitat provides the common wild flowers that can be expected in central Missouri. Mo rare species of plants arc known to exist in the vicinity (source: List of rare plants by Julian Steyemark and advice by Mr. Larry Legman, a local b io lo g is t). This is to be expected as the normal criteria for their presence , namely acid or sandstone soils, cool north-facing valleys, or unusual habitat are absent.
■iarvest records from the Missouri Department o f Conservation in dicate that Jefferson County, in which the Rush Island fa cility w ill be located, and adjoining Ste. Genevieve County support w ild life to varying degrees. Doth o f these counties are in the east Ozark Border region, which is one of eight zoogcographic regions in Missouri. The Mississippi River bottom land, in which the plant fa cility is located, is primarily farmland. This habitat supports small game such as rabbit, quail, dove, pheasant, crow, duck and goose. The following tabulation summarizes game density values for the Ozark Border region as calculated from information obtained from the 1071-72 Missouri Game harvest Survey. Further, the impact o f the Rush Island fa cility was projected assuming that 350 acres (0.55 square miles) of land would be removed from the ecosystem. 2-30
o W ildlife Density 'Wildlife Affected W ildlife Total Harvest Per Square Mile By F acility Number
Rabbit 411,113 55.4 31
Quail 438,826 59.1 33
Dove 175,160 23.6 13
Pheasant None Reported
Crow 66,049 8.9 3
Duck 14,219 1.9 i
noose 1,030 0.1 i
The river hotton land is bounded on the west by timber covered bluffs. As previously mentioned, the wooded area of the escarpment and the H ills to the west are covered with the typical oak-hickory tyre forest o f Central Missouri. This habitat supports snail pane, furbearing pare and large game, particularly deer. The Push Island facility is ex pected to have minimal impact on the small terrestrial animals or pane indigenous to this area. Although many hunters frequent this area in Jefferson County, the game harvest represents a small percentage as compared to all other counties in Missouri. In 1371 the deer harvest (237 of .32,635) was 0.83'a of the state total, while the turkey harvest (57 of 2,864) was 1.991# of the state total. There is also some fur trapping in Jefferson County, primarily opossum, nuskrat and raccoon, with lesser quantities o f red and gray fox. There were a total o f 36 trapping permits issued in this County in 1371, representing 1.10*1, of the state total, following is a summary of the fur harvest data for 1971:
Missouri Jefferson W ildlife Total Countv o f Total
Opossum 40,559 215 0.53
Muskrat 84,559 730 0.86
Raccoon 157,577 571 0.36
Red Fox 1,544 25 1.62
Cray Fox 2,075 49 2.36 2-31
Aquatic setting
Results o f water sampling at approxinate nile 210, upstream from the confluence o f the .Missouri River, and at approximate river mile 161, which is downstream from the City o f St. Louis, are shown in Figure 2-9. These results are based on a single sampling and therefore cannot be considered as representing an average condition. However, these parameters do characterize the in fluence o f St. Louis and the Missouri River discharge on the total water body. As one would expect, there is a significant increase in solids in the lower Mississippi River primarily resulting from erosion products in the Missouri River. There is also a notice able increase in nitrate, phosphorus, sulfate, potassium, and sodium at the downstream sampling point.
The ambient monthly temperatures of the Mississippi River are tabulated below. This information is taken from Union K lectric Meramec Plant logs and charts for the years 1964 through 1970. More detailed information on ambient river temperatures may be found in Figures 3-3-A through 3-3-L.
Max. Recorded Ambient River Month Ambient River Temp Temp " o p - op
Jan 44 39.5 Feb 44 42 Mar 55 52 Apr 69 64 May 76 75 Jun 82 80.5 Jul 87 86 Aug 86 85 Sep 82 80 Oct 72 71 Nov 57.5 57 Dec 46 43
Crystal City, Missouri, 3 1/2 miles to the northwest, is the closest major source of river contamination upstream from Rush Island. However, the impact o f the discharge from this community relative to the St. Louis metropolitan area would be minor. The closest major source of thermal discharge to the Mississippi River upstream from the Rush Island Plant site is the 880 mega watt Meramec Plant which is located on the west bank o f the river at river nile 161.
Union L lectric conducted field surveys o f the Mississippi River in the immediate area of Rush Island to determine the following in for mation: (1) preliminary characterization of the Rush Island Site (2) identification of possible c ritica l problem areas that require additional investigation and (3) definition of a program plan for the environmental investigations essential to meet the requirements o f an environmental report. The environmental factors were evaluated by collecting and analyzing existing data and by field surveys. Maximum possible use was made of pertinent data obtained from.the Sioux Aquatic Program. 2-32
The emphasis for the Rush Island Survey Program was placed on the e ffe ct of cooling water discharge on the aquatic ecology. Field studies were conducted to obtain a broad characterization of local aquatic life forms at the Rush Island site. These studies included the following five major areas: (1) benthic analyses, (2) plankton distribution, (3) water chemistry, (4) physical measurement and (5) fish analysis.
To acquire the physical, chemical and b iologica l data a river sampling program was established at locations above, adjacent to, and below the proposed Rush Island Station site. Sampling areas were located between Mississippi river miles markers 141 and 139. With the ex ception of the benthic sampling, the sample stations were located on river transects normal to tiie river flow. A total of 3 field surveys were conducted; September 1971, November 1971 and April 1972. A summary o f the tasks completed during each of these fie ld surveys is shown below.
Survey Task September 1971 November 1971 AorH U \ 7 2 _ benthos X X X
Plankton X X
Water Chemistry X X X
Physical X X X
Fish X (adult) X (larval)
Benthics survey
The benthic community is one o f the best indicators o f water quality in an ecosystem. Benthos have limited mobility, slow turnover rates, high substrate selectivity and differential tolerance to environmental stresses. Characteristics of the benthic community, combined with physical data (including bottom temperature and v e lo city ), were inte grated to nrovide a baseline for the Rush Island Site and to assess the influence of the Sioux Plant on the aquatic environment. When it was possible to collect an adequate number of samples, statistical methods were used to compare data. benthic sampling at the Rush Island Site was restricted to the nroposed recirculating water discharge area downstream o f Dike No. 140.3R. This area is sheltered from the rapid current of the river channel by the dike and should provide an ideal site for benthic evaluations. The water velocity is significantly lower than the river and the bottom type, mostly mud, is well suited for benthos. The heated condensor water is expected to have no impact on the benthos in this sampling area because of the relative positioning of the discharge plume. 2-33
There are several ways to analyze fie ld data to assess water quality. The two most widely used techniques today are the key indicator organisms concept and the community structure concept. Specifically, the community diversity index concept was used in these studies since the community not only reflects the distribution of species but includes the relative importance of each species.
Margalef (1958) first proposed an analysis of mixed-species populations by methods derived from information theory. Wilhm (1970) presented the diversity expression which will be used within this paper. _ s 3 =“£ (nj/n) log2 Ou/n)
Where d is the diversity
s is the number of taxa
n^ is the number of organisms per taxon
n is the number of organisms
Although the diversity was developed to compare communities at a species level, the d's calculated in this report are family diversities. It is further recognized that less information can be gained and comparisons w ill be less detailed; however, gross differences w ill be seen even at this level of analysis.
The benthic community at Rush Island was sampled three times; September 1971, November 1971 and April 1972. The September survey consisted of 24 samples which contained 455 organisms with 8 taxa represented. Oligochaeta comprised 92.75% o f the sample. The diversity index was 0.51. The November survey consisted o f 16 samples in the same general area studied in September. A total of 111 organisms were collected with 5 taxa represented. The Oligochaeta made up 90.09% of the collection. The November diversity index was 0.61. The last survey was in April 1972 with 475 organisms collected that represented 15 taxa. This survey consisted of eight samples. The Oligochaeta were again the dominant organisms, 93.68%. The diversity index was 0.51.
The physical environment of this benthic community with regard to tur bid ity, depth, velocity and bottom type is as follow s: turbidity (transparency) 3 to 6 inches; depth 6-38 feet; velocity (1 foot above bottom) 0.025 - 1.3 Ft/Sec; bottom type varied from black mud to fine sand with the muds predominating. 2-34
The benthic community sampled at the Rush Island site shows a normal sh ift in total number o f organisms collected with respect to seasonal changes. The smallest nunber were collected in the winter (November sample) and the largest nunber were present in the spring before the hatch occurs (April sample). Although there was a slight change in the taxa distribution for the three sampling periods, as shown in Figures 2-9-A and 2-9-B, the diversity index remained almost constant for the three sampling periods. The extreme domination o f the com munity structure in all three cases by the Oligochaetes is the major reason for so little change in the community diversity.
A species diversity index of approximately 1.50 and lower is an indication that a body of water is being badly stressed by pollutants.
In order to use the family community diversity index and make comparisons with the species diversity index, the family diversity index should be increased by some factor, x. A clean stream would be expected to have a species diversity index o f 3.00 or greater. As stated ea rlier, the Rush Island family diversity index was between 0.51 and 0.61. This is significantly less than a clean stream snecies diversity index of 3.00, excluding the factor x.
The Oligochaetes are considered to be organisms very tolerant to organic enrichment (high levels o f nutrients and organically-generated carbon compounds) and their preferential habitat consists of soft mud and silts. At least four of the Diptera genera found at Rush Island are commonly associated with organic detritus and fine s ilt substrata. The primary source of food for many of these organisms are diatoms and algae, while a few arc predacious on other benthic invertibrates. The presence of the Oligochaetes and Diptera supports the community diversity index con clusion states earlier.
Samples taken in the main river channel for benthic analysis, where the bottom was composed primarily of fine sand, indicated a lack of benthic organisms.
Holoplankton Survey llolonlankton are an aquatic group whose members remain in the planktonic form for the duration of their life cycles. The group is comprised of phytoplankton, which convert photic energy into carbohydrates, and zoo plankton which prey upon phytoplankton. Both groups of organisms are important in the aquatic food chain and are responsive to adverse change in water quality.
The holoplankton were sampled at Rush Island on two occasions, November 1971 and April 1972. Two different methods of collection were used, water samples (Van Doren Bottle) and three minute olUque metered tows. The collections were made above and below the proposed intake and discharge areas o f the Rush Island plant in both the Missouri and Illin o is waters. The November survey water samples were collected from two depths, surface (0-1 ft.) and mid-water (15-16 ft.). However, in April only sur face samples were taken. 2-35
The November phytoplankton collection was composed o f 44 taxa with the cominant phylum being the diatoms (Chrysonhyta) which contained 24 genera. The green algae (Chlorophyta) was second most abundant form with 15 genera being present. The blue-green (Cyanophyta) algae were repre sented by only 3 genera. The April collection contained 25 taxa with the diatoms making up the greatest percentage o f the organisms. 'Hie Jiatoi.iS had 14 genera present with the green algae having 9 genera. Only two genera o f blue-green were in the samples.
The zooplankton were not found in any great abundance during either o f the two sampling periods. This applied to both the water samples and the tow samples. The November collections contained 4 taxa with copepods being the most abundant. The April collection contained 5 taxa with copepods again being the most abundant. In each case the dominant copcpod has been the genus Cyclons.
In general, the presence of many genera of diatoms and green-algae would indicate fair to good water quality, However, some caution must be exercised when using the genus level to predict water quality. There are many species of diatoms and green algae which can be used to indicate organic enrichment and hence poor water quality. Blue-green algae are most frequently found in streams containing either large quantities o f organic matter or in areas of elevated temperature. The lack o f large quantities of blue-green algae found at the Rush Island site is a desirable condition. A summary of the holoplankton survey data is presented in Figures 2-P-C through 2-S-F. hater chemistry
The chemical data obtained from the fie ld surveys at Rush Island in September and November o f 1971, and April of 1972, are listed in Figures 2-19 through 2-21. Chemical analyses were conducted to evaluate the capabilities o f the aquatic life-support system, to asses seasonal changes in certain chemical parameters, to obtain baseline data prior to construction of the proposed power plant, and to discern the similari ties or disimilarities between the Sioux and Rush Island sites.
/lost indices of water quality, such as pH, alkalinity and specific conductivity fall within the ranges that are listed in the literature. Since these criteria are for the most part "normal, ' those factors sp ecifica lly concerned with biological productivity w ill be emphasized.
Nitrate data are presented in the referenced Figures. With two excep tions, these data show rather uniform distributions in the water column for a given sampling period. This is to be expected because o f the rapid mixing o f the river water, a fact made obvious by the high river velocity and turbulence created by the spur dikes, 'lhe first exception is for the month o f September 1971, when the river was at one of its lowest stages. The second exception is for the sixth transect for the month o f November. At that time, the river bottom was being dredged between transects 5 and 6. 2-36
Lower nitrate values are shown for September and November 1971, than for April o f 1972. This phenomenon was expected, and results from the effects of spring rains. Great tracts of land along the Mississippi River and its tributaries are heavily farmed, and spring rains wash relatively large quantities of fertilizers into the watershed. Animal industries adjacent to the Missouri River generate large quanitics of nitrogenous materials which also find their way to the Mississippi watershed.
Sewage facilities along the rivers should provide a relatively constant input o f nitrates. In a ll cases, the average values are above that estimated to be the critical concentration (0.3 ng/1) above which algal bloom conditions have been observed in lakes (Sawyer et a l., 1945: Gollenweider, 1968). Therefore, the concentrations of nitrate are su fficien t to support a high degree o f biological productivity.
Phosphate is distributed rather uniformly for a given tine period. This exception most probably resulted from the dredging between transects 5 and 6 in November o f 1971. The uniform nature o f the phosphate concen trations for September 1971, relative to those o f the nitrate, may reflect the ratios of the nutrients in the water column and sediments. Nitrogenous input to the river, relative to phosphate input, is greater because of year round activities of the animal industries. Sewage fa c ilitie s provide a relatively constant input o f phosphate, but the total input is more cyclical as a result of runoff from spring rains. The highest phosphate values are found in the 1972 April data, as in the case of nitrate, and for the reasons previously stated. The critical phosphate concentration above which algal bloom conditions have been observed is 0.01 ng/1 (o n .c it.). The indications arc that phosphate may be prod u ctivity-lim itin g in some months (for example, November 1971) but is available in sufficient quanitics at others.
A deficiency in any trace element, such as Fe. 'In, Si and Co can limit productivity. The minimal quantities of many trace elements, that are necessary for life processes are still being studied. The average con centrations of Fe and Mn in the river should not be limiting factors for primary productivity.
As previously discussed, the organisms indigenous to the benthic com munity arc of types tolerant to high concentrations of organically-gen erated materials. Such results are expected in view of the preceding statements.
With consideration for the relatively high levels of nutrients in the river at various times, it is interesting to note the low numbers of blue- green algae. This phylum normally thrives when NO and FO are available in sufficient quantities, and actually consitutes a nuisance in many cases. This apparent anomaly is easily explained by the test results o f a simple instrument that is used to measure the extinction of light 2-37
as a function of depth in the water column, namely the Cecchi disc. When placed in Mississippi River waters, this disc disappeared at a depth of approximately six inches in all cases. The basic factor determining the distribution of plants in the water column is light, because plants will grow only in the cuphotic zone, that zone which receives sufficient light for the photosynthetic processes, because of the rapid attentuation of incoming radiation, within inches of the water surface, the bulk of the river must be considered as aphotic. Due to the turbulence of the water, plants would be expected to spend variable amounts of time in the eunhotic zone, and even then the quality of light would be variable. Therefore, it is concluded that light is the limiting factor for primary productivity.
Many elements that are present in relatively s'a ll concentrations can impair or destroy life processes, liven the trace elements necessary for these life processes can become harmful i f present in sufficiently large quantities. Tt will be noted that the concentrations listed for l:e , Cu, Cd and Zn are wi thin acceptable limits as stated in effluent guidelines and standards for the state of Missouri and Illin ois. These baseline data will be useful when considered in conjunction with water discharge from the proposed plant.
It will be noted that several chemical species present in the river water exceed, at times, the limits specified in the Federal hater Quality Administration Prinking Water Standard. The species are: ammonia iron, magnesium, phosphate and sulfate. These analyses help evaluate the overall quality of the water.
The fleshy portions of Gizzard Shad were analyzed for various metals and pesticides in order to evaluate the influx of toxic naterials into the food chain . Data for these analyses arc listed below:
M etals Concentrati on Pes ti ci de Concentration
Copper 1 . lOOpp:; DDT 0 . 0 12pn::
Cadmium 2 . 500ppn PGR 0 . 040ppm
Z in c 35 . OOOppm. D ie ld rin 0 . 004pprr.
Mercury 4 . 800ppb* Chlordane O.OSOppm
* Mercury levels in the water were 0 . 2pnb.
Aiiibient levels of several pesticides were also determined during this phase of the sampling and testing. These levels are listed below. Metal analyses were previously presented. 2-38
Pesticides - ppm
Transect Sampling Location DDT PCB Dieldrin Chlordane
3-2-S 0.007 0.1 0.007 0.03
5-2-SS 0.007 0.1 0.007 0.03
4-2-S 0.007 0.1 0.007 0.03
4-2-SS 0.007 0.1 0.007 0.03
10-2-S 0.007 0.1 0.007 0.05
10-2-S5 0.007 0.1 0.007 0.03
10-4-S 0.007 0.1 0.007 0.03
10-4-SS 0.007 0.01 0.007 0.03
As expected, these materials are being concentrated up the various trophic levels. The main concern in this regard is possible synergism between heavy-netal and pesticide levels in the bodies of poikilothermic animals and heated water. The body temperature o f these animals obviously w ill increase in the heated water, and heavy metals and pesti cides are known to exhibit greater toxicites at elevated temperatures.
Physical measurements
Routine physical measurements made at the Rush Island site during the survey periods included: turbidity, velocity, temperature, water depth and bottom type.
The average transparency, a measure o f water turbidity, was six inches throughout the study area. The velocity o f the river ranged from 0.1 ft/s e c in the sheltered area to 6.0 ft/s e c in the river channel. The temperature was nearly uniform throughout the water column as seen in Tables 10, 11 and 12. The temperatures ranged from 50.0 to 80.6°F. The dentil of water in the channel varied from 28 feet to 64 feet in the April 1972 survey, which was a high water month. The river stage during Anril was approximately 10 feet above the September 1971 survey which had the lowest flow observed during this study. The bottom substate was composed o f muds to fine sands, depending on the bottom velocities. The sheltered areas were primarily fine silts and muds with fine sand located in the higher velocity river channel. 2-39
Tish Survey
Tish sampling was completed at the Rush Island s ite , in the v icin ity , of river n ile marker 140.3, in September 1071. Fish were collacted on both the Illin o is and Missouri sides of the river at distances of 0 to 100 feet and 100 to 200 feet from the shoreline. Fish were collected bv means of four 100-foot sill nets and two winded boon nets. The nets were not baited and remained in the water for a^nroximatelv 3 hours at each location. The river channel comes within 200 feet of the Missouri bank at Dike No. 140.3 R. where the collections were made. The slope o f the Illin o is shore is much less annular than that of Missouri in this area and the shallows extend more than 500 feet from the shore.
The fish collected in September 1971 consisted of 147 total fish with Gizzard Shad being the most abundant (74). There were a total of 28 commercial fish representing 6 species. The forage fish consisted of Gizzard Shad and Mooneye (14 individuals). The oredators were rep resented by two species of Gar (24 individuals). The sport fish were represented by three species (7 individuals) witli walleye being the most predominant. The catch on the Illin o is side was greater, as expected from the physical condition of the river. Details of the catch are summarized below:
Species Size Range (Inches) (Common Name) 2.0-8.0 8.0-12.0 12.0 Total Number Number Number Number
Commercial
Shovelnose Sturgeon 0 0 7 7 Largemouth Buffalofish 0 0 4 4 European Carp 0 4 3 7 Blue Catfish 0 3 0 3 Channel Catfish 3 2 1 6 Freshwater Drum 1 0 0 1
Forage
Mooneye 0 13 1 14 Gizzard Shad 14 60 0 74
Predator
Longnose Gar 0 0 7 7 Shortnose Gar 0 0 17 17
Sp_°rt
White Bass 1 0 0 1 Black Cranpie 1 0 0 1 Walleye 1 4 0 5 TOTAL 21 86 40 147 2-40
The September 1971 survey catch was compared with fish data obtained from the Missouri Department of Conservation for nettings in the vicin ity of Rush Island during 1967. The September 1971 catch had a higher percentage of forage fish than shown by either the September 1967 or total 1967 data. This may be due to bias in the collection techniques. The most outstanding difference was the absence of the carpsucker in the September 1971 catch. This is consistent with the September 1967 data which showed reduced number of carpsucker when compared to the 1967 totals. All sport fish collected in the September 1971 catch were represented in the 1967 records. Walleyes were col lected in the 1967 to a limited extent. The predator soecies were more abundant in 1971 that 1967, but in both years the same soecies were reported. Although the September 1971 data has a slightly different composition, it appears to be indicative of the fish community in this area of the river. The tabulation below summarizes the. compara tive data cited above.
Number Number Date Type Fish Of Soecies of Fish Total
4 L'eriod During Commercial 12 579 59 19 C 7 * Fora:- e 2 30 ^ 31 Predator O 9 1 Snort 5 oo 0
r. r Fen Lumber l 0 9 7 Commercial ’.) f<2 « ) Fora'-o 1 7 i1 re dator 1 1 Snort O 6 (- O ' * September l'"*71 Co nercia! 1* r r - n T’or"':'’ 2 C;r - ■'’reejatm* ?.! V -* Moort J 7
* data supplied by the "issouri Department of Conservation from netting records, Personal Communication John W. Robinson, Fisheries Biologist, June 1972.
The Anril 1972 survey included a program for the colle.ctior. of fish eggs and larvae. Sampling was accomplished using a l-'-V-ji nosh net nod a speciallv de.sig ied cod end. -\ series of 22 to'-s wore te'-cn hnfoeo mi In uarkar l-V'.'i a. nu 12C. The tn'-s -’ere. ohlione. 2 minute net<*red tow;, T.n addition to thes e fish larval tows . all plankton samples were analined for the presence of fish eggs and larvae. Mo fish eggs were present and only one fish, larva was found. The fish larva would probably have tlu. ir^ maximum density in the month of June. 2-41
2.4 Interrelation of Projects in Operation by Others^
In the vicin ity o f the Rush Island Plant s ite , there are no public or quasi-public facilities of the Magnitude of the proposed project. The only significant operations involving a large number of em ployees are shipment and storage of materials and related activ itie s at the USS, Arri-Chcmicals plant and the River Cement Company plant. Both of these operations are independently operated, using access roads from U. S. 61 and the St. Louis-San Francisco Railway Company (F risco).
The Frisco has a single track operating along the base o f the bluffs adjacent to the Rush Island Plant site. The Mississippi River is probably the most important transportation fa cility within the area o f the proposed plant. This river is in active use, has a high volume o f t r a ffic , and is in a constant state o f maintenance and improvement.
The St. Louis D istrict, Corns o f Engineers maintains a 9 -foot by 300-foot channel for navigation on the Mississippi River adjacent to the site of the proposed project. The navigation channel is ap proximately 150 feet of the Missouri shore, and is 20 to 25 feet deep in this area. Project dimensions are primarily obtained by channel stainlization works to constrict river widths, i.c., dikes and bankline revetments. Some dredging is necessary, however, to maintain the project dimensions.
The proposal for a St. Louis Metropolitan Airport in the Waterloo area, approximately ten miles to the northeast o f the Rush Island Plant site, will have no direct interrelation with the area.
2.3 Future Environmental Setting in Absence of Project
A number o f studies have been made in Jeffoi'son County relating to present and future development. These include a report on Economy and Population, ' prepared by ilarland Bartholomew and Associates in 1964: the Comprehensive U’ater and Sewer Plan for Jefferson County,’ prepared in 1970; the 'Major Highway Plan for Jefferson County. ’ prepared in 1968: and the proposed land use plan, The Quest for Tomorrow, submitted in three volumes, dated 1969. All of these reports and studies, except for The Quest for Tomorrow,' were prepared without knowledge of the proposed Rush Island Plant development.
The Quest for Tomorrow' (Land Use Plan), Jefferson County, dated June 1969, indicates continued urbanization of the northern portion o f the county, with this urbanization extending down tne 1-55 cor ridor to Festus-Crystal City. A second level of residential develop ment is expected to take place in the area between the 1-55 corridor 2-42
over the urban corridor extending down Missouri Highway 30. Minor and major commercial centers are expected to be established throughout the urban and suburban areas previously described, with the largest commercial area anticipated in Festus-Crystal City.
A majority of the future industrial development in the county is expected and planned within the 1-55 corridor. Four industrial areas were recommended by the Land Use Plan in the northern portion, one on the Meramec River, one on the Mississippi River, and two immediately west of 1-55. Three large areas are planned at the lower end of the corridor, the largest of these located along the Joachim Creek west of Festus-Crystal City. Another future industrial development is planned in the Herculaneum area, and another fairly large one south of Crystal City.
The eighth and largest industrial area is planned in the southeast corner of the county on Ilarlow and Rush Islands - the site of the Rush Island Plant. Smaller industrial areas are also shown on the Land Use Plan in DeSoto.
A greater part of Jefferson County is expected to remain in a rural or agricultural status. A ''rural resource area is anticipated in the central parts of the county, extending over into the southeast com er. Thus, those parts of the county immediately west of the Rush Island Plant site are expected to remain relatively sparsely populated and rural in character. The western and southern parts of the county are shown as agricultural areas in the Land Use Plan.
The Land Use Plan served as a basis and was incorporated into the Comprehensive Sewer and Water Plan, and the population distribution and long-range sewer and water systems were designed on the basis of the densities created by this Land Use Plan. Projections of popu lation for Jefferson County were prepared in the original reports and were continually refined. A preliminary report on land use for Jefferson County, prepared in 1967, provided projections of popula tion distribution and density for the entire county. The latest projection of this type was contained in the report on the Com prehensive Water and Sewer Plan prepared in 1970. For Plattin Township (see Figure 2-2) with a 1960 population of 3,260, popu lation was estimated at 4,505 in 1967, and 5,500 in 1970. The population, according to the 1970 Census, was actually 4,407. The I960 density of 31 persons per square mile increased to 42 persons per square mile in 1970, or approximately 12 families per square m ile.
The population of Plattin Township is estimated at 18,000 persons by 1985, and 19,000 persons by 1990. However, these estimates appear to be high, and the population is expected to be something less than 2-43 that figure. Should this area continue to attract approximately five percent of the county's population, it would have a 1990 population of about 12,000 persons, or a density of 100 to 110 persons per square mile.
It should be pointed out, however, that most of this population growth in Plattin Township will consist of the expansion of the Festus-Crystal City area, in the neighborhood south of the U. S. 61-67 intersection. Also, much of this population increase is anticipated to extend along 1-55 and U. S. 61 south to the Ste. Genevieve County lin e. In summary, there would be very li t t le population growth within most of the rural areas of Plattin Town ship. In the absence of any unexpected land use developments, these areas should remain relatively the same, i.e., sparsely populated rural areas. Much of the land will remain in forests, will be relatively remote, and will have a character similar to its present circumstances.
The future environmental setting within Plattin Township will be greatly dependent upon the types o f planning and controls initiated by county and metropolitan agencies. The present lack of controls has resulted in development of a considerable number of low-quality residential structures, placement of mobile homes on an individual lot basis, illegal dumping of trash and refuse, open storage of materials, and other unfortunate manmade intrusions upon the land scape within Jefferson County. Serious water pollution problems exist within the county and the disposal of solid wastes is now endangering the county's environment.While Plattin Township is somewhat remote from the growing northern areas and the Festus- Crystal City area, and their serious environmental problems, it will to some extent reflect these problems to a lesser degree. There is the prospect of water pollution, waste disposal and uncon trolled and unregulated building and development.
A Mississippi River bridge crossing has been proposed as a part of the long-range highway plan for Jefferson County. This bridge is under consideration by the Missouri-Illinois-Jefferson and Monroe County Bridge Commission, and an in itia l study has recommended a crossing in the vicin ity of Herculaneum. This crossing would be located approximately 10 to 12 miles north of Rush Island. However, it is anticipated that this bridge crossing would not become a reality until approximately five to ten years after the completion of the Rush Island Plant.
The proposed Pine-Ford Reservoir is a part of the overall flood control project for the Meramec River Basin. This reservoir, partially located in the southwest section of Jefferson County, would lie approximately 20 miles to the west of Rush Island Plant and would have no effect on the area in the vicin ity of the Rash Island Plant. 2-44
Since this site has been devoted to agricultural use for some period of time, such use would probably continue in the future, i f the project was not implemented. Use o f the area for agri culture is reasonably compatible with the natural setting. There is , however, no assurance that the semi-natural nature o f this area would be preserved in the absence of this project. The site has a number of qualities, such as accessibility, water supply, extent, and level topography, which might well influence a shift to some form of Indus tria l use unless the area was zoned to prevent such use. 3-1
SECTION 3
ENVIRONMENTAL IMPACT OF TOE PROPOSED ACTION
The following sections identify the environmental impacts o f the Rush Island Plant as changes or conversions of the environmental elements of the surrounding area. This includes an analysis of the impact on land areas, water quality, air quality, the economy, social conditions, noise, aesthetics, roads, commercial a ctiv itie s , fish , w ild life and recreation.
3.1 Air Quality Considerations
With the two boilers at the proposed Rush Island Plant operating at the maximum load with low-sulfur coal, the local and national primary am bient air quality standards w ill be sa tisfied . The concentrations of air contaminants are calculated to be lower than the national secondary ambient air quality standards, set by the Federal Environmental Pro tection Agency. The expected concentrations and emission rates are compared to the national and state a ir quality standards in the table below, and the comparison is detailed in the following paragraphs.
Sulfur Dioxide Nitrogen Oxides Particulates
Expected Emission Rate (lbs/m illion BTU heat input) 2.0* 0.45 0.06
Missouri Allowable Emission Rate (lbs/m illion BTU heat input) 2.3 None 0.18
Maximum Expected Ground Level Concentration (ppm) 0.0004* 0.0002 **
National Primary Ambient Air Quality Standards (ppm) 0.03 0.05 0.025
National Secondary Ambient Air Quality Standards (ppm) 0.02 0.05 0.02
* Expected values based on use of low-sulfur coal. ** Not expected to cause any measurable ground level concentration due to plant operation. 3-2
A list of calculated maximum ground level concentrations of sulfur dioxide and nitrogen oxides resulting from plant operation Is shown in Figure 3-17.
These concentrations were calculated using computer modeling techniques and show maximum hourly concentrations o f each compound under neutral, unstable and very unstable atmospheric conditions. The impact on inversion is discussed later.
The Federal Environmental Protection Agency has prepared estimates o f annual ground level concentration of sulfur dioxide resulting from the operation of coal burning power plants in the St. Louis area. Curves showing these annual concentrations are presented in Figure 3-18. The curve o f ground level concentrations for the Labadie Plant, which has boilers similar to Rush Island boilers, shows a maximum concentration occurs at a distance of three to four miles from the Labadie Plant and that the average annual concentration is estimated to be 0.0006 parts per m illion (ppm). This curve, however, is based on the operation of only one unit. Therefore, the annual average for two units would be about 0.0012 ppm i f they were to burn a 32 sulfur content coal. As the proposed Rush Island Plant will burn 12 sulfur content coal, the annual average groun level concentration resulting from the operation of this plant should be approximately 0.0004 ppm.
The contribution from the Rush Island Plant, as a percent of the national allowable concentration of 0.02 ppm, w ill be 22. Based on measurements of sulfur dioxide in and around the St. Louis metropolitan area, the present estimated background concentration of sulfur dioxide in the vicin ity of Rush Island is expected to be 0.01 ppm. Based on the foregoing analysis, the Rush Island Plant will contribute only 42 to the ground level concentration of sulfur, dioxide in the area after the plant is in operation.
The concentrations of nitrogen oxides in the flue gas of power plant boilers w ill typically range between 330 ppm and 1200 ppm, depending upon the b oiler design and whether the boiler is burning natural gas, o il , or coal. The only known means of reducing these emissions is through the use of special firing techniques or by designing the boiler so that the burning process results in a minimum amount of nitrogen oxide generation.
The boilers which will be Installed at the Rush Island Plant site are tangentially fired. This particular method of firing is to date the most favorable in terms of limiting nitrogen oxide production.
The Federal Environmental Protection Agency conducted tests on the boilers at Union E lectric's Labadie Plant on 7 and 8 June 1971. These boilers are basically identical in design to the boilers which will be installed at the Rush Island Plant. Nitrogen oxides in the flue gas of the Labadie Plant boilers was found to average 340 ppm. This is about one-third the concentration of sulfur dioxode which will be contained in the flue gas. By comparison, ground level concentration of nitrogen oxides resulting from the operation of the Rush Island Plant will be approximately one- third the expected ground level concentration of sulfur dioxide. Therefore i f annual average concentration of sulfur dioxide at ground level is on the 3-3
order of 0.0004 ppm at the Rush Island Plant as indicated previously, the ground level concentration of nitrogen oxides at the Rush Island Plant will be 0.0001 to 0.0002 ppm. The operation of the flush Island Plant will probably add only 0.3% of the standard ground level concentration of nitrogen oxides.
Electrostatic, ash collectors with a design efficiency of 99.5% will be installed to remove particulate matter from the stack gas. Based on the ash content of the coal to be burned, the emission from the stacks w ill be less than 0.06 pounds per million Btu of heat input to the plant. At full load on the plant this would result in the emission of 600 pounds per hour of particulate matter. On an annual basis it is expected that the plant would emit about 2000 tons of particulate matter. This should not, however, produce any measureable ground level concentration in the immediate area of the proposed plant.
During periods of inversions, mentioned in Section 2, no major action was required to reduce emissions from the power plants in the St. Louis area. The additional contaminants emitted by the Rush Island Plant should not affect the normal actions taken during periods of inversions, nor appre ciably affect ground level concentrations during such periods.
The coal that will be burned at the Rush Island Plant contains a trace of Mercury (0.2 ppm). Many of the common metals in the coal such as copper and aluminum w ill be carried through the boiler in the flue gases and w ill be collected by the electrosta tic precipitators. Mercury, w ill, in part, vaporize and pass through the precipitators and out the stack.
An investigation regarding the emission of mercury from the Four Corners Power Plant was the subject of a letter from the Administrator of the Federal Environmental Protection Agency, Mr. Ruckelshaus, to Senator Clinton P. Anderson of New Mexico. The le tte r, dated 25 June 1971 re garding these emissions, stated that i f the coal burned at Four Corners contained 0.5 ppm by weight mercury, and a ll of this mercury was assumed vaporized and emitted from the stacks of that 2165 MW plant, estimated mercury concentrations at ground level would be less then 0.05 micrograms per cubic meter. The letter went on to state that the threshold limit value of 50 micrograms per cubic meter has been set by the American Con ference of Government and Industrial Hygienists for industrial exposure over an 8-hour day, 40-hour week. It was also pointed out by Mr. Ruckelshaus that based on present medical evidence, 0.10 micrograms per cubic meter is well below levels at which health or welfare effects have been observed.
As the mercury content of Illin o is coal is about 0.2 ppm as compared with the 0.5 ppm burred at Four Comers, it is considered that mercury emissions from the Rush Island Plant will probably not be significant. 3-4
3.2 Land Loss and Land Use Changes At or Near the Project Site.
The Rush Island Paver Plant complex w ill convert approximately 500 acres of Mississippi River flood plain into 3n industrial type operation. This will obviously change the character of the project lands, fror. open space to buildings and related structures. The plant facility will consist of buildings, roads, parking spaces, storage areas, and levees within inter vening landscaped areas. Parts o f the proposed site w ill remain in a natural state. Union Hlcctric has stated that this property will be main tained at a level comparablc to the higher quality private developments in the v icin ity.
There w ill be very few employees from the project living near the project, therefore, the project w ill not cause a demand for housing in the area with tiie subsequent alteration o f land use in the area. F-urthcr, it is anticipated that existing service and commercial establishments will realize a moderate amount o f business due to the proposed power plant. The increased business, however, is not expected to result in the estab lishment o f any new commercial fa c ilit ie s . In summary, it would appear that the proposed power plant complex at Rush Island w ill create no sig nificant land use changes or loss of rural land in the vicinity.
In order to minimize the effect of the proposed plant on the terrestrial wildlife, as much area on the site will be left in a natural state as construction activity will allow. After construction is completed, ad ditional area will be allowed to return to a wild or natural state. Of the approximately 500 acres o f river bottom land at the s ite , the company plans to permit over 150 acres to remain or return to a wild or natural state. Preconstruction activities at the site , including the placement of hydraulic fill, have removed most of the natural wildlife habitat and caused the relocation of most terrestria l animals. Thus, the land which is restored or remains will provide more wildlife habitat than is currently available, and will provide more wildlife for a variety of small ter restrial animals than was available when the area was used for agricultural purposes.
3.3 Ippact on Economic and Social Conditions.
The Rush Island Plant will have very lit t le impact unon the economy of Jefferson County as a whole. This is due to the fact that very few of the 175 employees w ill reside in Jefferson County, nor w ill the employees be using, supporting facilities to a degree that would greatly affect any single element of the economy. Therefore, there w ill be no significant house construction and related supporting facilities normally generated by new residents because of the Push Island Plant. It is anticipated that pro bably fewer then ten employees w ill locate within the vicin ity and it is entirely possible that none of the employees w ill live east o f U. S. 67 and south o f Crystal City. It is anticipated that no commercial estab lishments will locate adjacent to the Rush Island riant solely to serve the plant. There is not enough employment to support a single-purpose commer cial establishment in the vicinity of the plant. It is anticipated that the employees w ill make use of such establishments as automotive services and restaurants on the highway. This w ill be in the form of increasing the 3-5
Business of established commercial fa c ilit ie s , but w ill not be of enough volume to create the need for new service stations, restaurants, and the like. The Rush Island Plant will create more of a demand for most of the commercial fa c ilitie s during construction than during actual operation. During final operation, the 100 to 125 employees on the normal weekday shift will not significantly affect highway traffic on U. S. 61, and it w ill create a relatively small volume of tra ffic on the access roads as compared to the tra ffic during construction.
