fishing for power lohner et al 5-1-06

7/30/2019 Fishing for Power Lohner Et Al 5-1-06

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114 E L E CT RI C P E RS P E CT I V E S

ENVIRONMENT

FISHING

FOR POWERBy Timothy Lohner, Douglas A. Dixon,and Elgin Perry

When most people familiar withthe Ohio River think about fishingthere, they imagine a hook and

line baited with a dough-ball for catfish.But that is not how it’s done when you’restudying the potential effects of powerplant operation on fish populations.

Tim Lohner is a principal environmental special-ist with American Electric Power; Doug Dixon is aprogram manager with EPRI; and Elgin Perry is astatistical consultant.

plant in the country, these fish collectionactivities have become more frequent andinvolved than ever before.

The U.S. Environmental ProtectionAgency (EPA) estimates that there are550 once-through cooled power plantsacross the country that must conduct newfish sampling programs. Twenty-sevenof those plants are along the Ohio River;and many of them are within the sameriver pool, some even within sight of eachother. Since each facility must do fishstudies, the Ohio River situation providesan excellent opportunity for a coordinatedsampling program. It was not hard toconvince most of the utility companies on

and trash racks and into the plant, wheresome can suffer injury or death due tomechanical stresses, elevated watertemperatures, and biocide treatments.Impingement occurs when larger organ-isms, typically larger fish and inverte-brates, are drawn to and trapped againstthe trash racks or screens.

Congress included section 316(b) aspart of the Federal Water Pollution Con-trol Act amendments of 1972. Under thisportion of the act, a cooling system oper-ator had to demonstrate that the “location,design, construction, and capacity of [its]cooling water intake structures reflect thebest technology available for minimizingadverse environmental impact.”

Initially, EPA allowed section 316(b)to be implemented on a case-by-case or

state-by-state basis. But, seeing incon-sistency in compliance requirementsacross states, a coalition of environmentalgroups sued EPA for failure to promulgatenational rules.

As a result, the agency issued newregulations in three phases. The phase Irule came out in December 2001 and cov-ers generating facilities built after January2002. The phase II rule, issued in July2004, covers all existing facilities that useat least 50 million gallons per day ofcooling water. The phase III rule— pro-posed in November 2004 and due to

receive final action in June 2006—willcover all remaining existing facilities.

The phase II rule has the most immedi-ate impact on the electric power industrybecause of the cost associated with com-pliance at existing facilities. Presenting asignificant challenge to power plants, thisrule contains national performance stan-dards that require companies to reduceimpingement 80-95 percent from baselineconditions and reduce entrainment atsome facilities 60-90 percent. (See thesidebar, “Calculating the Baseline.”)(Facilities subject to entrainment controlare those with intakes on oceans, estuar-ies, tidal rivers, and the Great Lakes, aswell as any facility that withdraws morethan 5 percent of a river’s mean annual

Researchers use hoop nets, gill nets,seines, and boats equipped with special-ized collection gear, electric generators,and sampling probes to collect fish fromthe open waters of the river for study.Equipment with even more specializationis used to collect fish that might accumu-late near plant intake systems.

Now that new Clean Water Act Section316(b) regulations require sampling atnearly every once-through cooled power

the river to combine their resources andapproach these studies in an organizedand collaborative manner.

Regulation of Cooling Water Intakes

The original 316(b) amendmentsaddressed concerns about losses to fishpopulations through entrainment andimpingement. Entrainment occurs whensmall aquatic organisms, typically fisheggs, larvae, and smaller invertebrates,pass through the typical intake screens

Electrofishing now occurs at night to be

more consistent with Ohio EPA and other

state agency sampling procedures.

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o h n e r , A E P




flow for cooling.) In the case of the OhioRiver, only one facility had to addressboth standards—the rest focused only onimpingement.

