An Electronic Newsletter
of EEA's Environmental Consulting Activities
Winter 2004
EEA, Inc.
55 Hilton Avenue
Garden City, New York
(516) 746-4400
(212) 227-3200
(800) 459-5533
additional New York offices:
Stony Brook
(631) 751-4600
Altamont
(518) 861-8586
New Jersey Office:
Weehawken
(201) 865-8444
e-mail addresses:
General:
mailto:eea@eeaconsultants.com
Individual:
First initial and last name
@eeaconsultants.com
EEA services include
Phase I ESAs, Haz-Mat
Testing and Remediation, Wetlands
Delineation
and Creation, Natural
Resources Inventories,
Marine Ecology Studies,
Air Quality and Noise
studies, and Environmental Management
System (ISO 14000) implementation.
Visit our web site at
http://www.eeaconsultants.com/
For information or
quotes contact:
Phase I ESAs
Richard
Fasciani
Phase II/III Haz-Mat
Testing and Remediation
Nicholas
Recchia, CPG
Dredge Management Testing
Jeffrey Shelkey
EAS/EIS Studies
Janet Collura,
CWS
Wetlands Studies and
Design
Laura Schwanof,
RLA
Marine Ecology
Teresa Rotunno
Terrestrial Ecology
Denise
Harrington, AICP
Air Quality and Noise
Victor Fahrer,
P.E.
Power Plants-Water Permitting
Glenn
Piehler, Ph.D.
Environmental Management Systems
(ISO 14000)
Robert
Clifford
EEA, Inc. -
founded in 1979
Principals
Leland M.
Hairr, Ph.D.
President
Allen Serper,
M.S., P.E.
Vice President
Roy R. Stoecker,
Ph.D.
Vice President
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ENTRAINMENT and IMPINGEMENT? What's That?
Power Plants and Cooling Water
Intake Structures
(CWIS)
Revised Regulations Expected Early 2004
(printer friendly version
uses Acrobat Reader)
A great variety of industries require water to cool some component
of their process train. Historically, however, the electric utility
industry has been one of the biggest users of cooling water, as it is
needed to condense, for re-use, the steam generated to turn the
turbines that produce electricity in fossil- or nuclear-fueled power
plants. The source of this “non-contact” cooling water has always been
some adjacent surface waterbody, which often must surrender huge
volumes to the plant’s CWIS. Most, if not all, of this water is
returned to the waterbody, but not without possible cause(s) for
environmental concern. |
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Power Plant
New England Coast, Massachusetts
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The initial cause for
concern centered on thermal pollution, since the cooling water was
discharged back to the waterbody much hotter than when it was withdrawn. Then, people started noticing that
large numbers of fish eggs and larvae could be taken into the CWIS with the cooling water (entrainment), and
sizeable quantities of adult fish and shellfish were being killed on the
screens protecting the CWIS pumps (impingement). |
Roots of Regulations for
Cooling Water Intake Structures (CWIS)
To address
these concerns, Section §316 was included in the 1972 amendments to the
Federal Water Pollution Control Act (PL 92-500). Section §316(a) dealt with
thermal discharges (another story), and Section §316(b)
required that the location, design, construction and capacity of
cooling water intake structures (CWIS) reflect the Best Technology
Available (BTA) for minimizing Adverse Environmental Impact (AEI)
of impingement and
entrainment.
It was up to the applicant for a CWIS permit to demonstrate that its
plan satisfied these conditions. |
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Sometimes both fish and fisherman
are attracted to thermal discharges
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To
do this, applicants had to perform a litany of biological studies, and
consider a variety of environmental, engineering design, safety, and cost
factors.
The EPA drafted guidance documents during the
mid-seventies to walk the applicant through the process. Much of the
period’s guidance evolved around study results that had become kind of
“rules-of-thumb” for location and design, such as picking a CWIS location
that had relatively lesser amounts of eggs and larvae; minimizing
screen approach velocities and avoiding dead-end intake locations. |
Scope of Studies: Some Examples
The most
comprehensive, exhaustive and expensive studies were typically associated
with existing or proposed nuclear plants, but large coal- or oil-fired
plants with CWIS in ecosystems perceived as being fragile, or being ±
the epicenter of the spawning or nursery grounds for economically
important species (e.g. striped bass), were given equal attention. Biological studies frequently
included lab tests of temperature and other stresses on fish eggs and
larvae; determination of juvenile fish’s swimming speeds; and pilot tests
of changes in fish impingement given a variety of behavior-altering
devices (light, sound, air bubbles, current vectors). |
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Engineering tasks included feasibility studies and cost-estimating work on
myriad CWIS options, including some tech-transfer systems made from
materials like stainless steel, fine-mesh, wedge-wire screens used for groundwater
monitoring wells. At a minimum, utilities had to conduct entrainment and
impingement studies at existing CWIS (baseline, predictive), or waterbody
studies at proposed sites.