The effect of the proposed plant on social conditions within Jefferson County will be inconsequential. The Rush Island Plant d l l not create an influx of new people, due to the fact that few of the people employed at the plant will reside within the area.
In the event that some of the employees eventually reside in the vicin ity of the plant, the economic impact would be relatively minor compared to total activity in tne area. Should as many as ten employees and their dependents move into the area, i t w ill not be a large percentage of the areas growth. Between 1960 and 1970, about 600 families moved into the eastern part of Plattin Township. A total of ten plant-generated families would represent only about two percent of the total.
After the Rush Island Plant goes into service, it is expected that the assessed valuation of the plant will be about $100 million. Of this $100 m illion about $10 m illion w ill be a local assessment and $90 m illion w ill be a distributable assessment.
The loca l assessment w ill be the subject of local taxes, such as school, taxes, county taxes, fire district taxes, etc. The taxes on the distri butable assessment are distributed over the area in Missouri served by Union Electric Company on the basis of the miles of line in each county. Currently, Jefferson County is the recipient of about 1/6 of the taxes paid on the distributable assessment and the other 5/6 of these taxes are distributed to other counties in the State of Missouri.
The Rush Island Plant will not cause the curtailment of any of the exist ing commercial uses in the area. These commercial uses are located along Highways 61 and 67, and are distant from the project. It is anticipated that the employees of the Rush Island Plant traveling to and from work w ill, in fact, contribute some limited amount of income to certain of these businesses, such as filling stations, restaurants, and the like.
3 .A Transportation
No major realinements or relocations of existing roads to serve the plant site are currently being contemplated by either the company or the public agencies responsible for roads. 3-6
A grade separation is under construction at the Rush Island Plant site entrance between Big Hollow Road and the St. Louis-San Francisco Railway Company tracks. This requires minor horizontal and vertical realinement o f Big Hollow Road to make the grade separation functional. Big Hollow Road will be raised to pass over the railroad in lieu of the current "at-grade" Intersection.
Jefferson County w ill add a surface treatment o f lignin sulfanite to Big Hollow Road and Johnson Road to provide a 95 percent dust-free surface, if a current experimental surface proves satisfactory.
Jefferson Countyis proposing to construction a bridge at the Saline Creek crossing on Big Hollow Road to provide approaches to the bridge and raise the roadbed above high water.
Jefferson County is also considering minor realinement at several hori zontal curves to reduce the curvature; however, extent and locations have not been determined.
New roads w ill be constructed within the Rush Island Plant site to provide ingress and egress to and from the various plant functions.
Anticipated plant-generated traffic
The construction and operation of a plant of this magnitude will generate traffic that otherwise would not be present in this particular area. Be cause of significant differences, traffic generated during the construction phase of the project will be treated separately from the operation phase.
Construction phase (1972-1976)
During the height of the construction phase, the number of construction employees may approximate 1,000 employees. An analysis of labor avail ability indicates that approximately 50 percent of these employees will originate in the St. Louis area and will be arriving and returning via northern routes. The remaining 50 percent of construction employees w ill probably originate from west and south of the plant s ite . Due to the absence of major east-west routes in the plant site area, and the more densely populated area west and northwest of the plant site, it is assumed that approximately 80 percent of the employees w ill be arriving via the north route and 20 percent arriving via the south route.
In addition, while most o f the heavy equipment w ill be arriving at the plant site via rail or river barge, it is anticipated that the piling and aggregate for concrete will be arriving via truck. It is assumed that these deliveries will average 50 trucks per day and will be arriv ing via the north route from the St. Louis area. 3-7
Undoubtedly, some car pool operations would develop, however, the maximum condition that could occur would be one employee per vehicle. For this analysis, it Is assumed that one occupant per vehicle w ill arrive and de part and that 50 trucks per day w ill arrive and depart.
Assuming a five-day work week, the anticipated generated ADT during the construction phase would be 1,210 vehicles per day via the north route and 285 vehicles per day via the south route.
Considering the north access to the plant site, i .e . Route 1-55 to Route 61 to Route AA to Drury Road to big Hollow Road, approximately 800 vehicles w ill be arriving during the hour before normal starting time and leaving during the hour after quitting time. During the several-month period for construction the bridge on 3ig Hollow Road over Saline Creek, it is anticipated that Big Hollow Road w ill be closed and all construction traffic would be required to use the south access route to the plant site.
Operation phase (1976-Future)
With Rush Island Plant Units Nos. 1 and 2 in operation, it is anticipated that 175 employees per 24-hour day w ill be required. While the majority of these employees w ill be on the day sh ift, the total employees determine the projected generated ADT.
As in the Construction Phase, it is assumed for maximum generated ADT, that one employee w ill arrive and depart per vehicle. Utilizing the same directional sp lit as for construction employees, i . e . , 80 percent to or from the north and 20 percent to or from the south,the generated ADT on the north access route would be 280 vehicles per day and 70 vehicles per day on the south route. These figures are based on a seven- day work week.
Road Summary
The critica l period, relative to generated tra ffic to and from the plant site, will be during the anticipated four year construction period. During this period, plant-generated traffic will increase ADT on roads in the plant area from approximately 10 percent on Route 61 to approximately 1,200 percent on Big Hollow road, a portion of Drury Road, and a portion of Route AA. Plant-oriented traffic should have little or insignificant effect on Route 1-55 ADT.
Congestion w ill probably be experienced at intersections along the north access route, particularly during the hour immediately preceding and after the daytime construction work shift.
Major construction, relative to building of roads, consists of the grade separation at the St. Louis-San Francisco Railway Company tracks and the 3-8
bridge at Saline Creek, both on Big Hollow Road. While considered as major construction, each project will involve relatively small lineal lengths of road.
State and County highway department maintenance operations on the access roads to the plant site , particularly on the aggregate and macadam sur faced roads between the Rush Island Plant site and Route 61, may need to be increased during the plant construction phase. The tra ffic w ill increase materially on these roads during this period.
There should be no significant environmental impact du»? to the construction of the above-named grade separation and bridge on parks, recreation facil ities or areas, historic sites, or known aboriginal sites. Any incon- vienience to the public during their construction will be materially offset by the increased safety provided by the railroad grade separation and the year-round use o f Big Hollow Road due to the construction o f the Saline Creek bridge.
River tra ffic
The construction of a power plant and appurtenant structures at Rush Island is not expected to adversely affect the rising trend o f tra ffic on the Mississippi River. In fact, the plant would probably reinforce the rising rate of commercial waterborne tra ffic in the area o f the plant. Proposed barge mooring and coal handling fa cilitie s w ill allow fuel to be delivered to the power plant complex by waterborne craft.
3.5 Impact o f the Plant on Wildlife
There have been reports of heavy killings when migratory birds fly into tall buildings. These fatalities are generally associated with brightly lighted structures, although red navigation lights, as installed on power plant stacks, have presented no known hazard to birds. All the company's power plants have been surveyed to determine i f any carcasses have ever been found at the stacks, at transmission towers, under trans mission lines, or at other structures; the answer is uniformly negative (Labadie, Sioux, Meramec, Cahokia, Venice Plants).
The Mississippi River flyway is quantitatively the largest in the United States. Ducks, both puddle and diving, as well as geese, (Canada, blue, snow, and a few white-fronted) use the flyway, feeding along the route. There are no feeding areas near the Rush Island plant site, that is , no lakes, shallow water in the river, nor shore habitat which would shelter waterfowl. However, the Rush Island Plant site it s e lf, while 400 of its 500 acres were under cultivation, would no doubt have been attractive to ducks and geese as a feeding area during migration.
The Mississippi River Valley is also an important flyway for song and shore birds. No detrimental effect on birds has been found at any existing 3-9
Union Electric Power Plant. Five of the company power plants are situated on the Mississippi Itiver, some of .them quite similar to the proposed Rush Island development. No adverse effect on the migration of song or shore birds is expected.
The construction and operation of the Rush Island plant and related trans mission facilities is not expected to appreciably affect local populations of small terrestrial animals or game indigenous to the area (see page 2-29). Although there will be a loss of habitat for these creatures, experience has demonstrated that local varieties of wildlife are adaptable to the intru sions of power plants and transmission facilities on their environs as long as appropriate habitat is available. Of the 500 acres comprising the plant s ite , about 150 acres are so located that they w ill not be involved in the construction or the functioning of the proposed plant. These 150 acres will be allowed to remain or return to a natural state, providing cover and refuge for wildlife. Crops of corn or soybeans raised on Rush Island may have contributed to the food o f deer, as well as other farmland' wildlife. Elimination of this intermittent source of forage in the re stricted area of Rusli Island is not expected to have any measurable • detrimental effect on the animal population of the surrounding area as a whole.
Implementation of the proposal is not expected to have any significant adverse e ffe ct to game species of birds such as quail. Although the acreage disturbed by construction, as well as the land immediately adjacent will no longer be available to game bird species, this was not the best country for such species. The land was cropped in small grains when cultivated, but game bird populations would vary, depending upon the amount of farming, efficiency of farming, and the available dispersion (edges of the field s and weeds blending into woods) . Because o f the frequency of flooding, the land was not available to game bird species on a year-round basis. Game bird populations fluctuated drastically with river conditions.
Despite the careful design of the plant intake, some fish eggs and larvae w ill be subject to transport through the cooling system of the power plant. The predominant fish species in the area include the gizzard shad, gar, blucgill, catfish and fresh water drum. Eggs and/or larvae of some of these species which may be differentially affected are shown in the following tabulation: 3-10
Mode o f Approximate Periods o f Maximum Spawning Eg£ Fecundity Species Mar Apr May Jun Jul Aug Deposition Per Female (in thousands)
Gizzard Shad X X X Benthic * 30-70 Adhesive
Freshwater X X Benthic 10-100 Drum Attached
Channel X X X Benthi c 3 -ISO Catfish Nest
White Bass X X X Benthic 25-10 Nest
Bluegill X X X X X X Benthic 1-5 Nest
* Benthic adhesive eggs o f shad are heavier than water and, there fore, sink to substratum to which they normally adhere. Other species deposit eggs either directly into nests or directly onto substratum in clusters.
It may be noted that none of the key species produce a pelagic or floating egg. Most of these fresh-water fish deposit eggs into closely guarded nests or attach sticky egg masses directly to the substratum. The intake o f eggs, if any are entrained, and larvae from gizzard shad will probably be greater than any other species because of the large number of these fish present in the Mississippi River. The reproductive rate of the gizzard shad is high. Moreover, these fish spawn in April and May when cooling water requirements for the plant are minimal compared to the river flow. Based on the preliminary aquatic survey conducted at Rush Island and comparative information obtained from the Connecticut Yankee and Consolidated Edison's studies, it is concluded that the plant oper ation will not measurably effect changes in populations of the gizzard shad or other fish species.
As previously mentioned in Section 2.3, the April 1972 Rush Island survey did not recover any fish eggs and only one fish larva in a total o f 22 tows. Although this information cannot be compared directly with the Connecticut and Consolidated studies, it is in general agree ment with the fish egg and larvae densities found in the Connecticut and Hudson Rivers, respectively. In the latter studies, the fish egg density varied from approximately 0.C0001 to 0.0001 eggs per gallon of water while fish larvae density varied from zero to 0.007 larva per gallon. For purposes o f illu stratin g the entrainment impact on gizzard 3-11
shad, assume the fish egg density to be 0.00005 eggs/gallon and fish larvae to be 0.0035 larvae/gallon. The maximum water require ment for the Rush Island condenser system is approximately 600,000 galIons/minute or 864,000,000 gallons/dsy. Therefore, the total number o f fish eggs that could be entrained is 43,200 per day or a total of 907,200 over a three-week period. If the fecundity of gizzard shad is assumed to be 50,000 eggs per female, and assuming that this species represents fifty percent of the total eggs present, the equivalent adults lost from entrainment (two adult fish per 50,000 eggs) will be approximately 18 fish. The impact of the individual remaining species should be less than the gizzard shad, since the entrainment density w ill be less and the fecundity w ill be about the same.
Little or no information is available from the literature concerning the rate of survival of eggs and larvae which may be entrained. In order to estimate the number o f adults that would have been produced from the number of larvae lost by entrainment, the following assump tions and considerations were made. TWo life stage sets were used in the survival rate calculation: eggs to larvae and larvae to adults. Mortality percentages of 75 to 25 were assigned to the set assuming the individual species exhibited little parental care. For the gizzard shad, the number o f larvae surviving from the eggs would be 25% o f the fecundity o f 12,500 larvae. Since two adult fish must survive to maintain a stable population, the survival rate for the 12,250 larvae is the two adults divided by the number of larvae, or 0.016%. The total number o f transported through the plant condenser system is estimated to be 3,024,000 larvae per day (864,000,000 gallons/ day with 0.0035 larvae/gallon). If fifty percent of the larvae present are gizzard shad, the final number o f adult gizzard shad that would have been produced is the number of gizzard shad larvae lost multiplied by the survival rate. This amounts to 242 adult fish per day or a total of approximately 17,000 fish , assuming the larval forms to be present over a period of 70 days. Larvae from other fish species will be transported through the plant condenser in a similar manner. However, since each of the other fish species represents no more than ten to twenty percent of the gizzard shad population, the total impact should be nominal.
The survival rate o f entrained organisms w ill depend on the final discharge temperature, the period of exposure and the incipient lethal temperature for the organism in question. Furthermore, experience" has shown that each developmental stage o f a fish egg and/or larvae is characterized by a different incipient lethal temperature. With out knowledge of these temperatures, it is impossible to predict organism survival. Therefore, in the preceding discussion it was assumed that all entrained eggs and larvae would experience 100% mortality during condenser system transport. 3-12
Whereas fish eggs and larvae result from a single annual reproduc tive period, bacteria, phytoplankton, and zooplankton reproduce many times per year or per day, or as is the case with the bacteria, possibly many times per hour. As a result o f the high reproductive capacity displayed by these organisms, their respective populations may be considered more resilient and, therefore, more resistant to predative alterations in population structure. The very nature o f the organisms imply that their functional niche in the aquatic ecosystem is one of resilience and fluctuation of abundance in accordance with natural environmental change, as well as predation pressure. It is therefore reasonable to assume that the removal o f relatively small numbers of such organisms from the ecosystem by transport through the condenser system of a power plant or entrainment in the thermal plume could easily be compensated for by the high reproductive potential o f the species involved.
Possible effects o f heated water discharge on the aquatic ecosystem o f a waterway, though subject to speculation and a variety of opinions, is a legitimate concern. The design of the heated water discharge outfall from the proposed Rush Island power plant provides a substantial margin of pro tection over that required by water quality standards o f Illin ois and those proposed by Missouri. The discharge port is 525 feet from the shoreline at median water level (elevation 368' m .s .l.). Thus, the heated water discharged w ill be mixed with the main channel river flow. This design w ill insure protection o f areas near the shoreline that provide habitat for aquatic life and encompass known fish migration routes. The influence on fish population and aquatic life-cycles from heated water discharged in this manner is expected to be minimal. In the event that this concept proves to be deficient, the company has stated that it will rectify the situation with the addition o f supplemental water cooling devices.
3.6 Water Quality Consideration
All water quality standards and guidelines, enacted or proposed by the Federal Environmental Protection Agency and the States o f Missouri and I llin o is , w ill be met with the design o f the Rush Island Plant. A b rief narrative describing the thermal discharge criteria of these Federal and State agencies is attached to this statement as Appendix C.
Thermal effects
After reviewing several alternate cooling system designs (see Section 5.5) Union Electric selected a once-through cooling system with a midstream point discharge for the Rush Island power plant. The flow in the Mississippi River at the Rush Island site is sufficient for this type of discharge (See tabulation below). The center river discharge will provide "a reasonable zone of passage for aquatic life " along both shorelines. 3-13
Increase in Average River Water Temper- Minimum 7-day Maximum % o f ature Caused by Average Flow-1000 River Diverted Rush Island Plant Month cubic ft. per sec.* Through Plant of**
January 38.4 3.5 0.70 February 49.2 2.7 0.54 March 52.8 2.5 0.50 April 121.3 1.1 0.22 May 124.6 1.1 0.22 June 111.7 1.2 0.24 July 79.1 1.7 0.34 August 60.7 2.2 0.44 September 68.0 2.0 0.40 October 63.0 2.1 0.42 November 64.1 2.1 0.42 December 36.7 3.7 0.74
* See Figures 3-1 and 3-2. ** Increase in average river water temperature is calcualted by using per- cent of river diverted through plant and a 20°F rise in temperature o f this water. Percent of river diverted through plant is based on minimum 7-day average flow. Average river water temperature is based on the daily mean temperatures recorded in the Union Electric Meramec Plant logs and charts for the years 1964 through 1970.
Monthly temperature lim its, maximum recorded river temperatures, and tern- peratures that w ill not be exceeded more than 1% of the tine are tabu- lated for each month as follow s:
RIVER TEMPERATURES AND PROPOSED STANDARDS*
Monthly Temperature Ambient River Maximum Recorded Standard That May Temperatures Which Ambient River Be Exceeded Less Are Exceeded Less Temperatures Than 1% of the Time Than 1% o f the Time Month °F °F °F
J anuary 44 50 39.5 February 44 50 42 March 55 60 52 April 69 70 64 May 76 80 75 June 82 87 80.5 July 87 89 86 August 86 89 85 September 82 87 80 October '72 83 71 November 57.5 70 57 December 46 57 43 * See Figures 3-3-A through 3-3-L. Temperatures shewn on these figures are daily mean temperatures taken from Union Electric Meramec Plant logs and charts fo r the years 1964 through 1970. 3-14
When using the once-through cooling system, the average temperature rise o f the river after mixing is expected to be approximately 0.5°F, based upon a minimum summer weekly river flow o f 60,700 cubic feet per second. This is the minimum flow o f record during the c ritica l summer months. River flow is usually substantially above this flow, and the change in river temperature is expected to be less than 0.5°F. During an abnormally high temperature summer, the maximum river temperature standard (column 3 of the above tabulation) might be exceeded less than one percent of the time. The normal ambient river temperatures which might be exceeded less than one percent o f the time, however, are less than the maximum recorded ambient river temperatures. The expected temperature rise is well within the enacted and proposed thermal discharge criteria.
Mathematical modeling techniques have been used to develop the temperature distribution patterns, or plumes, in the Mississippi River caused by the discharge of heated water from the Rush Island power plant. The isotherms, lines drawn connecting points o f equal temperatures, for the midstream point discharge for the months o f May, July and August are shown in Figures 3-4-A through 3-6-C. May, July and August are the months of the year in which the heated water discharge temperature w ill result in river tempera tures approaching the maximum temperature limits o f the standards and the proposed criteria . The mathematical modeling techniques are included as Appendix D. This model was developed after an analysis o f existing power plants was made.
A detailed evaluation o f water quality standards and proposed criteria the isotherms developed from the mathematical modeling and other related physical data for May, July and August is shown on Figure 3-7. The evalu ation Figure 3-7 clearly shows the heated water discharge from Rush Island Plant w ill comply with the water quality standards of Illin ois and those proposed by Missouri, which both follow the proposed standards of the Environmental Protection Agency.
Additional mixing and spreading of the heated plume will occur at times as a result o f river tra ffic and wind forces. However, the widths o f the mixing zones estimated for Rush Island Plant are always less than 50% of what is allowed by the standards which allows a very great margin to cover these conditions. biological effects
The biological impact from the operation of a power plant at Rush Island may possibly result in four types of adverse effects upon the aquatic forms in the Mississippi River. These are (1) impingement and destruction of Organisms against the screens at the intake structure, (2) mechanical damage to organisms during passage through the plant pumping system, (3) thermal effects on entrained organisms resulting from rapidly increased 3-15 temperatures in condensers together with some sp ecific resident time at these eleyvated temperatures and (4) thermal distress to aquatic life in the mixing zone because of elevated temperatures, low dissolved oxygen and/or yoxic chemicals. Secondary effects may result in alteration of food webs and changes in reproductive cycles of the biota.
Since/the actual aquatic impacts o f the proposed Rush Island Plant cannot be de/termined until the plant is in operation, many o f the impacts described in this section are predicted on the basis of actual effects experienced at the/existing Union E lectric Sioux Power station. This impact analysis is bas/ed on information obtained from several aquatic programs conducted by Union E lectric at the Sioux Plant as part o f their Environmental Surveil lance Program. The Sioux Power Plant Aquatic Program was conducted to evaluate the effects on the aquatic ecosystem of the Mississippi River resulting from the operation of a power generation station. A description of the Sioux Testing Program and a comparison o f the two power plant sites follows :
A Sioux Program
In August of 1970, Union E lectric in itiated an aquatic study program in the vicin ity o f their Sioux Power Plant near Portage de Sioux, Missouri. The principle objective of the study was to define the three dimensional thermal plume from the Sioux Plant and to evaluate the biological effects of the plume on the aquatic ecosystem. The in itia l studies were completed in November, 1970. The following year, these studies were extended to cover the remaining seasons and thereby provide an annual assessment of the Sioux Plant operation. These later studies were completed in June, 1971.
The studies at the Sioux Plant covered three general areas: (1) the chemical and physical state o f the river, (2) the extent o f the thermal plume under various operating and meteorological conditions and (3) relative distribution and condition o f the biota found in the plume and in controlled areas.
The major biological sampling areas for the Sioux Program were located between Mississippi River mile markers 210 to 209. Most of the sampling was accomplished adjacent to and within the plant intake and discharge canals. Figure 3-8 is a sketch showing the plan o f the plant in relation to the river and sampling stations.
The Sioux Study has provided an information base from which to operate in the future. In terms of sp ecific interest, the study had given in sight into the effect upon the aquatic ecosystem by operation of a power plant. In a broader context, data has been collected to quantitatively evaluate the effect of plant operation. The significant results from this 3-16
study, which can be related to the Rush Island Site, include the aquatic biota and the chemical and physical state of the river (see Figures 3-9 through 3-15). A preliminary report on the Sioux Program is available for review in the St. Louis Engineer D istrict at St. Louis, Missouri. The final reports on the aquatic studies conducted at the Sioux Plant and the s ite of the proposed Rush Island Plant w ill be available after September 1, 1972.
B. Site Comparison
The validity o f predicting aquatic impacts at the Rush Island Plant on the basis of the Sioux Program is dependent upon the extent that physical and biological parameters are similar. Although important differences can be identified, the limited projections are justifiable on the basis of many significant points of similarity.
The Sioux Power Station is located on the Mississippi River and is a fossil- fuel plant with a design output o f 1,000 MWe. The plant has bee-'n designed to use once-through cooling water with a circulating water flow rate of 1,040 cfs and a temperature differen tial o f approximately 20°F. A supply o f cooling water is obtained by pumping approximately 467,000 gpm of river water at ambient temperatures from the M ississippi River, through the main condensers of the plant, with subsequent discharge of the heated water back into the river downstream of the intake. The intake structure abuts with the Sioux Plant, which is located at the end of a 1,000-foot intake canal, normal to the river flow. Vertical screens, located in the intake structure, are designed for an intake velocity of one-foot per second. Having passed through the plant, water flows into a discharge canal and then into the river. The discharge node is thus a surface open channel discharge, in which the heated water is laterally spread over the cooler river water due to density stratification. Water in the discharge canal is considered to be homogeneous and w ill have a uniform temperature throughout.
The Rush Island Plant is being bu ilt adjacent to the Mississippi River approximately 55 miles downstream from the Sioux Plant. This station will be fossil fired and have a capacity of 1,200 MKe. This unit will also utilize once-through cooling with a circulating water flow rate of 1,330 cfs and a temperature differential o f approximately 20°F. Cooling water will be supplied from the Mississippi River, with the intake struc ture located at the riv er's edge and discharge through a submerged pipe into the main channel downstream from the intake. The basic function o f the submerged discharge is to enhance mixing o f the bouyant je t . This submerged discharge w ill effect more complete mixing with the cooler am bient water, and by contrast with the surface discharge mode, lower sur face temperatures w ill result. Also, discharging heated water in the main channel w ill avoid the highly-populated benthic shore areas that also serve as migratory routes for fish. 3-17
In addition to the differences of plant structure and design requirements differences also exist for the Mississippi River for the two plant loca tions. The Sioux Plant is located at the Alton Pool and approximately 6 miles upstream from the Alton Dam. Because of this location the river velocity is significantly less then would be experience if the plant were located on the open river. The Rush Island Plant, on the other hand, is located below the confluence of the Missouri and Mississippi Rivers and is considered to be on the open river. As a resu lt, water flow rate is nearly doubled past the Rush Island Plant as compared to Sioux, and because of unrestricted river flow the river velocity is nearly three times as fast as at Sioux.
Perhaps the most significant difference between the two facilities will be the residence time o f the water mass that travels through the plant and discharge areas. Water that traverses the Rush Island circulating water system enters through a 114 inch diameter pipe which is approx imately 1,200 feet long, traverses the condensers and exits through a 114 inch diameter pipe of 540 feet in length to the seal well/weir structure. From the weir structure the water discharges through a 144 inch diameter steel pipe to the mass discharge exit (132 inch diameter) at mid-channel, which is an approximate length of 900 feet. Total travel time from the intake screens to the discharge nozzle is approximately 3 minutes and 15 seconds. Travel time from the condensers to the discharge nozzle is approximately 2 minutes. Rapid mixing of the heated effluent by je t inertia and a;nbient turbulence reduce the high plume temperatures by about 10°F within a few seconds. The temperature distribution in the nixing or near field zone is a function of river stage, flow rate and temperature. Because of the larger volume of the intake and discharge canals at Sioux, the resi dence time o f the heated discharge water is significantly greater than would be expected at Rush Island, and the thermally heated water to traverse the discharge canal at the Sioux Plant w ill be in excess of 20 minutes. In addition, the rate o f dissipation in the main river w ill be slower because of the surface discharge made.
Intake screens
Plant intakes on waterways inevitably will kill some fish. A value judgement is necessary to determine whether the numbers and kinds lost to the plant's operation are acceptable in terms of broad public inter est. Without any attempt to depreciate the problem, it is fa ir to say that no emergency situation exists. The river adjacent to the Rush Island site contains a variety of fish. The principle species that occurred in counts at Rush Island and collected on cooling water intake screens on the same waterway include: Gizzard shad, catfish, suckers, freshwater drum, and to a smaller extent bass, bluegill and crappie. General numerical information gained from the work o f the Sioux and the Rush Island aquatic studies indicate that the principle fish species collected on the plant intake screens are not an appreciable fraction of the numbers present in the general area. 3-18 o With the condenser cooling water intake structure located at the river's edge, water w ill flow through bar racks for coarse trash removal and then through vertical traveling screens to collect finer debris. Water will be drawn from near-surface to the bottom. A design flow rate of approximately 0.5 foot per second at the traveling intake screens should slow enough so that active swimming fauna will not be drawn onto the screens, providing this subtle current does not act as an attraction. Fish that are drawn into the traveling intake screen may drop off when the air-water interface is passed or they may be killed by the high velocity water jets used to clean the screens. Fish that enter the stream within the intake structure can escape by swimming out through the trash bar racks back into the main river. Some fish w ill come in contact with the screen or trash racks and w ill not be caught. Some of these fish could experience injury that may make them more prone to in fection , disease, or predation.
Devices and techniques whidi might exclude fish from intake structures have been investigated. A bubble screen was briefly evaluated by the Essex Marine Laboratory on the Connecticut River, but did not appear to be effec tive. An experimental electric screen was built and installed in front of the trash rack. Results of this electric screen have not yet been fully evaluated but it appears, at least in the case of fish 3 inches and larger, that there has been some improvement because o f a reduction in the number of fish collected on the traveling screen. Hie way in which fish move about in the plant area, together with natural fluctuations and abundances of the various species , makes a judgement as to the effectiveness of these or any fish exclusion devices a d iffic u lt and time-consuming task.
A brief program was conducted by Union Electric to evaluate the piscatorial impact associated with cooling-water screens. A three-week fie ld sampling program was used to obtain quantitative information on fish removed from screens at the Meramec, Labadie and Sioux plants during March 1972. The plants are similar in that they all utilize once-through cooling water; however, there are significant differences that result from plant location and cooling water intake and discharge structures.
The Rush Island Plant is most likely to be similar to the Meramec Plant in that it is located on an onen river below the city o f St. Louis with cooling water intake structures located at the river edge. The Labadie Plant is considered to be an open river site located on the Missouri River upstream of St. Louis, and with cooling water in let structures at the river edge similar to those at the Meramec Plant. The Sioux Plant is located on the Alton Pool of the Mississippi River, above the confluence of this river with the Missouri and upstream from the city of St. Louis. The cooling water intake screens are located at the end of an intake canal that is approximately 1000 feet long and 200 feet wide. 3-19
A complete analysis o f the intake screen study is not yet completed; however, some general conclusions may be drawn from, the raw data. Pre liminary results are summarized below. Approximately 60 to 90% o f the fish collected on the cooling water intake screens were forage fish, and the balance was a combination o f sport, commercial or dead fish . The predominant species of forage fish was identified as the Gizzard shad. The composition o f sport and commercial fish ranged from 10 to 20%. The predominant commercial species were catfish and fresh-water drum, while the predominant sport fish were bass and crappie.
PERCENTAGE OF FISH COLLECTED
COMMERCIAL AND DEAD PLANT FORAGE FISH SPORT FISH FISH
Labadie 90 10 0
Meramec 80 15 5
Sioux 65 20 15
The average number o f fisli collected per day at the Labadie, Meramec, and Sioux Plants were 179, 355, and 1,080 respectively. The corresponding total weights were 2.3, 24, and 127 pounds. Using commercial fish values provided by the Bureau of Commercial Fisheries for the Mississippi River, the total economic value o f the fish collected on the intake screens for each plant was computed. These values were then adjusted to represent economic fishery values for plants operating at full capacity. These economic values were further adjusted for seasonal vari ations of fish densities reported for regions of the upper Mississippi River. With the previous data and foregoing assumptions, the annual estimated values for fish collected at the various plants are $35 for Labadie, $900 for Meramec and $1,500 for Sioux. Thus, on the assumption that Rush Island w ill be similar to the Meramec Plant, the total commercial value of fish expected to be collected on the cooling water intake screens will be less than $1,000 per year.
Mechanical transport
The second impact o f the aquatic biota w ill be from the mechanical process o f passing large volumes o f water that contain aquatic organisms through the circulation pumps. The result o f this process w ill be mechanical abrasion to any organism capable o f passing through the small openings o f the cooling water intake screens. The organisms pumped through the cooling system are expected to consist almost entirely o f planktonic algae and invertibrate animals that serve as part of the food base. In addition, fish larvae and perhaps fish eggs, particularly the floating eggs, would experience the same transport phenomenon providing these forms 3-20
are drawn into the intake structures. The Sioux studies reported earlier with circulators operating, but without heat additions, have shown that moralities caused by mechanical abrasion did occur but were minimal. On another survey at Sioux, i t was observed that female Copepods had been pumped through the cooling system and were collected in the discharge canal with their eggs attached.
In conjunction with information provided by the literature and ongoing programs, a special study was completed at the Pilgrim Nuclear Power Station that assessed the biological impact on phytoplankton and zooplankton by the mechanical circulation system. Although this study was concerned with the mechanical transport of natural seawater, some results may be applicable to fresh water systems. The effect on the phytoplankton was measured by primary productivity. Results o f the study showed that the differences recorded between intake and discharge were no greater than thos differ ences measured on different days at any one station location. It was concluded from the Pilgrim Study that the mechanical operation o f the circulation system does not appear to e ffe ct the rates o f oxygen production of the phytoplankton entrained in the system. In the zooplankton investi gation of this study, the dominant species was the Copepod Acartae Clausea. Assessment o f the plankton m ortalities indicated that the daily average was less than 10% for all species under conditions of full circulatory flow. The observable damage to the zooplankton was attributed to turbu- lance associated with the mechanical circulation system. No single group o f organisms wass found to be especially sensitive to the mechanical entrain ment process in the Pilgrim Study.
Chemical additions to the circulating water for the control of the fouling organisms will have a severe impact on entrained organisms. Studies per formed on the Patuxent Estuary have shown that the primary production was reduced as much as 90% due to chlorine applications in an operational plant. In addition, bacterial densities and levels of chlorophylea_were reduced. It is important to note that no chemical additives w ill be introduced into the cooling water at the Rush Island Plant. I f operational cleaning of the condenser surfaces is required it w ill be accomplished by mechanical means.
With consideration for all preceding statements in this section, the Rush Island Site should have a minimal impact on the organisms transported through the entire circulation system by the cooling water.
Thermal stress
One o f the most important impacts on the aquatic biota w ill result from the elevation o f water temperatures. The in itia l change in water temperature at the condenser w ill be approximately 20oF above the temperature o f the intake water. The residence time of the water in the condenser will be a few seconds. It then w ill pass through a discharge pipe to the river. The total residence time for water within the Rush Island circulating water system (from the condensers to the river discharge) is less than 3 minutes At the point of discharge the effluent water temperature w ill rapidly drop by at least 10°F because of the submerged character of the discharge mode. 3-21
The aquatic biota that will show direct thermal effects of the operation of the Rush Island station will be necktonic form drawn into the intake the suspended planktonic forms from the river, plankton organisms later ally entrained in the discharge water and the benthic environment in the immediate area of the discharge. Some indirect affects may result from cumulative b iolog ica l, chemical and physical changes which may result in the alteration of the existing ecosystem. Whether these subtle effects will detract from, or actually enhance, the present situation is not predictable at this time.
The organisms most certain to be affected by the entrainment process w ill be the plankton and weak swimming species drawn through the screens and pumped through the condenser cooling system. The cropping that w ill result from the thermal affects w ill be from two causes. One w ill be thermal damage from the very rapid increase in temperatures in the con densers. The second will be thermal damage as a result of the residence time at these elevated temperatures.. Although the maximum incipient lethal temperature is not reached for a ll organisms, an incipient lethal temper ature w ill be the result of elevated temperature exposure for prolonged periods of time. The determining factors for this incipient lethal temper ature are the acclimation to the temperature changes of the ambient water for the exposed organisms, and the life stage o f the biota involved in the duration of exposure at higher temperature. Certainly the Rush Island sta tion has been designed to minimize the exposure o f entrained organisms to the higher temperatures generated by the condenser.
Use of the literature pertinent to biological thermal effects can have direct applicability to the situation at Rush Island only with certain quali fica tion s. Studies of cooling water systems, both freshwater and marine, show essentially no mortality for planktonic organisms exposed to tempera ture differentials of 10° F for 3 1/2 minutes or less, and no mortality of zooplankton exposed to temperature increases o f approximately 18°F for a period o f 3 minutes. Experiments conducted on the Connecticut River to evaluate the survival rate of larvae substantiated the time/temperature relationship previously discussed. The results of this program indicated that larvae would survive passage through the plant provided that the tem perature and exposure times did not exceed critica l lim its. For example, a survival rate o f approximately 25% was noted for larvae exposed at 82°F for time periods 5 minutes or less. As the exposure time was increased to 50 and even 100 minutes the survival rate decreased to approximately 10%. Increasing the temperature to 91°F reduced the survival rate to approxi mately 17% for short exposure times and to 0% when the exposure time was increased from 50 to 100 minutes. At 95°F the larval survival rate was 0% at all exposure times.
The maximum stress on larval forms w ill occur during the spawning season. Basically, this period exists from April through July. Using average river water temperature data measured at the Meramec Plant Site and adding the maximum differen tial temperature increase from the condenser, the calcu lated maximum discharge temperatures are 73, 84, 93and 99°F respectively - for the months o f April through July. On the assumption that spawns occur 3-22
predominantly in the months o f March and April the larval forms would not appear until May and June. Since the proposed Rush Island fa cility has such a short cooling water residence time it can be expected that the larva will experience a reson able survival rate if transported through the con denser system. Obviously, maximum cropping would occur in June and July when larval density is greatest and the maximum temperature would be highest. The Mississippi River channel at the Rush Island Site is adja cent to the Missouri bank and hence adjacent to the proposed Rush Island facility. The Illinois shore at this location is basically a long, sloping shallow flat leading to the main channel. Although no fish larval studies were made at Rush Island it can be assumed that the Illin ois shore would be a preferential fish, spawning area. Therefore, the entrainment o f fish larvae in the Rush Island cooling circulation system should be further minimized simply because the larval density in the water column at the Missouri shore will be less than at the Illinois shore. The results of the Rush Island fish survey support these conclusions. Details o f the estimated effect of transporting eggs and larvae through the plant con denser system was summaried in Section 3.5. It is recognized, however, that larval fish distribution in the water column is a co-function of the larvae sustained swim speed and flow properties of prevailing river currents. Two factors would appear operative: (1) larvae possessing su fficien t stamina would attempt to remain in shallow near shore waters in which they were spawned until they were ready and capable of sus taining stronger mid-channel currents, and (2) normal alterations in either river direction or velocity would undoubtedly remove a small number of larvae from the nursery grounds on the Illin ois side o f the river (as well as upstream), and thus possibly expose these organisms to entrainment within the thermal plume. The number of larvae re moved from shallow waters would necessarily have to be small, or the nursery would not be so located to begin with. The fact that signifi cant spawning areas exist on the Illin o is side o f the river, in the vicinity of the Rush Island plant site, indicates that relatively stable environmental conditions (low current, ample food supply) exist in order to assure the growth, development and protection o f sufficient larvae needed to perpetuate the species.