Power Plants on the River

The first coal-fired power plants wereconstructed in the Ohio River Valleyduring the late 1800s and early 1900s—there was little concern then about theeffects on local fish populations. At thesame time, damming for navigational pur-poses had changed the Ohio from a freeflowing, clear-water river, to a series ofimpoundments, in which industrialand domestic wastewater discharges

strongly influenced water quality. Stu-dies have shown that fish species (suchas mooneye, stonecat, and grass pickerel,which prefer clear water or clear waterwith aquatic vegetation) saw declining

populations during the 1800s in responseto the river modifications and increasingturbidity. Other species, such as blackbullhead and channel catfish, which aremore tolerant of degraded water quality,increased. Populations of skipjack herringand gizzard shad also increased duringthis period of declining river conditions.

How the Ohio’s fossil-fuel powerplants, which withdraw up to 500 milliongallons of water a day, affect those popu-

lations through impingementor entrainment is less obvious.

But itwas only a matter of time beforethere was a concern about howthese water withdrawals wouldaffect fish populations in theriver.

While river conditions didinitially decline, water qualitybegan to improve between 1950and 1970, following the instal-lation of sewage treatment facil-ities and greater regulation ofindustrial activities. And therewas a corresponding increase

in the abundance of numerousfish species. American ElectricPower (AEP) researchers con-ducted fish collections from1973 through 1985 and notedthat the abundance of 22 spe-cies, such as largemouth andspotted bass, had increased,while catches of seven typicallypollution-tolerant species, suchas black bullhead, had declined.Even with the ongoing concernabout entrainment and impinge-ment, the findings indicated

that the Ohio River fishery had improved,while at the same time there was anincreasing number of power plants alongthe river.

Historical Data

There is a large amount of historicalfish impingement data that researcherscan use to assess similarities in fish

populations and impingement rates at thevarious Ohio River facilities. The majorsource of data is the original impingementstudies, which were conducted at mostof the plants between 1977 and 1979,with some being done as late as 1986.Most of these studies followed a weeklyor biweekly sampling schedule, involving24- or 32-hour collection periods.

A second source of data is the OhioRiver Sanitation Commission (ORSANCO)

Lock Chamber fish study program,wherein ORSANCO staff, as well as otherstate agency fishery staff, collect fish fromthe dam lock chambers.

Perhaps the largest data source is theOhio River Ecological Research Program(ORERP), a utility-sponsored program in

Calculating the Baseline

The calculation baseline of impinge-

ment, as defined by the phase IIrule, is an estimate of the impinge-

ment mortality that would occur assum-

ing the intake is located flush with the

shoreline, the trash racks and 3/8-inch

mesh screens are aligned parallel to the

shoreline, and no fish protection tech-

nologies or other reduction measures are

in place. The rule, however, does allow

for a considerable amount of flexibility

on how to estimate the baseline rate of

impingement using

• historical impingement mortality and

entrainment data from the facility or from

another facility with comparable design,operational, and environmental condi-

tions;

• current biological data collected in the

water-body in the vicinity of the facility’s

cooling water intake structure; and

• current impingement mortality and en-

trainment data collected at the facility.

For example, historical 316(b) in-

formation may be used, provided it is

representative of current conditions and

was collected with adequate quality con-

trols in place. Impingement can also be

extrapolated from one facility to another

similarly designed facility, or new im-pingement studies can be conducted.

A white bass from impingement sampling.

Water quality on the Ohio River began to

improve between 1950 and 1970, follow-

ing the installation of sewage treatment

facilities and greater regulation of industrial

activities.

C o u r t e s y : T i m L

o h n e r , A E P




place since 1970 for the study and col-lection of fish and aquatic invertebratesupstream and downstream of generatingfacilities along the river. Utility companiesoriginally designed the program to evalu-ate the effects of discharging heated cool-

ing water on river fish populations.Fourteen power plant locations, from

river mile 53 through 946 (of the 981-mile Ohio) representing nine electriccompanies, have participated duringORERP’s 35-year history. Some facilitieshave been sampled nearly every year; oth-ers have been in the program only for ayear or two; still others have been in andout of the program over the entire period.

