Clean Water Act §316(b):
Forecasting Power
Generation Industry
Impacts
Dave Bailey
RFF Modeling Workshop
July 19, 2011
Final Rule Delayed
EPA announced yesterday that an agreement has been
reached with the Riverkeeper for a one year delay in the
§316(b) Final Rule – New Date is July 27, 2013.
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Overview
• EPA Considered four Regulatory
Options – any could be selected for
the §316(b) Final Rule
• For Proposed Rule and NODA:
– Entrainment to be decided on a sitespecific basis
– Impingement, based on NODA has six
possible compliance alternatives
• Outcomes in terms of potential
premature unit retirements highly
dependent on:
1. EPA option selected
2. Impingement mortality reduction
requirements
3. Region of the U.S.
4. Waterbody type
© 2007 Electric Power Research Institute, Inc. All rights reserved.
EPA Staff touring Chalk
Point Cooling Towers
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Inventory of Potentially Affected Units
• Any facility having at least one
once-through cooling unit and
using >50 million gal/day
• Surveyed potentially impacted
facilities for unit specific MW,
flow and capacity info
• Responses returned by
– 75% of fossil units
– 95% of nuclear units
# Facilities
# Units
MW
Fossil
389
1093
252,392
Nuclear
39
63
59,931
Total
428
1156
312,323
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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EPA Considered Four Options
• All options required IM reductions:
– 3 options required for design flows >2
MGD
– 1 option required for design flows >50
MGD
• For entrainment two options required
closed-cycle cooling:
– One option required for all facilities >2
MGD
– One option required for facilities >125
MGD
– Entrainment for other two options sitespecific
• All options required closed-cycle cooling
for new units at existing facilities
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Estimated Retrofit Cost (includes capital cost, O&M,
extended outages, heat rate and energy penalties)
Cost (Billions)
Nuclear
Fossil
Total
Net Present Value1
$31.9
$63.3
$95.2
Annualized Cost
$2.3
$4.7
$7.0
1 Assumes
© 2007 Electric Power Research Institute, Inc. All rights reserved.
a 30 year system life.
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Summary of Units and Capacity at Risk of Premature
Retirement if Closed-cycle Cooling Retrofits
Designated as BTA (EPRI Technical Report 1022751)
Region
All Waterbody Types
Units at Risk
MWs at Risk
PJM
21
3,250
ERCOT
25
5,458
ISO-NE
12
2,561
7
906
NYISO
11
3,325
SERC
38
3,044
FRCC
21
2,196
SPP
20
1,475
WECC
18
2,699
MRO
8
328
RFC
33
816
214
26,058
Midwest ISO
Totals
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Note EPRI
estimates an
additional 15,600
MW may be lost
due to inadequate
space to retrofit or
permitting issues
for a total of
~42,000MWs at risk
Basic Requirements for Entrainment Control
• Required for all facilities using
>2 MGD; however, information
requirements apply only to
facilities that use >125 MGD
actual intake flow
• Compliance determined by
permitting authority on a caseby-case basis and may range
from:
– existing intake is BTA, to
– closed-cycle cooling
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Facilities Most Likely to Be at Risk of ClosedCycle Cooling Retrofit for Entrainment
• Facilities in the Northeast (ex.
Massachusetts, New York, New Jersey,
New Hampshire, Connecticut, Delaware,)
• Facilities withdrawing from oceans,
estuaries, tidal rivers and some Great
Lakes (due to commercial fisheries and
depressed populations for some species)
• Only those facilities using >125 MGD AIF
required to submit entrainment studies
• BTA Considerations include:
 Cost-benefit
 Energy system impacts
 Environmental impacts of retrofits
 Adequate land availability
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Based on NODA Six Compliance Alternatives
Now Under Consideration for Impingement
• Direct biological monitoring with traveling
water screens (88% annual and 69%
monthly reduction in impingement
mortality required)
• Reducing through screen velocity to not
exceed 0.5 fps
• “Streamlined” (pre-approved) approach
based on modified traveling water screens
(NEW)
• Use of a “defined” technology – closedcycle cooling or velocity cap (NEW)
• Site-specific approach – same approach
used for entrainment either generally or
based on a demonstration (NEW)
• Exemption for low levels of impingement
(NEW)
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Cost of Meeting Impingement Mortality
Reduction Requirements
• EPRI has evaluated 18 intakes in
terms of compliance cost based on the
proposed rule and NODA:
 $8.7 million avg. cost of modified
traveling water screens
 $47.5 million avg. cost to expand intake
to not exceed 0.5 fps
 $19.5 million avg. cost of wedgewire
screens to not exceed 0.5 fps
 $1.9 million avg. cost for barrier nets to
achieve 0.5 fps (only practical for 50%
of facilities evaluated and many require
a pilot study)
• Majority of evaluated facilities on
freshwater
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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Questions?
Dave Bailey
dbailey@epri.com
571-226-0614
Doug Dixon
ddixon@epri.com
804-642-1025
© 2007 Electric Power Research Institute, Inc. All rights reserved.
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