Power Play

Nukes like San Onofre may be exempted from the state's already watered-down policy on once-through cooling.

Good things come to those who wait. Unless you’re a fish.

Last week, Gov. Arnold Schwarzenegger’s office finally allowed the State Water Board to release a modified once-through-cooling power plant policy. The governor’s office held the policy hostage for months while every major power generator in the state lobbied heavily to weaken the last draft. What a surprise. The power brokers won. They should at least say “Thanks for the fish” like the dolphins in the “The Hitchhiker’s Guide to the Galaxy.”

For those keeping score at home: The State Water Board had already weakened the last version of the policy because of power industry lobbying, but the California Energy Commission, the Public Utility Commission and the California Independent System Operator supported the draft.

The environmental community largely welcomed the draft policy, but still wanted some of the loopholes filled, such as making the preferred compliance method one that does not rely on seawater for cooling power plants and instead requires air cooling.

Meanwhile, despite over two years of a painful public process, a technical advisory committee review and numerous opportunities to comment on the policy, the power industry by and large wanted to maintain the status quo.

Numerous lobbying trips to the governor’s office led to severe erosion of the technically sound policy. What did the power industry get for its troubles? Ka-ching!!  Here goes:

The nukes at Diablo Canyon and San Onofre got a potential way out of the policy altogether. 

Because nukes don’t produce greenhouse gases, and this administration has remained tough on climate change, the plants could use economics as an argument that saving marine life is just too darn expensive. 

They may even skate without having to implement any significant controls to reduce fish impingement and larval entrainment. I’m not sure if the decision to go with marine life death by boiling vs. acidification factored into the decision making, but I’m sure that the nukes’ arguments about the multibillion dollar cost to retrofit the plants played the key role.

The nukes getting their way isn’t much of a surprise, but the rest of the policy surprised even the most cynical of environmental leaders. 

One of the big national fights that the environmental community has won is the definition of “Best Technology Available.” Once-through-cooling is not BTA and there isn’t much debate that closed cycle or recycled cooling does count as BTA.

The state decided to waffle on the issue by providing two tracks to comply with the policy. The first makes it clear that a power plant would comply through the use of BTA – closed cycle or recycled cooling. The second track calls for reduction of the impingement and entrainment by the equivalent amount of reducing the flow by about 90% of the design flow, not the actual or generational flow.

That leaves plenty of opportunity for power plants to have fun with statistics and provide minimal reductions in actual cooling water flows, especially for all of the peaker plants that run only when base energy isn’t adequate to meet the local region’s needs. 

Thanks to the state removing its stated preference for the first track, guess which track that most power plants will choose?

The first, which will move California forward on energy efficiency, create green jobs and protect marine life? Or the ambiguous second track, which will allow for many power plants to maintain the status quo with the implementation of a few screens and intake flow management measures that surely won’t meet the marine life protection goals of S.316b of the Clean Water Act?

It’s definitely an easier pick than choosing the winner of the latest March Madness tourney. 

Furthermore, the state made the second track even weaker by regulating based on the design flow of the plant. Keep in mind that many of these coastal power plants were designed in the 1950s. Because much more efficient plants now exist, these older facilities only kick in during times of peak energy demand. They rarely, if ever, operate according to design.

So if plants are being asked to reduce their salt-water intake by roughly 80% a year, it’s easier to meet that goal if it’s based on designed potential rather than actual use.

Compliance should be determined based on the amount of flow actually needed to generate energy.

For some reason, the fish and larvae sucked into the power plant to make bouillabaisse don’t understand the real-world difference between how much ocean water actually gets sucked into the intake vs. a vastly larger engineering design flow that will make policy compliance easier.

But wait. That’s not all. Thanks to the lobbying of Moss Landing and LADWP, there is now a combined cycle power plant clause. If a power plant already ditched 1950s technology to go to combined cycle cooling, then it gets credit for that intake flow reduction.

The way the policy is written, it appears as if the facility gets to apply these flow reductions for the entire plant, even if only one or two units were converted to combined cycle.

There are other creative ways to meet policy requirements, like reducing intake flow velocity to 0.5 feet per second based on monthly flow to account for seasonal impacts. (There are more fish larvae in SoCal during the summer than in winter.)

So, there’s not much chance that any of those power plants will move to BTA in my lifetime. 

And if these watered-down compliance requirements are still too hard to meet, the energy industry can always go back to Cal-ISO to ask for extensions. Construction delays, CEQA compliance problems, financial issues and inclement weather could all lead to further appeals for delay.

The appeal process has been modified despite the multi-year extension of the many compliance deadlines, including those for DWP power plants. These extensions have been determined in conjunction with Cal-ISO, the Energy Commission and the Public Utilities Commission.

 The final decision on the policy rests with the State Water Board, which votes May 4.

The environmental community, business community and fishing community should get together to strongly advocate for a strengthened policy.

If they don’t, then the odds of California’s OTC policy making a significant beneficial difference for marine life will be similar to those of the Butler basketball team winning it all a week from tonight.

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