The impact o f the thermal plume on any larval fish should be minimal as the plant condenser cooling water is discharged through a submerged pipe near the center o f the river channel. The top of the pipe is approximately 20 feet below the lav water level of the river. Al though the temperature differen tial between the hot water discharge and the ambient river water w ill be a maximum of 20°F, the 15°F isotherm of the discharge plume will extend approximately 60 feet downstream (based on thermal plume model calculations for low water flow ). In fact, these calculations show that the maximum allowable cross section of\the mixing zone w ill not exceed 15°i of the river cross section and the maximum length is less than 1300 feet (4°F isotherm). At a river velocity of 5 feet/second, the maximum residence time for low flow conditions in the 15°F isotherm w ill be 12 seconds and in the 4op isotherm about 4 minutes. 3-23
No appreciable effect on the economically valuable species is likely to result from the mortality of food-base organisms such as phytoplankton and zooplankton that are pumped through the cooling system. Nutrients would be supplied from dead planktonic organisms to the filt e r feeding organisms that use them as food. Nutrients would remain until complete decomposition occurred. Further, the small void in the total aquatic pasture made by the loss of such plankters soon would be filled by the reproduction of living plankters.
The interest in benthic forms arises from their role as an integral link in the food chain o f the river. Many are eaten by fish who live in the river the year round. Consequently, i f the structure of this segment o f the food chain were to be altered as a result of plant operation, one might ex pect significant changes in the fish population to follow, evaluation of the benthic community at Rush Island, in the vicinity of the proposed cool ing water discharge, indicated a community primarily composed of Oligochaetes. As previously discussed, the community diversity index for this location was significantly different than a similar evaluation of the benthic community at the Sioux Plant site .
The benthic surveys conducted at Sioux, to measure the effect o f the thermal stress o f the plant, have shown that a viable benthic community resides in the discharge canal. The community diversity indices calcu lated for the intake-discharge canals fluctuated for the different sampling periods. However, the values calculated for a given sample period were essentially the same. The data were analyzed statistically and it was concluded that the plant did not alter the composition o f the benthos in the discharge canal. There may be some bottom scouring at Rush Island in the vicin ity o f the condenser water discharge. The increased water velocity and the elevated temperature in the ou tfall area might affect any benthic community in that vicinity. However, since the discharge port is located near the center line o f the channel and is angled at approximately 20° to the horizontal, the effluent water w ill be discharged toward the river's surface. The discharge momentum, coupled with the buoyancy o f the heated water, should prevent the high-temperature isotherms from touching the bottom. Calculated isotherms for various river conditions, show a 4° isotherm covering the bottom for a distance o f approximately 50 fe e t.. Depending on the river conditions, this 4° isotherm w ill extend downriver approximately 600 feet. The composition of the river bottom in the middle o f the channel at Rush Island is primarily sand. Dredge samples taken in this area did not contain any benthos. It can be concluded that the mode and location of thermal discharge to be used at the Rush Island site w ill have a negligible effect on the benthic community. In the event that the thermal plume intrudes into the shore-based benthic community, the data from the Sioux Plant Site would suggest that the benthos w ill experience few adverse effects. 3-24
Migrations o f spawning fish are not expected to be hampered by the thermal discharge because the 5° isotherm w ill not touch the bottom in the vicin ity of the discharge zone. In addition, no thermal barriers will occur as the maximum width o f the measurable isotherm w ill be confined to mid river and will not exceed 1/3 of the river width. Those that are resident to the Rush Island area can be expected to move toward temperatures that they prefer and to move away from areas that are unfavorable. Since the thermal discharge and resulting plume is in mid-river and is not contiguous to the shore line, fish may be expected to pass without any interference.
Chemical parameters
The State of Missouri Water Pollution Board issued new Effluent Guidelines in November 1971, and the State o f Illin ois adopted new Effluent Standards in January 1972. These parameters and allowable concentrations are shown in Figure 3-16.
The ash pond discharge will be the only discharge at Rush Island that could contain concentrations of substances differing significantly from those of the natural water body. Blowdown water from the boiler drums, water from the plant demineralizer system, and drains from the coal pile will be directed to the ash storage pond.
There has not been time since the issuance o f the Missouri and Illin ois guidelines to complete a sampling program at other power plants, to obtain an indepth understanding o f the problems associated with meeting these guidelines. However, based on a limited sampling o f existing Union Elec tric power plants, it is expected that the Missouri and Illinois effluent standards w ill be met with the proposed details o f the Rush Island Plant design. If necessary, changes in design will be made as information is developed to assure that the standards are met.
The expected values of chemical and physical parameters that w ill discharge from the ash pond are tabulated below. This information is based on measurements taken at existing fa c ilit ie s . All parameters are reported as concentrations in milligrams per liter unless otherwise noted. 3-25
Maximum Average Parameter Maximum lbs. per day Average lbs.per day Minimum Flow (million gal. per day) 6.5 5.95 3.0 pH 8.4 8.0 7.8 Winter temperature (of) 50 40 32 Summer temperature (°F) 87 80 70 Alkalinity as CaCC>3 150 7443 150 7443 B.O.D. S-day 1 50 1 50 C.O.D. 10 500 10 500 Total Solids 400 19848 350 17367 Total dissolved solids 3S0 18855 330 16374 Total suspended solids 20 992 20 992 Total volatile solids 130 6450 110 5458 Ammonia as N 3.0 148 2.5 124 Kjeldahl nitrogen 5.3 263 5.3 263 Nitrate as N .00 0 .00 0 Total phosphorus as P .00 0 .00 0 Total hardness 306 16585 306 15177 Sulfate 236.1 12796 236.1 11710 Chloride 22 1192 22 1091 Calcium 82 4444 82 4067 Magnesium 6.3 341 6.3 312 Potassium 10. 10 547 10.10 500 Sodium 64 3468 64 3174
Mississippi River water w ill be circulated through the Rush Island Plant condensers for rejecting heat from the steam turbines. Most condenser tubes are fabricated from a copper alloy and there w ill be some erosion of the metal from this system resulting from the flow of river water and/or mechanical cleaning. It is estimated that the maximum concentration o f copper in the circulating water resulting from erosion will be less than 0.002 PPM. The Illinois Standards and the Missouri Effluent Guidelines have set 0.02 PPM as a maximum permissable concentration in an effluent. The detectable level is 0.01 PPM, therefore, the concentration of copper in the discharge at the Rush Island Plant will be insignificant.
During construction
During construction water quality guidelines and standards issued by the Missouri Water Pollution Board will be followed. The hydraulic filling operation for the power plant site will be done by borrowing fill material from the ash pond area on the site and all of the water used in the fillin g operation w ill be recycled back to the ash pond.
Sanitary wastes will be treated such that water quality standard and guide lines are followed. 3-26
No herbicides or pesticides will be used in clearing operations. The use of pesticides will be limited to applications within buildings and struc tures or to small areas immediately adjacent to buildings or structures. Herbicides will only be used to control weeds in construction storage areas which will involve less than 2« of the plant site or 10 acres.
Summary
No steam electric generating plant can be operated without causing some change to the aquatic environment of the immediate v icin ity. The question o f judgement is involved in each case as to whether it can be mitigated.
The impacts detailed in this section are anticipated on the basis of in for mation obtained at the company's operating plants, supplemented by a review of existing literature. The most significant effects on the aquatic envir onment are as follows:
1. There is unquestioned fatal damage to numbers of fish on the intake screens as a result of plant operation. However, the numbers of fish collected on the intake screens should be minimized because of the design o f the intake structure.
2. There is no evidence to suggest that the overall quality, diversity and quantity of the plankton community w ill be adversely affected by the plant operation. Primary productivity did not decrease significantly for phytoplankton that experienced condenser transport in an operating plant and subsequent exposure to the heated effluent. The biomass o f holo- plankton that exited the plant with the cooling water is not dissimilar to that o f water samples collected in the intake zone. This indicated that condenser transport did not materially affect the organisms.
3. There is unquestioned mortality of juvenile fish and larvae which pass through the intake screens and are entrained in the condenser system. Wien the temperature o f the water rises above 95°F the mortality level is expected to be 100°o of the entrained organisms. Lower m ortalities are expected as the temperature decreases. A spot survey sample taken with no thermal input from the condensers indicated high survival rate for fish larvae that were transported through the cooling system.
4. There is no indication that the benthic community w ill be adversely affected as a result of the Rush Island effluent discharge. The design of the effluent outfall restricts the cooling water discharge to the main channel of the river. The temperature o f the effluent w ill be rapidly lowered to ambient levels by the submerged mode o f discharge. This should minimize the encroachment o f the thermal effluent on the shoreline. There may be some localized disturbance o f the bottom in the vicin ity o f the discharge but this will be in an area of little or no benthic community population. Evaluations o f the benthic community in the area o f an operating plant did not indicate that the discharge had adversely affected the food chain in the river. 3-27
5. Based on the results of mathematical modeling techniques, the cooling water effluent is not expected to create a thermal barrier within the Mississippi River which might be detrimental to fish movement. It is not likely that such a barrier will be created under foreseeable con ditions because of the large flow o f water past the plant site at a ll times.
6. Chemical parameters o f the river water in the vicin ity o f the Rush Island Plant will not be significantly altered by the operation of the plant. There w ill be no chemical additions to the condenser water. Pas sage o f water through the condenser tubes is not expected to produce oxygen deficient conditions and under certain conditions may slightly increase the dissolved oxygen concentrations. The chemical system in the area is s u ffi cient for aquatic life support systems. Routine operation o f the plant is expected to create no chemical dificiency or excess that might serve as a threat to aquatic life.
3.7 Noise
Noise that would be associated with the operation o f the plant has been appraised on the basis of experience at other recently constructed power plants. It is expected that at the property line o f the s ite , the normal operating noise level could not be heard above noise leve that would be experienced next to a quiet idling automobile. However, it is recognized that noise generated by the Rush Island Plant may be heard at night by persons in boats anchored in the river near the bank adjacent to the Rush Island Plant site.
During construction higher noise levels are expected during the day, but such noise levels will normally be less than that from the quarries that have been operating in the area for many years.
On March 10, 1972, noise level readings were made at Union e le c tric 's Labadie Plant. At the time o f the readings one unit o f the plant was in service, another unit was undergoing major modification, and two units were under construction. Some representative decibel (dB) readings were as follows :
dB
At construction gate 46
At the operating gate 55-58
At the river bank 55-58
For comparison, it may be noted that the noise level in a private office or the average residence is normally considered to be 50 dB and that the noise level in a large store or open office is considered to be 60 dB. These standards may be found in the Handbook of Noise Measurement 6th edition, published by the General Radio Company. 3-28
3.8 Scenic and Aesthetic Impact
The Rush Island Plant will be located on a low Mississippi River delta island close to the bluffs on the west side o f the river. This location w ill tend to minimize the visual aspects o f the plant, as opposed to a location in the center of large level landscape.
Essentially, the Rush Island Plant w ill be almost totally obscured from all areas on the west side o f the Mississippi River. The bluffs adjacent to the site rise up sharply, from a delta elevation of 385 feet to the abutting face o f the bluffs with an edge elevation o f 600 to 700 feet. Therefore, all o f the buildings, with the exception o f the 700-foot stack, w ill be completely obscured from U. S. 61 and from a ll areas between the highway and the b lu ffs, except at a point immediately on the edge o f the b lu ffs .
From the Illin ois side, the Rush Island Plant w ill be visib le from two major areas - one being the delta area along the east side o f the river and the other the highlands and bluffs area approximately four miles to the east. In the delta area, access is accomplished only by a limited number o f roads. Views o f the river are obscured much of the time by trees. Thus, an actual line of sight to the proposed building can be accomplished only in a limited num ber of locations from the delta area. The Rush Island Plant will not provide a silhouette as it will be back grounded by the western bluffs in Jefferson County.
The Rush Island Plant w ill occupy a very small percent o f the total area in this section of the Mississippi River delta. The four-mile wide delta, with the bluffs rising on either side, provides a wide expanse of which the actual project w ill take up a very small part. The total scenic impact of the Rush Island Plant and its appurtenant structures would be borne by river craft on the Mississippi River and persons traveling along the minor roads in the Illin ois delta. There are no passenger trains using the St. Louis-San Francisco ra il line.
As previously pointed out, much of the view from the roads on the Illin o is side is obscured by trees along the riverbank and by the tree masses on Beagles Island. The only access point for a number o f miles in either direction is at Kemper Landing, located on the Illin o is side approximately two miles upstream.
Illin o is Highway 3 is located approximately 12 miles each o f the Mississippi River and, therefore, there will be no visual connection between the Rush Island Plant and this highway. County Highway 3 runs along the base of the Illinois bluffs approximately four miles from the Rush Island Plant. The Missouri bluffs w ill provide a backdrop and obscure much of the view, as will tree cover on the Illinois side. However, it is expected that the 700-foot high stack w ill be rather prominent because i t rises about 300 feet above the bluffs on the Missouri side o f the river. 3-29
3.9 Hydro logical Inpact
The proposed Rush Island Power Plant w ill occupy the entire Missouri side o f the Mississippi River flood plain for about 6,000 feet along the river. Width of the Missouri portion o f the flood plain is about 2,000 feet. The Illinois portion of the Mississippi flood plain is presently pro tected by the Ft. Chartres, Stringtown and Ivy Landing Drainage and Levee D istrict. Original levee design was to protect against a 5U-ycar fre quency flood (then estimated at 1,080,000 c . f . s . , St. Louis Gage). This flow corresponds to a water surface elevation of 406.7 m.s.l. at the proposed power plant at mile 140. The existing fill for the proposed power plant is approximately 2,500 feet by 9,000 feet, and has been carried to elevation 410 feet m .s.l., thus eliminating overbank flow area for the design Hood amounting to about 40,000 square feet. This decrease in flow area constructs the reach to be occupied by the proposed power station, thereby causing a light rise in the water surface immediately upstream o f the f i l l . The rise in water surface w ill be about 3 inches on the occurrence o f the 50-year flood. This 3-inch rise w ill not appreciably affect the freeboard required for the Ft. Chartres Levee. With the many flood control reservoirs now in operation on the Missouri River and its tributaries, the 50-year frequency flood flow will now occur even less often as a portion of this flow would now be caught and controlled by these reservoirs. The occurrence of a 1,080,000 c.f.s. flood at the present time is estimated to be a 1 in 200 year frequency event.
Increased channel velocities during floods with the Rush Island fill in place are not expected to cause excess channel scouring. Average velocity increases will be about 0.2 to 0.4 feet per second for the more frequent floods.
3.10 Impact on Projects in Operation by Others
The construction and operation of the Rush Island Power Plant is not ex pected to have any adverse impacts on the channel maintenance project of the Corps of Engineers. The navigation channel adjacent to the site has not required significant maintenance and the loss of possible dredge spoil area and/or dike field area is not considered significant.
T raffic on St. Louis-San Francisco Railway Company (Frisco) tracks which serve the site will increase if the plant is built. The company states that the low sulfur coal will be delivered via rail, at least for the pre I sent time. 3-30
3.11 Site Preparation and Landscaping
The site preparation work is well underway with approximately 20a of the site fill in place. The main portion of site fill will consist of material (sand and clay) dredged from the ash pond. Since the major portion of the plant site was cultivated farmland when purchased, only a small amount of clearing will be required for construction of the Rush Island Plant. All areas cleared for construction but not required for plant operations will be seeded and allowed to return to a natural or wild state. All areas disturbed by construction w ill in a ll cases be treated to control erosion and to pre vent a dust nuisance.
In addition to the site improvements described in Section 1, landscape im provements will be incorporated during and after construction. The land scape improvements w ill include planting o f small areas o f grass near the plant entrance and main plant structures. In some cases topsoil and sod will be installed as required. Planting of shrubbery and trees near the adminis tration building, similar to that indicated in Figure 1-14, will be incor porated into the landscape program.
In the immediate area of the main plant structures the slope of the fill on the west bank of the Mississippi River will be rip-rapped to control erosion. Other sloped areas will be seeded as required.
The service and entrance roads, in addition to the parking lots will be maintained during and after construction to prevent a dust nuisance.
During construction several temporary buildings will be required for ware housing and field personnel. Such buildings will be built to satisfy the codes and permit requirements of Jefferson County and the State of Missouri.
Construction debris and trash will be collected within the plant area on a continuous basis. This material will be removed from the plant site for proper disposal or buried in a sanitary land fill on the plant site. Any open burning of this material w ill be with the approval from the Missouri Air Conservation Commission with the use of an air curtain destruc tor type system.
3.12 Public Access to the Mississippi River
Public access to the Mississippi River will be provided by Union Electric at the proposed Rush Island Plant. This access will be in the form of a roadway with a varying width of right-of-way and w ill be routed near the north edge of the proposed plant site to the slough that crosses the north east corner of the plant site; thence the roadway will parallel the slough to the west bank of the river. After this roadway is completed, it is ex pected that Jefferson County will accept the roadway as a county road. 3-31
3.13 Transmission lines
The route selection and treatment of transmission line rights-of-way and the design of the structures and lines will follow the guidelines recommended by the Federal Power Commission, entitled "E lectric Power Transmission and the Environment." These Federal Power Commission guidelines parallel those published by the Secretaries of the Interior and of Agriculture in October 1970.
The Federal Power Commission has stated that these published guide lines, when used in a reasonable manner for planning and design of transmission facilities, "will provide the most acceptable answers from an environmental standpoint taking into account also of such factors as safety, reliability of service, land use planning, eco nomics and technical feasibility."
Some of the sp ecific implementation o f the published guidelines and other practices that will be incorporated in the design and construction of the transmission facilities to minimize any effect to the environ ment are as follows :
1. The rights-of-way will be selectively cleared. Only those trees which are in con flict with construction or pose a hazard to the operation of the transmission lines will be cut. The cut trees will be stacked along the edges o f the right-of-way to provide natural cover for small w ild life in the area. No trees or brush w ill be burned unless sp ecifica lly requested by the land owner. Tree stumps w ill not be removed, so that natural soil stability can be preserved.
2. Construction methods will be employed that will conserve the so il and minimize disturbances to roads, land, and land improvements. During construction day-to-day clean up of rights-of-way will be maintained to avoid litte r problems. The construction o f temporary access roads w ill be kept to a minimum. Where temporary access roads are required, the area w ill be graded to minimize s o il erosion. Temporary crossings of creeks and small streams will be constructed to avoid damming or restricting the flow of water. Existing farm access roads w ill be maintained during construction and restored to their original condition.
3. After the initial clearing of the rights-of-way and construc tion of the transmission lines, ground cover vegetation, including the small trees, will be allowed to grow on the rights-of-way. The plant ing of "Christmas, trees" and low profile orchard or wood lots will be permitted and encouraged, however, i t w ill be required that this type of activity on the rights-of-way be done under the company's super vision to protect the safety of individuals and the operability of the transmission lines. Crop and pasture land use under transmission lines can be carried on with no disturbance. 3-32
4. The transmission line rights-of-way will avoid existing and/or recorded parks, monuments, scenic recreation areas, and historic sites except for the projected Ozark Scenic Railway and Selma Road. These lengthy projected scenic rights-of-way must of necessity be crossed. These crossings will be given special con sideration so that the visibility of the lines and right-of-way will be minimal.
5. Special efforts will be made to route lines along and parallel to the slope of hills rather than over the crest of hills to reduce the silhouetting of towers against the skyline. Where crossing of valleys is necessary and where heights permit, clearing of valleys will be reduced to a minimum for construction.
6. Highways will be crossed as nearly perpendicular as feasible to reduce the time which passing motorists may view the right-of-way. Structures will be located as far from highway crossings as feasible without jeopardizing the safety of the line. To further screen the rights-of-way from view, "buffer zones" or screens of small trees and brush will be left for a minimum distance of 100 feet either side of the highways. The rights-of-way w ill change direction at the struc tures on both sides of Interstate highway crossings so that views from the highways o f long lengths o f rights-of-way are avoided.
7. The transmission lines will be designed to eliminate radio and television interference. The conductor sizes, configuration, fittings, and insulators will be of designs that have been specifically pro duced to avoid such interference. No conductors will be less than fifty feet from the edges of rights-of-way for 345 kv lines and this "edge distance" has proven to be sufficien t to avoid interference problems for residents and other occupants o f land adjacent to the company's existing transmission lines. 4-1 o SECTION 4
ADVERSE environmental effects which cannot be avoided
Construction and operation of the Push Island power plant will result in Increased activity In the vicinity of the plant site. Increased use of the local road system will generate some local ized increase in airborne particulate matter and exhausts from vehicular traffic. The existence and support of personnel in volved in the construction and operation of Rush Island Plant will generate some additions and modifications in the facilities o f the surrounding communities.
The plant site w ill be modified by grading and filling of some areas, and by the erection of the power plant structure, parking fa c ilit ie s , roadways, and bulk power handling fa c ilit ie s .
Emission of some sulfur dioxide, nitrogen oxides, and particulate matter to the atmosphere w ill result even with the use of low sulfur fuel and the application of available technology to re duce such emissions.
The waste heat produced as a result of power generation must be released to the biosphere, either directly to the atmosphere or through water as the transfer medium. River water drawn through the condensers will carry fish eggs and larvae that will result in some damage, but studies indicate the operation at a somewhat similar installation will not markedly affect the population dynamics o f the water body. There may be some loss of mature fish on the plant water intake screens even though the design velocity of water through the screens will be held to a low value ».n order to allow the escape of most fish entering the area of the intake structure.
Hunting opportunities will be lost in the project area and possibly reduced in the immediate region. During construction, there w ill be a decrease in wildlife habitat available for nesting by birds, although this impact should not be permanent. The activities of ^ e plant w ill also reduce the habitat values for game species in the immediate v icin ity .
The erection of transmission facilities, in conjunction with the power plant comolex, w ill detract from the natural aesthetic value o f some areas of the county. Although this impact w ill be kept to a minimum, this is a definite adverse effect of the plant. 5-1
SECTION 5
ALTERNATIVES TO THE PROPOSED ACTION
During the evaluation of the alternatives to the proposed Rush Island Plant, environmental crite ria , fe a sib ility , availability, and economics were considered. Where some other factor made an alternative completely unacceptable to the applicant, environmental criteria may not be in cluded in the discussion. Factors such as a lack of technology to implement an alternative, in the case of dry cooling towers, or in sufficient fuel supplies, such as natural gas, make an alternative impractical. In such cases the environmental criteria may not be in cluded in this section.
5.1 Not Building the Plant
The Public Service Commission of the State o f Missouri, under whose jurisdiction Union Electric Company operates a public utility in the State of Missouri, requires that electric utilities must ade quately supply electricity to the area served by that electric u tility . The Iowa State Commerce Commission and the Illin ois Com merce Commission sim ilarly charge public u tilitie s with providing adequate and reliable electricity to their service areas in those states. The total service area for the Company and its subsidiaries, Missouri Power and Light Company and Missouri Edison Company, accounts for 19,000 square miles in Missouri, Illin o is , and Iowa.
Because o f the long lead times required for siting and construction of large power generation facilities, electric utilities plan their plant expansion programs based on demand forecasts developed from historical growth trends adjusted for predicted changes in consumer requirements. The Company's most recent estimate o f demand on its system indicates that its load w ill reach approximately 5870 mega watts (MW) by the summer o f 1975, and 6259 MW by the summer of 1976.
Without the addition of the capacity that Rush Island Plant w ill supply, the Company's capacity in 1975 (including interchange power agreements) w ill amount to 6253 MW. This capacity w ill provide for an estimated reserve o f 383 MW, or about 6-1/2% of the load estimated for 1975. By 1976 the reserve would drop to 0.2% or 14 MW. Statistics show that reserve levels of 6-1/2 % on 0.2% are in su fficien t to assure reliable service.
The Company's agreements with other u tilitie s and the Mid-America Interpool Network (MAIN) call for the reserve level in 1975 to be 18%. This 18% reserve level is based upon studies made by these groups to optimize design and operation o f the interconnected e le ctric system. The Federal Power Commission is a strong proponent for the maintenance of reserves higher than 18%. ° 5-2
In July 1966, the Company was not able to provide full service to its service area because of inadequate reserve or margin which re sulted from an extended period o f extremely high temperatures and the delayed completion of a 525 MW unit. The in-depth investiga tion of this adverse operating period revealed that the severe heat spell caused demands to be 10.5% higher than the demands that nor mally would be expected and that the delayed completion o f the 525 MW unit reduced the reserve to 11% of the demand that would normally be expected. In order to reduce the p ossib ility o f major and widespread blackout in the Midwest, the Company par tially interrupted service because of inadequate reserve or margin.
I f the Rush Island Plant is not b u ilt, older less e fficie n t gen erating equipment w ill supply some of the energy that would have been provided by Rush Island Plant. This will result in more fuel being consumed and therefore more emissions from the stacks and more emissions o f heat to the rivers.
A computerized mathematical model that can simulate system oper ation under varying conditions has been employed by Union E lectric to study the e ffe ct on the system i f Rush Island Plant is not available for use in the years 1975 and 1976.
In the year 1975, the proposed Rush Island Plant is expected to supply some 1,089,000,000 kilowatt hours o f energy for distribu tion to customers. I f the plant is not b u ilt, a ll but 112,000,000 kilowatt hours of required energy will be provided by existing equipment within the Union E lectric system. That which cannot be generated w ill have to be purchased from an external source or power curtailments will be necessary. To generate this electrical energy at less e fficie n t plants w ill result in the consumption o f an additional 1,944 b illio n British Thermal Units (btu) o f heat energy which would be conserved by having the Rush Island Plant equipment in service.
In the year 1976, the proposed Rush Island Plant is expected to supply some 2,974,000,000 kilowatt hours of electrical energy for distribution. If the plant is not available, all but 319,000,000 kilowatt hours of this energy will be generated at existing facil it ie s . So in 1975, that which cannot be generated w ill have to be purchased from an external source or power curtailments will be necessary. To generate this power existing plants with lower thermal efficien cies w ill require the consumption o f an additional 5,415 billion btu of heat energy. 5-3
Generation o f additional electrica l energy at older, less e f f i cient plants not only increases the total amount of fuel consumed to generate a given amount of energy, but also results in the re lease of more stack gases into the atmosphere at a much lower e le vation, which will increase ground level pollution concentrations.
Older power plants are not equipped with the e fficie n t electro static precipitators that can be designed into a new plant. Efficiency o f the older equipment w ill typically range from 90 to 95%. The Rush Island Plant w ill emit approximately 2000 tons o f particulate to the atmosphere annually. To replace this energy by use of older equipment will result in the release of 6000 to 8000 tons of particulates annually. In addition, at least 50,000 tons per year more sulfur dioxide will be released to the atmosphere if the particular low sulfur coal that is to be used at Rush Island Plant cannot be used elsewhere. This emission would, in some cases, be at an elevation of two or three hundred feet above ground whereas the emission from the Rush Island Plant would be from 700-foot stacks. This increase in elevation of release can reduce ground level concentrations of particulate matter, sulfur dioxide and nitrogen oxides for a given set of conditions by several orders of magnitude.
5.2 Purchase Power
The purchasing of power in lieu of installing the Rush Island Plant is not a feasible alternate. None of the Company's neighboring utilities has or is expecting to have a surplus of generating capacity su fficien t to supply the power that the proposed Rush Island Plant will supply.
The Company is a member of the Mid-America Interpool Network (MAIN) which includes almost all of the investor owned electric utilities in Missouri, Illin o is , Iowa, southern Minnesota, southeastern Wisconsin, a portion of upper Michigan, and the southeastern part o f South Dakota. In working with the members o f MAIN, the Company has stated that there are no possibilities for buying substantial quantities o f power from the member companies, or other u tilitie s in and adjacent to the region. The smaller specific amounts of capacity that are available for limited periods of time have been included in the appraisal o f power requirements discussed in Section 1.
In order to maintain re lia b ility in the Mid-America Interpool Net work, each member seeks to maintain capacity at least 18 percent in excess of anticipated peak loads. Union Electric states that the lack of adequate reserve capacities currently has made it im possible for some members to undertake scheduled unit maintenance. 5-4
It is conceivable that continuation of this situation would ulti mately result in an increased number of forced outages and lower unit reliability.. To allow all pool members opportunity for the required maintenance, and to enable the pool to have su fficien t capacity to meet load requirements, each member must meet his capacity obligation to the pool. During and subsequent to the summer of 1975, there will be insufficient excess capacity within the pool to allow Union Electric to meet its reserve obligation without the construction of Rush Island Plant or other sources of additional generating capacity.
5.3 Alternate Means of Generation
Natural gas
At the present time, there is no assurance that natural gas w ill be available in su fficien t quantity to supply the fuel requirements for the Rush Island Plant. The natural gas requirements for two 600 MW units is approximately 275 million cubic feet per day which is about equal to maximum peak demand for heating the residences in a city with a population of about 1,000,000. In the United States the annual consumption of natural gas continues to exceed the discovery of new reserves and it is expected that this situation w ill continue through the 1970's.
Synthetic natural gas
Current estimates indicate that economic synthetic natural gas (SNG) will not be available until the 1980's. SNG is gas that is produced from coal or o il shale and substantial development work will be required before large quantities of economic SNG will be available.
Fuel o il
Fuel oil is not a reasonable alternative to the low sulfur coal that w ill be burned at the Rush Island Plant because o il is ex pected to cost 1.5 to 2.0 times as much as low sulfur coal. Also, the uncertainties involved in the availability and logistics of the supply o f o il fuels are much greater than the uncertainties involved in the supply of low sulfur coal.
Environmental air quality standards require that only low sulfur oils can be considered for oil fired power plants similar to the Rush Island Plant. The sulfur limitations can be met with domestic and foreign distillates, many domestic and foreign crude oils, a very limited number of foreign residual oils, and desulfurized residual oils from domestic and foreign sources. 5-5
The supply of low sulfur domestic oils (crude, distillate, or desulfurized residual) is in limited supply and it is expected that foreign sources of o il would have to be depended upon for power generating capacity such as the Rush Island Plant.
Imports of oil are subject to quota limitations and licenses issued by the Federal Government. The Company is included in D istrict 2 and quotas for this district are currently difficult to obtain if low sulfur coal or other acceptable alternate fuels are available. Imported o il probably would only be available from North Africa (low sulfur) or South America (desulfurized). These supplies are subject to the vagaries of international politics as to availa bility and pricing.
The price of low sulfur o il during the middle 1970's and early 1980's is difficult to predict. Demand is expected to remain heavy because of increasing electric utility usage and domestic refinery demand for foreign crude. Current prices for low sulfur o ils in the St. Louis area are in the order o f 70< per m illion btu for residual oil and 80{ per million btu for distillate. Crude oil is priced just below or equal to d istilla te because o f its demand for conversion to light oil and gasoline. Considering an escala tion rate of 2 to 5 percent per year, the projected oil prices would be 1.5 to 2.0 times the price o f low sulfur coal in 1976.
Nuclear fueled unit
A nuclear fuel plant is not a feasible alternate to the Rush Island Plant because the earliest date that a nuclear plant could be placed in service if it were authorized in 1972 would be in 1979. The minimum time from the order date of the nuclear steam supply system to commercial operation is currently estimated to be seven years.
To maintain a schedule as short as this seven year schedule, the Atomic F.nergy Commission and others involved in the project w ill have to expedite the licensing procedures.
Combustion turbines
The construction of combustion gas turbine capacity in lieu o f the Rush Island Plant would not necessarily present a timing problem unless a substantial amount of time is required for obtaining per mits. However, the Company has stated that this alternative would be impractical for several other reasons. This type of capacity could supply the required generating capacity but not the base load energy requirements for the system. Combustion turbines are generally unsuited for the continuous operation required of base load units. The increased maintenance resulting from base loading these units would result in lower unit availability. Due to the higher fuel cost o f o il over coal, and the lower efficien cy o f the *a combustion turbines, the energy cost for the combustion turbine "i units would be approximately 5 times that of the proposed units. 4 5-6
Hydroelectric facility
The area in and surrounding the Company's service area does not include sites which possess the hydroelectric potential for supplying the electrica l output necessary to meet the 1975 load demands. Ap proximately 15" of the Company's present generating capacity is pro vided by three hydroelectric power stations. Two of these facilities are used for peaking and the third is a base loaded unit of 128 MW capacity. A large pumped storage project would not be suitable because of the base load capacity required to meet the area's power needs.
5.4 Alternate Sites
The influence of an electric generating plant on the environment, as well as the economics of e le ctric power generation have been considered in selecting the Rush Island Plant site. Prior to selecting the s ite , two "mine-mouth" plant sites in Illin ois and 27 sites in Missouri were also seriously considered and evaluated as alternates. The sites investigated are indicated on Figure 5-1.
The "mine-mouth" power plant sites require the development o f cool ing lakes involving substantially greater investment in real estate and construction costs. Also, these sites are outside of the Company's service area and would require greater investments in transmission fa c ilitie s and rights-of-way to connect the "mine- mouth" plant with the utilities existing transmission system.
Two of the 27 sites considered in Missouri are on the Missouri River about 60 to 70 miles west of St. Louis. These sites, like the Illin ois sites, would require greater investments in transmission facilities to bring the electricity to the metropolitan St. Louis load. The Missouri River has considerably less flow than the Mississippi River, and consequently does not provide as good a source of cooling water or year around navigation for possible barge delivery of fuel.
The remaining 25 sites are located along the Mississippi River. Nine of these are over 50 miles north o f St. Louis which was a major factor in not selecting one o f these sites at this time. It also developed that these sites would require extensive flood protection work, which would be costly and would influence the river stages during periods of high flooding. 5-7
Eleven o f the sites are located on the Mississippi River within 50 miles north of St. Louis. Construction of the proposed units at one of these sites would concentrate a large quantity of gen erating capacity to the north of the metropolitan St. Louis load area. In addition, these sites would require extensive flood protection work.
The Rush Island Plant site is one of the six sites considered on the Mississippi River to the south of St. Louis. One o f these sites was rejected because of its proximity to an existing power plant which would have resulted in concentrating too much capacity at one location. Detailed analysis of two sites indicated that the amount of land and the way i t was deployed would not permit good plant layout. Two of the sites were outside of the company's service area and offered no advantages over the Rush Island Plant site.
The Rush Island Plant site was selected on the basis o f abundance of water for direct cooling; location in the service area where the capacity is needed, thereby reducing the extent o f transmission facilities; proximity to a source of coal supply in Illinois; relative ease in providing flood protection for the facility; and the environmental characteristics that minimize any adverse effects on the quality of life in the region. This site offers the best overall advantages for locating this type of generating capacity at this time.
5.5 Alternate Cooling Methods
After a detailed comparison and analysis o f alternative cooling systems, the direct cooling method with a midstream mass discharge was selected, based on the following considerations:
1. Limited available land space.
2. Capability of meeting the proposed Mississippi River tempera ture standards.
3. Greater re lia b ility than cooling systems with more mechanical equipment.
4. Environmental impact o f cooling towers - including increased consumptive use o f water, vapor emissions, particulate emissions, discharge o f cooling tower blowdown, and massive appearance.
5. Lowest investment and operating costs. 5-8
The overall evaluation for locating the 1975 and 1976 units at the Rush Island Plant site was influenced by the abundant supply of cooling water provided by the Mississippi River. Cooling system studies have indicated that either a midstream mass single point discharge or a midstream multipoint diffuser will meet the Missis sippi River water temperature standards proposed by the States of Missouri and Illin o is and the Environmental Protection Agency.
Cooling pond
A cooling pond was considered by Union E lectric and was found not to be a feasible alternate because the pond area required fo r the plant development is over 1000 acres. The present site is approx imately 500 acres and the land surrounding the site is not suitable for reasonable development o f a cooling pond. Also, such ponds could result in environmentally objectionable ground level fog.
Spray canal
The spray canal system considered by Union E lectric was designed to dissipate the condenser heat load to the atmosphere under ex treme summer conditions, which would probably coincide with peak river water temperature. Under normal conditions, this system would operate as a conventional once-through system with a long discharge canal. Predicted performance of this type of cooling system is somewhat theoretical with only limited test data avail able and no experience with a system of any appreciable size. Ground level fogging is a strong possibility with this type of cooling system.
Topping tower
Under normal conditions this system would operate as a basic once-through system. The topping tower would be used in order to meet the thermal discharge temperature limits established by the regulatory agencies regarding the use of a mixing zone. The high fir s t cost and characteristic performance o f natural draft cooling towers favor a circulating water system with a high temperature rise and low flow. An extra set of pumps, additional valves and piping are required to pump the warmed water from the condenser to the cooling tower where it would be returned by the gravity to the river. This concept essentially adds the cost of a second circulating water system to the total plant investment, without any improvement in the normal thermal performance. 5-9
Closed cycle cooling tcwer
An evaporative cooling tower system is another method of trans ferring waste heat to the atmosphere. It has an advantage over the spray canal and topping t'wer in that the cooling water is circulated in a closed cycle which eliminates the expense o f a redundant once-through cooling water system with its associated large river intake and discharge structures.
There are presently two basic types o f towers available, natural draft and mechanical draft. The size of a natural draft cooling tower for a given heat load is based on the relationship between cooling range and water flow rate. A higher cooling range, the temperature difference between the warm water to the tower and the cooled water to the condenser, results in a wanner temperature of air rising through the cooling tower thus producing a greater air flow. Natural draft towers for handling the waste heat from the Rush Island Plant units would be in the order o f 300 feet in diameter and 400 feet high. Natural draft cooling towers have several disadvantages compared to mechanical draft towers. They are higher capital cost, greater visual impact because o f the height and diameter o f the tower and the massiveness o f the e le vated visible plume, and greater freezing problems during cold weather operation.
