| Marine and Freshwater Ecosystems | 867 Bates Avenue
| Assessment and Management
| El Cerrito, California
| 94530
| |
Blue-green algae increase. The first omission is that the EIR makes no mention that the Lake Source Cooling (LSC) project will cause or increase nuisance blooms of blue-green algae (cyanobacteria), which could cover several miles of near shore water in summer. Release of large volumes of nutrient-rich water will, by definition, cause eutrophication in the shallow southern area of the lake near the shallow water discharge. This area is already above the NYSDEC standards for total phosphorous. Total algae as measured by chlorophyll a is already high, water transparency is poor, nitrate is very high, and the likelihood of increased nuisance blooms of blue-green algae in this region were not mentioned in the EIR. Near-surface discharge of bioavailable nutrients sucked up from deep water will inevitably worsen the situation.
Over reliance on math models. The EIR relies almost entirely on a mathematical model supported by a limited field-monitoring program. In other projects of this kind in which I have been involved an equal amount of time and money as was spent on models or field monitoring was spent on experimental measurements of lake effects. In particular, actual measurements of the production and kinds of algae produced by the waste were carried out in the lake and in the laboratory. In this way some more direct prediction of effects can be made instead of complete reliance on a mathematical model. Complex lake models are excellent tools for determining the relative differences between predict options, but are less useful in providing reliable absolute numbers and at predicting specific biological responses.
Underestimation of eutrophication. The eutrophication potential is underestimated in the EIR due to the method used to estimate the percentage increase in phosphorus, the algal growth-limiting nutrient in this lake. Underestimation of phosphorous automatically underestimates the amount of algae that will grow as a result of the project. The EIR states that the LSC project will increase total phosphorous (TP) in the area by an "insignificant" 3-7%. The EIR omits the fact that this calculation is based on using a very large area of the lake as a dilution basin. If a more reasonable local area of the southern basin had been used based on the plume model in the EIR, the LSC's percentage contribution to TP would rise by a factor of five. The other reason the EIR can claim that the LSC project has a small impact is that it ignores likely future reductions in TP loading from other sources such as city sewage plants. If both of these factors are considered, the contribution of the LSC project to the future TP budget of the area can rise to 30% and may exceed 50% in dry years. Such an increase would definitely be significant and must be considered and mitigated in the EIR. In addition, the bioavailable phosphorus added by the LSC will not be physically diluted: it will be quickly taken up by algae and used for growth.
Underestimation of algae produced. The EIR makes several assumptions about the conversion of TP to algae, the amount of algae that will be produced in an area, that considerably underestimate the amount of algae that will be produced. Alternate assumptions show that instead of increasing algae by only 2.5 µg/L (as chlorophyll a, EIR p. 2.3.3-25) over the summer, the LSC will actually increase the concentration to 40 µg/L above the current 6-8 µg/L - a huge increase in the several km2 region near the discharge plume. The EIR also totally neglects the surface drifting ability of blue-green algae. Adding feasible horizontal drift to the amount of drifting produced in the LSC plume could lead to dense local accumulations of blue-green algae that could shut down drinking water systems for weeks, kill livestock and pets that drink lake water and produce odors that would close beaches and shoreline cottages. These effects would only occur irregularly and not always at the same place but other lake users have found them intolerable. This aspect of lake eutrophication should be fully described and mitigation determined.
Pipe fouling effects. The EIR does not consider the effect on the lake of the organic and bacterial loads that occur following any type of inlet and outlet pipe cleaning. Cleaning with physical methods will result in the discharge of millions of fragmented zebra mussels and other fouling organisms. In addition, there are potential toxic effects since the proposed physical cleaning method may not work. Mussels and other fouling organisms have been difficult to remove in other piping systems and the EIR does not consider alternative mechanisms to prevent fouling. A common reliable method for removing pipe fouling is regular static chlorine addition. This would provide quite a toxic problem in this lake but is not addressed in the EIR. There was also no consideration of chronic or acute leaks in the heat exchanger system. This problem, the pollution of the once-through cooling water by toxic slimicides and heavy metals in the continually circulating water system, has proven very difficult to cure in other projects and is not addressed in the EIR
Temperature shock and ice reduction. Also omitted in the EIR are the typical consequences of warm water discharges to shallow water in winter. Fish become acclimated to the warmer winter water and when the system shuts down for maintenance or repair they die. Similar consequences occur due to the shifting of breeding cycles. These are typical environmental problems with thermal pollution and should be discussed and mitigated. Another typical effect of thermal pollution is decrease in ice cover in winter. The effect on ice reduction in the outflow area was not backed up by data in the EIR.
For the above reasons, the EIR should be rejected until such time as the full impacts of the LSC are considered. In particular, the eutrophication caused by a major nutrient discharge into a sensitive area must be described in terms of increases in nuisance blue-green algae. Mitigation for the inevitable consequences of eutrophication caused by the LSC should be detailed in the EIR. There is no mention of such mitigation in the EIR. In addition, serious attention should be given to ice cover, toxicity, pollution, and fish temperature shocks that will occur with the current pipe design and its maintenance.
Conclusion
Here is the complete Horne Report.
Short Resume
Alex J. Horne
Professor Of Ecological Engineering
University of California at Berkeley
22 December 1998
| Education: | Ph.D. 1969. University of Dundee, Scotland: Limnology & Oceanography. |
| B.Sc. 1964 University of Bristol, England: Biochemistry |
Experience: Dr. Horne has been the professor of Ecological Engineering at the Department of Civil & Environmental Engineering at the University of California since 1971. Initial research on algae in lakes, oceans, and wetlands in four continents included the first studies on the eutrophication of Clear Lake California (1970-78). He is an expert in biological and chemical aspects of water and aquatic management including pollution in lakes, reservoirs, wetlands, rivers, streams, estuaries and the open ocean. He has studied lakes, reservoirs, streams, wetlands and oceans in Africa, Antarctica, Alaska, Europe, Australia, Asia and N. & S. America. He has been principal investigator in over 30 research projects and acted as a major consultant or advisor in over 200 water-related projects in California, Nevada, Oregon, Washington, Colorado, Florida, New York, as well as Canada, Taiwan and Central America.
Areas of specialty include:
Recent projects:
Professional Affiliations: 14 scientific societies encompassing most aquatic organizations in the US and Europe.
Publications: 170+ publications in major scientific and engineering journals & reports including a best-selling textbook Limnology (the study of lakes, ponds, reservoirs, wetlands, rivers, streams, and estuaries).
CLDF 1998