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MA SUPREME COURT RULES STATE AUTHORITIES MAY REGULATE WATER INTAKE AT NUCLEAR PLANTS (April 2011)

SJC: STATE AUTHORITIES MAY REGULATE WATER INTAKE AT NUCLEAR PLANTS

By Kyle Cheney
STATE HOUSE NEWS SERVICE

STATE HOUSE, BOSTON, APRIL 11, 2011…..Environmental authorities, arguing that water intake systems used by nuclear facilities kill “billions” of aquatic organisms each year, scored a victory Monday in Massachusetts’s highest court.

The Supreme Judicial Court, in a ruling authored by now-retired Justice Judith Cowin, said the Massachusetts Department of Environmental Protection has the authority to regulate water intake, rejecting an argument by Entergy Nuclear Generation Co. that the agency overstepped its authority.

Entergy, which operates Pilgrim Nuclear Power Station and draws water from Cape Cod Bay, had argued that DEP may only regulate nuclear “discharge” and other traditional forms of pollution, but that water intake was off limits. Entergy also claimed federal regulators pressured the state to regulate water intake.

“The emphasis on traditional threats to water resources cannot be read to deprive the department of authority to address atypical or novel threats that may also harm those resources,” Cowin wrote in the unanimous ruling. “The department's authority to create a discharge and pollution reduction program does not limit its authority to deal with water quality issues other than discharges and traditional pollution under its broad statutory powers. Restricting the department's authority to water pollution control, as Entergy suggests, would render superfluous the department's parallel duty to protect ‘the quality and value of water resources.’”

“We conclude that the language of [state law] does not support, nor did the Legislature intend, such a narrow view of the department's authority,” she continued.

The ruling overturned a Suffolk Superior Court ruling in Entergy’s favor.

At issue is a December 2006 regulation issued by the department declaring its authority to set standards for the intake systems used by nuclear plants to cool their reactors. The regulation emerged after years of urging by the U.S. Environmental Protection Agency to expand DEP’s authority beyond water discharge and more traditional forms of pollution, according to DEP’s filings in the suit.

Officials for Entergy declined immediate comment on the ruling.

“We have received the decision and our attorneys are studying it,” said Jack Alexander, Entergy’s manager of government relations.

According to the ruling, Entergy purchased the Pilgrim plant in 1999. The facility includes a “cooling water intake system” that draws water from Cape Cod Bay and discharges heated water and other pollutants. The facility holds a “discharge permit” issued by the EPA and state environmental authorities.

Nuclear issues burst into public consciousness last month after an earthquake and tsunami in Japan disrupted a cluster of reactors, releasing radioactive material into the air and water. Last week, Gov. Deval Patrick and legislative leaders urged the Nuclear Regulatory Commission to halt any steps toward relicensing the Pilgrim plant until all of the lessons from the Japanese nuclear crisis have been learned.

In its lawsuit, Entergy argued that DEP’s decision to regulate water intake systems represented a “reversal” in policy and lacked the explicit backing of Massachusetts law.

“Indeed, in the thirty-plus years that MassDEP has administered [water quality laws], it consistently maintained, until 2006, that it lacked statutory authority to regulate withdrawal,” Entergy attorneys argued in a brief submitted to the SJC. “Only after concerted pressure by EPA did MassDEP change its long-held position, though offering no explanation for the change. That administrative capitulation is not entitled to judicial deference.”

Entergy argued that Massachusetts law lacked any specific reference to intake by nuclear cooling systems and that the EPA already regulated nuclear cooling systems.

“Therefore, notwithstanding any aspirational goals of the State Act or whatever force may be derived from its apologetic, policy-based arguments, MassDEP cannot evade the fundamental hurdle that it may not take any action unauthorized by statute,” according to the brief, signed by three attorneys from Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, a Boston-based firm representing the company.

But the SJC argued that in areas like Cape Cod Bay, “with a designated use as aquatic habitat,” nuclear cooling facilities “hinder the attainment of water quality standards.”

“Accordingly, authority to regulate [cooling facilities] reasonably may be implied as necessary to protect water quality in the Commonwealth,” Cowin wrote.