Mechanical draft cooling towers u tilize a fan to move the air through the tower rather than depending on the stack effect as in the hyperbolic natural draft tower. Because of the power require ment for the fans operating costs are higher. Ground level fog ging and icing of the surrounding terrain can be significant problems because of the low-level moist air discharge. Consid erably greater plant site area is also required for mechanical draft towers.
Closed cycle cooling towers require a greater capital investment than once through cooling, have a higher operating cost, pose the p ossib ility o f problems o f an esthetic nature due to the structure size and discharge plume (natural draft), present a ground level fogging and icing problem (mechanical d ra ft), present a problem o f disposal o f the cooling tower blowdown, and fin a lly , they pro duce an overall system that is less efficient due to the turbine back pressure resulting in more fuel burned for the same plant electrical output. 5-10
Dry cooling tower
Dry cooling towers are mentioned as an alternate cooling method in a theoretical sense only. They are lowest in efficiency and highest in cost of any cooling system. At present, neither need nor state of the art of large steam turbine-generator design has advanced o the point where serious consideration is being given to actual installation of this type of tower on large power plants. i Turbines as presently developed cannot operate at the high back pressures that would result from the use of dry cooling towers. Considerable development work is required before turbines can be desigred and constructed for these exhaust conditions. Dry cooling towers are net an available alternate at this time for cooling units the size of the proposed Rush Island Plant units.
5.6 Alternate Air Quality Controls
Rush Island Plant Units 1 and 2 w ill both be equipped with high efficiency electrostatic precipitators for control of particulate emissions, designed to remove 99.5% of the total dust entrained in the flue gas. This w ill enable the plant to meet particulate emission requirements and reduce the total particulate in the flue gas to approximately 0.06 pounds per million btu o f heat input to the plant.
In the initial design of the proposed Rush Island Plant, in-depth studies were made of both foreign and domestic particulate removal equipment including electrostatic precipitators, scrubbers, and mechanical filte r s . E lectrostatic precipitators w ill enable the proposed Rush Island Plant to meet more stringent conditions than required by the current particulate emissions standards.
Work is currently being done by the applicant and others to develop commercially acceptable sulfur dioxide removal systems, and the Rush Island Plant is being designed to include space for installation of sulfur dioxide removal systems. Meanwhile, the Company has arranged for in itia lly fueling the units with a Southern Illinois coal having an initial sulfur content of about 1%, which will permit compliance with the Missouri Air Conservation Commission's regulation.
When sulfur dioxide removal equipment is commercially available, and i f sulfur emissions cause substandard ambient a ir quality, Union E lectric w ill in stall this type of equipment.
5.7 Alternate Circulating Water Intake Arrangements
An average water supply of 600,000 gallons per minute (gpm) or 1337 cubic feet per second (cfs) is required for removing the rejected heat from two 600 MW units. This cooling water w ill be removed from the river by circulating water pumps located in an intake
77 5-11
structure situated at the bank of the Mississippi River. The velocity of the intake water w ill be approximately one foot per second or less which should permit the escape of the majority of fish entering the intake.
Other methods considered for obtaining a cooling water supply from the river included a circulating water intake canal and an off shore intake structure. The river bank intake structure was select ed based on the following considerations:
1. Less impact on the aquatic ecosystem than the intake canal.
2. Less effect on river channel maintenance and navigation than the offshore intake structure.
3. Lowest investment and operating cost.
Intake canal
The Company's operating experience with circulating water intakes at other power plant installations on the Mississippi River has indicated that fewer fish are attracted to and trapped by the in take screens where the river provides a sweeping action past the intake structure. The slower moving water associated with an in take canal appears to attract fish with the result that a greater density of fish generally exists at the intake with this type of installation than it does where the river flows across the face of the intake area.
Offshore intake
Locating the intake offshore would remove it from the shoreline region which is reputed to be a migratory route for fish along the lower Mississippi River. However, an offshore structure of this type would be, during construction, more o f a problem to navigation and, once erected, be more vulnerable to damage from navigational related operations.
Fish screens
The Company has surveyed the industry with respect to fish screens that will prevent or discourage fish from entering water intakes. This survey indicated that electric fish screens have been in effective and that other types of screens are not in a state of commercial development or of reasonable effectiveness. The Com pany is going to make a test installation o f a compressed air screen at an existing plant. Should this installation or other types o f fish screen installations prove to be e ffe ctiv e , relia b le, and maintainable, Union Electric will install such a screen if it o is necessary. 6-1
SECTION 6
RELATION SHIP BETWEEN U )CAL SHORT-TERM USES OF ENVIRONMENT AND THE JLUNTENAl'iCE AND *Ei»llANCEHE»»T ~OF LONG-TERM PRODUCTIVITY
6.1 Cumulative and Long_-Terin Effects
''Short-term use : in this section is defined as the construction of a power plant and its operation for a period of 35 to AO years. During this tine, the condition of the surrounding area w ill not be significantly affected, nor will the facility limit potential de velopment of the area for other uses. Following the useful life of the plant, the site would be returned to its former state i f this proves to be necessary for maintenance of an acceptable ecological balance.
6.2 Short-term Effects
The Company's short-term use of the site will involve a construc tion period of 5 to 6 years, followed by operation of the gener ating facilities for a period of 35 to AO ypars. During the con struction period, a naxir.un of about 1000 workmen w ill be employed. Although most of these people will not become residents of the area, their day-to-day influx w ill affect the surrounding local communi ties in that demands for goods and services w ill be increased. It is also recognized that vehicular traffic will substantially in crease and that in some ways, construction activity may temporarily affect life-styles of local residents. During this period, various components of the ecosystem may be disturbed, but no serious or permanent disruntion will occur.
Present use of the land encompassing the Rush Island Plant site is primarily agricultural. It is estimated that the plant and its associated facilities will remove approximately 350 acres from cultivation. However, short-term use of the land for a power gen eration installation will not preclude its future use for other productive purposes. Aside from its possible return to agricul tural use, the area has a potential for commercial, residential, and recreational development, which is considered impractical at the present time. Possible development of the land areas surround ing the site should not be seriously affected by the presence of the plant. The installation and operation of the Rush Island Plant w ill probably enhance the short-term productivity of the land and economic status of the area without having significant deleterious effects on its future, long-term potential for productivity. o 6-2
Operation of the proposed power plant complex is not expected to have significant long-range effects on local wildlife. Wildlife w ill be displaced during construction, but plans submitted by Union Electric indicate that wildlife habitat for small game will be provided.
Short-term effects of discharges into the atmosphere can become less significant as feasible technological advances result in less objectionable stack emissions. Emissions are expected to fu lly comply with existing air quality standards, and can be modified to meet more stringent standards i f necessary.
Effluents returned to the river from the plant complex will not result in any significant adverse effect to the acquatic ecology. The e ffects of the heated water discharge are expected to be mini mal. Modifications to the cooling system can be made i f this expectation is not realized. All discharge will be monitored to assure that water quality standards are met. The discharges are not expected to have any cumulative e ffe ct to the ecosystem.
The resources of land, air, and water will remain intact and un harmed regardless of the short-term use of the area as a power generating station.
o 7-1
SECTION 7
IRREVERSIBLE AND ^RETRIEVABLE COMMIT? IE NTS OF RESOURCES \J}1_ICH WOULD BE INVOLVED IN THE~"P!ROPOS_ED" ACTION ~SHOULD~IT ~BE~ If ELEMENTED
A major irreversible and Irretrievable commitment of resources resulting from the proposed installation is the burning of coal for the operation of the plant. Coal requirements for Rush Island units 1 and 2 will amount to approximately 2.5 million tons per year. Based on current production of 600 million tons per year in the United States, these units w ill u tilize about 0.4 percent' of the coal supply mined annually. Minable coal resources in the United States are estimated at 1.48 x 10^ metric tons or about 650,000 times the annual estimated consumption of the Rush Island Plant.
For the most part, material resources involved in the construction of the plant will be nonrecov«rable. In terms of national pro ductivity and resources, quantities of copper, steel, and other building materials that will be used for the Rush Island Plant are infinitesim al.
It may also be reasoned that labor hours and manufacturing capa bility devoted to this project comprise an Irretrievable allotment of productive capacity. An order of magnitude estimate of this commitment would approach 20 m illion manhours.
Proposed plans provide for the disposal of ash by burial on the site. The ash pit will be constructed by excavation, and the mate rial removed w ill be used on the s ite . A permanent alteration to the existing substrata of the island will result if these plans are implemented. Vegetation indigenous to the area should not be affected, and could be used to protect the pits from erosion when ' they are filled. This plan is not expected to affect water quality, and the permanent alteration of the substrata is not considered adverse. 8-1
SECTION 8
COORDINATION WITH OTHERS
Numerous meetings and briefings have been held to discuss the pro- prosed plans to construct a power plant and appurtenant structures on and adjacent to Rush Island. Except for the meetings and b rie f ings with permitting agencies, the presentations have been informal discussions and no official written record was made. Sections 8.1 through 8.3 describe coordination accomplished prior to release of the draft environmental statement. Section 8.A contains summaries of written comments received from organizations that reviewed the draft environmental statement, and the responses to those comments. All correspondence received from reviewing agencies is incorporated in Appendix E. All pertinent comments received from individuals have been addressed in this statement.
8.1 Public Participation Prior to Draft Environmental Statement
As required by Missouri Regulatory Law, on A January 1971, the Union Electric Company filed an application with the Missouri Public Service Commission for permission and authority to construct, operate, and maintain the Rush Island Plant. After notice to in terested parties, a public hearing on this application was held in Jefferson City on 8 April 1971. The Public Service Commission subsequently issued a report and order dated 21 May 1971 stating "That Union Electric be, and is, hereby authorized to construct, operate and maintain a multi-unit steam electric generating plant to be known as its Rush Island Plant in Jefferson County, M issou ri..." The order sp ecifica lly did not waive compliance with any air or water quality standards of the States of Illinois or Missouri or the Government of the United States.
The Rush Island power plant was also the subject of a meeting held by the Coalition for the Environment and the East-West Gateway Coordinating Council on 25 January 1972 at the Ethical Society Auditorium. Some of the Issues raised at this meeting included the adoption of a policy by Union Electric to discourage use of e le ctricity in order to alleviate demand for power, the fish k ill rate at Union Electric's Portage de Sioux Plant, the relation of height of proposed stack to elevation of bluffs near Rush Island, the ratio of the proposed output of the plant to Union Electric's total power output, and the visual and aesthetic impact of the power plant and transmission lines.
This meeting generated a great deal of response to the project, including repeated requests that an environmental impact statement be filed for the project.
The St. Louis District held a public hearing on 29 March 1972, to discuss the pending construction permit. The hearing was attended by approximately 150 persons, many of whom live in the 8-2
immediate vicinity of the proposed power plant site. Also attend ing the hearing were representatives o f the Environmental Pro tection Agency, Missouri Clean Water Commission, State and inter state conservation agencies, and local groups concerned with en vironmental issues. Some of the more important issues raised during the discussion included loss o f public access to the Mis sissippi River, increased traffic on local roads, and the possi bilities of excessive air pollution, thermal pollution, fish k ills , and undesirable land use. These issues are addressed in this statement. A copy of the hearing transcript is available for review at the St. Louis D istrict O ffice.
8.2 Coordination wi_th Government Agencies Prior to Draft Environ mental Statement "
Local level
The regional planning commission of the area involved by the project, East-West Gateway Coordinating Council, was informed o f the project. Also involved was the Upper Mississippi River Conservation Commit tee, a panel composed o f members of the State conservation commis sions on the Mississippi River. These two groups were represented at the meeting held on 25 January 1972.
The Upper Mississippi River Conservation Committee was present at a meeting on 31 August 1971 to discuss the plant with Union E lectric officials and representatives of Federal and State agencies. The East-West Gateway Coordinating Council attended a briefing on 17 December 1971 prior to the public meeting they co-hosted.
The Upper Mississippi River Conservation Committee has identified certain sp ecific environmental impacts that may result i f a power plant is bu ilt. These possible impacts include the effect o f passing barge tr a ffic and wind on the "mixing zone" for the dis charge, the stratification of heated water, and the possibility of significant destruction of fish, fish eggs, larvae, and other aquatic organisms. These issues are addressed in this statement.
Initial contact with these organizations was made when the appli cant's detailed plans were circulated by public notice.
Representatives of Union Electric and Bechtel Corporation met with Warren Lynch, Jefferson County Highway Engineer, and Judge Krodinger o f Jefferson County on 2 August 1971. The purpose of the meeting was to acquaint the county o fficia ls with Union E lectric's plans for the development of Rush Island, and included a discussion o f the roads in the area and Union Electric's plans to limit access to the proposed construction site. The county officials expressed no objection to the proposal. h
8-3
State jUjvel
State level agencies have been consulted concerning the project. Those agencies granting specific permits were informed in detail of proposed plans. Other agencies were briefed on the project by public notice and subsequent correspondence and meetings. These agencies and their comments on the proposed plans include:
Missouri Public Service Commission has issued a certificate of convenience and necessity to construct and operate Rush Island power plant.
Missouri Water Pollution Board (since reorganized as Missouri Clean Water Commission) has issued preliminary certifica tion for construction permit application, stating that applicant's plans for construction will comply with water quality standards.
The Missouri Department o f Conservation has recommended that the construction permit not be separated from the discharge permit. This agency also requested that an environmental impact statement be filed due to the complex environmental issues involved. The agency makes specific reference to heated water discharges that could violate temperature standards, resulting in excessive fish kills and destruction of fish eggs, larvae, and aquatic organisms. The issues raised were discussed at the hearing and are addressed in this statement.
The Missouri Department o f Community Affairs originally objected to the issuance of the permit because of questions concerning water temperature standards, and thermal pollution, air quality, water quality, and other areas o f concern. Union E lectric, how ever, answered the objections adequately and the agency withdrew its objections.
The Missouri State Park Board and State H istorical Survey and Planning Office voiced no objections to the permit application.
The power plant was designed to meet the emission regulations prescribed by the Missouri Air Conservation Committee. Union Electric thus conformed to State requirements regarding air quality.
Federal level
The Environmental Protection Agency, Region VII, reviewed the plans submitted by Union Electric and recommended that the original open channel discharge structure be redesigned. When Union E lectric 8-4
revised their plans to include an offshore discharge structure, rather than an open channel discharge o u tfa ll, the Environmental Protection Agency commented that this action satisfied the "initial objections from a water quality standpoint to issuance of a Section 10 (construction) permit."
The Department of the Interior, Division of Fish and Wildlife Service, Bureau of Sport Fisheries and Wildlife comments that Union E lectric's previous environmental assessment is inadequate. They request "more satisfactory documentation that their (Union Electric's) operation will not adversely affect the Mississippi River habitat and its resources." The Bureau also comments that Union E lectric's proposed discharge cannot meet proposed standards as it is presented. These issues are addressed in this statement.
The National Park Service, Midwest Region, interposes no objec tions to the proposed construction.
The Field Representative, Missouri Basin Region, Department of The Interior, has requested the construction permit be denied until an environmental impact statement is file d . His objections cite an inadequate treatment o f environmental issues such as recreation potentials and destruction of fish and wildlife. These issues are addressed in this statement.
The construction work that is presently being done at the Rush Island Plant site has been authorized by a permit dated 3 June 1971 from the Corps o f Engineers and revised by a letter dated 18 November 1971. The 3 June 1971 permit authorized the excava tion of the main power plant building area and the filling of this area with 1,000,000 cubic yards o f sand to be dredged from the river. The 16 November 1971 revision authorized additional filling o f the plant site with material to be dredged from the ash d is posal pond. This permit revision also terminated the authoriza tion for dredging fill material from the river.
In response to an application dated 14 May 1971 the Federal Aviation Agency notified Union Electric on 15 July 1971 that con struction o f the 700-foot high stack at the Rush Island Plant w ill not be a hazard to air navigation.
8.3 Coordination with Citizen Groups Prior to Draft Environmental Statement
The St. Louis District issued public notices concerning the con struction of Rush Island power plant and received replies as follow s: 8-5
a. The Navigation Committee, Waterways Operations Conference (formerly Navigation Committee, River Operations Cc;nmittee for Common Carriers) objected to the proposed plans because that organization believed the proposed plans presented a navigation hazard. In a meeting held 5 October 1971, their objections were sa tisfied when Union E lectric agreed to a barge mooring re striction . This meeting also included representatives o f the Marine Officers Association. Objection to the issuance of the construction permit was withdrawn, pending the incorporation of the barge mooring restriction in the construction permit.
b. Both the Coalition for the Environment and the Jefferson County Environmental Committee requested an environmental impact state ment be filed prior to issuing a construction permit. The Coalition for the Environment also held a public meeting on the project in conjunction with the East-West Gateway Coordinating Council. The Jefferson County Environmental Committee submitted a list of questions that were addressed at the public hearing on 29 March 1972. Some of the more important issues raised by this group include land use in the area o f the proposed power plant, public access to the Mississippi River, local road and traffic considerations, transmission line rights-of-way, and possible air, water, and thermal pollution. These points, except for transmission lines, were discussed at the hearing. All these issues are addressed in this statement.
c. The League o f Women Voters o f Missouri has expressed concern over thermal pollution. They also requested that an environmental impact statement be file d before the permit is issued.
8.4 Comment and Response on Draft Environmental Statement
Copies o f the draft environmental statement, dated 24 July 1972, were sent to the following organizations and agencies for comment:
Date of Date o f Transmittal Comment
Environmental Protection Agency 26 July 31 August Kansas City, Missouri
Department o f the Interior 26 July 4 October Washington, D.C.
Department of the Interior, Field Representative 26 July 4 October Denver, Colorado
U.S. Fish and W ildlife Service 26 July 4 October Twin C ities, Minnesota
Department o f Health, Education, and Welfare 26 July No comment Washington, D.C.
Department o f Housing and Urban Development 26 July No Comment Washington, D.C. 8-6
Dcte of Date o f Transmittal Comment
Federal Highway Administration 2o July 24 August Kansas City, Missouri
Second Coast Guard D istrict 25 August 30 August St. Louis, Missouri
Department o f Commerce 26 July No Comment Washington, D.C.
Office of Economic Opportunity 26 July 14 August Kansas City, Missouri
Department of Agriculture 26 July 30 August Washington, D.C.
U.S. Forest Service 26 July 17 August Rolla, Missouri
Missouri Water Resources Board 26 July 9 August Jefferson City, Missouri
Missouri Clean Water Consnission 26 July 10 August Jefferson City, Missouri
Missouri Department of Conservation 26 July 24 August Jefferson City, Missouri
Missouri Department o f Community Affairs 26 July 18 September Jefferson City, Missouri
Illin o is Environmental Protection Agency 26 July 8 August Springfield, Illinois 20 October
Illinois Department of Conservation 26 July No Comment Springfield, Illinois
Illin o is Department o f Business 8 Economic 26 July No Comment Development Springfield, Illinois
Upper Mississippi River Conservation Conmittee 26 July 19 September Davenport, Iowa
Coalition For the Environment 26 July 25 August St. Louis, Missouri
League o f Women Voters 26 July 23 August St. Louis, Missouri
East-West Gateway Coordinating Council 26 July 30 August St. Louis, Missouri
Jefferson County Environmental Committee 26 July No comment Ballwin, Missouri 8-7
Following is a summary of the conments received from reviewing organizations, and a response to the comment, where appropriate:
Illin o is Environmental Protection Agency, Permit Section, Springfield, Illin ois
Comment: 1. There is no reason for concern over the ash pond discharge i f i t is baffled to prevent floating material from reaching the effluent and i f the ash is kept covered with water to prevent acetic conditions in the pond.
Response: 1. The applicant's proposal provides for the ash being kept covered by water at all times. The conpany indicates that a baffle or float arrangement w ill be used at the ash pond discharge pipe to prevent floating materials from entering the discharge.
Missouri Water Resources Board, Department of Business and Administration, Jefferson City,"Missouri
Comment: 1. The statement is adequate and sufficiently covers the local environ ment to permit an in telligen t appraisal o f environmental impact. The Union E lectric proposal has been programmed to eliminate or minimize possible environmental impacts.
Response: 1. None.
Missouri Clean Water Commission, Department of Public Health and Welfare, Jefferson City, Missouri
Comment: 1. Our review o f the statement was limited to water quality effects. All conditions previously issued to applicant by this office are in cluded in the statement.
Response: 1. None.
Office of Economic Opportunity, Region VII, Kansas City, Missouri
Comment: 1. Rush Island Power Plant would probably have very lit t le impact on poverty in Jefferson County. No detrimental inpact to the low-income population would appear to result from this undertaking.
Response: 1. None. 8-8
United States Department o f Agriculture, Forest Service, Northeastern Area, State and Private Forestry, Upper Darby, Pennsylvania
Comments: 1. Provisions should be made for the removal of sulfur dioxide from stack emissions should the sulfur content of the coal increase.
2. Forest land adjacent to the site should be monitored to detect any vegetative damage from stack emissions and corrective action should be taken if vegetative damage is detected.
3. Comments from the Illin o is Department o f Conservation should be reviewed for reference to any effects of stack emission on Illinois.
Responses: 1. Applicant has already made provisions for installation of sulfur dioxide removal equipment when such equipment is necessary and avail able. Plant is designed so that such equipment can be added. Appli cant is also actively involved in experimental research to develop sulfur dioxide removal equipment. This information is found in Section 1.3.
2. The concentrations of emissions from the applicant's power plant are expected to be below the level that results in damage to plants, as determined by the national secondary ambient air quality (page 3-1). It is expected that emissions from the proposed power plant will have no adverse e ffe ct on vegetation in the area, and no plan to monitor local vegetation has been developed. Air monitoring stations, however, w ill be placed in the immediate plant area to measure local ground level concentrations of some air pollutants.
3. Comments were requested from the Illin o is Department o f Conserva tion. That agency did not comment.
League of Women Voters of Missouri, St. Louis, Missouri
Comment: 1. Our prime concern was effects of heated water to the ecology of the receiving stream. We find no objection to applicant's proposal since both the stack emissions and water circulating system can be altered if necessary.
Response: 1. None. o 8-9
United States Department of Transportation, Federal Highway Adminis tration, Kansas City, Missouri
Comment: 1. This statement adequately documents the effects the project w ill have on resources under this agency's jurisdiction, and will not adversely affect any o f our highway programs.
Response: 1. None.
Missouri Department of Conservation, Jefferson City, Missouri
Comments: 1. A statement on page 3-11 o f the draft statement is confusing: '"During an abnormally high temperature summer, the maximum river temperature standard (column 3 o f the above tabulation) might be exceeded less than one percent o f the time." Column 2 is the tem perature standard, not column 3.
2. The temperature standard listed in the table (page 3-11) is greater than the maximum recorded temperature. Will power reduction be re duced or supplemental cooling be available when the standards would be exceeded?
3. Provision should be made to monitor the intake screens to docu ment fish losses at that point so that the State can be reimbursed for damage to aquatic resources. Monitoring should be continued until a satisfactory system is found to prevent loss o f fish on the intake screen. The monitoring system should be mutually agreeable to the involved parties and fish values should be based on a generally recognized and accepted publication such as "Monetary Values of Fishes" (Pollution Committee, Southern Division, America Fisheries Society). Recognition should be made that values will change and require updating.
Responses: 1. Column 2 is the maximum recorded ambient river temperature. Column 3 is the maximum river temperature standard.
2. The standard in Column 3 is greater than the maximum recorded ambient river temperature. The temperature o f the river, however, is not expected to rise above this maximum recorded temperature. A comparison o f Column 4 to Column 2, on the referenced tabulation, shows that the ambient river temperatures that may be exceeded less than 1% o f the time are not as great as the maximum recorded river temperatures. The applicant must conform to the standards established by appropriate Federal and State agencies. I f the standards are ex ceeded, Union E lectric w ill u tilize some supplemental cooling system. The determination as to the exact supplemental cooling system w ill be o made i f , and when, the proposed system proves inadequate. 8-10
3. Union Electric has expressed willingness to meet with the Missouri Department of Conservation to arrive at some "mutually agreeable" monitoring system for the intake structure. Union Electric will also continue its ongoing intake screen study to determine some method o f preventing, or minimizing, any destruction of fish. This study, when completed, will be available at applicant's corporate offices.
Coalition for the Environment, St. Louis , Missouri
Comments : 1. Would it be possible to aim for a nuclear power plant by 1979 1980 and to manage in the interim by expanding existing fa c ilitie s and borrowing power? The report does not make clear i f the proposal precludes transition to nuclear power or if it itself can be a limited interim measure.
2. While the report states that no alternate site offers "substan tial advantage" over the proposed site, is some other site in a less conspicuous area?
3. The report seems very uncertain as to the extent or effects of thermal pollution. Shouldn't the estimate gc further than a prelude to experimentation? With better information, the plant could be upstream o f the confluence.
4. The Corps o f Engineers should evaluate the project on the basis o f impact on the river rather than the community's power needs. An analysis on the basis o f power needs might be more appropriate from the Federal Power Commission.
5. Is the issuance of a permit a major Federal action requiring an analysis o f the project impact from a ll aspects?
6. Do applications for private development require the public agency to develop alternatives? Does this not place an impossible burden upon the Corps o f Engineers?
Responses: 1. Construction and operation of the proposed power plant is an interim measure by Union Electric to provide power. Applicant plans to build a nuclear power plant, but the planned nuclear fa c ility cannot be bu ilt in time to meet predicted power demands o f 1975. The Rush Island Power Plant is intended to meet these predicted demands. This is explained on page 5-5 in a discussion o f a nuclear fueled unit as an alternative to the proposal.
2. The proposed site is in a very nonconspicuous area, in the es timation o f this D istrict. The applicant also made this a primary factor in the original decision to construct the power plant at Rush Island. 8-11
5. The cooling water discharge from the Rush Island Power Plant is not expected to have any significant adverse environmental impact. The effects of a proposed thermal discharge cannot be directly measured, but must be predicted. The methods o f predicting the impacts that are described in the statement appear to be valid. No alternative method has been offered.
4. Corps o f Engineers regulations for the preparation o f environ mental statements, published 2 February 1972 in the Federal Register, require an analysis of the effect that a proposal would have on the total environment. This statement has attempted to report all the expected environmental impacts o f the proposed power plant on a ll areas o f the environment that might be effected. A determination o f community power needs is necessary in order that a comprehensive report be developed that completely discusses a ll environmental trade-offs. Only in this way can the best interests and needs of the public be determined.
5. Council on Environmental Quality Guidelines, published 23 April 1971 in the Federal Register, state that projects involving a Federal permit can require the preparation of an environmental statement.
6. None.
United States Department o f Transportation, United States Coast Guard, Second Distri c t , St.' Louis , Missouri
Comment: 1. Proposed project w ill not affect anything under our ju risdiction .
Resnonse: - - .... - - i - - 1. None.
East-West Gateway Coordinating Council, St. Louis, Missouri
Comments: 1. The statement adequately justifies the need for additional elec trical generating facilities at this time, and at the proposed site.
2. The City of St. Louis is now conducting a pilot program utilizing so lid waste as a fuel to generate e le ctric power. Will Rush Island be convertible to that use if the pilot program is successful?
3. What is the environmental impact from all four of the 600 million Watt units?
4. An environmental assessment o f one power generating fa c ility within a metropolitan area has relatively little meaning. As part of the planning process for the next power generating fa c ilit y , we would strongly urge that the applicant prepare a plan for their entire metropolitan area system. 8-12
Responses : 1. None.
2 . The program referred to is being conducted at one o f Union Electric's existing facilities. Rush Island could be converted to use solid waste as fuel without extensive redesign.
3. I f the proposed Rush Island Power Plant is expanded to four units in the future, it is expected that additional permits or mod ifica tio n o f existing permits would be necessary. The environmental impact o f a ll four units wouid be considered at that time.
4. None.
United States Department o f Agriculture, Washington, D.C.
Comments: 1. There is nothing in this statement to indicate the environmental impact o f the coal mining operations which w ill supply the fuel for the proposed plant.
2. There is no clear estimate of the probability of flooding at the plant site. The probability and associated adverse effect of waste material being carried out of the ash pond into the river should be acknowledged.
3. More specific information on proposed transmission lines should be given.
4. After construction, control should be exercised in allowing the site to return to a natural state. Control should prevent a dense overstory from shading out a ll grasses. I f grass is not present, storm water runoff could cause erosion.
Response s: 1. A detailed analysis of the environmental impact of coal mines is not provided as coal mining is too remote to the project for detailed consideration. Coal mining is not part o f the proposed power plant. Applicant will only purchase low sulfur coal from a coal company. The proposed project does not include a proposal by the applicant to open coal mines for fuel. A brief description of the reclamation policy of the state where the coal is mined can be found on page 1-10.
2. Concur. More detailed information has been included on page 3-29. If a flood of sufficient magnitude to enter the proposed ash pond occurred, the wastes carried out o f the ash pond would be relatively minor. The proposed ash pond will be protected from floods by a dike constructed to elevation 410 feet m .s.l., two feet above the 200-year o flood. 8-13
3. Section 3-13 has been included in the final statement to outline the applicant's proposed methods o f minimizing adverse environmental effects due to installation of the transmission lines. A detailed description is not provided. Transmission lin es, while part o f the power plant, are not a part o f the pending permit. An exact descrip tion of lands involved is not available in that the applicant has not yet determined the exact right-of-way.
4. The applicant has invited conservation agencies to suggest any plans they might have for the area in question. By returning the area to a "natural state," applicant does not intend to create a densely forested area. Applicant also indicates that plans for a park at the access area could be discussed.
United States Environmental Protection Agency, Region VII, Kansas City, Missouri
Comments 1. There is insufficient information concerning flood protection measures. The statement should include a table of flood frequencies so that the adequacy o f flood protection measures can be determined.
2. The statement should assure that the purchase o f low sulfur coal w ill net contribute to environmental degradation due to inproper strip-mining practices.
3. Fly ash composition should be analyzed to determine the nature o f the leachate that may enter the water table and river both through the soils and from the overflow pipe.
4. In citing two specific items that may increase the initial life of the ash pond beyond 10 years, the statement declares, "Second, as the life of the plant increases, the load factor (percent of time in operation) decreases." This sentence is unclear and should be explained.
5. Contaminated storm water, draining directly to the ash pond, could contain oil or grease and be directly discharged to the river.
6. A more detailed discussion o f the environmental inpact o f the transmission lines to be built from Rush Island should be included in the statement.
7. In reference to the method for estaimating SO2 ground level concen trations on page 2-8, one cannot always assume that SO2 concentrations in two different areas of similar population density and relative location to a metropolitan area are the same or similar. Measurements o f SO2 concentrations should be made at the proposed plant s ite . 8-14
8. The statement on page 2-9 that emissions from ta ll stacks penetrate inversions in the lower 500 feet of.the atmosphere and the inversions often act to reduce ground level concentrations of emissions is not usually the case. Although the in itia l thrust o f the plume inversion may push emissions above the inversion layer, the cooler air above the layer forces the contaminants back down.
9. The expected emission rate for NO is omitted from the table on page 3-1.
10. The expected particulate emission is stated to be "0.06 per million BTU" o f heat to the plant. It would cla rify the statement i f units are added to the numerical value.
11. The draft statement declares that mercury emissions from the proposed power plant will probably not be significant. Equally important is the total ground level concentration. Current ground level concentrations should be measured for mercury as well as the other pollutants.
12. If the proposed plant does "reinforce the rising rate of water borne tr a ffic in the area of the plan t," the mooring fa c ility may be required to provide facilities for disposal of wastes from holding tanks of boats using the facility to comply with the Marine Sanitation Device Standards , 37 CFR.
13. The distance offshore of the heated water discharge is not specified. Although an estimation can be made with the scale o f Figure 1-8, the distance from the bank should be given in the final statement.
14. The discussion o f thermal effects was well done, especially Appendix C. The report, however, did not explain the type or basis o f the mathematic modeling techniques used to determine temperature distribution patterns, and did not state to what extent the mathemat ical model has been verified by studies on existing plants. Also, compliance or noncompliance with thermal discharge criteria depends on the nixing zone set by the states involved.
15. A sign ificant item missing from the statement was an evaluation of the cumulative thermal loadings on the Mississippi River from above the metropolitan St. Louis area to a point below the Rush Island plant. This point should be investigated and included in the final statement.
16. The statement assures, 'The final reports on the aquatic studies conducted at the Sioux Plant and the site of the proposed Rush Island plant w ill be available after 1 September 1972." Page 3-19, paragraph 1, also admits, "A complete analysis of the intake screen study is not yet completed." Additional information acquired after completion of the aquatic studies should be included in the final statement. 8-15
17. In Section 3, the report notes, "Some indirect effects may result from cumulative b io lo g ica l, chemical and physical changes which may result in the alteration of the existing ecosystem. IVhether these subtle effects w ill detract from, or actually enhance, the present situation is not predictable at this time." A continuing ecological monitoring system should be considered by Union Electric in order to determine any alteration o f the existing ecosystem. I f these effects are found to detract from the present quality o f the environment, corrective measures should be planned.
18. In reference to chemical parameters for the discharge from the Rush Island plant, the statement asserts, "... based on a limited sampling o f existing Union E lectric power plants, it is expected that the Missouri and Illin ois effluent standards w ill be met with the proposed details of the Rush Island plant design. If necessary, changes in design will be made as information is developed to assure that the standards are met." Additional information as to the pro posed "changes in design" which might be undertaken should be in cluded in the final statement.
19. The report states, "Herbicides will only be used to control weeds in construction storage areas which will involve less than two percent of the plant site or ten acres." The statement should also indicate what measures w ill be taken to prevent damage to the natural environment, including the Mississippi River.
20. The statement indicates that construction debris and trash will be removed from the plant site for proper disposal or buried in a sanitary la n d fill on the plant s ite . Recently enacted Senate B ill No. 387 o f the 76th General Assembly states the requirements for solid waste management in Missouri. These requirements include a permit system administered by the Division of Health for a ll solid waste processing and disposal facilities in the state.
Responses: 1. Concur. More detailed information has been added to page 3-29.
2. A detailed analysis o f the environmental impact o f coal mines is not provided as coal mining is too remote to the project for detailed consideration. Coal mining is not part of the proposed power plant. Applicant will only purchase low sulfur coal from a coal company. The proposed project does not include a proposal by the applicant to op^n coal mines for fuel. A brief description of the reclamation policy o f the state where the coal is mined can be found on page 1-10.
3. An analysis of coal ash is included on page 1-11 of the final environmental statement. IL
8-16
4. The statement concerning a decreasing lead factor has been ex plained in more detail on page 1-12.
5. Applicant's discharge from the ash pond must conform to all Federal and State regulations. Union Electric will install oil and grease removal equipment i f such equipment is necessary to comply with regulatory agency requirements.
6. Section 3-13 has been included in th . final environmental state ment to outline the applicant's proposed method o f minimizing adverse environmental effects due to installation o f the transmission lines. A detailed description is not provided. Transmission lines, while part o f a power generating fa c ility , are not part o f the pending permit. An exact description of lands involved is not available be cause the applicant has not yet determined the exact rights-of-way that w ill be used. A general description o f the rights-of-way may be found on pages 1-13 and 1-14 o f the final environmental statement.
7. Continuous air monitoring stations w ill be installed and oper ating in the immediate vicinity of the proposed power plant substan tially before start-up of the first unit. Ambient air quality at the Rush Island area will be recorded before the plant is in operation. This was recommended by applicant's meteorological consultant (see Appendis B), and the commitment to in stall air monitoring stations was made by the applicant at the public hearing held by this District on 29 March 1972.
8. The statement referred to in this comment is based upon actual observations made by the applicant. Conditions described in the comment do not occur with sufficient frequency or duration to create a significant pollution potential in this area. This conclusion, and its basis, are stated on page 2-10 o f the final environmental state ment.
9. Concur. Expected N0X emission rate has been included in the table on page 3-1. The allowable emission rate has not been deter mined by the State of Missouri.
10. Units o f expected particulate emission are pounds, and this omission has been corrected in the final environmental statement.
11. There is no known accurate and reliable method o f measuring ground level concentrations o f mercury without the permanent in stal lation o f atomic spectographic equipment. In addition, regulatory agencies have no standards for ground level concentrations o f mercury.
12. Union E lectric must, and w ill, comply with all regulations promulgated by Federal and State regulatory agencies.
13. Concur. This information may be found on page 1-8 o f the final environmental statement. 8-17
14. The mathematical model was developed by studies on existing plants. Appendix D is an explanation o f the mathematical model.
15. Temperature data on the Mississippi River, collected at applicant's existing u tility plants, indicate no discernible cumulative thermal loading through the metropolitan St. Louis area. No formal study o f cumulative thermal loading is planned. The thermal impact o f the proposed cooling water discharge was discussed on pages 3-10 through 3-12 o f the draft environmental statement, and appropriate figures.
16. Information from applicant's completed environmental surveys is included in the final environmental statement, as well as preliminary reports from ongoing studies. All environmental surveys performed by Union Electric will be made available at applicant's corporate offices when final reports are completed.
17. Applicant plans to perform ecological monitoring after the proposed plant is in operation. Although the exact extent o f this monitoring has not yet been determined, the applicant indicates that the program will at least be as extensive as the pre-construction environmental survey.
18. No sp ecific information is available on the "changes in design" referred to in this statement. Applicant must comply with all state and Federal effluent standards, and w ill employ whatever equipment or treatment necessary to comply with these standards. Until a specific parameter, or combination of parameters, is known to violate the standards, the exact method o f treatment cannot be accurately described. I'.herever possible, contaminants w ill be intercepted at the source and not be permitted to intermix with other effluents.
19. Herbicides will only be applied locally, to specific areas re quiring control. Methods for treating large areas, such as aerial spraying, are not planned. No e ffe ct to the environment is expected.
20. Union Electric must, and w ill, comply with all regulations promulgated by Federal and state regulatory agencies. Applicant has applied to the state for the referenced permit.
