Friday, December 10, 2010

Oyster Creek and Cooling Towers

oyster-creek Exelon has announced that its Oyster Creek nuclear plant will close in 2019, ten years before the license to operate it expires. These are the reasons Exelon gives for its decision:

“The plant faces a unique set of economic conditions and changing environmental regulations that make ending operations in 2019 the best option for the company, employees and shareholders,” [Exelon President and COO Chris] Crane said.

And to expand on this a little more:

The decision is based on the cumulative effect of negative economic factors which has caused Oyster Creek’s value to decline.  These factors include low market prices and demand, and the plant’s need for continuing large capital expenditures. Also, potential additional environmental compliance costs based on evolving water cooling regulatory requirements – at both the federal and state government levels – created significant regulatory and economic uncertainty.

The first half of that explanation may well have been mitigated by an improving economy and a rising demand for clean electricity sources. The second half – about environmental regulations – is rather more serious because it is potentially more intractable.

Although Exelon is specifically referring to rulemaking by the New Jersey Environmental Protection Agency, the federal EPA is likewise considering a change to the Clean Water Act that mirrors that of the NJEPA.

This rulemaking concerns cooling towers. Now, while cooling towers are almost iconic symbols of nuclear energy, not all plants use them. Oyster Creek, for example, does not. Likewise, nuclear energy plants are not the only kinds of plants that use them – coal-fired and gas-fired plants do, too, but as with nuclear plants, not universally.

Up to now, rule 316(b) of the Clean Water Act has allowed plant operators to use what it calls the “best technology available” to capture water for plant cooling purposes. The question is: does capturing that water – and returning it to the source – harm aquatic life.

The EPA actually doesn’t know the answer to that question, but it is knowable. A fair number of studies have been done on the issue and have reached similar conclusions.

Take, for example, this Third Way report:

“316(b) could have serious environmental consequences that should be considered in EPA’s analysis. Closed-cycle cooling is not the panacea it appears to be.

Third Way is a centrist think tank. Here’s the British version of the EPA, the U.K. Environment Agency:

A distinct difference in the U.S. approach has been the assumption of 100 percent mortality of any fish eggs, larvae or juveniles entrained in plant cooling systems and discharged back to sea. U.K. studies have shown that substantial portions survive cooling water system passage, potentially reducing the magnitude of entrainment impacts.

Entrainment refers to aquatic creatures, mostly fish, that get pulled into the plant’s cooling system along with the water.

EPA also means to bar from the rule a number of factors, such as water use conflicts, climate change, land use, and the potential cost of electricity to consumers, that represent elements of a cost benefit analysis. This analysis is important because it permits plant operators to demonstrate that taking on the cost of a technology such as cooling towers can do far more harm (up to and including shuttering the plant) than good (rescuing a few fish). The cost and its benefits and harms can be weighed against each other and an option chosen. That option still might be cooling towers – but maybe not, if the full case against them is compelling.

Weighing costs against benefits can be a tough concept – we want modern convenience without negative consequences because it seems the just way to go about things – but that doesn’t really work in any known human endeavor. What one does to keep the scales balanced is to mitigate potential harm as much as possible to gain the considerable benefits.

Power plants do this – they take the environmental impact of the plants very seriously and spend serious money to prove it. NEI’s Insight newsletter has written extensively on the subject of plant operators and their involvement with the aquatic bodies they sit astride. See here for more on impingement and entrainment (and minimizing their harm) and here for more on the ecological stewardship practiced at nuclear energy plants. (I’m sure that coal and gas fired plants do this too, but that’s not our brief.)

Obviously, regulation that might have the impact of closing so many plants has to be considered very seriously and from all angles. Forcing nuclear energy plants to shutter at a time when their emission-free nature is so prized – and alternatives to cooling towers are so effective - seems nutty.  (It’s why the Supreme Court advocated a cost-benefit analysis be applied in these situations.)

The solution isn’t very tough to grasp. Here’s the North American Electric Reliability Corp., which manages the electricity grid:

“The pace and aggressiveness of these environmental regulations should be adjusted to reflect and consider the overall risk to the bulk power system. EPA, FERC, DOE and state utility regulators … should employ the array of tools at their disposal to moderate reliability impacts, including, among other things, granting required extensions to install emission controls”

That’s written in NERC-ese, but it contains a workable solution: clearly, the government and industry both want fish and other aquatic creatures to live happy and full lives, so a rule that allows utilities the flexibility to choose the “best available technology” that works best at their sites and permits cost-benefit analyses strikes a balance between the needs of business and the prerogatives of EPA. Granted, a “one-size-fits-all” rule makes things easier for EPA, but promises a good deal of unnecessary havoc for energy consumers.

None of this has come to pass yet – EPA expects to issue a draft rule, with a public comment period following, around February – but if you are so inclined, read through the documents referenced below and email the EPA and your representatives in Congress.

NEI has gathered together an extensive collection of documents on this issue. Start here and, if you want to know more, start googling. There’s a lot out there.

Oyster Creek.

10 comments:

Anonymous said...

The plant is too important to the local economy. I am not saying that Exelon is bluffing, but I do expect the announcement will spur locals to do whatever possible to keep the plant operating as along as they are able. My crystal ball shows Exelon receiving some local / state funds to help pay for the cooling tower(s). This would yield several win-wins (environmental, political and economic).