In February, the EPA issued a new permit for a power plant in Cambridge, ending longstanding litigation and requiring the facility to reduce its heat discharge and water withdrawal levels by 95 percent, a mandate that environmental regulators said would address “adverse impacts” on fish populations in the lower Charles River and Boston Harbor. The water discharge permit for the 256-megawatt Kendall Cogeneration Station plant requires the plant's owner GenOn, formerly Mirant, to closely monitor river temperatures to make sure its discharges into the river do not cause excessive warming of the waters.

According to the EPA, Kendall Station’s cooling system withdraws an average of 70 million gallons a day from the Charles River and discharges it back into the river at temperatures increased by 20 degrees, up to a maximum discharge temperature of 105 degrees. Under a modified permit, station owners will be required to make facility upgrades that, in combination with a new steam pipeline to be built across the Longfellow Bridge in the next few years, will enable the plant to sell up to twice as much steam into Boston as is currently possible, resulting in a reduction in the station's heat discharge and cooling water withdrawals of about 95 percent. The modified permit requires Kendall Station to install and operate a back pressure steam turbine and an air-cooled condenser that will enable the plant to reduce its water flow to 3.2 million gallons a day, according to the EPA.

“Although the [SJC] seems to have rejected in silence a host of unsound statutory arguments that DEP made in support of its position, I was disappointed that the Court accepted DEP’s argument that general statutory language permits it to control water intakes, despite the fact that the focus of the statutes clearly is elsewhere,” said John Pagliaro, an attorney with the New England Law Foundation, which submitted a brief in support of Entergy.




_____________________________________________________________________________________________________________________


ONCE THROUGH COOLING

Nuclear Power Plants Destroy Marine Life – why no federal/state action?

The US Environmental Protection Agency (EPA) knows that power plants may kill marine life.  For that reason, it is demanding strict controls on the Brayton Point power plant in Somerset.  Oddly, state and federal agencies have turned a blind eye to the same problem at nuclear power stations such as Pilgrim.  There is no reason for this, but the outcome is clear:  fish die and fisheries suffer.

Just like a car's engine, power plants need coolant to keep from overheating.  Most plants take water from the ocean or a river, pump that water through, and discharge it -- now 30 degrees hotter -- back into the ocean or river.  This process kills marine life. 

Marine animals, large and small, are sucked in along with the coolant water. The larger animals become trapped against barrier nets or screens and drown.  Those animals that can fit through the screens -- the tiny organisms essential as the foundation of the marine ecosystem essentially get cooked as they travel through the power plant. 

The discharge of super-heated water causes problems, too.  Imagine pouring water from a tea kettle into a fish tank:  most of the fish move or die.  Those that adapt to the heat die when the warm water flow is diminished or halted because of maintenance, cleaning, or repair work on the reactor.  In addition, the heated water is discharged with such force that surrounding sea beds are often scoured to bare rock, leaving a virtual marine desert bereft of life on the ocean floor.

Pilgrim is located on Cape Cod Bay where fishing already is heavily restricted because of reduced stocks.  However, Pilgrim is allowed essentially to suck the waters dry.  Each gallon of super-heated water that Pilgrim pumps back into the bay risks ecological and economic hardship.

This is not necessary.  Technology exists to lessen the impact, but the power plants are unlikely to install it unless required to do so by state or federal agencies.  Nuclear reactors must be held to the exact same standards as other individuals and industries.  Like everyone else, they should be required to employ the “best technology available to minimize adverse environmental impact.”

Primary Resource:
Licensed to Kill
: How the nuclear power industry destroys endangered marine wildlife and ocean habitat to save money

http://www.nirs.org/licensedtokill/Licensedtokillintropage.htm

_______________________________________________________________________________________________________

Pilgrim Nuclear Power Station - review of intake and discharge effects to finfish
 
Technical Memorandum For The Record
By:  Gerald M. Szal
Subject:  Pilgrim Nuclear Power Station: review of intake and discharge effects to finfish

Date:  August 30, 2005

Potential impacts to aquatic life from the operation of the Pilgrim Nuclear Power Station are divided into two categories: those from the intake of cooling water, and those from the discharge of heated effluent. Intake effects are further divided into two categories: those from impingement on intake screens at the entry of the intake bay; and those from entrainment of fish eggs and larvae through the facility. Discharge effects discussed include those from the cooling water discharge and those from the heated backwash used to control biofouling in the intake bays.