State of Missouri, Department of Community Affairs, Jefferson City, Missouri
Comment: 1. No state agency has comments outstanding on the draft environmental statement.
Response: 1. None. 8-18
Upper Mississippi River Conservation Committee, S t. Paul, Minnasota
Comments: 1. We can find no clear-cut definition of what will be done to rectify damages to the river's ecosystem caused by the heated water discharge.
2. The number of fish destroyed on intake screens at other power plants should be provided rather than percentages.
3. An overall review o f the environmental impact statement clearly shows the degrading effects of a variety of projects on the environ ment of the Mississippi River.
4. The environmental impact statement does not discuss the possible effects o f future navigation developments on the Rush Island power plant. For example, the current 12-foot channel project study may recommend four or five additional locks and dams below St. Louis as the best alternative to achieve 12-foot navigation depths. All of the possible effects stated in the environmental impact statement assume the continuance o f a modified free-flowing river throughout the 45-year life o f the power plant. What would be the e ffe ct o f the power plant on the river i f dams are constructed and the open- river section becomes a lake-type environment?
5. Another issue not addressed in the environmental impact state ment is the impact o f decreased water flows from the Missouri River Basin. We understand that the Comprehensive Basin Study for the Missouri River predicts a flow decrease from 54,000 cfs to about 40,000 cfs. If so, what effect would this decrease have on thermal patterns of the discharge water from Rush Island?
6. Section 1, page 1-2, indicates that potential air-conditioning demand was a factor in the need for the Rush Island power plant. An alternative to this is the need for an electrical conservation policy by the Union E lectric Company to attempt to reduce such demands. Such a policy is not discussed in the environmental impact statement.
7. The environmental impact statement should be modified to include a continuing biological sampling program at a ll seasons o f the year prior to plant construction and operation. The study results should be provided to the Missouri and Illinois Conservation Departments.
8. Although various alternate cooling methods are eliminated as unfeasible for one reason or another (pages 5-7 through 5-10) the overwhelming opinion of professional biologists would be in favor o f retaining the p ossib ility o f an alternate cooling system for discharge waterat Rush Island. It should be mentioned, too, that although spray canals are eliminated as an alternate cooling method because they are "somewhat th eoretica l," sudi a cooling system is 8-19
currently being constructed at the Quad-cities nuclear power plant. This power plant is sign ificantly larger than the proposed Rush Island power plant.
9. The cumulative and long-term effects (page 6-1) o f the power plant are not adequately discussed. This section should at least include a requirement for a long-term study to determine what the long-term effects would be.
Responses: 1. Concur. Applicant w ill be required to provide some alternate cooling system i f the heated water discharge damages the ecosystem. Plant design and layout include provision for several alternate cooling schemes. The decision as to what alternate cooling system w ill be u tilized w ill be determined i f , and when, the need for such a system arises.
2. The final statement has been revised to include this information on page 3-19.
3. None.
4. A decision to build dams below Rush Island and impound the Mississippi River at the proposed construction site has not been made. Inasmuch as no detailed information is available concerning the possible impoundment of the river, this is not discussed in the statement. Furthermore, the environmental statement for the dams, if proposed, will discuss all the effects of impounding the river. It should be noted that quantity of flow is not essentially altered by navigation dams. Applicant has in itiated a thermal plume study at its Sioux Plant. This study should determine the effect and distribution o f a thermal plume in an impounded section of the river.
5. Low flows o f 54,000 and 40,000 cfs mentioned in this comment serve as baseline flows for this District's channel maintenance responsibilities below the mouth o f the Missouri River. The values are unrelated to possible flow reductions that are discussed in the Missouri River Basin Study. This D istrict can presently o ffer no comment on the Basin Study, nor on water usage p riorities discussed in this study that might decrease flows.
6. This is beyond the scope o f an environmental statement. A
8-20
7. The applicant's testing program for the pro-construction environmental assessment did not include sampling during the summer months. Union Electric plans to perform additional surveillance of aquatic biota which w ill include sampling during the summer months. The pre-constnjction survey does, however, provide an adequate basis for prediction o f possible adverse environmental e ffe cts.
8. The alternate cooling systems outlined in Section 5 are not eliminated as possible alterations. This section presents all alternatives considered and the reasons for not selecting them for the original design. If the actual effects of the thermal discharge are not in accord with the predicted e ffe cts , any of these alternate cooling systems ccuid be incorporated into the Rush Island plant to mitigate adverse environmental e ffe cts.
9. Union Electric has indicated that post-construction environmental assessments will be conducted. The company will continue to main tain surveillance of aquatic biota, and will install air quality monitoring stations before operation of the power plant. Environ mental surveys w ill be conducted after the plant is in operation to determine whether supplementary cooling devices are necessary. Any discharge from the ash pond w ill also be monitored and the data on the efflunet will be reported to the proper regulatory agencies. The company has committed it s e lf to determining the environmental effects of power plants, and ongoing studies at existing facilities indicate that thorough surveys are performed to determine these e ffe cts. Although there may be some adverse environmental effects i f the proposal is implemented, there is no evidence to suggest that any cumulative or significant adverse environmental effects w ill occur.
United States Department of the Interior, O ffice of the Secretary, Washington, D.C.
Comments: 1. The statement does not give adequate consideration to outdoor recreational opportunities in relation to the project. Since the proposed project is to be located along the river front of the metropolitan center of St. Louis, consideration should be given to all p o ssib ilitie s with water oriented a ctiv itie s.
2. Operation of the proposed plant may affect the historic and visual integrity of the Fort de Chartres National Historic Landmark located in Randolph County, Illin o is . The statement should also detail steps taken to assure compliance with Section 106 o f the National H istoric Preservation Act of 15 October 1966.
3. The statement should recognize that a b ill, H. R. 13831 (Alexander), has been introduced in Congress "to provide for a study o f a proposed 8-21
Huckleberry Finn National Recreational Area on the Lower Mississippi River and for other purposes." The bill would require the National Park Service to undertake a study of the Lower Mississippi River to determine the desirability and fe a sib ility o f establishing sudi an area.
4. The final statement should show evidence of consultation with the State Liaison Officers for Historic Preservation in Missouri and Illin o is .
5. More information should be developed concerning the potential geologic hazards described on page 2-16. The seismic potential is not adequately described, and anticipated remedial development measures pertinent to such hazards should be explained.
6. Section 2.3 on page 2-29 should be expanded to include the densities of listed wildlife species, and habitats on which they depend.
7. Section 2.3 should be modified to more accurately reflect the loss of wildlife habitat. Since the croplands, because of their seasonal cover and feeding benefits, should also be classified as w ild life habitat, it does not appear that more w ild life cover w ill be available after the plant is operational than was available previously. Important game species such as the bobwhite could be adversely affected by this loss of cropland habitat.
8. A more detailed description o f the proposed management plan for the 150 acres, which will be allowed to return to a natural or wild state, should be given. The expected wildlife uses of these lands and the amount o f hunting expected should be described. Im proper positioning of new cover with surrounding lands and project structures could greatly diminish the value of the land for w ild life. Assistance in developing plans for wildlife management should be obtained from appropriate Federal and State conservation agencies.
9. The evidence referenced on page 3-9 o f the draft statement should be identified and the data presented should be expanded to an evaluation of the expected changes in population dynamics of shad or other fish species. The other fish, eggs, andlarvae being entrained should be identified and the impact described. The impacts on the life stages o f fish and other aquatic life such as planktonic flora and fauna, that are carried into the thermal plume, should also be evaluated. We think that the positioning o f the downstream thermal plume should be established in order that this entrainment o f plankton and fish can be evaluated. 8-22
10. We are pleased that the applicant is w illing to modify project Intake fa c ilitie s and to provide supplemental water cooling devices, if required to protect fish resources. In this regard we suggest that the applicant consult with Federal and State agencies in assessing project e ffects on fish and implementing any needed pro tective modifications of structures and operation. These agencies should be listed in this section of the final environmental state ment .
11. Section 3 should describe the plant's effect on river icing and the associated impacts on fish and w ild life resources. For example, are waterfowl likely to over-winter in the area i f there is a lack of ice cover?
12. The cumulative environmental impacts of this plant, other power plants and other industry on the river on the water and land should be described. This discussion should include effects on aquatic life resulting from thermal and chemical discharges and entrainment and entrapment at the intakes. It should also include the effects of development and transport of the coal from the mine to the plant. The cumulative impacts o f a ll fa c ilit ie s could be greater than the separate impacts of each fa c ility evaluated alone.
13. We believe that the design velocity of approximately one f.p.s. at the intake screens is too high to maintain acceptable levels of entrainment and entrapment damages to fish and other aquatic l i f e . An approach velocity of approximately 0.5 f.p .s . is recommended by this Department. We further suggest that the final statement recognize that some fi9h which come in contact with the screen or trash racks will escape but will ultimately die of injury-related infection, disease, or predation.
14. The fir s t paragraph on page 3-19 o f the draft statement should include a discussion of spawning occurrence upstream from the plant and the resulting larval fish downstream migration. Most larval fish are dependent on the currents after hatching and i f they are transported to midstream and into the plume, mortality from thermal shock may be high.
15. The draft environmental statement does not adequately describe the transmission lines associated with the proposed power plant nor assess their environmental impacts. In regard to minimizing the impacts of the transmission lin es, we suggest the applicant follow the guidelines of the 1970 joint Agriculture - Interior publication "Environmental Criteria for E lectric Transmission Systems" pertaining to transmission system design, construction and maintenance.
16. The statement appears to give appropriate consideration to existing hydrologic conditions and to the probable impact of the proposed action on those conditions. However, some clarification seems desirable for the last sentence on page 3-25 of the draft statement. It Is not clear i f the statement refers to a flood of 1,080,000 c.f.s. or to one of lesser flow. The statement should be revised to "... three inches on the occurrence of a 200-year flood" i f this is the case. A
8-23
17. The criteria used in rejecting the alternatives do not ade quately include the consideration o f environmental impacts. Con siderations o f these impacts are needed to compare the impacts o f the proposed project to the alternatives.
18. Section 6 should be expanded to quantify the annual production o f natural renewable resources, such as fish and w ild life , which w ill be lost or gained during the short term and long term.
19. Section 7 should be expanded to include any annual production losses of fish and wildlife resources. Annual production of a renew able natural resource is generally irretrievable.
Responses: 1. Proposed construction site is approximately 40 miles downstream from the metropolitan center of St. Louis, Missouri. No recreational fa c ilitie s are planned for the area, but Union E lectric indicates that public access will be allowed to the river, and that plans for a small park could be discussed.
2. The National Register of Historic Places was consulted and no National Register properties will be affected by the proposal.This statement was provided on page 2-13 o f the draft environmental statement, and assured compliance with Section 106 o f the National Historic Preservation Act of 15 October 1966. The operation of the plant is not expected to have any effect cm the Fort de Chartres National Historic Landmark.
3. When informed of the proposed power plant, the National Park Service commented that no established or studied units of the National Park System would be affected and no eligible sites for registration as National H istoric, Natural or Environmental Educa tional Landmarks are involved. These remarks were contained in a letter from that agency dated 10 February 1972.
4. The Missouri State Liaison Officer for Historic Preservation was invited to comment on the proposal and indicated no objection (page 8-3). The State Liaison Officer for Historic Preservation in Illinois was informed of the project by public notices and invited to comment on the draft environmental statement. No comment on the draft statement was received (page 8-6).
5. The seismic potential has been defined in Section 2. Further information concerning the incorporation of recognized geologic hazard to plant design is found on page 2-16 o f final environmental statement. 8-24
6. More information concerning wildlife densities has been in corporated into Section 2.3 in response to this comment. It should be noted that the paragraph referred to in the comment does not pertain to the proposed construction site alone. The "area" refers to the Rush Island vicin ity in general, including the surrounding farm lands, bluffs, river bottoms, and wooded areas.
7. The referenced section has been modified in response to this comment.
8. There is no proposed management plans for the referenced acreage. Union Electric has offered to discuss 'planting plans with conservation agencies, but has received no response. The company has no plans to allow hunting on the acreage due to the proximity of the power plant. This is stated in Section 4.
9. The evidence referred to on page 3-9 o f the draft statement is presented in Sections 2.3 and 3.6, and the appropriate figures referenced in these sections. The thermal plume is thoroughly defined in Section 3,6 and appropriate figures.
10. Union E lectric has agreed to meet with the Missouri Department o f Conservation to arrive at a mutually acceptable method o f monitoring the intakes, and will continue to seek an effective method to protect fish from damage due to the intake screens. Although the cooling water discharge is not expected to adversely affect fish resources, supplementary cooling schemes w ill be utilized i f the thermal dis charge has an adverse impact on aquatic biota.
11. The proposed power plant is not expected to measurably affect river icing. The Mississippi River at the proposed plant site, al though subject to large amounts of floating ice, is open the year round for navigation. The thermal discharge will be at mid-channel, and the prescribed mixing zone should not allow excessively heated water to reach the shore.
12. This statement attempts to evaluate the environmental impact of the proposed power plant. A discussion of industrial and urban development in the Mississippi River Valley, in general, is not pertinent to the pending permit. While the environmental effect o f these developments may be sign ifica n t, i t is not the result of the proposal for which approval is sought. The cumulative effects of the proposed power plant alone are discussed in this statement.
13. Design velocity for the intake water has been revised to 0.5 foot per second. The applicant indicates that the actual velocity of water through the intake structure will vary according to river elevation; as river elevation lowers, intake velocity increases. The final statement reflects the changes made as a result o f this comment. 8-25
14. The pre-construction environmental survey did not include sampling immediately upstream of the proposed plant site . A dis cussion of actual spawning occurrence upstream of the plant is not possible. This area of interest could be included in the post-con struction environmental assessment. A determination of the e ffect of thermal discharge on larval fish would definitely be a factor in evaluating the adequacy of once-through cooling and the possible need for supplementary cooling. More information on this subject has been added to pages 3-19 and 3-20 o f the final statement.
15. Section 3-13 has been included in the final environmental statement to outline the applicant’ s proposed method of minimizing adverse environmental impacts due to installation of the trans mission lines. A detailed description is not provided. Trans mission lines, while part of a power generating facility, are not part o f the pending permit. A exact description o f the lands in volved is not possible because the applicant has not yet deter mined the exact Tights-of-way that w ill be used. A general de scription o f the rights-of-way may be found on pages 1-13 and 1-14 of the final environmental statement.
16. The referenced statement concerning flood protection has been slightly altered to clarify the information presented.
17. In compiling alternatives to the proposed Rush Island power plant, environmental criteria as well as fe a sib ility , availa bility, and economics were considered. Environmental characteristics o f an alternative are not included in Section 5 where the alternative is impractical for some other reason. Where an alternative could be implemented into plant design but was not, environmental characteristics are noted. Section 5 of the final statement is prefaced with an introduction which states that environmental criteria were considered in each alternative, but that this area o f consideration may not be presented where some other area of consideration made the alternative completely unacceptable.
18. There is no basis to expect any effect to the annual production of natural renewable resources such as fish and aquatic organisms. Relocation of wildlife will probably cause the annual production of small terrestrial game to decrease at Rush Island, but i t is ex pected that the relocated w ild life w ill be absorbed into the adjacent areas. Unless the adjacent areas are supporting their maximum number of wildlife, there will be no net loss of annual production of any natural renewable resource. I f the adjacent areas are already at their carrying capacity, the annual production of wildlife affected by the proposal (see Section 2.3) will be lost. The applicant in tends to perform environmental monitoring, including the sampling of aquatic and terrestrial organisms, during the construction and operation of the plant in order to defin itely evaluate the impact o f the proposal and to take timely remedial measures i f required. 8-26
19. The annual production of natural resources is discussed in the previous response. Since the Rush Island area has not been identified as a unique breeding site for any particular fish or wildlife species, annual production losses should not be construed as irretrievable, even if there is an effect to production. If the plant site reverts to its previous use after the plant is shut down, full repopulation of the area by indigineous species would be expected.
I l l inois Environmental Protection Agency, Division of Air Pollution Control, Springfield, Illinois ~
Comments: 1. Low sulfur fuel reserves will probably be depleted in the future, resulting in the need to use coal of higher sulfur content. Prior to reaching a sulfur dioxide emission exceeding the Missouri Allow able Emission Rat2 of 2.3 pounds per million btu heat input, sulfur dioxide control equipment should be installed. Such action will incure compliance with the State of Illinois emission limitations.
2. It should be realized that some curtailment of plant operation may be imposed during episodes of atmospheric stagnation in the St. Louis region. Such action will only be taken in conjunction with direction of the Technical Coordinating Committee of the St. Louis Interstate Air Quality Control Region.
Responses: 1. Applicant has made provision for installation of sulfur dioxide removal equipment when such equipment is necessary and available. Plant is designed so that such equipment can be added. Applicant is also actively involved in experimental research to develop sulfur dioxide removal equipment. This information is found in Section 1.3.
2. Union Electric has developed special operating procedures for use at existing facilities during air quality alerts. These measures include the use of special fuels and the curtailment of power gener ation. It is expected that similar procedures will be developed for the Rush Island Plant. FIGURES
UNION ELECTRIC COMPANY PEAK DEMANDS. NET OUTPUT. LOAD FACTOR. LOSSES AND SALES YEARS 1967-1976
Net Integrated Hour Net Output 7/o Losses, Etc. Sales Peak Demand Kwh Load Kwh % of Kwh Actual MW % Incr. (Millions) % Incr. Factor (Mi 11i ons) Output (Millions) 'Yc Incr.
1967 3 218 *4.2 15 108 3.6 53.6 965 6.*+ 1*+ l*+3 *4.1
1968 3 5**3 10.1 ‘ 16 *+25 8.7 52 .6 1 081 6.6 15 3*4*+ 8.5
1969 3 791 7.0 17 781 8.3 53.5 1 1*46 6.*+ 16 635 8.*+
1970 *4 120 8.7 18 573 *4.5 51.*4 1 170 6.3 17 *403 *+.6
1971 *+ 728 2.6 19 *+8*+ *4.9 52.6 1 16*+ . 6.0 18 320 5.3
Forecast
1972 *+ 810 13.8 20 710 6.3 **9.0 1 2*+3 6.0 19 **67 6.3
1973 5 170 7.5 22 201 7.2 *49.0 1 332 '6.0 20 869 7.2
197** 5 5**0 7.2 23 823 7.3 **9.1 1 *+29 6.0 22 39*+ 7.3
1975 5 910 6.7 25 603 7.5 *49.5 1 536 6.0 2*+ 067 7.5
1976 . 6 280 6.3 27 350 6.8 *49.6 1 6*+l 6.0 25 709 6.8 UNtOH ELECTRIC COMPANY KWH SALES YEARS 1967-1976 (In Millions)
Small Larqe Ccitmm ercial S Industrli al Commercial Firm Run o f S treet P u b lic Sales for Resale T o t .! Actual Residential & Industrial Commerc ial Industrieit Total R iver Interruptible L iqhtinq Authorities M.P.6 I t . Other S ales
1967 3 266 1 313 1 697 5 022 6 719 620 307 95 133 938 952 16 163 1968 3 782 1 626 1 886 5 266 7 152 311 316 100 156 1 106 999 15 366 1969 6 225 1 696 2 100 5 633 7 533 387 336 106 175 1 298 1 121 16 635 1970 6 531* 1 570 2 309 5 656 7 763 631 290 no 182 1 329 1 196 17 603 1971 It 925 1 656 2 532 5 611 8 163 662 162 120 199 1 389 1 286 IB 320
Forecast
1972 5 329 1 726 2 800 5 866 8 666 653 30 126 223 1 535 1 383 19 667 1973 5 823 1 810 3 087 6 086 9 171 652 30 136 259 1 696 1 696 20 869 197^ 6 366 1 901 3 611 6 358 9 769 652 30 161 278 t 8a ; 1 616 22 396 1975 6 956 1 996 3 786 6 676 10 662 652 30 168 291 1 989 1 763 26 067 1976 7 617 2 100 6 208 7 058 II 266 653 30 156 306 2 161 1 622 25 709
% INCREASE OVER PRECEDING YEAR
Actual
1967 5 .9 5 .2 10.6 5.3 6 .6 -25.1 6.1 5.1 9 .2 11.5 -8 .6 6.1 1968 15.8 8 .6 I I . 1 6 .9 6 .6 -2 5 .6 2 .9 5 .5 1 5 -6 17-9 6 .9 8 .5 1969 H .7 5.0 11.6 3.2 5.3 2 6.6 6 .2 3 .7 13.5 13.8 12.2 8 .6 1970 7.3 6 .5 10.0 O.i* 3.1 11.6 -1 3 .7 5 .8 *♦.0 5 .6 6 .5 6 .6 1971 8 .6 5.6 9 .7 2 .9 6 .9 2 .6 -66.1 9.1 9 .3 6 .5 7 .7 5 .3
F orecast
1972 8 .2 i*.2 10.6 6 .5 6 .6 2 .5 -8 1 .5 5 .0 12.1 10.5 7 .5 6 .3 1973 9 .3 5 .0 10.3 3.8 6 .3 . - 6.1 16.1 10.5 8 .0 7 .2 1971* 9 .3 5 .0 10.5 6 .5 6 .7 - . 5 .0 7 .3 8 .8 8 .0 7 .3 1975 9 .3 5 .0 11.0 5.0 7.1 ~ - 5 .0 6 .7 7 .8 8 .0 7 .5 1976 9 .5 s .2 11.1 5.7 7 .7 0.2 - 5 .0 6 .5 8 .6 - 6 .9 6 .8 UNION ELECTRIC COMPANY KWH SALES YEARS 1971 £• 1972 (In Millions)
Small Larqe Com tercial & Industrl.ftl Commercial FI rm Run of Street Public Sales for Resale Tota 1 1971 ResIdent ial & Industrial Commercial Industrial Total River Interruptible Liqhtlnq Authorities M.P.Ut. Other Sales
Actua1 Jan. 36b. 6 127.0 188.6 655.6 666.0 66.2 29.9 13.6 15.1 111.9 109.0 1 659.3 Feb. 321.9 115.7 170.2 610.7 580.9 38.9 27.0 9.1 13.6 106.9 103.6 1 315.6 Mar. 365.1 127.1 181.8 658.6 660.2 35.8 30.0 10.6 15.0 112.6 92.2 1 608.2 Apr. 289.7 118.3 178.9 655.1 636.0 35.8 30.0 8.2 16.8 101.7 76.6 1 309.1 May 279.3 121.0 193.0 675.6 668.6 36.6 25.1 7.9 16.6 101.5 86.9 1 361.1 June 660.9 186.7 260.6 562.8 783.2 36.9 3.5 8.9 19.2 136.3 123.6 1 935.0 July 596.9 157.6 256.1 666.9 723.0 31.2 3.0 7.0 17.7 125.0 136.6 1 795.8 Aug. 569.5 168.8 256.3 505.7 760.0 32.3 3.0 9.6 20.9 126.6 112.3 1 802.8 Sept. 692.6 153.6 250.6 676.8 725.6 36.6 2.4 10.3 19.0 116.6 116.8 1 671.1 Oct. 338.6 125.8 218.1 651.0 669.1 35.7 2.9 10.9 16.1 113.6 112.6 1 622.9 Nov. 306.0 125.6 201.6 655.7 657.1 61.1 2 .5 10.9 16.9 120.5 106.0 1 386.6 Dec. 380.0 128.6 199.3 658.3 657.6 60.9 2.7 16.0 16.7 118.1 . 116.5 1 673.1
Total 6 925.1 1 653.6 2 532.5 5 610.6 8 163.1 661.6 162.0 120.6 199.6 1 388.9 1 286.1 18 320.6
1972
Forecast Jan. 378.6 139.0 203.0 666.8 669.8 38.3 2.5 12.7 17.6 120.0 117.6 1 695.5 Feb. 360.5 126.8 187.6 630.6 618.0 35.9 2.5 10.6 16.0 112.0 108.7 1 388.8 Mar. 367.9 131.6 203.6 686.6 688.0 38.3 2.5 10.8 17.0 125.0 109.8 1 690.7 Apr. 315.0 122.7 202.2 669.7 671.9 37.2 2.5 9.3 17.0 109.0 91.6 1 376.0 May 368.9 138.6 222.9 501.6 726.3 38.3 2.5 8.6 17.6 116.0 97.9 1 512.5 June 551.0 161.6 255.6 517.8 773.2 37.2 2.5 8.6 19.0 131.0 115.6 1 799.1 July 771.2 183.1 297.9 529.5 827.6 38.3 2.5 8.6 20.8 168.0 139.3 2 139.2 Aug. 697.6 176.5 291.8 519.0 810.8 38.3 2.5 9.8 21.6 156.0 131.7 2 062.6 Sept. 666.5 160.5 266.3 685.5 769.8 37.2 2.5 9.8 19.7 123.0 112.6 1 639.6 Oct. 356.1 132.9 236.6 687.9 726.5 38.3 2.5 11.5 18.5 130.0 116.9 1 529.2 Nov. 308.6 129.0 213.1 680.8 693.9 37.2 2.5 12.6 19.0 126.0 116.2 1 662.8 Dec, 611.0 166.1 221.8 690.8 712.6 _ 2 L i 16.0 19.6 161.0 127.7 1 610.8
Total 5 328.5 1 726.0 2 800.2 5 866.0 8 666.2 652.8 30.0 126.3 222.8 1 535.0 1 383.0 19 666.6 UNION ELECTRIC COMPANY NUMBER OF CUSTOMERS YEARS 1967-1976
1967 1968 1969 1222 1971 1972 1221 1974 1975 1976 Residential Gross Additions Single Family Total Electric Heat 281 638 684 591 1 158 1 359 1 408 1 535 1 665 1 795 Other 8 166 9 .609 8 241 _i_£22 7 865 7 057 7 585 7 515 7 910 7 845 Total H T W j 10 247 8 925 6 185 9 023 8 416 8 993 9 050 9 575 9 640 Multi-FamiIv Total Electric Heat 822 1 154 1 162 1 649 3 511 2 444 2 415 2 429 2 608 2 622 Other } 508 _3 ?&7 4 064 3 472 586 4 535 4 479 4 508 4 810 4 839 Total 4 330 4 521 5 226 5 121 8 097 6 979 6 894 6 937 7 418 7 461 Mob i 1e Home Total Electric Heat 4 17 33 77 97 192 238 294 328 352 Other 1 041 1 606 1 773 1 822 2 589 2 081 2 310 2 498 2 530 2 570 Total 1 045 1 623 1 806 1 899 2 686 2 273 2 548 2 792 2 858 2 922
Total Gross Additions 13 822 16 391 15 957 13 205 19 806 17 668 18 435 18 779 19 851 20 023 Less: Demolitions and Net Change in Vacancies 3 205 6 380 8 179 7 817 10 889 8 517 8 152 8 270 8 665 8 543
Tota1 Net Add i t ions 10 617, 10 Oil 7 778 5 388 8 917 9 151 10 283 10 509 11 186 11 480 Residential Customers - Year End 612 988 622 999 630 777 636 165 645 082 654 233 664 516 675 025 686 211 697 691 % Increase 1.8 1.6 1.2 0.9 1.4 1.4 1.6 1.6 1.7 1.7 Non-Res ident ia1
Total Net Addi tions 1 624 1 683 1 235 358(1) 2 060 1 585 1 760 1 890 1 920 1 930 Non-Residentia1 Customers - Year End 64 272 65 955 67 190 67 548 69 608 7' 193 72 953 74 843 76 763 78 693
Total Customers - Year End 677 260 688 954 697 967 703 713 714 690 725 426 737 ^69 749 868 762 974 776 384 % Increase 1.8 1.7 1.3 0.8 1.5 1.5 1.7 1.7 1.8 1.8
(I) Reflects 1099 Dusk-to-Dawn accounts combined with metered service in Jan. 1970. UNION ELECTRIC COMPANY KWH OUTPUT YEARS 1967-1976 (In Mill ions)
Actual Forecast 1267 1 2 ^ 1969 1970 1971 1972 1973 197i* 1975 J1Z& Steam Plant Generation Ashley 59.0 69.1* 96.8 63.1 22.7 30.0 5.0 9.0 9.0 9.0 Mound 23.7 22.2 9.9 16.7 9.9 - - - - Cahokia 357.** 1*08.5 918.9 967.0 911.0 376.0 190.0 70.0 70.0 75.0 Venice 1 9.6 19.9 3.2 8.9 9.0 18.0 2.0 2.0 - 9.0 Venice 2 2 102.8 2 198.2 2 183.5 2 166.1 1 960.9 1 007.0 509.0 398.0 322.0 302.0 Meramec 5 809.6 5 1*85.5 5 971.1 9 875.5 9 660.3 3 676.0 3 392.0 3 099.0 3 160.0 3 098.0 Sioux 1 065.0 3 500.3 9 919.3 5 661.5 9 737.5 5 395.0 9 616.0 5 529.0 5 520.0 5 652.0 Labad i e - - - 1 389.0 3 805.1 9 128.0 12 120.0 13 967.0 19 562.0 19 703.0 Rush Island ------1 092.0 2 977.0 Total Steam Plant Generation 9 *+22.1 11 701*.0 13 096.7 19 692.3 15 610.9 15 630.0 20 729.0 22 569.0 29 730.O 26 820.0 Less Energy Input for Pumped Storage 207.5 117.0 156.2 279.1 190.1 253.0 292.0 217.0 160.0 186.0 Total Steam Generation for Load 9 21 *+. 6 11 587.0 12 890.5 l9 368.2 15 920.8 19 377.0 20 987.0 22 397.0 29 570.0 26 639.0 Hydro Generation Osage **70.6 513.3 779.6 517.6 313.0 990.0 938.0 937.0 938.0 990.0 Keokuk 780.5 920.0 839.6 919.0 887.3 807.0 805.0 805.0 805.0 807.0 Total Hydro Generation l 251.1 1 933.3 1 609.2 1 931.6 1 200.3 1 297.0 1 293.0 1 292.0 1 293.0 1 297.0
Combustion Turbine Generation - Venice 2.2 9.5 9.9 19.0 8.7 11.0 1.0 3.0 1 . 0 10.0 Pumped Storaqe Generation 101.3 59.9 73.7 130.7 86.5 111.0 105.0 97.0 70.0 80.0 Total Net Generation for Load 10 569.2 13 089.2 19 577.8 15 999.5 16 716.3 20 796.0 21 836.0 23 689.0 25 889.0 27 971.0 Purchased and Interchanged Energy Joppa Surplus 2 625.** 2 381.7 2 997.5 1 953.6 1 023.8 968.0 707.0 761.0 811.0 798.0 Deficiency Energy 2 865.7 1 252.5 23.9 719.1 1 220.6 227.0 - * - - Purchases/Sales/Other - (Net) -952.7 -293.0 732.0 -93.8 523.7 -1 231.0 -392.0 -627.0 -1 092.0 -1 919.0 Net Purchased and Interchanged for Load 1* 538.*« 3 391.2 3 203-1* 2 628.9 2 768.1 -36.0 365.0 139.0 -281.0 -621.0 Total Output 15 107.6 16 925.9 17 781.2 18 573.9 19 989.9 20 710.0 22 201.0 23 823.0 25 603.0 27 350.0
LEGAL DESCRIPTION OF THE RUSH ISLAND PLANT SITE
A tract of land containing approximately 500 acres located in p?.rt of Fractional Sections 3. 4, and 5, and part of Fractional Sections 4, 5, 8, and 9 cn Island 7A (Rus’i Island) and part of Fractional Section 9 on Island 7B (Lee's Island), all in Township 39 North, Range 7 East, Jefferson County, Missouri, and more particularly described as follows:
Beginning at a point on the east-west quarter section line of said Section 4 which point is located South 82° 20' East 3025 feet from the quarter section corner on the west side of said Section 4, as measured along said cast-west quarter section line, said beginning point also being the point of intersection of the cast-west quarter section line of sa.id Section 4 with the centerline of the 100-foot wide right of way of the St. Louis-San Francisco Railway Company; thence along the centerline of the said Railway right of way South 34° 48' East 472 feet to a point; thence . South 33° 15' East 572 feet to a point; thence South 32° 24' East 200 feet ■ (chord) to a point; thence South 30° 19' East 224. 60 feet (chord) to a point; thence continuing along the centerline of sa.id Railway right of way to the point of intersection with the northerly bank of Isle Du Bois Creek; thence northeasterly and southeasterly along the northerly bank of Isle Du Bois Creek and with the meandcrings thereof to the point of intersection of said northerly creek bank with the west bank of a certain slough from the Mississippi River; thence northerly along the said west bank of the slough and with the meandcrings thereof to the point of intersection of said west sloxigh bank with the westerly prolongation of an old fence; thence east along said prolongation of the old fence to a point in the center of said . slough which bears South 77° 18' East 5,304.40 feet from the quarter section corner on the west side of said Section 4; thence South 89° 25' East 488 feet, more or less, to the water's edge of the Mississippi River; thence northwesterly (upstream) along the water's edge to the most northerly corner of Lot 2 in the Commissioner’ s Report in the Partition in the case of Theodore Ehrichs and wife vs. Ellen A. Weaver, et al. , in the Circuit Court of Jefferson County, Missouri, dated January 17, 1S79, from which an iron pin bears South 57° 52' West 40 feet, more or less; thence along the northwest line of said Lot 2 in the Commissioner's Report dated January 17, 1879, South 57° 52' West 3,285. 80 feet to a point on the center line of the right of way of the St. Louis-San Francisco Railway Company from which an iron pin bears North 57° 52' East 51.40 feet; thence along the centerline of said Railway right of way South 45 32' East 43. 00 feet to a point;-thence South. 46° 06' East 272. 90 feet (chord) to a point; thence South 46° 44' Ea.st 1, 090. 09 feet to the point of intersection of the centerline of said Railway right of way with the south line of Lot 4 of the Northeast 1 /4 of said Section. 5; thence continuing along the centerline of said Railway righto: ■way the following bearings and distances: South 46° 44' East 209.91 feet; South 45° 26' East 200 feet (chord); South 41° 31' East 200 feet (chord); South 37° 55' East 200 feet (chord) marking the point of intersection of the centerline of said Railway right of way with the north-south section line between said Sections 4 and 5; thence continuing along the centerline of said Railway right of way South 37° 14' East 4, 836. 76 feet to the point of beginning.
Together with all accretions thereto.
» • Subject to the right of way of the St. Louis-San Francisco Railway Company. Subject also to roadway easements of record.
