Fish Emulsion and the Albatross

By Published On: February 21, 2004

“Water, water everywhere, nor any drop to drink,” laments the shipwrecked Ancient Mariner. Old and rejuvenated power plants along the coast that swallow huge quantities of seawater to cool their feverish turbines may soon be saying the same thing. Two dozen power plants along the California coastline guzzle millions of gallons or more of ocean water daily. A few hundred of these wet-cooled plants in the U.S. are estimated to withdraw a few hundred billion gallons of water a day and excrete the equivalent in hot wastewater. The water-intensive cooling technology wreaks havoc on aquatic life that gets in its path. If sucked into the facility’s intake structure, the resources get turned into fish emulsion, which generally only houseplants appreciate. Marine plants and critters get heatstroke from the warmed wastewater discharges. While wet-cooling technology is not fish-friendly, particularly at the super soaker plants, it’s by no means the only factor affecting coastal water quality and habitat. Be that as it may, wet-cooling technology is looking more and more like an albatross around the neck of generators both private and public. “The environmental impact of these systems is staggering: A single power plant might impinge [trap] a million adult fish in just a three-week period, or entrain [suck in] some 3 to 4 billion smaller fish and shellfish in a year, destabilizing wildlife populations in the surrounding ecosystem,” states a recent court decision that found deficient a habitat-enhancement plan to offset the impact at a new intake power plant. But for affected generators, the albatross is the cost of water-light cooling. Lowering the heat on spinning turbines with large fans in place of water is more costly. Given current power prices, this would result in drowning repowering projects before they begin. “The power market has to get rosier for these guys to justify this expense,” said Kent Zammit, manager of the Electric Power Research Institute’s (EPRI) cooling water technologies. To get an idea of the controversy over wet cooling’s environmental costs, look at Pacific Gas & Electric’s 2,200 MW Diablo Canyon nuclear plant along the central coast. PG&E has been in an ongoing tug of war with the Central Coast Regional Water Quality Control Board to settle alleged violations of discharge limits in its requisite Clean Water Act permit. Consider also two proposed overhauls of wet-cooled plants in the Santa Monica Bay and Morro Bay?the former proposed by Dynegy and the latter by Duke Energy. Plans to modernize the two facilities involve cooling newfangled facilities with estuary water. They have been stuck in the permitting queue at the California Energy Commission for a long while. Of course, the companies’ financial woes have wobbled the projects’ prospects. In fact, the Morro Bay plant has been shuttered for months because of Duke’s financial difficulties. Also noteworthy is that the energy commission staff has strongly objected to the proposed CEC permit decisions that would approve wet cooling for Dynegy’s El Segundo project and Duke’s Morro Bay plant because of the facilities’ “severe impacts” on marine plankton, fish larvae, adult fish, and other species living in already impaired estuaries. Furthermore, the California Coastal Commission has made it clear that only water-light cooling is acceptable under the state’s coastal act. In addition to rising heat at the state level, the issue is bubbling at the federal level as well. In early February, the U.S. Court of Appeals for the Second District rejected the U.S. Environmental Protection Agency’s interpretation of the Clean Water Act that requires mitigation measures to reduce entrainment and impingement impacts at new?and possibly existing?intake structures. Since then, EPA secretary Mike Leavitt signed a rule that interprets the same section of the act and specifically applies to existing plants with wet-cooled infrastructure. The regulation once again interprets Section 316(b) of the Clean Water Act, which requires significant environmental mitigation measures; the language specifically requires the intake structures to “reflect” best available technology to minimize environmental harm. Since the decision was released, there has been much debate over whether the federal appellate court decision applies to existing plants. Now there are questions about its impact on EPA’s rule released February 17, with coastal and industry advocates taking opposite stances. “It is a big issue,” said Michael Thomas, a central coast water board staff member who is working on wastewater discharge permits for PG&E’s Diablo Canyon plant and Duke’s Morro Bay project. The latest intake rules will affect coastal power plants, but whether it forces them to retool or close down remains to be seen. “Until it is all settled, we won’t know what the answer will be,” said Tom Luster, environmental specialist with the California Coastal Commission. Expect a battle royal, specifically over whether habitat-protection plans sufficiently offset degradation caused by water-guzzling plants. “EPA has made a mockery of the Clean Water Act by maximizing fish kills with the worst technology available, when it was required to do the opposite,” Reed Super, an attorney with Riverkeeper?the group that sued over EPA’s earlier rule?said this week. Edison Electric Institute’s Rich Bozek countered that the appellate court decision “does not preclude use of restoration” in EPA’s other rulemaking. The new EPA rules require intake structures at power plants to reduce the environmental harm by between 60 percent and 90 percent via performance standards. The cost of more fish-friendly technologies will be factored into this yet undefined standard, which rather than being uniform for all plants will be site-specific. Industry representatives were pleased with the EPA’s latest rule, though it will hit some facilities harder than others. “It will be expensive for a lot of plants, and more expensive for ones on estuaries,” according to EPRI’s Zammit. Not good news for Duke’s and Dynegy’s modernization projects. In addition, state water boards are allowed to impose more stringent environmentally protective criteria than the feds. “It depends how aggressive the water board is. It can go way beyond the rule,” he added. EPRI is evaluating new technology to minimize entrainment and impingement, Zammit noted. Until this water is under the bridge, we would all do well to heed some other words of the salty old mariner: “He prayeth well, who loveth well, both man and bird and beast.”

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