Intake Effects

Impingement

Effects to winter flounder:

Impingement effects to this species are typically small at the Pilgrim facility. An estimated total of slightly over 2,000 winter flounder were impinged in year 2004. Most, if not all, of these were young of the year. This is the second highest impingement rate in the past 25 years of monitoring, but does not appear to represent a significant impact to the population.

Effects to other finfish species:

The following fish species were considered those suffering the greatest numerical losses due to impingement over the last 11 years of monitoring at Pilgrim (Environmental Protection Group 2005):

Table 1

Year

Atlantic silverside

Atlantic

menhaden

blueback herring

grubby

rainbow smelt

alewife

1994

36,498

58

269

1,094

9,464

123

1995

13,085

1,560

1,244

648

2,191

39,884

1996

16,615

2,168

2,462

1,347

3,728

216

1997

6,303

1,329

424

405

1,978

317

1998

6,773

1,423

134

335

1,656

158

1999

8,577

42,686

550

628

875

610

2000

25,665

34,354

5,919

1,105

13

2,443

2001

4,987

3,599

229

517

879

1,618

2002

4,430

53,304

943

1,087

335

334

2003

23,149

119,041

1,968

237

532

438

2004

13,107

10,431

2,046

2,257

1,092

145

Of particular interest are the rainbow smelt. These fish are an anadromous species and smelt impinged at Pilgrim most probably come from the Jones River population.  Although there are two other rainbow smelt runs (Town Brook and Eel River) in the Plymouth/Kinston/Duxbury Bay area they are apparently quite small in comparison to that from the Jones River (based on pers. comm., Brad Chase, MA Division of Marine Fisheries [DMF] to Gerald Szal, DEP). Rainbow smelt are not known to reproduce elsewhere in streams entering Cape Cod Bay or in streams elsewhere on Cape Cod.

During the late 1970s, there were a number of rainbow smelt impingement events at the Pilgrim facility. In 1978 an estimated 6,200 rainbow smelt died during a three-week period in December from impingement episodes at the facility. At the time, a group of state, federal, university and facility personnel met regularly to address potential impacts from the facility. Concern was expressed by these biologists that impingement events from Pilgrim could be significantly affecting the Jones River smelt population. This prompted DMF to conduct an intensive, three-year (1978-1981) study (see Lawton, et al., 1990) to develop an estimate of the adult rainbow smelt population size in the Jones River so that an assessment of the plant’s effects could be evaluated.

Results of the Lawton, et al., study state that, based on an estimate of egg production, an unbiased sex ratio, and age-specific fecundity, rainbow smelt spawning stock abundance was estimated to be 4,180,000 adults in 1981. The 6,200-fish loss due to impingement was projected to have reduced the Jones River spawning population by less than one percent, and was not considered to have a significant, negative effect on that population.

Based on a recent interview with personnel at the Division of Marine Fisheries, there have been no recent quantitative estimates of the adult rainbow smelt population in the Jones River. However, judging from visual information on both egg density and adult movement, Brad Chase, DMF (pers. comm. to G. Szal, August 29, 2005) estimates that there has been a sharp decline in the rainbow smelt population in the Jones River since the time when the Lawton, et al. (1990), studies were conducted. Unfortunately, without a quantitative evaluation of the rainbow smelt population size in the Jones river, Mr. Chase felt it was not possible to assess the potential impact of Pilgrim’s impingement events on the Jones River smelt population.

Entrainment

Effects to winter flounder:

Entrained organisms at power plants are typically subjected to a number of stresses including mechanical stress, stress from pressure drop and stress from rapid heating (delta temperature effects). Winter flounder are the primary species of concern at many facilities along coastal Massachusetts due to their intrinsic economic value and recent population decreases. The Pilgrim Nuclear facility employs several methods of evaluating the impact of the intake on the local winter flounder population adjacent to the facility. The first is the “equivalent adult” method in which the estimated number of eggs and larvae entrained (and assumed killed) by the facility are theoretically “grown up” into adults of different age categories based on literature reports on percent survival from one life stage to the next in wild populations. The number of equivalent adults of a particular adult age (e.g., 3-year olds) can be compared with the number of actual adults, of many year classes, found per square mile in areas adjacent to the facility to form an index of impact.