AMR l AI I'ilOTO-RvISii ISIA'JD LOOK!HC SOUTH Fo! . 1", ;Q7? AERIAL PHOTO-RUSH ISLAND LOOKING EAST Feb. 16, 1972 FIGURE 1-23 AERIAL PHOTO-RUSH ISLAND LOOKING NORTH Feb. 16, 1972
RUSH ISLAND TOPOGRAPHIC SURVEY MAP C i i y - C <"i!: > > / x i;i: i r ■ iT.ur.rwY _ st a t io n s
1. 12th t. Clark ?. Rroedv;ay & llurck 3. Shrove & Route 70 /}. Hn Terry & Lindberoh ' SS Hunter Avenue 0. r-ox 30G - V.'eidiinn Rd. 7. 102G7 St. Charles Rock Ro, T;’. SU or Routes C7 l 270
I'ar.'imot ers Measured at Kacli Station
Wind Epecd A direct Jon Tcuporalure Sulfur dioxide Nitropen oxide Nitropen dioxide Hydroca rbor.s Carbon Monoxide Coh
O MONITOR SlAlir-MS - c!. e.
i,:. union incisue kam is
1‘aram ters Kear.ercd at ‘U.K. Stations
All - r.ulfvi dioxide CO, C'T* 11 • v ’ n 1 vt lot- tty ri ’ i ' ' ■ r ■ ' - 1 i - .< A ; : . d l-.v.-i t : . • -v f A1 1. tut St • . 21 - so •.pv.ded > -: l * t : 1 •' N 3 6 0 °
340 !£ 2 0 34^ 5 0 3 6 0 |0 ^ 0
2 ' 0 200 l9^ l70 '60 150 Mean Wind Sp^cd: 11 Mph WIND DIRECTION, ALL HOURS, ALL VELOCITIES WIND DIRECTION, ALL HOURS, ALL VELOCITIES GROUND LEV EL STACK HEIGHT LEVEL SEPT., 1968 TO MAY, 1970 MAY. >969 TO MAY, 1970
Wind Blowing From Direction Shown
POPULATION TRENDS
RUSH ISLAND PLANT SITE VICINITY
20-Year Missouri 1950 1960 1970 Numerical Change
Jefferson County
Plattin Township 1,844 3,260 4,487 +2,643
St. Genevieve County
Jackson Township 1,233 1,381 1,705 +472
Illinois
Monroe County
Mitchie Precinct 570 564 504 -66
Renault Precinct 1,197 1,065 1,074 -123
Randolph County
Prairie du Rocher Precinct 1,252 1,219 1,113 -139 MISSISSIPPI RIVER WATER QUALITY UPSTREAM AND DOWNSTREAM FROM THE CITY OF ST. LOUIS. MISSOURI (sampled spring 1971)
(1 ) Approximate River Mile 210 161 pH 7.4 Alkalinity, PPM (as CaCO3 ) 117 125 B. O.D. (5 day), PPM 0.5 0 C . 0•D . 22 Total Solids, PPM 335 1122 Dissolved Solids, PPM 239 343 Suspended Solids, PPM 96 779 Volatile Solids, PPM 174 192 Ammonia, PPM (as N) 6.42 1.40 Keldahl Nitrogen, PPM 0.51 Nitrate (as N) 0.95 1.58 Total Phosphorus (as P) 0.33 1.4 Total Hardness, PPM (CaC03) 202 226 Sulfate, PPM (as S) 37.1 118.1 Chloride, PPM (as Cl) 15 20 Total Calcium, PPM (as Ca) 46 47 Total Magnesium, PPM (as Mg) 19 20 Total Potassium, PPM (as K) 2.2 4.3 Total Sodium, PPM (as Na) 14 60 Turbidity, Jackson units 540
Samples at approximate river mile 210 were taken at the Union Electric Company's Sioux Plant which is upstream from the con fluence of the Mississippi and Missouri Rivers. Samples taken at approximate river mile 165 were taken at Union Electric Company's Meramec Plant which is downstream from St. Louis near the confluence of the Meramec and Mississippi Rivers. IDENTIFICATION OF BENTHIC ORGANISMS
RUSH ISLAND - SEPTEMBER 1971 - ALL STATIONS
ORGANISMS NUMBER RELATIVE 7o
Annelida - phylum Oligochaeta - class 422 92.74
Arthropoda - phylum Diptera - order Tipulidae - family 4 0.88 Simuliidae - family 1 0.22 Tabanidae - family 1 0.22 Coleoptera - order Staphylinidae - family 1 0.22
Crustacea - phylum Isopoda - order 1 0.22
Mollusca - phylum Gastropoda - class 21 4.62 Pelecypoda - class 4 0.88
TOTAL 455 100.00
Family Diversity Index - 0.51
RUSH ISLAND - NOVEMBER 1971 - ALL STATIONS
ORGANISMS NUMBER RELATIVE 7 Annelida - phylum Oligochaeta - class 100 90.09 Arthropoda - phylum Ephemeroptera - order Ephemeridae - family 2 1.80 Diptera - order Tendepadidae - family 1 0.90 Mollusca - phylum Gastropoda - class 7 6.31 Pelecypoda - class __1 0.90 TOTAL 111 100.00 Family Diversity Index - 0.61 IDENTIFICATION OF BENTHIC ORGANISMS
RUSH ISLAND - APRIL 1972 - ALL STATIONS
ORGANISMS NUMBER RELATIVE % Annelida - phylum Oligochaeta - class 445 93.70 Hirudinea - class 1 0.21 Arthropoda - phylum Ephemeroptera - order Ephemeridae - family 3 0.63
Diptera - order Tipulidae - family 1 0.21 Psychcdidae - family 1 0.21 Culicidae - family 1 0.21 Ceratopogonidae - family 2 0.42 Tendipedidae - family 8 1.68 Syrphidae - family 3 0.63 Enthomyiidae - family 1 0.21 Trichoptera - order Hydropsychidae - family 3 0.63 Coleoptera - order Elmidae - family 1 0.21 Lepidoptera - order Pyralididae - family 1 0.21 Moll usca - phylum Gastropoda ■ class 2 0.42 Pelecypoda - class 1 0.21
TOTAL 475 100.00
Family Diversity Index - 0.51 HOLOPLANKTON DATA FOR RUSH ISLAND * NOVEMBER 1971 TOW SAMPLES
Station No. 3-2-T 3-4-T 4-2-T 4-4-T 5-2-T 5-4-T 6-2-T 6-4-T
ORGANISMS Z 0 0 P LANKTON Protozoa Euqlena Phacus Vorticella X X
Copepoda Cyclops X X nauolius(staqe) X X X X X
P H Y T OPLANKTO N Chrysophyta Achnanthes X Amphi pleura Amphora Asterionella X Cyclotella X X X X X X X Cylindrotheca X X Cymbella X X X Eunotia Fraqilaria X X X X X Station No. 3-2-T 3-4-T 4-2-T 4-4-T 5-2-T 5-4-T 6-2-T 6-4-T
ORGANISMS
Frustulia X X Gyrosiqma X X X X X Melosira X X X X X X X Naviculum X X Neidium X Opehora Peronia X Pinnularia Rhopalodia Scoliopleura Stavroneis Stephanodiscus X X X X X X X X Surirella x Synedra X X Tabellaria X X
Chlorophyta Actinastrum X Ankistrodesmus X Botr.yococcus X X X Coelastrum Desmidium X X X X X Gonatoz.yqon X Haematoccus X X Microspora X X X X X Netrium Pediastrum bcryanum X Station No. 3-2-T_ 3-4-T____ 4-2-T__ 4-4-T_ __5-2-T__ 5-4-T _6-2-T 6-4-T
ORGANISMS
Pediastrum duplex X X Pediastrum simplex X Scenedesmus Sphaerocystis X X X Spirogyra X Uiothrix ~ x X X X X X X X Zygnema X
Cyanophyta Coelospherium Gomphosphaeria x X X X Microcystis
Samples collected by means of a 3 minute oblique metered tow using a 200p mesh net and a number 20 cod end.
Quantitative analyses has not been completed HOLOPLANKTON DATA FOR RUSH ISLAND * NOVEMBER 1971 WATER SAMPLES
Station No. 3-3-1 3-3-2 4-3-1 4-3-2 5-3-1 5-3-2 6-3-1 6-3-2
ORGANISMS ZOO PLANKTON Protozoa Etiql ena X Phacus X X X Vorticella
Copepoda Cyclops nauDlius(stage)
PHYTOPLANKTON Chrysophyta Achnanthes Amphipleura X X X X X X Amphora X Asterionella Cyclotella X X X X X X X X Cylindrotheca X Cvmbella Eunotia X Fraqilaria X X
(Continued) VI o O
FIGURE 2 -9 -D (Continued)
Station No. 3 -3 -1 3 - 3 - 2 4 -3 - 1 4 - 3 - 2 5 -3 -1 5 - 3 - 2 6 -3 -1 6 - 3 - 2
ORGANISMS
Frustulia X X X Gyrosiqma X X Melosira X X X X X X X X Naviculum X X X Neidium Opephora X Peronia Pinnularia X Rhopalodia X Scoliopleura X X X Stavroneis X Stephanodiscus X X X X X X X Surirella X X Synedra X Tabellaria X
Chlorophyta Actinastrum X Ankistrodesmus X X X Botryccoccus X X Coelastrum X Desmidium X X X X X X Gonatozyqon Haematoccus X Microspora X X X X X X Netrium X Pediastrum Y boryanum A A
(Continued)
T7 Station No. 3-3-1______3-3-2__ _4-3-1__ 4-3-2_ _5-3-1 5-3-2__ 6-3-1 6-3-2
ORGANISMS
Pediastrum duplex X X X Pediastrum simplex Scenedesmus X X Sphaerocystis X X Spiroq.yra X Ulothrix X X X X X X X Zyqnema X X X ■X X
Cyanophyta CoelosDherium X
GomDhosDhaeria x Microcystis X X X X X
Samples collected by means of a 3 liter Van Doren Bottle
Quantitative analyses has not been completed HOLOPLANKTON DATA FOR RUSH ISLAND * APRIL 1972 TOW SAMPLES
Station No. 3-l-T 3-2-T 3-3-T 3-4-T 10-l-T 10-2-T 10-3-T 10-4-T
ORGANISMS ZOOPLANKTON
Protozoa Euqlena X
Rotatoria Keratella X X X X X
Copepoda Cyclops X X X Diaptomus X Limnocalanus X nauplius(stage) X
PHYTOPLANKTON Chrysophyta Asterionella Cvclotella X X X X CvmatoDleura Diatorca X X X X X X X Desmidium X Diploneis Station No._ _ 3-1-T__ 3-2-T__ __3-3-T__ _3-4-T 10-1-T_ 10-2-T 10-3-T 10-4-T
ORGANISMS
Fraqillaria X X Melosira X Navicula Nitzschia X Pinnularia X Stephanodiscus X Surirella S.ynedra X
Chlorophyta Coelastrum X Cladophora Microspcra X X X X X X X Mouqectia X X X X Oedraonium X Spiroqyra X X X X X X X X Ulothrix X X X Vo1 vox X Z.yqnema X
Cyanophyta Coelosphaerium X X X Oscillatoria X X X X
Samples collected by means of a 3 minute oblique metered tow Quantitative analyses has not been using a 200u mesh net and a number 20 cod end. completed HOLOPLANKTON DATA FOR RUSH ISLAND * APRIL 1972 WATER SAMPLES
Station No. 10-3-1 3-3-1 3-2-1 3-5-1
ORGANISMS ZOOPLANKTON Protozoa Euqlena
Rotatoria Keratella
Copepoda Cyclops Diaptomus Limnocalanus nauplius(stage)
PHYTOPLANKTON Chrysophyta Asterionella X C.yclotella X X X C.ymatopleura X X X Diatoma X X Desmidium Diploneis X Fragillaria X X X X Melosira X X X Navicula X X X Nitzschia Pinnularia Stephanodiscus X X Surirella X X S.ynedra X X
Chlorophyta Coelastrum Cladophora X X X Microspora Mouqeotia
(Continued) FIGURE 2-9-F (Continued) Station No. 10-3-1 3-3-1 3-2-1 3-5-1
ORGANISMS
Oedoqonium Spiroq.yra X X X X Ulothrix Volvox X Z.yqnema
Cyanophyta Coelosphaerium Oscillatoria X X
Samples collected by means of a 3 liter Van Doren Bottle
Quantitative analyses has not been completed FIGURE 2-9-G
CHEMICAL AND ASSOCIATED PHYSICAL DATA FOR
WATER SAMPLES COLLECTED SEFTEMBER 1971 - RUSH ISLAND SITE
TRANSECT SPECIFIC TOTAL SAMPLING CONDUCTIVITY TEMP. DISSOLVED ALKALINITY TOTAL LOCATION V mho °F pH OXYGEN * (Ca CO,) N0,-N po4-p Na X Ca Mg Cl S04 Fe A1 Cu Mn Cd Zn
1-2-S** . 505 ’ 80.6 8.15 9.8 176 1.20 0.02 40.6 4.04 54.90 23.60 17.4 92.00 0.31 <0.50 <0.01 0.01 <0.02 0.01
1-2-SS 495 80.6 8.03 9.2 162 0.66 0.011 35.4 3.99 55.60 24.00 14.00 98.00 0.18 <0.50 <0.01 0.02 <0.02 0.004
1-3-S 500 80.6 8.20 10.0 160 0.32 0.02- 37.00 4.04 54.60 23.80 16.6 101.00 0.32 <0.50 <0.01 0.01 <0.02 0.01
1-3-SS — 80.6 8.10 9.9 — — — 37.30 5.07 54.60 23.20 — — 0.51 <0.5 <0.01 0.02 <0.02 0.005
3-1 -S 562 80.6 7.80 8.3 161 1.55 0.01 51.00 4.23 59.70 23.80 20.4 91.00 0.20 1.1 <0.01 o.02 <0.02 <0.001
3-1-SS 562 81.5 7.90 8.1 160 2.37 0.C2 38.80 4.20 57.20 24.40 17.5 108.00 0.24 0.6 <0.01 0.02 <0.02 0.009
3-2-5 512 80.6 8.10 9.5 166 0.35 <0.001 41.40 4.28 58.10 23.60 16.70 103.00 0.26 <0.5 <0.001 0.01 <0.02 0.01
3-2-SS 524 80.6 — 9.5 161 0.17 0.02 40.00 3.96 55.90 23.50 17.00 127.00 0.25 1.4 <0.001 0.01 <0.02 0.01
* Except for the first four columns, all values expressed in mg/^.
** The first digit denotes the transect number, the second digit the station number; S is used to denote a surface sample, SS to denote a subsurface sample (10-15 feet in depth). FIGURE 2-9-H
CHEMICAL AND PHYSICAL AND ASSOCIATED DATA FOR
WATER SAMPLES COLLECTED N0VEM3ER 1971 - Rl’SH ISLAND SITE
TRANSECT SPECIFIC TOTAL SAMPLING CONDUCTIVITY TEMP. DISSOLVED ALKALINITY TOTAL LOCATION p mho °F pH OXYGEN * (Ca C03) N03-N P04-P Na K Ca Mg Cl so 4 Fe
3-3-S** 483 50.0 7.35 n . o 138 0.51 '0.005 40.90 3.91 59.90 23.00 9.80 120 0.21
3-3-SS 480 50.0 7.35 11.2 137 0.58 0.006 39:80 4.18 59.30 23.40 10.20 115 0.34
4-3-S 437 50.0 7.72 11.0 135 0.50 0.007 33.20 3.10 52.00 22.30 8.60 89 0.45
4-3-SS 433 50.9 8.11 10.8 135 0.51 0.003 31.40 3.12 52.70 22.20 8.60 85 0.72
5-3-S 485 50.0 7.35 — 137 0.48 0.025 .41.80 4.13 57.60 22.90 8.70 111 0.29
5-3-SS 485 50.0 7.35 . 10.8 137 0.47 0.025 40.60 4.15 57.20 23.10 10.20 123 0.34
6-3-S 437 50.0 8.12 11.1 131 2.77 0.258 32.20 2.90 50.70 22.20 8.40 95 0.38
6-3-SS 442 50.0 8.12 11.0 132 2.SI 0.167 33.40 3.12 51.40 22.30 8.70 89 0.35
* Except for the first four columns, all values expressed in mg/^ irk The first digit denotes the transect number, the second digit the station number, S is used to denote a surface sample, SS to denote a subsurface sample (10-15 feet in depth). o o
FIGURE 2-9-1
CHEMICAL AND ASSOCIATED PHYSICAL DATA FOR
WATER SAMPLES COLLECTED APRIL 1972 - RUSH ISLAND. SITE* **
TRANSECT SPECIFIC SAMPLING CONDUCTIVITY TEMP. TOTAL LOCATION p mho °F pH N03-N P04-P Na X Ca Mg Cl so 4 Fe A1 Cu Mn Cd Zn > O £ o# 3-2-S 420 ' 53.6 7.6 3.02 1.86 26.00 5.30 C V o 16.00 14.20 75.60 1.10 0.86 <0.02 0.02 <0.01 <0.02 3-2-SS 3S6 55.4 7.9 2.58 2.14 26,00 6.10 40.00 15.00 12.50 67.70 2.20 2.50 <0.02 0.05 <0.01 0.04
3-4-S 390 53.6 7.8 4.65 1.65' 18.00 5.10 46.00 17.00 18.50 57.40 1.20 0.87 <0.02 0.03 <0.01 <0.02 3-4-SS 415 53.6 7.6 4.52 1.41 20.00 5.00 50.00 17.00 18.80 59.10 0.91 0.75 <0.02 0.03 <0.01 0.04 10-2-S 413 53.6 7.8 2.87 2.02 25.00 5.70 44.00 16.00 14.70 70 .-00 1.60 2.20 <0.02 0.04 <0.01 0.02 10-2-SS 434 53.6 7.7 3.21 1.53 23.00 5.80 44.00 15.0Q 56.80 68.00 1.80 1.40 <0.02 0.05 <0.01 0.04 10-4-S 336 53.6 7.7 3.93 1.74 18.00 5.00 46.00 16.00 17.30 54.10 1.40 0.89 <0.02 0.03 . <0.01 <0.02 10-4-SS 408 53.6 7.6 4.20 2.08 20.00 5.10 46.00 16.00 18.10 53.90 1.60 1.40 <0.02 0.04 <0.01 0.03
Except for the first four columns, all values expressed in mg/^.
** The first digit denotes the transect number, the second digit the station number; _ S is used to denote a surface sample, SS to denote a subsurface sample (10-15 feet in depth). AMblENT AYR QUALITY PUSTEALL______
Tons/Sq. Hi.le/Month
Station Nun.be r 1970 1 2 3 4 J: u.iery 9.1 10.8 6.7 11.3 L o b r u a r y 17.3 24.2 7.9 13.9 ± . 1 - il 22.2 15.5 12.4 19 .C April 30.9 22.C 18.8 11.2 Hay 22.0 12.2 19.6 ,21.8 June 25.0 - 16.1 11.7 July 17.5 - 9.0 12.2 August 14.8 39.8 9.6 16.8 September 26.2 24.5 9.4 17.8 October 9.2 19.4 9.4 15.1 MoveMbor 24.0 21.3 9.9 7.2 Doccrbe.r 14.5 17.5 6.7 11.5
Avorage 19.4 20.8 11.3 14.2
Station Location
1 - Arnold, Missouri 2 - Crystal City, Missouri 3 - Fcvely, Missouri A - St. Louis University
Source of Data: Missouri Air Conservation Cor.: «i or. ion Report - 1970. AMBIENT AIR QUALITY SULFUR DIOXIDE CONCENTRATION
Concentration in PPM Station No. 12 Station No. 15 Station No. 22 1970 January .007 .013 February .010 .016 March .011 .016 April .015 .021 May .015 .021 June .018 .023 July .024 .024 .024 August .017 .022 .017 September .008 .017 .011 October .005 .012 .011 November .003 .007 .006 December - - - 1970 Average .012 .017 .014
1971
January - - -
February - - - March .008 .012 .013 April .003 .015 .016 May .007 .015 .015 June .013 .021 - July .005 .009 .022 August .003 .024 .025 September .002 .018 .025 October .003 .009 .015 November .004 .009 .014 December .002 .013 .022 1971 Average .005 .015 .019
Station No. 12 - Gray Summit, Missouri
Station No. 15 - Intersection of Highways 100 & 109 in west St. Louis County.
Station No. 22 - Intersection of Becker & Finestown Roads, south St. Louis County. AMBIENT AIR QUALITY SUSPENDED PARTICULATES
Concentration In Micrograms per Cubic Meter Station No. 12 Station No. 15 Station No. 22 1970 January 33.8 20.3 February 26.0 44.6 March 26.0 48.2 April 46.5 55.4 May 48.1 39.1 June 45.9 42.0 July 53.0 49.9 64.6 August 29.4 60.3 46.1 September 17.2 39.1 30.6 October 18.4 39.0 49.3 November 26.2 36.8 December - - • Annua1 Geometric Mean 37.0 38.0 42.0
1971
January - -
February 39.0 36.8 • March 43.1 18.8 55.8 April 76.9 56.8 - May 46.3 53.4 55.2 June 91.1 67.7 «• July 63.7 48.2 67.9 August 79.2 118.6 72.0 September 72.3 67.1 44.3 October 80.6 48.9 65.7 November 83.3 27.6 26.8 December 35.9 18.4 46.8 Annual Geometric Mean 51.0 51.0 44.0
Station No. 12 - Gray Summit, Missouri
Station No. 15 - Intersection of Highways 100 & 109 in west St. Louis County.
Station No. 22 - Intersection of Becker & Finestown Roads, south St. Louis County. MISSISSIPPI RIVER FLOW DATA-RUSH ISLAND
Month Minimum River Water Period 7-day Average Elevation Flow (1000 cfsl (Ft. MSL)
January 38.4 357.0 22-28, 1963
February 49.2 358.0 11-17, 1964
March 52.8 358.5 1- 7, 1964
April 121.3 366.0 23-29, 1963
May 124.6 366.3 11-17, 1968
June 111.7 365.0 8-14, 1964
July 79.1 362.4 25-31, 1964
August 60.7 359.5 14-20, 1964
September 68.0 361.3 24-30, 1963
October 63.2 360.3 10-16, 1963
November 64.1 360.7 11-17, 1963
December 36.7 356.5 25-31, 1963
This data is based on the published stage discharge data for the St. Louis gage and the "Mississippi River Slope Profiles, Chester, Illinois to Alton, Illinois Sheet 2 of 2, U.S. Army Engineer District, St. Louis Corps of Engineers, St. Louis, Missouri. PERCENTAGE OF TIME FLOW IS EQUALED OR EXCEEDED
MEAN DAILY FLOW DURATION CURVE FOR MISSISSIPPI RIVER AT ST.LOUIS
This data is based on the published stage discharge data for the St. Louis gage, and the "Mississippi River Slope Profiles, Chester, Illinois to Alton, Illinois" Sheet 2 of 2, U.S. Army Engineer District, St. Louis, Corps of Engineers, St. Louis, Missouri. PIGURL 3-3-^ o MISSISSIPPI RIVER TEMPERATURE TEMPERATURE AT MERAMEC PLANT o PERCENT OF TIME FIGl'RF -3' o MISSISSIPPI RIVER TEMPERATURE TEMPERATURE AT MERAMEC PLANT O
RIVER WATER TEMPERATURE 0 0 0 0 0 0 0 100 90 80 70 60 50 0 4 30 0 2 10 EPRTR A MRMC PLANT MERAMEC TEMPERATURE AT RIVER TEMPERATURE MISSISSIPPI E C N O TIME PERCENT OF APRIL IT r i < j ' . h i ; -67 CLT 5-26-71 3-3-D
RIVER WATER TEMPERATURE °F ....
o
RIVER WATER TEMPERATURE ISSIP RVR TEMPERATURE RIVER MISSISSIPPI EPRTR A MRMC PLANT MERAMEC AT TEMPERATURE AUGUST IUE 3-3-H FIGURE
10 20 30 40 50 60 70 80 90 100 PERCENT OF TIME o
RIVER WATER TEMPERATURE °F EPRTR A MRMC PLANT MERAMEC AT TEMPERATURE TEMPERATURE RIVER MISSISSIPPI r ; re - 3-3-J
RIVER WATER TEMPERATURE 0 0 0 0 0 0 0 0 100 90 80 70 60 50 0 4 30 20 10 E CN O TIME OF PERCENT NOVEMBER FIGURE 3—3—1.
DECEMBER o o
o
>
\
ELEVATION IN FEET ABOVE MSI 80 70 40 30 40 30 20 10 00 O 0 70 0 30- 0 30 O 10 0 100 WO. 300 400 - 300 400 700 800 WO 1000 1100 1200 1300 1400 1300 1400 1700 1800 E G R A H C S I D T N I O P E L G N I S - Y A M .AEA DSAC* N FEET- IN DISTANCE* .LATERAL ' DEGREESABOVE AMBIENT
O 3-4--C - - 4 - 3 . G I F O
ELEVATION IN FEET ABOVE MSI i « . _i_ % • 9 • •• •' f SUBSURFACE ISOTHERMS NEAR SINGLE POINT DISCHARGE - RUSH ISLAND UNITS I & I UNITS ISLAND RUSH - DISCHARGE POINT SINGLE NEAR ISOTHERMS SUBSURFACE JULY - RIVER DISCHARGE -79,100 CPS. i DOWNSTREAM DISTANCE (FEET) DISTANCE DOWNSTREAM 4 2
60 i
O > 3-5- FIG.
o
ELEVATION IN FEET ABOVE MSI 89 70 *0 50'WO 30 29 10 00 9 BO 0 *0 0 *0 0 30 0 0 100 300 300 *00 500 *90 700 BOO 190 1090 1100 1209 1*00 ‘ * 1500 '1300 WOO 1700 1809 E G R A H C S I D T N I O P E L G N I S - Y L U J .LATERAL 0! STANCE IN FEET FEET IN STANCE 0! .LATERAL DEGREES ABOVE AMBIENT T I ecer lf71 - 1 7 f l , 1 2 Oetcfeor o
'01J O
ELEVATION IN fEET ABOVE MSL 360 __ USRAEIOHRSNA SNL PITDSHRE-RS ILN UIS 2 1 1 UNITS ISLAND RUSH - DISCHARGE POINT SINGLE NEAR ISOTHERMS SUBSURFACE ADCDST - RIVER DISCHARGE - 60,700 CFS. O > O -9-e *~n
ELEVATION IN fEET ABOVE MSI E C R A U C S I D T N I O P E L G N I S - T S U G U A
O I. 3-6-C FIG. EVALUATION*OF WATER TEMPERATURE STANDARDS AND WATER TEMPERATURES RESULTING FROM RUSH ISLAM) PLANT OPERATION
1. River temperatures that nay be exceeded May 75 less than lit of ths time In a month, °F July 86 (Based on available historical records) August 85 With Rush Islard Plant In operation and besedvon Items 1 and 2 of this tabulation, the dimensions of the mixing zone will be less than Indica 2. River temperature standard at the edge of May 80 ted belowi mixing zone that may be exceeded less than July 89 lit of time, °F. August 89 3. Maximum temperature limits at edge of 5° Above May 83»» mixing zone, (whichever is lower) With Rush Island Plant In operation Ambient July 92** and based on Item 3 of this tabula August 92** tion, the dimensions of the mixing sons will be less than Indicated below:**** A. Maximum allowable width of mixing zone 33 May (percent of river width) 5 May 5 July 10 July 5 August 15 August 15 5. Maximum length of mixing zone 1,500*** May (feet) 500 May 500 July 1250 July 500 August 1300 August 500 6. Maximum surface area of mixing zone 1,130,000 May 50,000 (square feet) May 50,000 July 150,000 July 50,000 August 150,000 August 100,000 7. Maximum allowable cross section of 25 May 5 May 5 mixing zone July 10 July (percent of river cross section) 5 August 15 August 15
* This is baaed on the width of the Mississippi River at the Rush Island Plant and the maximum recorded ambient river temperatures of 76°F In May, 87°F in July, and 86°F In August. ** Illinois standard not included In Missouri proposed criteria. *** Missouri proposed criteria not included in Illinois standard. ****Mixing zone on the basis of 5°F above maximum recorded ambient rather than on specific monthly temperature limits. Schematic illu s tra tin g biological sampling stations for the fa ll and spring study at the Sioux power plant. NUMBER % TOTAL
Annelida Oligochaeta 27 46.6 Hirudinea 1 1.7
Arthropoda Trichoptera Hydropsychidae 25 43.1 Odonata Zygoptera 1 1.7
Mollusca Gastropoda Lymnaea 1 1.7 Pelecypoda Musculium 2 3.5 Unio JL 1.7 58 ORGANISMS NUMBER % TOTAL
Annelida Oligochaeta 33 32.0 Polychaeta 3 2.9
Arthropoda Ephemeroptera Hexagenia 13 12.6 Diptera Tendipedidae 25 24.3 Heleidae 7 6.8 Culicidae 6 5.8 Tricnptera Hydropsychidae 7
Mollusca Gastropoda Physa 3 2.9 Lymnaea 1 1.0 Gyraulus 2 1.9 Pelecypoda Musculium 2.9 TOTAL: 103 m u m ,
Figure 3-11 O Benthic organisms identified in samples collected at the Sioux Site October, 1970 at Station 3.
ORGANISMS NUMBER % TOTAL
Annelida Oligochaeta 67 49.3
Arthropoda Ephemeroptera Hexagenia 7 5.1 Odonata Coenagrionidae 8 5.9 Diptera Tendipedidae 13 9.6 Heleidae 3 2.2 Culicidae 1 0.7 Tricoptera Hydropsychidae 19 14.0 Psychomyiidae 4 2.9 Coleoptera Elmidae (adult) 1 0.7 Elmidae (larva) 5 3.7
Mollusca Ga stropoda Physa' 3 2.2 Pelecypoda Musculium _5_ 3.7 TOTAL: 136 ORGANISM SPFC1ES NUMBER RELATIVE S ABUNDANCE Zooplankton Protozoa Blepharisma sp. 46 ■ • 8.10
Phytoplankton Chrysophyta Navicula sp. 106 18.67 CycloteHa sp. 72 12.68 Stephanodiscies niagarae 60 10.57 Melosira niagarae 180 31.71
418 73.63 Chlorophyta Phacus curvicauda 12 2.11 Volvox sp. 12 2.11 Pediastrum simplex 1 0.13 Oocystis sp. 6.6 1.16 SpTrogy^a sp. 20 3,52 Scenedesmus qua dr i cat'da 32 5 .C4
83.6 M .7 2
Cyanopr.yta Anabfenfr sp. 20 3.52
TOTAL 567.6 99.97 ORGAN'ISM SPECIES NUMBER RELATIVE ! PER ml. ABUNDANCE
Zooplankton Protozoa
Blepharisrna sp. 26 4.85
Chrysophyta
Navicula sp. 72 13.43 Cyclctena sp. 26 4.85 Stephanodiscus sp. 66 12.31 Melosira Qranulata 92 17.16
256 52.60
Chlorophyta
.Phacus curvicauda 12 2.24 Volvox sp. 20 3.73 Pediastrum simplex 92 17.16 _(b_cys tis sp. -12 2.24 Sc(.nede.sr.ijs qu?,idic dUC? Sprioqyrc sp. 12 2.24
148 27.61
Cyanophyta
Anabaena sp. 46 8.58 Oscillatoria sp. 60 11.19
106 19.77
TOT/!. 636 93.98 ORGANISM SPECIES NUMBER RELATIVE PER ml. ABUNDANT!
Zooplankton
Protoza
Paramaciu:n r.ul t'inuc1caluiii 3.13 2.48 Blepharisn.a sp. 1.52 1.20 Euglena 17.00 13.45
21.65 17.13
Phytoplankton
Chrysophyta
Stephanodiscus niaaarae 28.78 22.78 Oephora martyi 3.80 3.01 Melosira granulata 38.95 30.83 Cyclotella sp. 16.15 12.78 Navicula sp. 14.53 11.50
1 0 0 .3 1 80.90
Chi crop!
Scenedesn’us cuadncauda .31 .25
Pile cl;s curvi cauda 2.18 1.7?
2.49 1.97
10TAL 126.35 100.00 ORGANISM SPECIES NUMBER RELATIVE % PER ml. ABUNDANCE
Zooplankton
Protozoa
Paramecium multinucleatum 1.52 .98 Blcpharisma sp. 3.80 2.44 Euglena 5.98 3.84
11.30 7.26
Phytoplankton
Chryscphyta
Steplianodi sous niaqarae 33.25 21.38 Opephora martyi 3.42 2.20 Melosira granulata 45/60 ‘ 29.32 Cyclotella sp. 27.55 17.72 flavicula sp. 24.70 15.88
134.5? 86.50
Chlorop'iyta
Sc one do sinus gu a c!r i c a a ci a 5.98 3.85 See n eel os mu s sp. 1.52 .98 Phecus curvicauda 2.18 -1.41-
9.68 -6t -24-
TOTAL 155.5 100.00 EFFLUENT GUIDELINES AND STANDARDS MISSOURI AND ILLINOIS
Missouri Illinoi Parame ter mg/l mg/l
pH 6.5-9.0 5-10 BOD (5-Day) 50 - COD 150 - Dissolved Solids 1000(1) - Suspended Solids - 15 Ammonia (2) — Chromium (As Cr) Total 1.0 Hexavalent 0.05 0.3 Trivalent 1.0 1.0 Copper (As Cu) 0.02 1.0 Iron (as Fe) Total 10.0 2.0 Dissolved - 0.5 Zinc (as Zn) 0.10 1.0 Arsenic (as As) 0.05 0.25 Barium (as Ba) 1.00 2.0 Cadmium (as Cd) 0.01 0.15 Cyanide (as Cn) 0.02 0.025 Lead (as Pb) 0.10 0.10 Mercury (as Hg) 0.005 0.0005 Nickel (as Ni) 0.80 1.0 Selenium (as Se) 0.01 1.0
Allowable increase over intake water.
Shall not exceed 0.10 of the toxic level at the prevailing pH value or 2 mg/l whichever is least. HOURLY MAXIMUM CONCENTRATION OF SULFUR DIOXIDE AND NITROGEN OXIDES _____RUSH ISLAND UNITS 1 & 2 ___
Sulfur Dioxide Nitroqen Oxide Meteorological Wind Speed Distance Cone. Distance Cone. Conditions M/Sec Km PPM Km PPM
Very unstable 3 4 0.05 4 0.03 Very unstable e. 3 0.06 3 0.04 Unstable 5 5 0.06 5 0.04 Unstable 8 3 0.08 3 0.05 Unstable 12 2.5 0.08 2.5 0.05 Neutral 8 12 0.06 12 0.04 Neutral 12 8 0.07 8 0.04 Note: 1) Nitrogen oxide concentration in stack discharge, 340 PPM.
2) Sulfur content of fuel burned, 1*. 3) M/Sec. -- meters/sec. (1 M/sec = 2.24 miles per hour) 4) Km - Kilometers (l Km = .62 miles) 5) PPM - parts per million o
. ESTIMATED CONCENTRATIONS OF S02 .ALONG RADIAL"TO NORTH OF PLANT, DUE TO RESPECTIVE SOURCE ALON UJ . • •
Reference - A .statement regarding the testimony of Edward W. Burt at • - a hearing conducted by the Missouri Air Conservation Commission, July 22-23, 1970, St. Louis, Missouri
rt o FORECAST OF HIGH-POLLUTION-POTENTIAL
. - > *. • • Reference Smith,* M'. E., "Recommended Guide for the Prediction • O of the Dispersion of Airborne Effluents," The American Society of Mechanical Engineers - 1968. FIGURE 5-1 RUSH ISLAND AND 29 ALTERNATE SITES ©ALTERNATES APPENDICES APPENDIX A
UNION ELECTRIC COMPANY LETTER TO UNITED STATES ENVIRON?tENTAL PROTECTION AGENCY DATED 4 APRIL 1972
RESPONSE TO UNION ELECTRIC COMPANY DATED 12 JULY 1972 Mr. William D. Ruckelchaus, Administrator Environmental Protection Agency Office of General Enforcement Waterside Mall, SW Washington, D.C. 20460
Dear Mr. Ruckelshaus:
Union Electric Company, a Missouri corporation with executive offices at One Memorial Drive, St. Louis, Missouri 63166, plans to erect an electric generating plant, named the Rush Island Plant, on the west bank of the Mississippi River some 33 miles downstream of the City of St. Louis.
The "Standards of Performance for New Stationary Sources," which were published in the Federal Register on December 23, 1971, are to apply to sources "... the construction of which was commenced after August 17, 1971." Commenced as defined under subparagraph (i) of para graph 60.2 is stated as follows:
"'Commenced' means that an owner or operator has undertaken a continuous program of construction or modification or that an owner or operator has entered into a binding agree.m;nt or con tractual obligation to undertake and complete, within a rea sonable time, a continuous program of construction or modification."
Following is a listing of commitments made by Union Electric Company which are related to the construction of the Rush Island Plant.
Description of Event Date of Event
Issued purchase order to Weetinghouse Electric Corp. for turbine-generator (Unit 1). 3-31-69
Issued purchase order to Westinghousc Electric Corp. for turbine-generator (Unit 2). 3-31-69
Original letter of intent to Combustion Engineering for purchase of Rush Island boilers. (This letter amended on October 16, 1970 and superseded by letter of December 30, 1970.) 6-10-70 Description of Event Date of Event
Letter of intent to have Bechtel furnish engineering end consulting services for Rush Island 1 &'2. (Started work at the site on September 11, 1970.) 7-1-70
Preliminary work order authorization for Rush Island 1. 7-31-70
Preliminary work order authorization for Rush Island 2. 7-31-70
Site survey contract (Started work at the site on August 26, 1970.) 8-20-70
Soils investigation contract (Started work at the site on September 2, 1970.) 8-21-70
Power block and stack excavation contract (Started work at the site on April 1, 1971.) 3-19-71
River dredging and hydraulic fill contract (Started work at the site on July 20, 1971.) 6-23-71
Based on the definition of "commenced" as stated under paragraph 60.2 of the Standard, our counsel has given an opinion that the Rush Island Plant could not be considered a new stationary source and, therefore, would not be subject to the provisions of the Standard. A b provided for under paragraph 60.5 of the Standard, it is requested that the Administrator re view the cor.nltnsnts listed above and following such review promptly notify us if you concur that these actions constitute construction or the com mencement thereof within the meaning of the Standards.
Sincerely,
Original Signed By EARL K. DILLE
Earl K. Dille Executive Vice President cc/Mr. Jerome H. Svore, Regional Administrator United States Environmental Protection Agency
Mr. H. D. Shell, Acting Executive Secretary Missouri Air Conservation Commission bcc/Mr. J. E. Birk Mr. J. K. Bryan Mr. J. F. McLaughlin Mr. J. D. Smith ENVIRONMENTAL PROTECTION AGENCY 5600 Fishers Lane Rockville, Maryland 20852 July 12, 1972
Mr. Earl K. Dille Executive Vice President Union Electric Company St. Louis, Missouri 63166
Dear Mr. Dille:
This is in response to your letter of June 23, 1972, requesting a determination, pursuant to 40 C.F.R. §60.5, of the applicability
We have reviewed the submitted materials and have found that a "binding commitment or contractual obligation" was in existence on Mar^h 16, 1971, the date on which you amended your October 16, 1970 letter of intent to accept changes in the boiler as proposed by Combustion Engineering. Accordingly, the Standards of Performance for New Stationary Sources are not applicable to the Rush Island plant
Sincerely yours,
Edward E. Reich Chief, Enforcement Proceedings Branch APPENDIX B
RUSH ISLAND AIR QUALITY STUDY SMITH-SINGER, METEdROLD GISTS, INC. 1Q3 CEDAR SHORE DRIVE MASSAPEOUA. N. Y. 1175B
79B-1445 T E L : S I 6 7 2 4 - B 6 5 4 5 1 6
S 0 2 A N D N0X CO NC EOT RAT TO MS RUSH ISLAND PLANT UNION ELECTRIC COMPANY
I . SUMMARY.
The probable ground-level concentration's of S02 and UOx have been computed for the initial units of the Rush Tsland plant, and. a stack of 600 feet should be quite acceptable from both standpoints. The terrain in the vicinity of the site is favorable and there are few other sources of the same pollutants, so that the calculations should be indicative of actual results after the plant is completed.
We have taken into account our experience with the Sioux plant, e s p e c i a l l y in terras of the S02 c o n c e n trations. Calculated hourly maximum values are undoubt edly higher than those observed, probably by at least a factor of 2. We cannot be sure that N0X will follow the same pattern since the atmospheric chemistry is different, but here also the calculated values should be somewhat higher than those observed.
IT . rNPirr DATA.
According to the letter from McLaughlin to Smith (10/27/70) the Rush Island facility is expected to consist of two 600 MW units, nearly identical to those at Labadte, Unit //I is to use coal containing 1% S, and unit ^2 may also, but we should be prepared for occasional emissions on the basis of S. N0X sion is difficult to estimate, but it should not exceed 500 ppm in the stack gas.