SteveK9 said...

As I understood it, studies have shown no effect on aquatic life in Barnegat Bay. It's just another irrational impediment being put in the path of nuclear energy, by those who don't like it --- for whatever reason.

Anonymous said...

If anything, there is likely a beneficial effect of the (limited) thermal discharge into Barnegat Bay. When my folks lived "down the shore", we'd always catch fish and crabs in the intake and discharge canals of OCNGS. The aquatic life there was abundant and flourished in the warm waters. One winter it was very cold and the rest of the bay froze over, but not the discharge canals (the plant kept humming along, cold, dreary weather or not, unlike solar power). It literally saved hundreds of swans which found open water and food in the unfrozen waters around the plant.

If the kooks succeed in forcing the plant to shutdown or use cooling towers, they will be personally responsible for significant death and destruction of wildlife and natural habitat in the vacinity of the plant.

Paul Lindsey said...

Anyone hear the result of this EPRI study that was supposed to be completed on 6/30/10: http://mydocs.epri.com/docs/AdvancedCooling/Task_Indirect_Dry_Cooling.pdf

In my home state of New Mexico, water usage is a big argument against thermal power plants and for wind & solar PV.

Anonymous said...

You may want to read up on how the Palo Verde plant dealt with the cooling water issue. It is in the middle of the desert, yet it is the largest (in terms of capacity and production) electricity-generating facility in the country. It hums along nicely and grinds out reliable, low-cost electricity in spite of not being adjacent to any large body of water.

gunter said...

Howdy folks,

Given that Oyster Creek is THE prototype for the troublesome GE Mark I BWRs, you'd think the rest of the industry would welcome the retirement of these Model Ts before something goes badly wrong? Oh,I almost forgot, you want to push these units for 80 years...

FYI:

Anon---NJ Senate Environment Committee hearings determined that there is more economy at risk from livelihoods lost as the result of the ecological collapse of Barnegat Bay than jobs at the nuke.

More of note than those bass fishing enthusiasts at the namesake reactor's ever hot discharge canal, the one indisputable fact that drove this early closure deal focuses on Oyster Creek taking in 1.4 billion gallons of water per day from Barnegat Bay.

If you do the math, 1.4 billion gallons per day equals 2.3% of the total 60 billion gallons in Barnegat Bay per day. So, a volume of water equivalent to over 800% of the total volume of the bay is strained of life each year.

Between now and 2019, Oyster Creek will still strain of bay life (spawn,fingerlings, etc.) from a volume of water equivalent to 7,200% of the total volume of Barnegat Bay. I could go on, but maybe you get the point.

SteveJ9---As I recall from being a principle instigator of the license renewal challenge at Oyster Creek, the evironmental report for license renewal application filed in 2005 relied upon a 30-year old study of Barnegat Bay impacts. So, despite NRC's predictable rubberstamp of the extension, Exelon's lawyers concluded that they did not have an legal leg to stand on in a law suit brought by the State.

So, rather than renewals, there are now two "countdowns to shutdowns" going at two of these antiquated GE Mark 1 BWRS; Vermont Yanke in March 2012 and Oyster Creek in December 2019.

Any bets on who is next?

I'll agree with Anon that there may yet be some shenanigans in the future for these deals. We'll have to sleep with one eye open.

Anonymous said...

Howdy, Folks,

Well, I lived there for years, went fishing in and around the plant's intake and discharge canals, and I can tell you from first hand experience that Barnegat Bay in that area is not now nor ever has been adversely impacted by plant operation. Aquatic life thrives in that area and is as healthy as any anywhere. No one has ever been harmed by OCNGS, "Model T" or not. The plant has been a reliable generator of low-cost power with essentially zero environmental impact. Replacing it's output with a dirty fossil gas-burning plant is sheer lunacy from an environmental viewpoint. Replacing a nuclear unit with 90% capacity factor, come snow, rain, heat, or cold, with some boondoggle of a windmill with maybe 25% capacity factor, stinks from a reliability and economic viewpoint. So take your "howdy" and stuff it.

Paul Lindsey said...

Regarding two EPRI studies:
"Application of Dry Cooling in Nuclear Power Plants" due 12/31/09
and "Assessment of Indirect Dry Cooling Systems" due 06/30/10

EPRI replied:
"These are actually "Project Proposals" that were drafted. EPRI did a prioritization with the funders and the two projects did not get ranked high enough to be funded, so there will be no report.

Sincerely,
Thomas Taylor
Electric Power Research Institute
Customer Assistance Center"

Foot, meet bullet.

Anonymous said...

"In my home state of New Mexico, water usage is a big argument against thermal power plants and for wind & solar PV."

So, how do the arguments go when people need electricity and the sun isn't shining and the wind isn't blowing? There are these strange natural phenomena called "night" and "calm days" (yes, these happen even in NM).

I'll answer my own question. The answer is either get the electricity from "somewhere else" (maybe that "somewhere" uses nuclear?), or burn more fossil fuel in the form of natural gas (methane), which is an unbelievably damaging greenhouse gas, as well as throwing tons more CO2 into the biosphere, totally uncontrolled, to be blown by the four winds to who knows where. So, some great "argument" that wind and solar PV make, eh?

gunter said...

No surprise that Anon neither gets the point nor has a sense of humor.