Strengthen Requirements to Reduce Fish Kills at Power Plants - RiverU Proposal by Evelyn Grainger and Thomas O'Rourke

An act to reduce the environmental impacts of power plants along the Hudson River by amending sections 316 A and B of the Federal Clean Water Act in relation to once-through cooling systems and fish monitoring systems.


Thomas O’Rourke and Evelyn Grainger

Thomas O’Rourke and Evelyn Grainger

  • Strengthen Section 316 (b) of the Clean Water Act by improving the definition of Best Technology Available to require development of economically smart solutions for individual power plants that utilize once-through cooling systems. This includes analyzing economic impacts of technology such as:
    • Closed-system cooling
    • Fish monitoring systems
    • Improved fish screens
    • Promoting energy efficiency through new technology
    • Exploring alternative energy resources
  • To strengthen the definition of heat as a pollutant in Section 316 (a), to specify it has a negative impact on the environment, and requires the adoption a 10 year plan to force reduction of thermal pollution:
    • 25% reduction in 3 years
    • 50% reduction in 7 years


There are currently four power plants along the Hudson River that rely on once-through cooling systems: Bowline, Danskammer, Indian Point, and Roseton. Amongst the four plants, it is estimated that more than 2.2 billion are entrained and 1.4 million fish are impinged. Nuclear power plants are 33% efficient, 1 unit energy going to the grid and 2 units exiting as heat out to environment. Any power plants utilizing once-through cooling systems are in violation of the Clean Water Act because heat is defined as a pollutant in section 316 C. Of the 104 nuclear power plant reactors in the United States, 60 use once through cooling systems, drawing massive amounts of water from rivers, lakes, and oceans.

Aquatic Ecosystem Impacts

  • 25,000-60,000 gallons water are used for each megawatt-hour of electricity, consuming and discharging about 2.5 billion gallons of water per day, directly impacting the aquatic ecosystems.
  • Fish, eggs and larvae are not protected by screens currently used; entrainment and impingement causes death to the fish.

o   Fish larvae and eggs are entrained because they are too small to be trapped by the screens.

o   Fish are impinged upon the screens.

  • Biodiversity and the health of ecosystems are affected, as fish are a significant source of food to other species and consume smaller organisms.
  • Temperature shock kills fish. Discharged water is 25-30⁰F warmer, disrupting aquatic life in the surrounding area, reducing oxygen, decreasing population sizes, causing fish kills, and affecting metabolic rates of aquatic animals.

Defining Best Technology Available

316 Section B requires that “cooling water intake structures reflect the best technology available for minimizing adverse environmental impact.” This language is unnecessarily vague and problematic to implement and enforce.

  • Closed Cooling System
    • Utilizes 97% less water, preventing large scale fish kills and the destruction of aquatic ecosystems.
    • The estimated cost for the project is $1.6 billion for materials and labor.
    • The temporary shut down for the upgrade would not mean the plant would have to fire or lay off workers, in fact would create jobs.
    • Upgrades are estimated to cost only 1 cent per kilowatt-hour for consumers.
  • Fish Monitoring Systems
    • Power plants are legally required to shut down during spawning season to protect eggs and larvae from being sucked into the power plant, but it is difficult to predict because of the size and unknown patterns of the eggs.
    • Monitoring systems can predict and develop known patterns of fish spawning.
    • The only monitoring of the fish and eggs is done by occasional sampling, which is both time consuming and unreliable.
  • Wedge Wire Screen
    • The $200 million screens collect fish and eggs before entering the cooling system, costing significantly less than the construction of cooling towers.
    • Prevents 51-91% more fish deaths in comparison to the once through cooling system than most power plants.

Indian Point

  • Indian point 2 is currently running on an extended license, as its previous license expired in September of 2013. Indian Point 3’s license will be expiring in December of 2015.
  • Indian Point lost their Water Quality certification.
  • Closing Indian Point would create a competitive market for developing new energy resources for the same quantity at a lower cost, environmentally and economically for New York State.