A single stack is to be used for the two units, with a diameter of approximately 26 ft, and a full-load emission velocity of 90 ft/sec. 1TI. CALCULATIONS.
A series of calculations has been made for seven different combinations of meteorological conditions, and stack heights ranging from 500- 700 feet in 50-ft intervals. No corrections or adjustments have been introduced into the calcu lations to correct them to match our experience at Sioux, because we are not certain whether meteor ological factors or chemical conversion is the primary cause of the discrepancy. We have considered these results, however, in our recommendations.
The data are best summarized In a series of three tables, representing various operating con ditions and pollutants. Table 1 shows the levels and distances of the maximum hourly concentrations computed for unit, i 1 operating on i'£ sulfur and u n i t tf2 on sulfur. Recognlzl nsr that our exper ience at Sioux indicates that these values exceed the typi cal hourly maximuras by about a factor of 2 , we would conclude that even a 500-ft stack would produce results within the Missouri hourly standard of .36 ppm (Table 1).
We cannot ignore the possible problem associated with downwash, however, and we feel that a 600-foot stack should he adenuate to eliminate any concern, especially with such a large volume of emission.
Obviously, operation on the basis of sulfur in both units would produce vpry low concentration jevels with a 600-foot stack as" shown in Table 2.
The NO* problem is slichtl.v different in two respects. First the acceptable maximum levels will probably be .10 ppm, and we cannot be sure that the NOx will undergo depletion In the atmosphere as raoldl.v as S02 does. If we simply accept the data in Table 3 at- approximately face value, we would c o n s i d e r 6()0 feet a suitable stack height.
IV. RKCOMMKNDATTONS.
A 600-foot stack should be quite suitable for the facility planned on the basis of either SO2 or NOx concentrations and present standards or criteria. The choice is largely dependent upon the necessity for preventing undesirable downwash, since a somewhat lower stack would achieve the purpose on the basis of theoretical calculations alone.
Even if two more units uslncj \% S fuel were to be added 1” the future, ♦’he 6OO-ft stacks should be adequate.
We do recommend that a monitoring program be established at this site, similar to that now in operation at Labadie. The value of such studies in discussion with air pollution control personnel far outweighs calculated data, and the experience gained is invaluable for future plant design.
If nuclear facilities are even tentatively con sidered for future installation at this site, the meteorological equipment should be carefully planned to meet the AEC requirements. o o
Tabjp .!
HOURi.Y MAXIMUM SO2 COiICbUTRA",I023
Unit //'] - li, Sulfur lTnlt rti. - 9*' sulfur
Stack Height (feet)
500 550 600 650 700 Yet, Wind Cond. Soeed ''.’one. 111 st . Cone. Hist Cone. 01 st. Cone. Dlst. Cone. Cist (n/sec) ( 0 or ) (k m ) (ppn) (km) (pum) (km) (ppm) (km) (ppm) (kra)
Very Unstable J .19 3 . 16 3 .13 9 .13 9 .12 9
Very Unstab'] e K. .29 <1 .23 .21 2 .18 2 .16 3
Unstable 5 • 26 9 .22 •>► .20 9 .17 5 .16 5
R Unstable .33 O .20 ■3 .26 3 .22 3 .20 3
Unstable 12 .9] 2 • 35 '3 • "30 2 .26 2 .21 2.5
Ueutrs] 9 V '3 O .2? • • - • .20 1 0 .18 10 .16 12 r'e'itr&l i? . V- 6 . •' '7 2 .2 * .20 R .1? g u o o
T a b l e 2
HOURLY MAXIMUM S02 CONCENTRATIONS
Unit #1 - l£ Sulfur Unit #2 - 1% Su lfu r
Stack Height (feet)
500 550 600 650 700 Met. Wind Cond. Speed Cone. D ist. Cone. Dist Cone. D ist. Cone. D ist. Cone. D ist (m/sec) (ppm) (km) (ppm) (km) (ppm) (km) (ppm) (km) (ppm) (km)
Very- Unstable 3 .08 3 .06 3 .06 9 .05 9 .05 9
Very- Unstable 5 .12 2 .10 2 .08 2 .07 2 .06 3
Unstable .10 9 5 .09 9 .08 9 .07 5 .06 5
Unstable 8 .13 2 .12 3 .10 3 .09 3 .08 3
Unstable 12 .16 2 .19 2 .12 2 .10 2 .08 2.5
Neutral 8 .11 9 .09 9 .08 10 .07 10 .06 12
Neutral 12 .13 6 .11 7 .09 7 .08 8 .07 8 o o
Table 3
HOURLY MAXIMUM N0X CONCENTRATIONS
N0X at 5^0 ppm
Stack Height (feet
500 550 600 650 700 Met. Wind C o n d . Speed Cone. Disto Cone. Dist Cone. D1 st. Cone . Dist. Cone. Dist (m/sec) (ppm) (km) (ppm) (km) (ppm) Ocm) (ppm ) (km) (ppm) (km)
Very Unstable 3 .07 3 .06 3 .05 4 .04 U .04 4
V e r y Unstable 5 .10 2 .09 2 .07 2 .06 2 .06 3 0 C Unstable 4 0 5 .09 U .07 U .06 5 .06 5
Unstable O
8 e .11 2 3 .09 3 .08 3 .07 3
Unst a b l e 12 .14 2 .12 2 . 10 2 .09 2 .07 2.5
Neutral 8 .09 9 .08 9 .07 ]0 .06 10 .06 12
Neutral 12 .11 6 .10 7 .08 7 .07 8 .06 8 APPENDIX C
THERMAL DISCHARGE CRITERIA The thermal criteria for the Mississippi River has been under review
during the past several months by the various state water quality agencies
and the Federal Environmental Protection Agency. Proposed thermal stan
dards would limit the maximum temperature rise above natural temperature
conditions to 5°F. In addition, maximum water temperatures are proposed
for each month of the year which is to have a probability of exceedance
less than one percent of the time in a year.
Proposed temperature limits which have been stated by the Federal
Environmental Protection Agency that could apply to the Rush Island
Plant are as follows:
January - 50°F July - 89°F February - 50°F August - 89 °F March - 60°F September - 87°F April - 70°F October - 78°F May - 80°F November - 70°F June - 87°F December - 57°F
In addition to these proposed temperature limits, mixing zones are proposed that would limit the maximum temperature at the perimeter of the mixing zone at the applicable maximum temperature listed above, or 5°F above the natural temperature, whichever is the lower.
The above temperature standards are those established for Zone 2 of the
Upper Mississippi River Basin which are based upon water uses for irriga tion, livestock watering, propagation of commercial fish, wildlife watering, industrial cooling water, industrial process water, drinking water supply, boating and canoeing, fishing, aesthetic value, receiving effluents, navi gation, and receiving surface runoff. Zone 2 is that part of the Mississippi
River from Lock and Dam No. 26, Alton, Illinois, down to the mouth of the
Arkansas River. The Missouri Water Pollution Board has proposed thermal standards which would adopt the above monthly maximum temperatures. In addition, the following conditions are to be observed:
Effluent temperatures shall not elevate or depress the water temperature of the river, outside a mixing zone, more than 5°F. The water temper ature in the river outside the mixing zone, shall not exceed the monthly maximum temperatures specified more than one percent of the hours in the 12-month period ending with any month.
In addition, there shall be no abnormal temperature changes that may affect aquatic life unless caused by natural conditions. The normal daily and seasonal temperature fluctuations due to natural causes are to be maintained.
Mixing zones are defined as the area of rapid diffusing of an effluent in the river; water quality standards are to be applied outside the mixing zone.
The boundary limits of the mixing zone are not to be a fixed linear distance or area, but would be delineated by several factors for each case. Consideration is to be given to discharge structure, the hydro- logic characteristics of the mixing stream, the use of the stream, stream bank configuration, etc., with the following conditions being met:
1) The mixing zone is not to include more than 25 percent of the cross- sectional area of the river, nor exceed more than one-third of the width of the river. 2) A mixing zone extending no farther in any direction from an effluent
discharge than 500 to 1,000 feet would be desirable, but may be extended
to 1,500 feet provided condition number 1 is met.
3) The effluent structure is to be located off-shore to allow free
passage of fish between the shoreline and outfall.
The State of Illinois Pollution Control Board recently proposed similar
monthly maximum temperature limits with the following qualifications:
1) There shall be no abnormal temperature change that may adversely
affect aquatic life unless caused by natural conditions .
2) The normal daily and seasonal temperature fluctuations that exist
before the addition of heat due to other than natural causes shall be
maintained.
3) The maximum temperature rise above natural temperatures shall not
exceed 5°F.
4) In addition, the water temperature at representative locations in the
main river shall not exceed the maximum monthly temperatures, as proposed,
more than one percent of the hours in the 12 month period ending with any
month. Moreover, at no time shall the water temperature at such locations
exceed the maximum monthly limit by more than 3°F.
As a part of these proposed regulations* the Illinois Pollution Control
Board described the application of the mixing zone concept as follows:
*Illinois Pollution Control Board, Rules and Regulations, Chapter 3:
Water Pollution, Part II: Water Quality Standards, adopted March 7, 1972. "Water quality standards must be met at every point outside the mixing
zone. The size of the mixing zone cannot be uniformly prescribed. The
governing principle is that the proportion of any body of water or seg
ment thereof within the mixing zones must be quite small if the water
quality standards are to have any meaning. This principle shall be
applied on a case-by-case basis to ensure that neither any individual
source nor the aggregate of sources shall cause excessive zones to exceed
the standards. The water quality standards must be met in the bulk of the
body of water, and no body of water may be used totally as a mixing zone
for a single outfall or combination of outfalls. Moreover, except as
otherwise provided .... no single mixing zone shall exceed the area
of circle with radius of 600 feet.
"In determining the size of the mixing zone for any discharge, the follow
ing must be considered:
1) The character of the body of water,
2) The use of the body of water,
3) The present water quality of the body of water,
4) The effect of the discharge on the present water quality,
5) The dilution ratio, and
6) The nature of the contaminant.
"in addition to the above, for waters designated for aquatic life (General • >
Standards), the mixing zone shall be so designed as to assure a reasonable
zone of passage for aquatic life in which the water quality standards are met. The mixing zone shall not intersect any area of any such waters in such a manner that the maintenance of aquatic life in the body of water as a whole would be adversely affected." APPENDIX D
MATHEMATICAL MODEL FOR
PREDICTING THERMAL DISCHARGE
DISPERSION UNIFORM FLOW DISPERSION MODEL FOR A
THERMAL SOURCE
by
E. Harvey Elwin, A.M. ASCE
ASCE National Environmental Engineering Meetin St. Louis, Missouri October 16-22, 1971 1. INTRODUCTION
In the design of power plants, either conventional or nuclear, the wasu heat must in some way be dissipated to the environment. Freshwater streams and estuaries are an intermediate in the ultimate discharge of heat to the atmosphere and to outer space. However, because of the increased size of individual power plants and the greater quantities of heat discharged by equivalent size nuclear power plants, the consideration of the thermal effects caused by the discharge of cooling water has become of great importance.
The analysis of rejected thermal loads in river or estuary environments has been primarily limited in available literature to two regions of the problem; "near field" effects and the "far field" effects. The state of development of temperature prediction has been restricted to "near field" effects due to the relatively small zone which existing turbulent jet theory is applicable or to well-mixed "far field" effects due to the limitation of most mathematical models to one dimension.
A region of much importance is the intermediate region. The evaluation of "intermediate field"thermal effects requires modeling in a minimum of two dimensions and because of variation in buoyancy, preferably in three dimensions.
Although efforts are now underway to develop sophisticated three-dimensional prediction models, there is a current need for a relatively ur-sophisticat*5 ' three-dimensional temperature prediction model.
1 Engineer, Bechtel Inc., San Francisco, California O
O FIGURE 1 REGIONS OF ANALYSIS OF A CONTINUOUS , th er m a l s o u r c e in a u n if o r m f l o v / In this discussion, a three-dimensional advective-dispersion model has been formulated to simulate and describe the dispersion of a continuous
thermal source in a steady state uniform flow. The model is based on the
general finite element heat equation for an advective system and consists of a three-dimensional array of elemental equations, which, when coupled with appropriate boundary conditions, may be solved through a progressive simultaneous solution of the system using matrix methods.
II. BASIC THEORY AND ASSUMPTIONS
Any material introduced into a steady uniform flow is transported by basically three processes; advectior., diffusion, and dispersion. Advection
is the transport of the pollutant by the current, while diffusion describes
the phenomenon of mixing resulting from pure diffusion (molecular) as well
as the effects, of turbulence (eddy diffusion). Traditionally the basis
of diffusion theory is given by a statement of Fick's first law:
dc M - -D dx
where M is the rate of transfer of c, c is the concentration of the diffusing dc substance, — is the diffusion gradient in a characteristic direction, and D
is the diffusion coefficient. Fick's law assumes that the rate of transfer
of diffusing material is proportional to the negative concentration gradient.
This quantitative form of diffusion originally was derived to represent
molecular diffusion, but by making an analogy between the transport processes
of.molecular diffusion and eddy diffusion within the advecting fluid it may
be used to describe the complete diffusion process in the advective-diffusion
equation for turbulent flow. The dispersion process refers to the mixing due to shear flow associated with the effects of differential convective displacement. Fluid elements at a section of a moving fluid may be ccnvected at different mean velocities, both vertically arid laterally, and would be displaced from one another by a distance equal to the product of the local
velocity difference and time period. This displacement is commonly termed
the convective displacement. In turbulent shear flows, the convective displacements are dominant and these effects are the basis of dispersion.
Accordingly, dispersion refers primarily to the mechanism where transport is associated with spatially averaged velocity fluctuations, and diffusion refers to cases where the transport is primarily associated with time averaged velocity fluctuations.
In view of the end effects of both the dispersion and diffusion processes being similar, it was assumed in the model that the effects of both processes
could be represented by a "composite dispersion" coefficient representing
the composite phenomena of nixing.
The general heat equation for an advective system can be written in
three dimensions for a unit mass within a water body as:
U, i t - - [D. & - 1-] .- Q(T) it wi ix. *x. where i = 1, 2, 3 corresponds to the x, y, z direction respectively; T signifies
the temperature per unit mass; lb represents the velocity component; is the
dispersion coefficient for heat; and Q(T) accounts for any heat gain or loss
in the system.
The basic building block of the model is the generalized fluid element.
Thu heat equation permits equating the sum of the heat exchange rate at the
element surfaces to the rate of heat inflow and the rate of heat outflow by the various cuss transfer mechanisms. However, it is necessary to idealize the physical situation to make the mathematics more tractable. The following assumptions were made in the derivation of the elemental heat equation.
1. The only gain or loss of heat to the system other than the heat source initial condition is the surface exchange between the water surface and atmosphere. The net rate of exchange, Q^, may be expressed as the algebraic sum of the rates at which heat is transported across the water surface by short-wave solar radiation, Q ; long-wave or atmospheric radiation, s Q ; reflected short and long-wave radiation, Q and Q ; back radiation sr dir from the water surface, Q^J evaporation, Qe ; and conduction, Q^:
(2)
It has been shown (5) that when the back-radiation, evaporation, and heat conduction are ejepressed in terms of their physical dependence on water temperature, T, air temperature, T , and air-vapor pressure, e , the net d rate of heat exchange becomes:
K(T-E) (3) ««- where K is the thermal exchange coefficient and E is the equilibrium tenoeratur
e e K = 15.7 + 0.051 (T+E) + CH (.00682 + .000682 W) (.26 + g (A) V i — £.
K = exchange coefficient, — r day °F; FT
T = surface temperature, °F;
E * equilibrium temperature, °F;
C ■ Keyer.evaporation coefficient; Hv » latent beat of vaporization, B7U/L3;
W e wind speed, MPH;
eg * saturation vapor pressure at T, MM H^;
e_ « saturation vapor pressure at E, MM H . E g
The equilibrium temperature, E, is the water temperature at which there is no net heat exchange across the water surface (Q = zero) and it is a function n of short-wave and long-wave radiation, air temperature, wind velocity, and air-vapor pressure. The actual water temperature at any instant is being driven toward the equilibrium temperature at a rate proportional to the difference between them.
2. A steady state situation exists. The response time of changes in flow conditions or atmospheric conditions is small in relation to the travel time of the effluent.
3. Only a uniform longitudinal current is considered. Vertical and horizontal advective terms are neglected. The velocity is also assumed uniform over depth and width. To simplify the development, the X-axis will always'conform to the direction of flow.
Incorporating the above assumptions, the governing elemental equation reduces to become:
3li _ J l __ . jL_ m ^ T , . K (?-?.) = ^ [D. s?] + I t [d . 4 x ^x IUX ^ x J y 5y z £cdz
where U * mean longitudinal current;
D “ longitudinal dispersion coefficient;
Dy « lateral dispersion coefficient; Dz * vertical dispersion coefficient;
T » temperature;
K ** thermal exchange coefficient;
£ » density of water;
c ■ specific heat of water.
The first term of the equation represents advective heat transport, the next three terms., the thermal dispersion across the temperature gradients, and the last term, the surface dissipation.
H I . MODEL SCHEME
The model grid system consists of a three-dimensional array of elements” and a section of it is shown in Figure 2. Each element and elemental interface is referenced by an integer index. This enables the whole system of interfaces and elements to be referenced by a single three-dimensional array of indices.
For the single general element as shown in Figure 3, equation (5) may be put into a difference form. The following are the finite difference represen tations of the partials in equation for the I, J, K element:
1^1 * ^ [T(I-1,J,K)+T(I+1 ,J,K)-T(I-1,J+2,K)-T(I+l,J+2,K)] RIGHT I.J.K FACE
LEFT FACE
UPPER I,J,K FACE LOWER FACE
These representations assume that the longitudinal temperature gradients at the element's end interface nay be approximated by the longitudinal gradient of the element and the vertical and lateral gradients are approximated by the gradients of the average elemental temperatures.
Substitution of the finite difference approximations into equation (5), multiplying by the elemental volume, and rearranging, the general elemental equation for I,J,K element is obtained:
- XK(I-1,J,K)) - (XX(I,J-1,K) + XKU.J+l.K)) - ^
T(I+1,J+2,K> XK(I,J+1,K)] + T(I+l,J,K-2) [jjg XK(I,J,K-1)]
+T(l+l,J,K+2) [ j £ XK(1,J,K+1)] * o
IN
3
o FIGURE 2 THREE DIMENSIONAL ARRAY OF ELEMENTS AND THEIR INDICES. o
I + ]
FIGURE 3 THE GENERAL FLUID ELEMENT - I, J, K The second partials in equation (5) physically represent the net heat flux by dispersion through the fluid element in a specific direction. These terns in equation (6) are general in that they allow for a spatially varying dispersion coefficient.
The total dispersion model consists of a three-dimensional array of equation (6), coupled with appropriate boundary conditions and solved through a progressive simultaneous solution of each longitudinal section. The x, y, and z dispersion coefficients are represented in a single array XK (I,J,K) by specified indices.
These indices are:
X 3 1,3,5...... J ■ 3,5,7,.... JC ■ 3,5,7,....
Dy I = 2,4,6...... J « 2,4,6.... K - 3,5,7,....
D I *= 2,4,6,.... J - 3,5,7,.... K - 2,4,6,.... z
Three types of boundary conditions are used. Where no dispersive transfer is desired through the sides or bottom, the dispersion coefficients in those faces are set as zero. Those terms in the general element equation become zero.' For surface elements surface heat transfer coefficients are calculated.
For all interior elements the surface heat transfer coefficients are set equal to zero. The upstream interface temperature distribution, T(1,J,K), must be specified as an initial condition. Thermal sources will enter a flow as jets if they have a relative velocity to the flow greater than zero, « and as line, point, or plane sources if they enter the flow with a small relative velocity. This model does not consider the "near field" region and is applicable at the point where the momentum of the effluent jet has essentially dissipated. The thermal source is represented by a heat flux through one or several element interfaces at the upstream end of the element array by means of the initial temperature distribution. A jet effluent
source nay be considered by establishing the temperature distribution of the jet after loss of momentum from empirical measurements or theory and using
this distribution as the initial temperature distribution in the intermediate
field model.
With the above boundary conditions, a system of equations is formed for
the first longitudinal set of stream tubes, 1 = 2 (Figure 2). The system consists of a simultaneous set of equations with equation (6) written for each stream tube in that segment. The unknowns in the set of equations are
the downstream interface temperatures. The number of equations and unknowns in the system are equal to the number of tubes.
The system is formed by using the terms in equation (6) systematically for each tube as a row in a matrix having an order equal to the number of tubes. For a nine tube system, as shown in Figure 1, the matrix form is represented in Appendix II.
The solution of this linear algebraic system is accomplished by a method known as "left-right decomposition" which has been adapted from a GE-625/635 simultaneous linear equation solver called SIMEQ. The method is a modified version of Gaussian elimination.
IV. COMPUTER PROGRAM
The previously described dispersion Dodel has been translated into a
computer program. A general flow chart of this model is shown in Figure 4. RECYCLE FOR EACH LONGITUDINAL
SET OF EL rn 1=2, 4, 6 ,
O
FIGURE 4 COMPUTER PROGRAM FLOW CHART
- 13-
• m m m r In order, the input required is:
a) number of longitudinal segments;
b) number of lateral rows;
c) nunber of vertical layers; 2 d) longitudinal dispersion coefficient for each segment, ft /sec.; 2 e) lateral dispersion coefficients for each segment, ft /sec.; 2 £) vertical dispersion coefficients for each segment, ft /sec.;
g) initial temperature distribution at upstream Interface, °F;
h) mean current velocity, ft/sec.;'
i) element dimensions (x, y, z), ft.;
J) Meyer evaporation constant;
k) equilibrium temperature, °F;
l) wind velocity, mph; 3 m) density of water, lb/ft ;
n) specific heat of water
Output from the program is in the form of temperature distributions of the system. The program prints out the vertical temperature distribution (yz-plane) between each downstream set of segments and then the horizontal temperature distribution (xy-plane) between each vertical layer.
V. MODEL APPLICATION
The most critical consideration in the use of this model is the evaluation of dispersion coefficients. Field and laboratory data necessary to establish general values for the mixing in heated discharges is still lacking. While considerable work has been done in dispersion, it is not yet known what portions can be translated directly to those cases where density differences exist. It is known, however, that where density differences exist, the lateral dispersion process will be enhanced while the vertical dispersion process will be suppressed. As more data becomes available, generalized relationships will be obtained. Until then, approximate coefficients will have to be estimated
and used.
„In situations where an existing plant is to be enlarged or an existing
plant is in proximity to a proposed one and temperature distribution data
exists, "composite dispersion" coefficients may be approximated from the
evaluation of existing temperature data. Extrapolated temperature predictions
from coefficients determined in this way are probably the most reliable L analytical solutions available to date for this type of problem.
As an example of prediction relations for the enlargement of a given
power plant for which temperature distribution data exists consider the
hypothetical case given in Figure 5.
The procedure of analysis is as follows:
1. River cross sections are analyzed at the plant site to obtain
characteristic values of average velocities, shear velocities, and hydraulic
radii for conditions; of the provided field data.
2. Various dispersion coefficients are tried in the model until the
predicted temperature distribution approximates the measured temperature data.
The lateral and vertical dispersion coefficients are assumed constant over
a section's depth and width.
3. The obtained dispersion coefficients and sectional data for the
existing plant are used to evaluate the constant in the classicial dispersion
formula at each river cross section for both vertical and lateral dispersion: where ** dispersion coefficient in i-direction;
= constant for i-direction;
■ sectional shear velocity;
R ■ sectional hydraulic radius.
Experimental and analytical investigations based on fluid mechanics consider ations have shown that dispersion coefficients are proportional to the product of the shear velocity and the hydraulic radius for a characteristic reach.
4. River cross sections are analyzed at the site to obtain characteristic t - values of average velocities, shear velocities, and hydraulic radii for the critical flow conditions.
5. Lateral and vertical dispersion coefficients for altered flow conditions are evaluated from the sectional data and the empirically derived * • dispersion relationships.
6. The extent and dilution of the enlarged surface thermal source at the
"near field" region limits is based on field data for other surface discharges.
The obtained temperature distribution is used as initial conditions to the three-dimensional model.
7. The model is run simulating the thermal effects of the enlarged power plant for specified atmospheric conditions and ambient river temperatures.
VI. SUMMARY AND CONCLUSIONS
The mathematical model presented herein is able to generate steady state three-dimensional temperature distributions for a continuous thermal source existing in a uniform flow.
Although more investigation- needs to be done in the general prediction of dispersion coefficients for heated discharges, the model may be applied with confidence in certain situations where temperature field data has been
obtained for the simulation of downstream effects of a thermal discharge. 1. Ahlert, R. C. , Biguria, G., and Tarbell, J., "Some Finite Difference Solutions for the Dispersion of Thermal Sources in Steady Prismatic Flow", Journal of Water Resources Research. Vol. 6, No. 2, April, 1970.
2. Baldwin, R. C . , "A Dispersion Model for Heated Effluent From an Ocean Outfall", Naval Post-Graduate School. Masters Thesis. Monterey, California, April, 1970.
3. Bella, D. A., and Dobbins, W. E., "Difference Modeling of Stream Pollution" Journal of the Sanitary Engineering Division. ASCE, Vol. 9A, No. SA5, October, 1968.
A. Cederwall, K., "Hydraulics of Marine Waste Water Disposal", Hydraulics Division; Chalmers Institute of Technology. Report Ho. A2. Coteborg, Sweden, January, 1968. -
5. Edinger, J. E., and Geyer, J. D., "Heat Exchange in the Environment", Edision Electric Institute Research Project No. A9. Dent, of Sanitary Engr. and Water Resources. Johns Konkins University. Baltimore, Maryland, June, 1965.
6. Edinger, J. E., and Polk, E. M., "Initial Mixing of Thermal Discharges Into a Uniform Current", Report No. 1. Dent, of Environmental and 'Water Resources Engineer. Vanderbilt University. October, 1969.
7. Eliason, J. R., Jaske, R. T., Sonnichsen, J. C., and Templeton, W. L., "Improved Methods for Planning of Thermal Discharges Before Site Acquisition with a Specific Case Example on the Columbia River", International Atomic Energy Agency Symposium on Environmental Aspects of Nuclear Power Stations. New York City, August, 1970.
8. Fischer, H. G., "Methods for Predicting Dispersion Coefficients in Natural Streams, with Applications to Lower Reaches of the Green and Duwamish Rivers Washington", U.S. Geological Survey Professional Paper 582-A. U.S. Government Printing Office, Washington, 1968.
9. Glover, R. E., "Dispersion of Dissolved or Suspended Materials in Flowing Streams", U.S. Geologic Survey Professional Paoer A33-B, U. S. Government Printing Office, Washington, 196A.
10. Harleman, D. R. F., Lee, Chok-Hung, and Kail, L. C., "Numerical Studies of Unsteady Dispersion in Estuaries", Journal of the Sanitary Engineering Division. ASCE. Vol. 9A. No. RAS. October. 1968. 11. Liggett, J. A., and Hadjitheodrou, "Circulation in a Shallow Hor-ogeneous Lake", Journal of the Hydraulics Division, ASCE. Vol. 95, No. KY2, March, 1969.
12. Liggett, J. A., "Cell Method for Computing Lake Circulation", Journal of the Hydraulics Division. ASCE, Vol. 96, No.: HY3, March, 1970.
13. O'Connor, D. J., St. John, J. P., and DiToro, D. M., "Water Quality Analysis of the Delaware River Estuary", Journal of the Sanitary Engineering Division. ASCE. Vol. 94, No. SA6, December, 1968.
14. Paulson, R. W., "Variation of the Longitudinal Dispersion Coefficient in the Delaware River Estuary as a Function of Freshwater Inflow", Journal of Water Resources Research. Vol. 6, No. 2, April, 1970.
15. Pritchard, D. W., "Dispersion and Flushing of Pollutants in Estuaries", Journal of the Hydraulics Division. ASCE, Vol. 95, No. HY1, January, 1969.
16. Senshu, S., and Wada, A., "Thermal Diffusion of Cooling Water in a Stratified Sea Basin", Proceedings of the 11th Congress of the International Association for Hydraulic Research. Leningrad, 1966.
17. Wada, A., "A Study of Phenomena of Flow and Thermal Diffusion Caused by Outfall of Cooling Water", Proceedings of the 10th Conference on Coastal Engineering. Tokyo, Technical Report of Central Research Institute of Electric Power Industry, 1966. LINEAR ALGEBRAIC SYSTEM FOR TH I LONGITUDINAL SEGMENT
TUBE J,K
3,3 A, ,T„ „+ A1 „T, „ + + 0 + 0 1,1 3,3 jL,2 5,3 + A1,4T3.5 +
5,3 A_ ,T, „+A„ _Te _+ A_ ,T, .+ 0 + A- CT 2,1 3,3 2,2 5,3 2,37,3 2,5*5,5 - C,i
7,3
+ A3,2T5,3+ A3,3T7,3+ 0 + A3,6T 7,5+ ° IJ
3,5 T 0 + 0 ,13 »3+ + \,4T3,5+A4,5T3.5+ ° + A4,7T3.7 + ° + 0 ' C4
5,5 0 0 + A5 ,2T5 ,3+ + A5,4T3,5+ A 5,515,5+ A 5,6T 7»5+ 0 + A 5,8T5,7+ 0 - CJ
7,5 0 + 0 T + A6 »3/,3+ 0 + A6,5T5,5+ A6,6T7,5+ 0 + 0 + A6,9T7,7 ' C6
3,7 0 + 0 + 0 - c_ + A7,4T3,5+ 0 + 0 + A7,7T3,7+ A7 f8T5f7+ 0 /
5,7 0 + 0 + 0 + 0 + A8,5T5,5+ 0 + A8,7T3,7+ A 8,8T5,7+ A 8,9T9,7 ' ce
7,7 0 + 0 + 0 + ° + ° + A9,6T7,5+ 0 + A9,8T5,7+ A9,9T7,7 ■ s APPENDIX E
CORRESPONDENCE ENVIRONMENTAL PROTECTION AGENCY • STATE OF ILLINOIS William L. Blaser, Director • Richard B. Ogilvie, Governor
Augu*t 8, 1972
ENVIRONMENTAL IMPACT STATEMENT - Union Electric Co. Rurh Hand Power Plant
Department of the Army St. Loui< District, Corp* of Engineer 210 North 12th Street St. Lou?«, Mi«ouri 63101
Gentlemen:
The Permit Section of the Division of Water Pollution Control ha* reviewed the Draft Environmental Impact Statement for the Ru*h Hand Power Plant - Unit*- ] and 2 prepared by the U.S. Army Engineer DMrict, St. Lour, Mi«ouri, Hued on July 24, 1972
Ba*-ed on our review, we believe the report to contain the proper information At thr time we do not believe there i* reason for concern over the a«h pond discharge providing that the drcharge r baffled to prevent floating material from reaching the effluent and providing that the a»h i* kept covered with water to prevent the formation of acetic condition*- in the pond.
Very truly your,
DIVISION OF WATER POLLUTION CONTROL
William H. Bu*ch, P.E. Manager Permit Section
JRL/lce CC-R.S. Nelle T H E STATE OF MISSOURI
Water Resources Board P.O.Box 271 CLIFFORD L. SUMMERS Department of Business and Administration Area Code 314 Acting Executive Director Telephone 635-9251 JEFFERSON CITY, MISSOURI 65101 August 9, 1972
Colonel Guy E. Jester District Engineer St. Louis District, Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101
Dear Colonel Jester:
The Draft Environmental Statement for Rush Island Power Plant - Units 1 & 2, Union Electric Company has been reviewed.
The statement is considered to be adequate and to cover the local environment in a manner sufficient to permit intelligent appraisal of those matters surrounding the construction and operation of the power plant.
The Union Electric Company proposal has been programmed to eliminate or minimize the environmental impacts that might be caused by the project.
