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Power-Plant Cooling: How Many Fish Per kWh?

EPA flounders on the Clean Water rule, while producers tackle the real enemy—shortage.

Fortnightly Magazine - July 2005

an effort to avoid permitting obstacles related to water use and availability.

In Nevada, for instance, the need to conserve water has driven utilities to search for alternatives to wet evaporative cooling systems. But the water issues go much further, says Zammit.

“In some areas around the country—not just the arid West—stakeholders are opposing new plants on the basis of water use. These plants will operate for 40 to 60 years, and the issue is the water they use may be very, very valuable 50 years from now. That can create timing issues as far as getting timely permits to be able to build the plants.

“Even in areas where water has historically not been an issue, we’re starting to see it become an issue. For instance in Georgia, they are starting to have trouble meeting their interstate river compacts due to drought and growth issues. There’s a concern about where they're going to get water for future development for business.

“You think of Georgia as being a relatively wet state and not really needing a water plan and yet with the booming growth of Atlanta, it's really putting pressure on their water usage. There are water impacts in other water-rich states, like saltwater intrusion of fresh water aquifers along the Gulf coast, in Louisiana and Florida. These kinds of developments will continue to increase the pressure to reduce water use in power generation.”

The State Regulatory Role

Ted Long, formerly supervisor, Environmental, for Reliant Energy, and now with Texas GenCo, gives some background on implementing EPA rules already issued under Sec. 316b, in Phase I and Phase II.

“The states have to implement the federal rule. … Basically we have to submit to the state something called a PIC, ‘Proposal for Information Collection,’ and that’s the first regulatory document that we submit.”

The applicant’s PIC outlines what it needs to do so that data collection and information collection comply with rule 316b.

“That’s the first thing, and that’s across the country,” he adds. In Texas one would go before the TCEQ, the Texas Commission on Environmental Quality, he explains.

“So much of this is state dependent. I would imagine that as far as dealing with 316b what you’re going to face in Texas—even though it’s the same regulation—could be a lot different than how it’s going to be looked at in California and New York.”

Long continues: “The state is supposed to get back and say, ‘Okay we agree.’ Then the next thing gets real complicated. It is part of a comprehensive demonstration study. Basically, you have several years to pull together your study where you’ve looked at all your different compliance options, your outline, how you want to go about trying to comply with the rule. And you have to have all that stuff submitted with your next permit renewal.”

Time is critical, however. And time is money.

“There are places,” Long explains, “where they say you need to get two years’ worth of data. Well, if you get two years’ worth of data, you’re running into some time constraints