Density of adult winter flounder was assessed primarily in Plymouth/Kingston/Duxbury Bay (PKDB) and adjacent waters, as these areas were thought to be the primary spawning ground that produced the larvae and eggs entrained by the facility.  Researchers conducted sampling in this area using a commercial “otter trawl”, a device used to capture bottom fish. The number of equivalent adults cropped by the facility divided by the mean number of flounder found per square mile of PKDB and adjacent areas was used to provide a rough idea of the effect of the facility’s impacts due to entrainment of winter flounder.

There are a number of difficulties to be overcome if one is to use this approach. First there are issues encountered in sampling both the adult population in the field as well as the egg and larval population entrained. For example, researchers conducting this work have assumed an otter trawl efficiency of 50%, but the actual efficiency may be much lower (or higher), which would alter the number of fish in the study area per square mile and the apparent impact. Second, entrainment sampling results, in addition, are quite variable. Third, it is difficult to determine the accuracy, and therefore, the applicability, of the survival matrix used in estimating equivalent adults.

Three age-specific survival matrices were provided by Entergy Nuclear (Environmental Protection Group 2005). One matrix uses un-staged larval information (i.e., all larvae are considered to be the same age); the other two use survival data from one stage to the next for four different larval life stages.  Because staged larval survival data should provide a greater degree of accuracy, un-staged information was not used for this review. Of the two remaining matrices, that provided by Gibson (1993) was chosen to evaluate winter flounder issues in Mt. Hope Bay as it was also used in analyses conducted for the Brayton Point facility in Mt. Hope Bay.

A fourth difficulty in estimating impact is choosing a particular adult age class for equivalent adults entrained. The author assumed (see below) that the number of Age-4 equivalent adults entrained is proper for comparison to the estimate of the number of adults per square mile, all ages, found in the study area. Many winter flounder are fully mature at Age-3, but some are not (pers. comm. Robert Lawton, MADMF to Gerald Szal, MADEP). Age-4 was used because almost all winter flounder in the Cape-Cod Bay area are mature at Age-4 (pers. comm. R. Lawton to G. Szal). A more accurate estimate of impact could be prepared if a matrix of length-age-survival data were available for the field population.

The following table provides estimates of entrainment impacts at the Pilgrim Nuclear Power Plant facility in Plymouth, MA, on the local winter flounder population. Estimates are based on data in Environmental Protection Group (2005).

 Table 2

Year

No. Adult Winter Flounder in study area1

No. Adult Winter Flounder per square mile2

Estimate age-3 adults entrained3

Estimate age-4 adults entrained4

Square miles age-4 adults lost to entrainment5

1995

212,989

2,063

9,703

5,919

2.9

1996

316,986

3,070

15,401

50,851

3.1

1997

313,959

3,041

47,091

28,726

9.4

1998

264,812

2,565

77,394

47,210

18.4

1999

176,271

1,707

2,383

1,454

0.9

2000

464,176

4,496

4,521

2,758

0.6

2001

400,812

3,882

33,626

20,512

5.3

2002

476,263

4,613

19,703

12,019

2.6

2003

262,604

2,544

2,951

1,800

0.7

2004

157,532

1,526

50,851

31,019

20.3

Footnotes:

1.     Adults were those fish that were > 280 mm in total length.

2.     The size of the study area changed over the course of the evaluations. According to J. Scheffer (Pilgrim) all estimates in this column are corrected to the same study area size. They have been based on the area swept by the otter trawl used to capture winter flounder and a trawl efficiency of 50%. The current (2004) size of the study area is about 103 square miles. 

3.     The equivalent adult method of estimating how many adult of age 3-years would have resulted from the eggs and larvae entrained by the facility, based on literature growth and survival data, was used to obtain these figures. Age-3 adult data were taken directly from Pilgrim Report No. 65; literature data used to calculate survival from one stage to the next was that from Gibson, 1993, as reported by Entergy Nuclear (2005).

4.     Age-4 adult numbers were estimated based on a survival of 0.67 (pers. comm., Robert Lawton, MADMF to Gerald Szal, MADEP) from Age-3 to Age-4.

5.     Calculated as: (Age-4 adults entrained)/(No. winter flounder per square mile). Because the study area is about 100 square miles (actually 103), these figures are approximately equivalent to the percentage loss to the population in the study area.  