Sincerely,
Clifrord L. Summers Acting Executive Director
CLSirjk
Chairman Vice-Chairman HAYSLER A. POAGUE JOSEPH R. SNYDER Clinton Gallatin ROBERT R. BRIGHT EARL R. SCHULTZ CHARLES A. HANNEGAN Lampe 1512 Kurte Lane 238 Randolph Cape Giraideau Ferguson REGIONAL omecs CHAIRMAN Theodore G. Scott. Buffalo
State Office Building VICE CHAIRMAN 615 Eavt 13th Street John W. Barnhart, Independence Kansas City, Missouri 64106 Telephone 8I6 274-6675 Thomas J. Fischer, M.D., Hannibal 8460 Watson Road S t. Lo u is, M issouri 0 3 119 Cluiencs’ C. Houk, Potosi -Telephone 314 84 10.8 Jefferson County Union Electric Company Rush Island Power Plant August 10, 1972 Colonel Guy E. Jester District Engineer S t. Louis D is t r ic t , Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 Dear Colonel Jeste r: We have reviewed the d raft Environmental Impact Statement for the proposed Rush Island Power Plant. Our review was limited to the expected effects on water quality and we believe that a ll of the conditions previously given to Union Electric by this office are included in the draft. We have no other comments. Yours truly, Jack K. Smith Executive Secretary JKS/JPO/ls cc: St. Louis Regional Office Environmental Protection Agency EXECUTIVE OFFICE OF THE PRESIDENT OFFICE OF ECONOMIC Region VII 911 Walnut Street OPPORTUNITY Kansas City, Missouri 64106 August 14, 1972 IN REPLY REFER TO: . Guy E. Jester, Colonel, CE Department of the Army St. Louis District, Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 Dear Colonel Jester: We have reviewed your draft Environmental Impact Statement concerning the Rush Island Power Plant to be built by Union Electric. Our office concluded after a review of the Statement of Findings that the Rush Island Power Plant would probably have very little impact on poverty in Jefferson County. It appears that only a few, if any, low- income persons might obtain permanent jobs as a result of this under taking. There is a possibility that some low-income people may get temporary jobs during the construction of the plant (if labor union rules allow it). The only long-term benefit that would appear to benefit low-income residents of Jefferson County would be the increased taxes received from Union Electric by Jefferson County. This could indirectly benefit low-income residents if the increased revenues were to convince elected officials they could afford to improve county services to the low-income population. No detrimental impact to the low-income population would appear to result from this undertaking. We are forwarding the Environmental Statement to our grantee, Jefferson- Franklin Community Action Corporation located at the Court House, Hillsboro, Missouri, for their review. They may have comments concern- these direct to your office. cc: Ronald Ravenscraft Dean Tyler, Field Representative United S tates D epartment of Agriculture FOREST SERVICE Northeastern A rea, State A Private Forestry 6S16 Market Street, Upper Darby, Pa. 19032 REPLY TO: 1940 August 17, 1972 SUBJECT: Draft Environmental Statement, Rush Island Power Plant Units 1 and 2, Union Electric Company TO: Colonel Guy E. Jester Department of the Army St. Louis District, Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 We have reviewed the draft environmental statement for Rush Irland Power Plant, Units 1 and 2, Union Electric Company. Present sulfur content of coal to be used at Rush Island is one percent, however, this will probably raise to two or three percent in the next few years. Provisions should be made for removal of sulfur dioxide should the sulfur content of coal increase. Crushed limestone has been used by other companies and it apparently works very well. Even though there seems to be little forest land involved in the plant site, efforts should be made to monitor forest land adjacent to the site, especially in the southern sector, to detect any vegetation damage from stack emission once the plant is in operation. Corrective action should be taken immediately if vegetation damage is detected. We note that several pages are devoted to discussion of effects on nearby areas of Missouri, but little is said about effects in Illinois, which could be affected by emissions from the plant. Comments from the Illinois Department of Conservation should be reviewed for reference 1" n thocp n ffp r fc Assistant Director Environmental Protection A Improvement LEAGUE OF WOMEN VOTERS OF MISSOURI 2138 Woodsoa Road % HAirisoa 9-6161 St. Loais, Missouri 63114 I HAirisoB 9*6162 Affili fed with the League of Women Voters of the United States August 23, 1972 Colonel Guy Jester District Engineer, St. Louis District U. S. A r m y Corps of Engineers 210 No. Twelfth St. St. Louis, Missouri 63101 Dear Colonel Jester: W e have received the Environmental Statement relating to Union Electric C o m p a n y ' s proposed Ru s h Island P o w e r Plant. It appears that careful consideration has been given to the environmental impact of the project. The p r i m e concern of the League of W o m e n Voters wa s the ecological effects of heated water being cycled back into the supplying streams. W e find no objection to Union Electric's proposal since future changes will be m a d e both to take care of emission from the stacks and by alterations to the water cooling and intake systems if it becomes necessary. T hank you for giving us this opportunity to c o m m e n t . Sincerely, L yj. / l c u l l ■■ Mrs. Harold C. Walters, President Mrs. J. Russell Wilson, E S W / B W / g d Co-Chairman, Environmental Quality U. S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION Region Seven P. 0. Box 7186 - Country Club Station Kansas City, Missouri 64113 August 24, 1972 IN REPLY REFER TO: 07-00-2.2 Colonel Guy E. Jester District Engineer St. Louis District Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 Dear Colonel Jester: Your Draft Environmental Impact Statement for a "Proposed Fossil- Fuel Power Plant, Rush Island, Jefferson County, Missouri" trans mitted to the Federal Highway Administration has been coordinated with the Office of the Secretary's Representative, Region 7, and reviewed by this office. The Statement adequately documents the effects the project will have on resources under the jurisdiction of the Federal Highway Administration, and we feel the project will not adversely affect any of our highway programs. The Federal Aviation Administration granted a permit for the 700- foot stack on July 15, 1971, and has no further comments on the Draft Statement. In discussions between Mr. T. P. Corbett of your office and Mr. B. A. Halver of this office, it was agreed that the Corps of En gineers would hand deliver a copy of the Draft Statement to the Coast Guard, 2nd District, St. Louis, so they could respond directly to you on the Statement. Thank you for the opportunity to review this Statement. Sincerely yours, John B . Kemp Regional Highway Administrator MISSOURI DEPARTMENT OR CONSERVATION 2901 Norih Ten Mile Drive • Jefferson City. Missouri 05101 1\ O. Box 180 - Telephone 514 89 5-2620 CARL R. NO REN. Director August 24, 1972 Colonel Guy E. Jester District Engineer U. S. A r m y Engineer District - St. Louis Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 D e a r Colonel Jester: Our personnel have completed a review of the Draft Environmental Impact Statement, prepared by the St. Louis Corps of Engineers District, for the R u s h Island P o w e r Plant--Units 1 and 2, Union Electric Company. The statement appears to be complete and does include an analysis of the expected adverse effects on the aquatic biota. W e would offer these comments: A. Page 3-11, Paragraph 1, Line 6 - The statement is confusing. "During an abnormally high temper ature summer, the maximum river temperature standard (column 3 of the above tabulation) might be exceeded less than one percent of the time". Column 2 is the temperature standard, not column 3. The temperature standard listed in the table is greater than the m a x i m u m recorded temperature. Will power production be reduced or will supple mental cooling be available at times w h e n the standards would be exceeded? B. Potential losses to the aquatic resources are still of concern to us. Provision should be made for the operating agency to routinely monitor the intake screens to document fish losses at that point. Findings o COMMISSION JIM TOM BLAIR ROBERT G. DELANEY WILLIAM A. STARK HARRY MILLS St. Louis Charleston Bethany Clinton Colonel Guy E. Jester August 24, 1972 P a g e 2 should be periodically reported to the Corps of Engineers, our department, and the State Attorney General's office so the state can be reimbursed for damages to the aquatic resource. Such monitoring should be continued until a satisfactory s y s t e m can be installed to prevent loss of fish on the intake screens. The monitoring system utilized should be mutually agreed on by the responsible agencies and the company. Too, there should be definite provisions for record auditing and on-site m e a s u r i n g checks to assure reporting accuracy. Fish values could be based on a generally recognized and accepted publication, such as "Monetary Values of Fishes" (Pollution Committee, Southern Division, A m e r i c a n Fisheries Society). Recognition should be given to the fact that values will change overtime and that updated figures will be needed. W e appreciate having the opportunity to comment on the Draft Environmental Statement. DIRECTOR cc: Attorney General B u r e a u of Sport Fisheries and Wildlife, T w i n Cities B u r e a u of Sport Fisheries and Wildlife, D e n v e r UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION VII 173S BALTIMORE - ROOM 349 KANSAS CITY. MISSOURI 6410& August 31, 1972 Colonel Guy E. Jester District Engineer U.S. Army Corps of Engineers St. Louis District 210 North 12th Street St. Louis, Missouri 63101 Dear Colonel Jester: We have reviewed the Draft Environmental Impact Statement for Rush Island Power Plant, Jefferson County, Missouri. The project consists of construction of a fossil-fuel power plant with two 600,000 kilowatts electrical generating units and appurtenant structures. Section 1 Project Description Page 1-6, Paragraph 3 : The paragraph provides insufficient information on flood protection measures. The data presented, "Fill ing the plant area to elevation 410 m.s.l. affords two foot freeboard against the '200 year flood' — the hypothetical maximum flood that might occur once in 200 years." is a restatement of the flood protection data in the previous Environmental Assessment Report, December 20, 1971. Reference is made to our letter dated March 23, 1972, in which we offered review comments on the assessment. Under Project Description, it was noted that, "Insufficient information on flood protection measures is provided. The statement should ... include a table of flood fre quencies either within this section or as an Appendix in order that the reviewer may determine the adequacy of the flood protection." These comments also apply to the Environmental Impact Statement. Page 1-10, Paragraph 1 : Another point not addressed in this Draft Environmental Impact Statement pertains to coal purchasing policies. Page 1-10 states that this facility will consume about 2.5 million tons of coal per year. The statement should include assurance that the purchase of low sulphur coal from Southern Illinois will not contribute to environmental degradation due to improper strip-mining practices. Page 1-10, Paragraph 6 : The paragraph states that up to 2400 tons per day of fly ash and bottom ash will be generated by the facility when both furnace units are operating. These solids, together with blowdown water, plant demineralizer system water, and coal pile drainage, will be conveyed to an adjacent 140-acre holding pond built in the floodplain alluvium. As indicated on Page 2-16, this alluvium is highly permeable. An analysis of fly ash composition should be made in order to determine the composition and quantities of chemical leachate which may enter the water table and river both through the soils and from the overflow pipe. Page 1-11, Paragraph 2 : In citing two specific items that may increase the initial life of the ash pond beyond 10 years, the para graph declares, "Second, as the life of the plant increases, the load factor (percent of time in operation) decreases." The meaning of this sentence seems unclear and should be explained in the final statement. Page 1-12, Paragraphs 5 and 6 : The impact statement indicates that all contaminated storm waters will drain directly to the ash pond. These collection points, for example, would be near equipment. Drains and miscellaneous waste lines inside the power house will also be collected in a separate system and discharged to the ash pond. This may be a satisfactory method of treating these wastes, depending upon the type of contamination. If storm water or floor drain waste contain oil or grease, this material could float through the ash pond and be discharged directly to the river. An oil and grease separator installed on these lines before discharge to the ash pond would correct this situation. Electrical Transmission System Page 1-13: The Final Environmental Impact Statement should discuss the environmental impacts of the transmission lines which will be built from the plant. The construction of the plant necessitates the need for the lines. Impacts which should be discussed include: a. The type of land being used for the lines. b. The methods of construction to be used such as clear cutting, bulldozing, etc. c. Possible interference with radio and television reception in the area. d. Ozone emission from the power lines and its effect on vegeta tion in the area near the lines. Section 2 Environmental Setting Without the Project Page 2-8, Paragraph 2 : It is not always accurate to assume that SO2 concentrations in two different areas of similar population density and relative location to a metropolitan area are the same or similar. Also SO2 is not the only parameter used in estimating ground level concentrations. Measurements of the SO2 concentrations should be made in the immediate vicinity of the proposed Rush Island plant. Figure 2-4 is referenced as a location map showing continuous ambient air monitoring stations maintained by Union Electric Company, the City of St. Louis and St. Louis County air quality control agencies. The Environmental Assessment Report states, "Inspection of the map indicates that no monitoring station exists or is planned in the immediate vicinity of the plant." Air flows in the evening tend to be from higher elevations into the river valleys and during days of low ventilation, pollutant emissions would remain near the source. Because of this phenomenon, an air quality monitoring station should be established in close proximity to the plant. Page 2-9, Paragraph 5 ; This paragraph states that emissions from tall stacks penetrate inversions in the lower 500 feet of the atmosphere and the inversions will often act to reduce the ground level concentra tion of emissions released from such sources. This is not usually the case. Although the initial thrust of the plume inversion may cause the emissions to rise above the inversion layer, the cooler air above the layer forces the pollutants back down and adds to the concentration build-up. Numerous observations have supported this. Section 3 Environmental Impact of the Proposed Action Page 3-1, Paragraph 2 : The expected emission rate for NO is omitted and should be included in the table. Although the State of Missouri has no emission regulations for nitrogen dioxides at present, regulations will either be adopted by the State or promulgated by the Federal government before October of 1972. A 4 - O Page 3-3, Paragraph 1 : The expected particulate emission from the stacks is stated to be 0.06 per million BTU of heat to the plant. It would clarify the statement if units are added to the numerical value. Page 3-3, Paragraph 5; The paragraph states that mercury emissions from the Rush Island plant will probably not be significant. Equally important is the total ground level concentration. Current ground level concentrations should be measured for mercury as well as the other pollutants. Page 3-8, Paragraph 3: The statement declares, "... the plant (Rush Island) would probably reinforce the rising rate of waterborne traffic in the area of the plant." To meet the requirements of the Marine Sanitation Device Standards, 37 CFR, the mooring facility may be required to provide facilities for disposal of wastes from holding tanks of boats using the facility. Page 3-9, Paragraph 3: The paragraph notes, "The outfall will be located offshore so that heated water discharged will be mixed with the main channel river flow." The distance offshore of the outfall is not specified. Although an estimation can be made with the scale in Figure 1-18, the distance in feet from the bank should be given in the final statement. Thermal Effects Page 3-10 to 3-12; The discussion on the thermal effects was well done, especially Appendix C explaining present and proposed thermal criteria. Only a few points were not fully explained. The report did not explain the type or basis of the mathematical modeling techniques used to determine temperature distribution patterns. The report did not state to what extent the mathematical model has been verified by studies on existing plants. Assuming that the modeling techniques are valid, the critical months evaluations show a zone where temperatures exceed the 5°F rise criteria. Figure 3-7 states that the 5°F rise plume extends 500 feet downstream during May, July and August. This is neither verified nor refuted in the detailed isotherm drawings although it appears to be plausible for May and June. The August isotherm drawing indicates that the 5°F rise plume would extend at least 1000 feet downstream. Com pliance or noncompliance of the thermal discharge therefore depends on the mixing zone which will be set by the States involved. Finally, the significant item missing from the statement was an evaluation of the cumulative thermal loadings on the Mississippi River from above the metropolitan St. Louis area to a point below the Rush Island plant. Six power plants listed in Figure 3-18 are located along the Mississippi in this area as well as the other municipal and industrial discharges. This point should be investigated and included in the final statement. Page 3-13, Paragraph 3 : The statement assures, "The final reports on the aquatic studies conducted at the Sioux plant and the site of the proposed Rush Island plant will be available after September 1, 1972." Page 3-16, Paragraph 2, also admits, "A complete analysis of the intake screen study is not yet completed." Additional information acquired after completion of the aquatic studies should be included in the final statement. Page 3-18, Paragraph 1; "Some indirect effects may result from cumulative biological, chemical and physical changes which may result in the alteration of the existing ecosystem. Whether these subtle effects will detract from, or actually enhance, the present situation is not predictable at this time." A continuing ecological monitoring system should be considered by Union Electric in order to determine any alteration of the existing ecosystem. If these effects are found to detract from the present quality of the environment, corrective measures should be planned. Page 3-21, Paragraph 1 : In reference to chemical parameters for the Rush Island plant, the paragraph asserts, "... based on a limited sampling of existing Union Electric power plants, it is expected that the Missouri and Illinois effluent standards will be met with the proposed details of the Rush Island plant design. If necessary, changes in design will be made as information is developed to assure that the standards are met." Additional information as to the proposed "changes in design" which might be undertaken should be included in the final statement. , Page 3-22, Paragraph 3 : "Herbicides will only be used to control weeds in construction storage areas which will involve less than two percent of the plant site or ten acres." The statement should also indicate what measures will be taken to prevent damage to the natural environment, including the Mississippi River. Page 3-27, Paragraph 3 : The paragraph indicates that construction debris and trash will be removed from the plant site for proper disposal or buried in a sanitary landfill on the plant site. Recently enacted Senate Bill No. 387 of the 76th General Assembly states the requirements for solid waste management in Missouri. These requirements include a permit system administered by the Division of Health for all solid waste processing and disposal facilities in the State. We appreciate the opportunity to review the draft statement. Please provide this office with a copy of the Final Environmental Impact Statement with review comments at the same time it is submitted to the President's Council on Environmental Quality. Very truly yours, l ..... Charles H. Hajinia(rr\ Chief, Program * \ Planning Branch ^ COALITION FOR THE ENVIRONMENT ST. LOUIS REGION X515 DU MAR BOULEVARD • S I. LOUIS. MISSOURI *> > I 21 S 14- 991-1850 August 25, 1972 Colonel Guy E. Jester, District Engineer St. Louis District, Corps of Engineers 210 North 19th Street St. Louis, Missouri 63101 Dear Colonel Jester: In reference to your letter of July 26, 1972 asking the Coalition for the Environment to comment on the Draft Environmental Impact Statement on the proposed Rush Island Power Plant, I have enclosed copies of comments received from two Coalition Board members. Thank-you for your cooperation with the Coalition. Sincerely yours, Charles A. Schweighauser Executive Director CAS/dz Enclosures Re: Environmental Statement on the Rush Island Power Plant, Units 1 & 2 Three points were unclear to me in the report. First, regarding alternate sources of power, would it be possible to aim for a nuclear power plant by 1979-1980, and to manage in the interim with an expansion of other sources (perhaps a mixture of gas, some borrowed power, etc.)? The report does not make clear if commitment to the Rush Island plan precludes transition to the use of nuclear power, or if it itself can be a limited, interim measure. Second, regarding the question of alternate sites, while it is stated that none show "substantial advantages", would some be in a less conspicuous area (perhaps off the flood plain?). Third, regarding thermal pollution, the report seems very uncertain about what the extent or effects would be. I'm not sure why, but shouldn't the estimates go further than a prelude to experimentation? Maybe with better information, the plant could be upstream from the confluence? S incerely, bavia scniessinger Chairman, Water Committee Coalition for the Environment DS/cj Aug. 24, 1972 To Charles Schwelghauser: Comments on the COE Rush Island Impact Statement Applicable statutes, 1899 Refuse Act and NEPA, place responsibilities on the Corps of Engineers which cover the general stewardship of rivers, the protection of their water quality and natural features. The problem posed by this project involves Federal responsibilities in assessing the merits of a private development on the Mississippi River. The Corps' responsibilities cover the river and its environs, not the community’s power needs. Therefore, the project should be evaluated by the Corps in terms of its impact on the river, not in terms of electrical power needs in the community. That job, perhaps, belongs with the Federal Power Commission. Yet, the Corps has undertaken to justify the project on grounds other than consideration of the river. Now, if the project were a Federal rather than private one the situation would be changed to the contrary. For example, if the Corps were charged by Congress with developing a new power plant to meet rising electrical demands, then it would incur responsibilities for assessing the economic, social, mineralogical aspects, etc. Of course, this is ridiculous; the Corps doesn't do that kind of work. That work is left to the AEC, the FPC, the TVA, and limited in scope within the Corps to the development of hydropower. This impact statement, then, puts the Corps' decision on a basis wholly outside the Corps' perview. Although this kind of evaluation might come appropriately from the FPC, as jLt is the legitimate review agency, the Corps' treatment should be left to an examination of the impact this project would have on the river. There will be times when we would expect an agency to look beyond its own discipline but only, I think, in consideration of its own projects. My comments do not concern the merits of the Rush Island project, itself, as I have not studied this aspect of the problem, but only the framework in which the impact statement was developed. If the Corps' responsibility for issuing a construction permit constitutes an anomaly in the law, then the situation should be identified and set forth clearly in a preface or introductory remark. A legitimate question remains unanswered: Is the permit issuance a major federal action requiring an analysis of the project impact from all aspects? Moreover, do applications for private development place a responsibility on the public agency for developing alternatives? And if so, does this not place an impossible burden upon the Corps of Engineers— namely, for assessing the merits and full range of impacts of every type of development that might be proposed, which might require a permit? This places the Corps in the position of being a super-agency rather than a corps of engineers. /s/ Jerry Sugerman DEPARTMENT OF TRANSPORTATION UNITED STATES COAST GUARD SECOND COAST GUARD DISTRICT FEDERAL BLDG. 1520 MARKET ST. ST. LOUIS. MO. 63103 Tel. ^14-622-4607 3270 30 August 1972 Mr. Robert R. Parsons Chief, Operations Division St. Louis District, Corps of Engineers 210 North 12th Boulevard St. Louis, Missouri 6 3 IOI Re: Draft Environmental Statement Proposed Fo ssil-fu el Power Plant Rush Island, Jefferson County, Missouri Prepared by U. S. Army Engineer D istric t, St. Louis 24 July 1972 Dear Mr. Parsons: The referenced environmental statement has been reviewed. We conclude that this proposed project w ill not affect any matters under jurisdiction of the U. S. Coast Guard. Accordingly, the Commander, Second Coast Guard D istric t, has no comment.to offer. The opportunity to review th is environmental statement i s appreciated. Sincerely, Second Coast Guard D istrict By direction of the D istric t Commander Copy to: Regional Administrator, FHWA Region V, Attention: Mr. B. Halver DOT Secretarial Representative, 601 East 12th St., Kansas City, Mo. 64106 DEPARTMENT OF AGRICULTURE OFFICE OF THE SECRETARY WASHINGTON. D. C. 20250 AUG 3 0 1972 Col. Guy E. Jester District Engineer Corps of Engineers St. Louis District 210 North 12th Street St. Louis, Missouri 63101 Dear Col. Jester: We have had the draft environmental impact statement for the Union Electric Company's Rush Island Power Plant, Units 1 and 2, in Missouri, reviewed in the relevant agencies of the Depart ment of Agriculture. Comments from the Agricultural Research Service, the Economic Research Service, the Forest Service, and the Soil Conservation Service, all agencies of the Department, are enclosed. 5inroy'o'l\/ T. C. BYERLY Coordinator, Environmental Quality Activities Enclosures ARS Comments on Draft Environmental Statement on Rush Island Power Plant- Units 1 & 2, Union Electric Company ARS has reviewed this environmental statement and finds the documentation satisfactory in regard to the siting, construction, and operation of the Rush Island Power Plant itself. It is noted, however, that the plant will consume annually some 2.5 million tons of coal which is mined and transported from mines in the DeSoto, Illinois area, approximately 110 miles southeast of the site. There is nothing in this statement to indicate the environmental impact of these mining operations which, apparently, are an integral part of the proposed power generation system. ERS Comments on the Draft Environmental Statement, Rush Island Power Plant, Units 1 and 2, Missouri The Statement could be improved by giving more consideration to two aspects of the environment with the project and the adverse environmental effects of the project. First, no mention is made of the type of mining used to obtain the coal used by the plant. If strip mining is employed, some discussion of the adverse effect of this activity should be included in the Statement. Secondly, the report does not provide a clear estimate of the probability of flooding at the plant site. This probability and the asso ciated adverse effect of waste material being carried out of the ash pond into the river should be acknowledged in the Statement. UNITED STATES DEPARTMENT OF AGRICULTURE FOREST SERVICE Washington, D. C. 20250 Re: Rush Island Power Plant - unit 1 and 2 Electric transmission impact will be felt beyond the confines of the power plant area. In order for the reader to visualize the impact, the statement should contain more specific information regarding proposed transmission lines. Criteria that will be employed in locating, designing and constructing lines to assure adequate considera tion of environmental values should also be made known. If possible, costs that are associated with environmental protection in transmission line construction should be presented. For example, in the clearing of rights-of-way, what are the company's intentions with respect to utilization of non-air polluting practices alternative to open burning - what precautions will be taken to minimize soil movement and sediment production, esthetic and wildlife impacts? UNITED STATES DEPARTMENT OF AGRICULTURE Soil Conservation Service Comments on Rush Isla n d Power P lan t Draft Environmental Statement The control of sedimentation during construction is adequately covered. It is stated that after construction a large portion w ill be allowed to return to a wild or natural state. Some control should be exercised to prevent a dense overstory from shading out a ll grasses. If grass is not present, small gullies w ill likely form from run-off water from parking lots, building roofs and the like. Although about 300 acres of cropland is being removed from production, periodic flooding of the lands prevent a crop harvest each year. EAST-WEST GATEWAY COORDINATING COUNCIL 720 OLIVE STREET, SUITE 2110 . ST. LOUIS, MISSOURI 63101 AREA COD E 618 274 2750 . AREA CODE 314 421 4220 Board of Directors VICE-CHAIRMAN C H A I R M A N T R E A S U R E R Lawrence K. Roos Francis J. Foley Douglas Soschert Sup+rvi'ior CAoirmo* P r e siding Judge Sf. louix County Sf. Clair County Board St, Chariot County August 30, 1972 A. J. Cervantes Mayor City of St. Louis James E. Williams, Sr. Moyor City of Bast St. Louis Colonel Guy E. Jester Nelson Hagnauer Choirmon Department of the Army fioord of Supervisors Madison County St. Louis District Joseph L. Badaracco Corps of Engineers P r e s i d e n t , Board of A ld e r m e n City of St. Louis 210 North 12th Street Erwin Plegge President. Southwestern St. Louis, Missouri 63101 I l l i n o i s Council of Mayors Harold L. Dielmann P r e s i d e n t , St, touts County Dear Col. Jester: M u n i c i p a l iooguo John Bellcoff V'f>',dent, Southwestern libnois M etropolitan In reference to your letter requesting our comments on the draft Area Plonmng Commission Environmental Impact Statement of the proposed construction of Marvin Leonard Presiding Judge Jefferson County a fossil-fuel plant at Rush Island, Jefferson County, Missouri, Roy Smith we are pleased to have an opportunity to review this document. V c* President, South western ' ''moil Council of Mayors Ralph Smith The staff has offered the following comments: Presiding Judge hanklm County Richard Ruff Chairman 1. It appears that adequate information has been presented fioord of Commissioners Monroe County justifying both the need at this time for additional electrical Edward J Delmore, Jr. generating facilities and the proposed site for the facilities. Cno-rmon. Bi-State £> r-’-'.bifft N. Hunter * Engineer, M issouri 2. However, it is difficult to comment on the proposed Highwoy Commission facilities without a complete understanding of the context h * hard H. Golterman < ~trof Engineer, Illinois of the proposal. Therefore, we would raise the following 0 vision of Highwayt Gene Sally questions: u» e-ecfor, M is s o u r i Donartment of C o m m u n it y Affairs a. The City of St. Louis is now" conducting a pilot Robert Lehnhausen D -ector, I l l i n o i s program which utilizes solid waste as fuel to C^nartment of loco/ Gcivernmonfoi A f f o i r s generate electrical power. Will the Rush Island plant be convertible to that use if the pilot REGIONAL CITIZENS Rev. James L. Cummings program is successful? Htmry Eversman. Jr. Rev. John Q. Owens. Jr Roy W. Jordan Dr Rosetta Wheadon L»r. George A. M a m m o n EXECUTIVE DIRECTOR Eugene G. Moody Colonel Guy E. Jester - Page two August 30, 1972 b. What is the anticipated environmental impact from all four of the 600 million watt units? 3. In addition, this agency feels that an environmental assessment of a single power generating facility within a metropolitan area has relatively little meaning. As part of the planning process for the next power-generating facility, we would strongly urge that the applicant prepare a plan for their entire metropolitan area system. This plan should evaluate the environmental impact of the present system; describe the need for additional facilities over a reasonable planning period; evaluate the impact of that anticipated system; and describe the advantages of the proposed system over other potential alternative patterns. This agency is prepared to work with the applicant, if necessary, to assist them in this effort. W e hope the above comments will be helpful, and if you need additional assistance, please feel free to contact us. Sincerely, E Executive Director E G M / r s STATE OF MISSOURI DEPARTMENT OF COMMUNITY AFFAIRS WARREN E. HEARNES 505 MISSOURI BOUUEVARO GOVERNOR JEFFERSON CITY, MISSOURI 65101 September 18, 1972 Colonel Guy E. Jester, CE District Engineer Dept, of the Army STL District, Corp of Engineers 210 North Twelfth Street St. Louis, Missouri 63101 Re: Draft Environmental Impact Statement for Construction of a Fossil-Fuel Power Plant and Appurtenant Structures In and Along the M ississip p i River at Rush Island DOCA 72070026 Dear Colonel Jester: The draft Environmental Impact Statement for the above project has been received and reviewed by the State Clearinghouse in accordance with Office of Management and Budget Circular A-95 (Revised) and Section 102(2)(c) of the National Environmental Policy Act of 1969. The following comments were received in regard to said proj e c t : No other state agency reviewing the draft Environmental Impact Statement had comments to offer and further review is not required by the State Clearinghouse. / State Clearinghouse Coordinator TLR/lj cc: East-West Gateway Coordinating Council ini OFFICIAL STATE CONSERVATION AGENCIES COOPERATING: ILLINOIS IOWA MINNESOTA MISSOURI WISCONSIN Bureau of planning 555 Y/abasha St. Paul, Minnesota 55102 September 19* 1972 C o lo n el Guy 2 . Jester, District Engineer St. Louis District Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 Dear Colonel Jester: We have reviewed the draft Enviroiioental Impact Statement prepared by your s t a f f fo r U n its 1 and 2 of the proposed Rush Is la n d power p la n t. We com..end you for requiring measures in your "Statement of Findings" to protect fishery resources which could be dama ed by operation of the power plant. This type of action supports our view for the conservation of these important resources. We offer the fo llo w in g comments; (1) W’e support the views expressed by the Missouri Department of Conservation in its letter of August 2k, 1972, relative to therm al standards and r e c t if ic a t io n o f damages to fish e s on the in ta k e sc re e n s. 'While the problem of damages to fish e s on the intake screens may be mitigated, we can find no clear-cut d e f in it io n of what w ill be dene to r e c t if y damages to the river's ecosystem caused by the heated discharge water. Comments on page 6-2 o f the LI3 mention what could be done ra th e r than what w ill be done to prevent such damages. These actions should be clearly identified. (2 ) The analysis of fish destroyed on the intake screens of other Union Electric power plants (page 3-16) lists percentages of fish destroyed rather than actual numbers, '.'e believe that this section should be rewritten so that biologists would have a better idea of how many fish are killed at these power plants. Such a display would also be of more value when compensating for losses at Rush Island. (3 ) An overall review of the EIS clearly shows the degrading efiects of a variety of projects on the environment of the M ississippi River. For example, interstate highways have increased the rate of industrialization and urbanization; river stabilizing dikes have aided in the elimination of Rush Island as an island; flood Colonel Guy E. Jester, District Engineer St. Louis District Corps of Engineers 210 North 12th Street St. Louis, Missouri 6j}101 September 19, 1972 Fage 2 potentials will be increased because of power plant citing on the flood plain; barge traffic will be increased; and power lines will lace the countryside. All of these project effects serve to emphasize the need to more fully protect the natural resources and values of the Mississippi Fiver. (H) The EIS does not discuss the possible effects of future navigation develojments on the Rush Island power plant. For example, the current 12-foot channel project study may recommend 4 or 5 additional locks and dams below St. Louis as the best alternative to achieve 12-foot navigation depths. The 12-foot channel study is scheduled for completion in 1976 which coincides with the completion date of the Rush Island power plant. All of the possible effects stated in the EIS assume the continuance of a modified free-flowing river throughout the ^-year life of the power plant. Cur cueatiwn is this: what would be the effect of the power plant on the river if dams are constructed and the open-river section becomes a lake-type environment? If the area near Rush Island is impounded, the effect of the ^ower plant could be as damaging to fishery resources as the Sioux power plant. (5) Another issue not addressed in the EIS is the impact of decreased water flows from the Missouri River 3asin. V.'e understand that the Comprehensive 3asin Study for the Missouri River predicts a flow decrease from 5**|0G0 CFS to about **0,000 CFi>. If so, what effect would this decrease have on thermal patterns of the discharge water from Rush Island? (6) Section 1, pace 1-2, indicates that potential air-conditioning demand was a factor in the need for the Rush Island power plant. An alternative to this is the need for an electrical conservation policy by the Union Electric Company to attempt to reduce such demands. Such a policy is not discussed in the LIS. Without an electrical conservation policy, there appears to be no real choice other than to continually sacrifice portions of our rivers to provide for electrical power demands which, in the past, have been promoted by the electrical power industry. It may be that this is beyond the scope of the EIS, but restrictions on electrical power consumption are undoubtedly a part of our immediate future. (7) The lack of biological sampling conducted during the summer season when plant and animal life is at its peak could be decisive in determining the total effect of the power plant on these resources. Therefore, we recommend that the EIS be modified to include a continuing biological sampling program at all seasons of the year prior to plant construction and operation. The study results should be provided to the Missouri and Illinois Conservation Departments. Colonel Guy £. Lester, District Engineer St. Louis District Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 September 19, 1972 Page 3 (8) Although various alternate cooling methods ar. eliminated as unfeasible for one reason or another (page 3-7 and 5-8) the overwhelming opinion of professional biologists would be in favor of retaining the possi bility of an alternate cooling system for discharge water at Rush Island. It should be mentioned, too, that although spray canals are eliminated as an alternate cooling method because they are "somewhat theoretical", such a cooling system is currently being constructed at the £uad-cities nuclear power plant. This power plant is signifi cantly larger than the proposed Rush Island power plant. (9) The cumulative and long-term effects (page 6-1) of the power plant are not adequately discussed. This section should at least include a requirement for a long-term study to determine what the long-term effects would be. We appreciate the opportunity to comment on this SIS. We believe that efficiency and responsiveness of government is enhanced when environmental considerations form an integral part of decision-making from the time a project is first considered and not merely added after-thoughts. Sincerely yours, Chairman JHK:cea cc: Coordinator (2) United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 E R -7 2 /9 2 7 OCT 4 Dear Colonel Jester: This is in response to your letter of July 26, 1972, requesting our comments on the Corps of Engineers* draft statement, dated July 2H, 1972, on environmental con siderations for Rush Island Power Plant - Units 1 and 2, Jefferson County, Missouri. R e c r e a t io n The statement does not give adequate consideration to outdoor recreational opportunities in relation to the project. Since the proposed project is to be located along the river front.of the metropolitan center of St. Louis, consideration should be given to all possibilities that such an area might have, particularly those asso ciated with water oriented activities. If recreational opportunities are needed or exist or are being planned, we feel that they should be fully described and assessed. H istorical Features The proposed powerplant w ill not affect any existing or proposed unit of the National Park System or any site eligible for registration as a National Natural or Environmental Education Landmark. However, operation of the proposed plant may affect the historic and visual integrity of the Fort de Chartres National Historic Landmark located in Randolph County, Illin ois. This possibility should be discussed in the environmental statement. Also, the statement should indicate the steps that are being taken in this specific instance to assure compliance with Section 106 of the National H istoric Preservation Act of October 15, 1966. This section should recognize that a b ill, H.R. 13831 (Alexander), has been introduced in the 2nd Session of the 92nd Congress "to provide for a study of a proposed Huckleberry Finn National Recreational Area on the Lower M ississippi River, and for other purposes." The b ill would direct the Secretary of the Interior, through the National Park Service, to undertake a study of the M ississippi River, its islands and adjacent lands between the mouth of the Missouri River and the Gulf of Mexico for the purpose of determining the desirability and feasibility of establishing such an area. We suggest that the final statement show evidence of consultation with the State Liaison Officers for Historic Preservation in Missouri and Illin ois. Their addresses are given below. Director, Missouri State Park Board Post O ffice Box 176 1204 Jefferson Building Jefferson City, Missouri D irector, Department of Conservation 102 State Office Building 400 South Spring Street Springfield, Illinois 62706 Archeological Features According to page 2-14, an archeological survey was not conducted and the Missouri State H istorical Survey and Planning•O ffice did not comment when informed of the permit application. This is unfortunate and since the site preparation is in an advance stage, the impacts of the Rush Island Power Plant on archeological resources w ill never be known. Topography and Geology It is recognized on page 2-16 that the site is located within the Ste. Genevieve fault region and within an area of moderate seismic risk. We do not think that this paragraph adequately describes the seismic potential. We think that more information should be developed con cerning these potential geologic hazards and any antici pated remedial development measures pertinent to such h a z a r d s . Animal Life and Vegetation We suggest that the third paragraph on page 2-29 be expanded to include the densities of the listed w ildlife species and the habitats on which they are dependent. Land Loss and Land Use Changes At or Near the Project Site The third paragraph on page 3-H should be modified to more accurately reflect the loss of w ildlife habitat. Since the croplands, because of their seasonal cover and feeding benefits, should also be classified as w ildlife habitat, it does not appear that more w ildlife cover w ill be available after the plant is operational than was available previously. Important game species such as the bobwhite could be adversely affected by this loss of cropland habitat. The third paragraph on page 2-29 should also include the important species of bobwhite. A more detailed description of the proposed management plan for the 150 acres, which w ill be allowed to return to a natural or wild state, should be given. The expected w ildlife uses of these lands and the amount of hunting expected should be described. Improper positioning of new cover with surrounding lands and project structures could greatly diminish the value of the land for w ildlife. Assistance in developing plans for w ildlife management should be obtained from appropriate Federal or State conservation agencies. Impact of the Plant on W ildlife The evidence referenced to on page 3-9 should be identified and the data presented in the third and fourth paragraphs should be expanded to an evaluation of the expected changes in population dynamics of shad or other fish species. The other fish, eggs, and larvae being entrained should be identified and the impact described. The impacts on the life stages of fish and other aquatic life such as planktonic flora and fauna, that are carried into the thermal plume, should also be evaluated. We think that the positioning of the downstream thermal plume should be established in order that this entrainment of plankton and fish can be evaluated. We are pleased that the applicant is v/illing to modify project intake facilities and to provide supplemental water cooling devices, if required to protect fish resources. In this regard we suggest that the applicant consult with Federal and State agencies in assessing project effects on fish and implementing any needed protective modifications of structures and operation. These agencies should be listed in this section of the final environmental statement. This section should also describe the plant's effect on river icing and the associated impacts on fish and w ildlife resources. For example, are waterfowl likely to over winter in the area if there is a lack of ice cover? Cumulative Impacts The cumulative environmental impacts of this plant, other powerplants and other industry on the river on the water and land should be described. This discussion should include effects on aquatic life resulting from thermal and chemical discharges and entrainment and entrapment at the intakes. It should also include the effects of develop ment and transport of the coal from the mine to the plant. The cumulative impacts of all facilities could be greater than the separate impacts of each facility evaluated alone. Intake Screens We believe that the design velocity of approximately 1 fps at the intake screens is too high to maintain acceptable levels of entrainment and entrapment damages to fish and other aquatic life. An approach velocity of approximately 0.5 fps is recommended by this Depart ment. We further suggest that the final statement recognize that some fish which come in contact with the screen or trash racks w ill escape but w ill ultimately die of injury-related infection, disease, or predation. Thermal Stress The first paragraph on page 3-19 should include a dis cussion of spawning occurrence upstream from the plant and the resulting larvale fish downstream migration. Most larval fish are dependent on the currents after hatching and if they are transported to mid-stream and into the plume, m ortality from thermal shodk may be high. Scenic and Esthetic Impact The draft environmental statement does not adequately describe the transmission lines associated with the proposed powerplant nor assess their environmental impacts. It does not give the width of rights-of-way, procedures for maintaining the rights-of-way, permitted land uses of the rights-of-way, the appearance and spacing of the towers, and ecological impacts resulting from construction and operation of the transmission lines. Graphic material portraying transmission line routing and appearance should also be included. In regard to minimizing the impacts of the transmission lines, we suggest the applicant follow the guidelines of the 1970 joint Agriculture - Interior publication "Environmental Criteria for E lectric Transmission Systems" pertaining to transmission system design, construction and maintenance. Hydrological Impact The statement appears to give appropriate consideration to existing hydrologic conditions and to the probable impact of the proposed action on those conditions. However, some clarification seems desirable for the last sentence on page 3-25. It is not clear if the statement refers to a flood of 1,080,000 cfs or to one of lesser flow. The statement should be revised to ". . 3 inches on the occurrence of a 200-year flood" if this is the case. Alternatives to the Proposed Action The criteria used in rejecting the alternatives do not adequately include the consideration of environmental impacts. Considerations of these impacts are needed to compare the impacts of the proposed project to the alternatives. Relationship Between Local Short-Term Uses of Man’s Environment and the Maintenance and Enhancement of Long- Term Productivity This section should be expanded to quantify the annual production of natural renewable resources, such as fish and w ildlife, which w ill be lost or gained during the short term and long term. Irreversible and Irretrievable Commitment of Resources This section should be expanded to include any annual production losses of fish and w ildlife resources. Annual production of a renewable natural resource is generally irretrievable. We hope these comments w ill be helpful to you in the preparation of the final environmental statement. Colonel Guy E. Jester D istrict Engineer Corps of Engineers Department of the Army 210 North 12th Street St. Louis, Missouri 63101 ENVIRONMENTAL PROTECTION AGENCY • STATE OF ILLINOIS William L. Blaser. Director Richard B. Ogilvie, Governor October 20, 1972 Department of the Army St. Louis District, Corps of Engineers 210 North 12th Street St. Louis, Missouri 63101 Ref: LMSOD-NP Gentlemen: SUBJECT: Environmental Impact Statement Union Electric Company Rush Island Plant In view of our comments concerning the Rush Island Plant which were generated in August having not been incorporated in the State of Illinois Natural Resources Development Board comments, we have been asked to provide our input directly to you. The draft Environmental Impact Statement for the planned Union Electric Company Rush Island Power Plant has been reviewed in detail at the Division of Air Pollution Control. Appendix A of the Environmental Impact Statement establishes that the Rush Island Power Plant will not be a "new stationary source" for purposes of determination of emission standards compliance; it establishes the.plant as an "existing" source. As an existing stationary source with low-sulfur coal burned exclusively, the expected emission rates fall within State of Illinois allowable rates. The impact statement indicates that low sulfur fuel reserves will probably be depleted in the future, resulting in a need to use coal of higher sulfur content. Prior to reaching a sulfur dioxide emission exceeding the Missouri Allowable Emission rate of 2.3 pounds per million btu heat input, sulfur dioxide control equipment should be installed. Such action will also insure that the State of Illinois emission limitations will not be exceeded. It should also be realized that some curtailment of plant operation may be imposed during episodes of atmospheric stagnation affecting the St. Louis region. Such action w i l l only be taken in conjunction with direction of the Technical Coordinating Committee of the St. Louis Interstate Air Quality Control Region. Respectfully, 'John J. Roberts, Manager Division of Air Pollution Control LFVrjab cc: Natural Resources Development Board (James Webb) Illinois Environmental Protection Agency (R. S. Nelle)