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CRWA's comment letter
on the draft permit (PDF file)
Boston
Globe article about CRWA and CLF's work (9/11/04)
Boston
Globe editorial supporting CRWA and CLF's work (9/13/04)
Cambridge
Chronicle article (9/16/04) |
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How to take action
Written
comments on the Draft Permit may be submitted until October 14,
2004 to: George
Papadopoulos, U.S. EPA, 1 Congress Street - Suite 1100, Mailcode
CPE, Boston, MA 02114-2023. Telephone:
(617) 918-1579
Following
the close of the comment period, the Regional Administrator of the
EPA will issue a copy of the Final Permit decision to the applicant,
Mirant Kendall, L.L.C., and each person who has submitted written
comments of requested notice. |
Mirant Kendall Station
Fact Sheet
Mirant Kendall Station (MKS) is located just downstream of
the Longfellow Bridge in the lower Charles River Basin. The area is bordered
by the Esplanade and Department of Conservation and Recreation parkland,
houses the Community Boating facility and the BU and MIT boathouses, and is
used by rowers, kayakers, sailors, power boaters, windsurfers and
recreational anglers. To date, millions of dollars have been spent by the
cities of Cambridge and Boston to clean up the Charles.
To cool its turbines, MKS draws water from a canal
connected to the Charles River, uses the water to absorb heat, and then
dumps the heated water back into the river. This is called "once-through"
cooling.
EPA and DEP have issued a joint draft permit under the
Clean Water Act which would permit MKS to discharge heated water into the
Charles River at excessive levels. This discharge would effectively render
50% of the area of the river between the Museum of Science and Community
Boating (approximately 60 acres of surface area) a dead zone for certain
life stages of some indigenous fish populations, would adversely affect
aquatic life, and may exacerbate existing problems with excessive nutrients,
oxygen depletion and water clarity.
The cooling water intake will on average amount to 70
million gallons per day at temperatures up to 105 degrees F., and up to 20
degrees higher than ambient temperatures. Excessive heat has been documented
to adversely affect fish populations. Also, increases in water temperature,
combined with nutrients can cause high production of algae (including
noxious blue-green algae) potentially leading to or worsening algal blooms.
The permit allows for increases in heat load to the Charles that would be
approximately 414% to 545% greater than historic heat load levels.
During periods of low water flow in the Charles, the flow
of river water passing through and being heated by the plant may be five
times greater than the natural flow of the Charles.
The permit sets thermal limits that allow 50% of the
cross-sectional area of the Charles River Basin (approximately 60 acres of
surface area) to exceed those deemed necessary to protect aquatic organisms.
The thermal limits set in the other half of the area more closely resemble
maximum tolerance levels than the thermal levels found to be the most
beneficial to aquatic species. Even though there are many other stressors
besides heat affecting the aquatic community in the Charles, the EPA did not
consider the impact of these additional stressors nor provide adequate
margin of safety to ensure the protection of aquatic life (as required to do
by the Clean Water Act).
MKS's cooling system kills millions of organisms per
year because of impingement and entrainment. Small organisms, fish eggs and
larvae are carried into the facility and die because of exposure to extreme
heat, chemical pollution and turbulence. Larger fish do not fare better -
they are impinged against the intake filters, where they are crushed or
drown. The draft permit does little to address this problem.
PUBLIC
COMMENTS:
We encourage
the public to submit comments to the EPA. Written comments on the
Draft Permit may be submitted until Septembr 30, 2004 to:
George
Papadopoulos, U.S. EPA
1 Congress Street - Suite 1100
Mailcode CPE
Boston, MA 02114-2023
Telephone:
(617) 918-1579
The public comment period will close September
30, 2004. Following the
close of the comment period, the Regional Administrator of the EPA will
issue a copy of the Final Permit decision to the applicant, Mirant
Kendall, L.L.C., and each person who has submitted written comments of
requested notice.
Information compiled by CRWA, Conservation Law
Foundation and Clean Water Action.
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