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During the hey-day of the
§316(b) decade (1974-1984), permitting decisions and the success of §316(b)
demonstrations were a function of best professional judgment, benefit-cost
comparisons, negotiations, hearing conclusions, and (sometimes) simply a
directive by the utility itself to propose cooling towers without further
evaluation to pave the way for permitting and getting on-line ASAP.
Cooling towers have always been the BTA of choice to interveners, since
they serve to recycle much of the cooling water, thus cutting the amounts
that must be taken from the source waterbody. In practice, both the
applicant’s scopes of study, and success of the demonstration, often
depended upon such factors as how large the plant was; whether it was
fossil or nuclear-fueled; how much public controversy surrounded the
plant; and even what State it was located within. Such issues led
to suspension of §316(b) rules in 1977, and, in 1995, a consent agreement
ordering the EPA to formulate new rules by the turn of the century.
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Regulations Revamped
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With some notable exceptions,
for example the Hudson River power plants, §316(b) took a vacation from
the mid-1980s through most of the ‘90s. Most of the existing power plants
were permitted to continue to operate on the strength of §316(b)
demonstrations performed during the mid-1970s. Periodically, they had to
address issues such as the need for fish return systems, but it was not
until the late ‘90s when agencies such as the NYSDEC, the CTDEP, and the
EPA Region I began calling for updates on entrainment and impingement at
all CWIS. This was effected through sampling and analysis require-ments
made part-and-parcel of the NPDES Permit renewal process, no doubt in
anticipation of final Phase II EPA rules now scheduled for publication in
February, 2004. Those rules have the potential for making operation of
once-through plants located on estuaries considerably more expensive.
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For both new and existing CWIS,
EPA has defined sets of criteria for (a) determining whether your CWIS
needs to comply with the regulation, and (b) if so, what kinds of design
and performance specs it needs to meet. To view the details of these
proposed regulations, as well as existing §316 (b) criteria, link to
US EPA §316 (b) Regulations |
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Some Solutions…
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Under the new
rules, CWIS owners
will have the option of simply
complying with new performance
criteria for minimizing entrainment
and/or impingement, or demon- strating that (a) the impact of their CWIS
is insignificant; (b) the costs of compliance far exceed the benefits; or
(c) that greater benefits may be realized by
implementing some “conservation measures”,
as opposed to installing expensive technologies like
cooling towers. |
As
an example, in the mid-1990s, as
part of an agreement to minimize
impingement mortality and also
create new ecological benefits
commensurate with CWIS losses at its Salem, NJ plant, PSE&G began
installing fish ladders in tidal creeks around Delaware Bay. This effort, which employed fish ladder
designs that have been evolving ever
since dams were first built to harness
power and/or control floods (the first
one being completed in 1798 at
Turner’s Falls, MA, on the
Connecticut River)was begun in order to
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restore alewife and blueback herring
runs to some of the many spawning grounds that had
been blocked by development dating back a
century or so.
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Extensive wetlands were also
re-created up and down the estuary.
These and other mitigative offsets are
expected to be available to CWIS
owners as they seek solutions to their
site-specific needs.
EEA’s
staff has experience over many
years conducting
§316 (b) permit
studies at numerous power plants.
While the jury will still be out for a few months as to how the
states may define their priorities and options with respect to
§316(b), owners of existing CWIS may want to revisit and update
those industry questionnaires of a few years ago, and maybe start
thinking about their likely options, starting with the strength of
their “calculation baselines”. EEA would be happy to offer its
services to help CWIS owners evaluate their profiles relative to
this important, re-emerging regulatory |
issue.For further
information, contact
Glenn Piehler, Ph.D. in EEA’s Weehawken, New Jersey office at
(201) 865-8444 or
Roy Stoecker, Ph.D. in EEA’s Garden City Headquarters at (516)
746-4400. |
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