Entrainment loss as square miles of adult flounder, using Age-4 equivalent adults entrained, ranged from 0.6 to 20.3 square miles over the 10 years of evaluations. That is, entrainment effects from the Pilgrim facility were estimated to be equivalent to a loss of all adult flounder in an area ranging from 0.6 to 20 square miles in the area adjacent to the facility, given the assumptions outlined above. Because the study area was approximately 100 square miles in size, the square mile losses in this last column approximate a percentile loss to the population at large, although, again, the caveats mentioned above should be kept in mind when viewing these estimates. Whether or not these levels of impact are a “significant” detriment to the population, and will result in slowing the return to much higher population densities, is currently unknown and a policy statement regarding losses on a square mile basis has not been issued by any of the state or federal agencies. EPA Region 1 has stated in the past that population impacts of 5% or greater are typically of concern. However, to the author’s knowledge, the geographic bounds of this particular population have not been agreed upon by state or federal agencies.

A second method of estimating entrainment impact to winter flounder used by the facility was to estimate the percentage of the total larval population passing in front of the facility that is entrained. Estimates of percent entrainment were very low, i.e., less than 1%.

The third method used by the facility to evaluate impact was the RAMAS (Risk Analysis Management Alternative System; Ferson, 1993) winter flounder model. It was used from 1999-2001 to further evaluate the effects of the facility on the Cape Cod Bay winter flounder population. Results suggested that stock reductions from 2.3 to 5.2% might occur as the direct result of entrainment at the facility.

Effects to other finfish species:

Several species, besides winter flounder, suffer substantial entrainment losses at the Pilgrim facility. These are cunner, mackerel, menhaden and atlantic herring. Numbers of equivalent adults (of different ages) estimated by the facility to have been lost due to entrainment effects on eggs and larvae are listed below:

Table 3:  Estimates of the equivalent numbers of adult fish (at age in years in parentheses)
          entrained by Pilgrim from 1994-2004. Estimates are based on data in Environmental Protection
          Group (2005); (note: Atlantic herring figures are for entrainment/impingement combined and
          could not be separated due to the manner in which they were reported).

   

Year

Cunner (1)

Mackerel (3)

Menhaden (2)

Atlantic herring (3)

1994

174,726

830

732

10,774

1995

525,573

6,245

2,452

25, 518

1996

313,002

3,526

1,781

6,096

1997

465,986

942

10,531

16,091

1998

1,542,473

1,824

7,564

2,697

1999

332,601

60

4,072

7,518

2000

319,247

1,216

178

8,120

2001

473,361

311

349

2,701

2002

101,668

482

1,382

2,425

2003

82,467

514

1,187

699

2004

188,107

304

50

3,169

 

Screenwash and Fish-Return System:

Intake screen wash: The cooling water intake bay at Pilgrim has a number of fine-mesh screens within it that are used to keep fish (but not most fish larvae and eggs) from being brought into the facility. Fish impinged upon these screens can suffer negative acute or chronic effects. At Pilgrim, impinged fish are knocked off the screens by a salt-water spray system. Under normal operation, screens are rotated only once per 8-hour shift. At the end of the shift, the screens are rotated, and the spray system is operated to dislodge fish from the screens. These fish are shunted to a holding tank where they are counted and further shunted to the intake embayment about 100yds upstream of the intake. If the number of fish during one of these 8-hour periods exceeds 160 fish (rate of 20 fish/hour) an “impingement event” is declared. During such an event, the screens are put into constant rotation, and the event is monitored (i.e., fish are counted) until the event is over. The event is reported as soon as possible after it begins and information on species involved, life stages and numbers of fish is related to the permitting authorities and the Massachusetts Division of Marine Fisheries.

Impinged fish are released into the intake embayment, about 100 yards upstream of the intake bay. To the author’s knowledge no studies have been done to evaluate re-impingement rates. Although large-scale impingement events (>100,000 fish) have taken place at the facility, most of these have been with young-of-the year.

The pressure-wash spray system has two sets of nozzles. The first to come in contact with impinged fish is a low-pressure wash (20 pounds per square inch [psi] or less) which is used to remove most fish from the intake screens. The second is a high-pressure wash (80-100 psi) which removes any remaining fish and/or debris. Water for the spray wash is drawn from the saltwater service system and is de-chlorinated prior to use. Reasons for chlorinating this system are explained below.