Multi-Facility Impingement

Sampling Approach

The phase II rule allows the use of histori-cal data to estimate impingement ratesand also recognizes the efficacy of apply-

ing that data to similar plants on similarwater bodies. So, with all the availablehistorical data and the close proximityand similarity of the Ohio River powerplants, why conductseparate 316(b) studies

at all 27 facilities, whenthe results are likely to besimilar? Since the plantsare likely to impinge thesame species and num-bers of fish, wouldn’t itbe better to coordinatethe sampling effort and take advantage ofthe flexibility allowed by the phase II ruleto estimate baseline impingement rates?Knowing that there could be significantcost savings by using historical data insome form made such an approach that

much more desirable. Moreover, theORERP framework could easily be used forphase II rule purposes.

Despite the historical data, there wererestrictions on how much could be used.

First of all, in most cases, the data werenearly 30 years old. In addition, mak-ing baseline impingement estimates onthe basis of fish populations in the river

is not feasible withoutlong-term, concurrently

collected impingement andpopulation data, which arenot available for any of thefacilities on the Ohio River.Still, it was possible todevelop a hybrid approach,which involves new

impingement studies as well as the use ofdata from nearby facilities. Working withtheir consultants, 12 Ohio River utilitycompanies are now working together tocost-effectively collect required informa-tion that will support 316(b) compliance

activities from each participating facility.Originally, electrofishing (stunning fisharound a boat with an electric current),

Wouldn’t it be bet-ter to coordinate thesampling effort andtake advantage of theflexibility allowed bythe phase II rule?




seining (dragging long, fine-meshednets through the water toward the shore),trawling (dragging a net behind a boat),hoop netting (trapping fish in a frameworknet), and gill netting (catch-

ing in a net by the gills)were used to collect fish forORERP, but to reduce costs,this has been limited toelectrofishing and seining.ORERP sampling involvesfish collection at threeupstream and three down-stream locations at eachparticipating plant, threetimes a year (spring, sum-mer, and fall). Electrofishing, originallydone during the day, now occurs at night

to be more consistent with Ohio EPA andother state agency sampling procedures.Habitat measurements are also takenaccording to ORSANCO procedures.

Estimating According to the Model

The group developed an impingementmortality sampling program based on“model-based estimation,” a survey

design tool used by

(among others) theDepartment of Energy,Department of Labor,and the Federal ReserveSystem.

The basic concept isthat you can predict thekey variable—the “vari-able of interest,” in thiscase, power plant fishimpingement—based

in part on context and in part on sampleinformation. Factored into the “context”of a sample are the location and sur-rounding conditions at the time of samplecollection. For example, if you know thatimpingement tends to be high in Augustand September, when the “young of theyear” grow to impingeable size, you can

use this information to improve the esti-mate of late summer impingement. If youobserve that a specific plant impingestwice as many fish on average as anotherplant, you can use this information to

improve the estimate of impingement atboth plants.

This is in contrast to other methods,which assume that the only informationon the variable of interest comes fromobservations in the sample. That is to say,only the mean from the sample is used toquantify the impingement estimate—evenif it seems to be an extreme outlier for aparticular plant at a particular time of year.Most utilities in the Midwest use tradi-tional impingement studies, which involvebiweekly or weekly sampling, according

to a stratified approach (that is, increasingthe sampling frequency during periods ofhigh impingement, as characteristicallyoccur on the Ohio River from mid-July

If you observe thata specific plant im-pinges twice as manyfish on average asanother plant, youcan use this informa-tion to improve theestimate of impinge-ment at both plants.


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through February). A traditional approach

typically requires that at least 39 to 52impingement samples be collected ateach power plant.

Under the proposed model-basedapproach, however, only 22 sampleswill be collected at each facility. In fact,despite the reduction in sampling fre-quency, this will improve the precisionover a standard approach: In the multi-facility design, the companies pool all theinformation, allowing a better estimateof the extent of variation and tighter confi-

dence intervals around sample means.To verify that the model-basedapproach would work, the group testedit in simulations using the historical

Impingement monitoring. An advantage of

this program is that one consultant conducts

all the sampling, ensuring consistent meth-

odology at each facility.

