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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

“Desert Rock Energy Facility.” The facility, to be located 25 miles southwest of Farmington, N.M., would produce 1,500 MW (gross). It would be composed of two units of 750 MW (gross), 683 MW (net) each. The applicant proposes to be water efficient because it will use a “once through, supercritical steam cycle”—a system with dry cooling. If everything goes according to plan, Dine authorities expect the plant to break ground in the latter part of 2005.

John Howard, an energy environmental and public policy attorney and former deputy director for the White House Council on Environmental Quality, predicts that EPA, Department of Energy, and the power generation sector will continue to push for technological innovation that will accelerate efficiencies and environmental progress.

“Hopefully,” he adds, “without breaking the bank.

“We should know whether dry cooling clears, or fails to clear, these hurdles for application across the United States in the next couple of years.”

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EPA’s Phase-III CWIS Proposal

Empowering Act. Section 316(b) of the Clean Water Act (CWA) requires EPA to ensure that the location, design, construction, and capacity of cooling water intake structures (CWIS) reflect the best technology available to protect aquatic organisms from being killed or injured by impingement (being pinned against screens or other parts of a cooling water intake structure) or entrainment (being drawn into cooling water systems and subjected to thermal, physical, or chemical stresses).

General Provisions. Proposed in November 2004, with a projected effective date of June 1, 2006, Phase III of the EPA’s rule for CWIS will apply to electric generating plants using relatively small amounts of cooling water—less than 50 million gallons per day (MGD), on the basis of design capability.

(The rule also would apply to similarly situated industrial and manufacturing facilities and new offshore and coastal oil and gas extraction facilities that use at least 25 percent of the withdrawn water exclusively for cooling.)

The facilities subject to the Phase III rule would have to meet the same requirements as those set in Phase II for large-flow power plants, for reducing mortality of aquatic and marine life from impingement or entrainment. However, the EPA’s Phase III rule, as proposed in November, leaves the matter open as to the exact size of power plant and type of water body that would be covered under the regulation.

Alternative Regulatory Regimes. The EPA in fact proposes several alternative optional regimes, with each one providing for a different definition of the size of facility and type of water resource subject to the rule:

  • Option 1 The rule would apply only to facilities that withdraw at least 50 million gallons per day (MGD) of cooling water from any type of water body. Choosing this option would mean that the rule would apply only to about 23 percent of the universe of power plants potentially subject to Phase III (some 155 facilities), and would cover about 75 percent of the total water intake in that universe.
  • Option 2 The rule would apply only to facilities that withdraw at least 200 MGD from any type of water body. This option