There are five salt service water pumps at Pilgrim, each with a capacity of 2,500 gallons per minute. The salt service water system has two purposes. It is used to supply cooling water to a number of components within the plant, but is also used for emergency cooling. Typically, four pumps are kept running and the other is kept in reserve. Because the salt water service system must constantly be available for emergency cooling, chlorine alone is used to prevent biofouling within the system. Thermal backwashing (see below), a method used to control biofouling in the intake bays, is not allowed by the Federal Nuclear Regulatory Commission within this system because the water in the salt water service system must constantly be kept cool. The target concentration for chlorine within this system is 0.25 mg/L but the system concentration may reach 1.0 mg/L. Water for this system is taken from the intake bay; chlorinated water from this system is released through the 010 discharge into the primary discharge canal (discharge number 001). Because the 001 discharge is so large (310,000 gpm), the chlorine concentration (after mixing) in the discharge canal due to the 010 release should not reach levels that are above water quality standards.

Discharge Effects

Cooling water discharge:

The Pilgrim Nuclear facility’s discharge is located in an open-coastal environment and is well situated for rapid mixing of its heated discharge. Effects of the heated discharge on finfish, benthos and Irish Moss were studied for more than twenty years. Primary impacts include at least two well-documented events of gas-bubble disease in finfish in the 1970s. Since that time, to the author’s knowledge, no other major events appear to have taken place. In addition, due to effects on Irish Moss, the facility reimbursed one harvester for losses. Effects of the discharge on the benthic community appear to be primarily limited to scouring. Judging from diver-assisted studies conducted in the late 1990s, it appears that no more than 1-2 acres of the benthic community were negatively affected by the plant’s discharge.

Thermal backwash:

About four to five times a year, for a period of about 1.5 to 2 hours, heated water from the downstream end of the steam condensers is re-routed back through the system and out through the intake embayment. This is done to control macro-fouling, primarily from mussels. To accomplish this, the facility shuts down one of the two intake pumps and pushes hot water back through half the system. During this period (about 34-45 minutes) the water within the half of the system receiving the backwash is typically heated to between 105°F and 110°F, but may reach as high as 120°F. The second half of the system is treated in the same manner. Because the facility has to reduce load during these times, which is expensive, the duration and number of backwashes per year is kept to a minimum.

In summary, during a thermal backwash, about 155,000 gpm of heated water (>105°F) is sent into the intake embayment for a period of about 1.5-2 hrs. Studies to evaluate potential impacts of the thermal backwash have not been performed to the knowledge of the author.

Recommendations to minimize impacts from Pilgrim:

1. Resource agencies, in concert with the permitting agencies, should consider further evaluation of the intake effects to winter flounder. If effects are found to be substantial, these agencies should determine what steps need to be taken to reduce the impacts of the facility on the winter flounder population.

2. Because impinged fish from the intake screens are shunted back into the intake, there is a concern that these fish, weakened from impingement, will simply be re-impinged. Permitting and resource agencies should consider requiring an assessment of re-impingement rates to select species of concern. These studies should also assess the need to re-locate the discharge point for impinged fish in order to minimize re-impingement.

 Literature Cited

Gibson, M.R. 1993. Population dynamics of winter flounder in Mt. Hope Bay in relation to operations at the Brayton Point electric plant. Rhode Island Division Fish and Wildlife, West Kingston, R.I.

Environmental Protection Group. 2005. Marine Ecology Studies, Pilgrim Nuclear Power Station. Report No. 65, Report Period: January 2004-December 2004, Date of Issue: April 30, 2005. Entergy Nuclear – Pilgrim Station, Plymouth, MA.

Ferson, S. 1993. RAMAS/stage. Generalized Stage-based Modeling for Population Dynamics. Applied Biomathematics, Setauket, New York. 107 p.

Lawton, R., P. Brady, C. Sheehan, S. Correia and M. Borgatti. 1990. Final report on spawning sea-run rainbow smelt (Osmertus mordax) in the Jones River and impact assessment of Pilgrim Station on the population, 1979-1981. Dept. Fisheries, Wildlife and Environ. Law Enforcement, MA Division of Marine Fisheries, 18 route 6A, Sandwich, MA 02563.

 

More about Once through Cooling-Pilgrim's Discharge Permit & Supreme Court Decision 2008

 

 

 

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