C o u r t e s y : E A

E n g i n e e r i n g

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M A Y / J U N E 2 0 0 6 123

impingement data for the Ohio Riverpower plants. The result was that ifonly eight power plants participated inthe study, they would find an improvedlevel of precision, even if the samplingfrequency were as low as once in fourweeks. Because the proposed designincludes fifteen power stations andbiweekly sampling during the highimpingement season, the group antici-pates even better results. Moreover, costswould be less: The savings estimate forAEP is more than 60 percent of what theutility would have spent by itself.

Road Trip to Real World

It was time to hit the road and explainthe program to state agencies. Since theprogram proposes reducing the frequency

of monitoring, the group was concernedthat regulatory agencies would not acceptit. Utility representatives met with agencystaff in all the Ohio River states—therewere also two meetings with ORSANCO,the multistate agency that regulates waterquality activities for the entire Ohio Rivermain stem. Indeed, staff members ineach state were initially skeptical of theprogram but ultimately agreed that, on thebasis of economic savings, administra-tive efficiencies, and technical merit, theprogram was worth pursuing.

Fish impingement monitoring at the

Ohio River facilities began in July 2005and will continue through December2006. EA Engineering, Science andTechnology conducts the testing and hashad to establish two field offices—onein Ohio and one in Kentucky—to handlethe logistics of such a large program.Sampling involves 24-hour coverage ateach facility and includes day and nightestimates of impingement mortality. EA

collects the fish and identifies, counts,and notes them as either live, fresh dead,or long dead. Up to 50 individuals of eachspecies and size class (young of the yearand adult) are individually weighed andmeasured. An advantage of this programis that one consultant conducts all thesampling, ensuring consistent method-

ology at each facility. This is in contrastto the variety of consultants conductingstudies independently at other facilitiesthroughout the country.

When it is all done, the result will bea database of in-river fish assemblageand population data, along with nearlysimultaneous collection of impingementdata. Such a comprehensive spatial andtemporal database has never existedbefore. It will allow the analysis of therelationship between field data and plantimpingement rates, as well as the analysisof the relationship between impingementrates and intake structure design charac-teristics. Such relationships could pro-vide an approach to establish a theoreticalimpingement mortality baseline for eachparticipating plant according to the phase

II rule definition of the baseline. Thiscould lead to obtaining credit for intakefeatures that protect the environment,

Environmentally-friendly,Economically-sound.

Many states are imposing new requirements to tightenemissions controls, establish renewable portfolio standards,

and regulate reductions and/or mitigation of carbon dioxideemissions.

This is a new challenge for many, but familiar territory forIUEP, which has led the way in environmentally-friendly energyproject development, including more than 60 million metric tonsof CO2 reductions since our inception in 1995.

Please contact Ron Shiflett to discuss how we can helpyou identify investments that may assist you in meeting newregulations and secure these investments with proper planningand documentation.

IUEP proudly leads the International Power Partnerships initiative, an importantpart of President Bush’s voluntary climate change program. IUEP supports the Administration’s Methane to Markets and Asia Pacific Partnerships initiatives.

Ronald C. Shiflett, Jr.International Utility Efficiency Partnerships, Inc.2000 L Street, NWSuite 805Washington, DC 20036 USA+1 (202) 293-7992www.iuep.org An Affiliate of EEI

reduce the impingement rate, and therebyreduce the impingement mortality per-formance standard and the plant-specificfinancial liability associated with comply-ing with the rule.

Catching Fish

The ORERP multi-facility program is anexcellent example of cooperation amongOhio River utilities to help meet regula-tory requirements and study the fishpopulations of the Ohio River. To thatextent, it is a model for similar programson other major U.S. river systems andwater bodies.

So next time you think of fishing on theOhio River, remember that power compa-nies are also catching fish. But they areinterested in much more than sport. They

want to know how those fish are doingand whether or not power plants willaffect their overall well-being. It may notbe traditional fishing, but the companiesare out there, “fishing for power.” ◆

fishing for power lohner et al 5-1-06

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