Water Quality Permit for
by John Dobken
"NMFS does not have design criteria specifically for cylindrical screens oriented parallel with the current in flowing water. . ."
Re: CBB, Oct. 31, 2014, "Groups File Suit Challenging Water Quality Permit For Northwest's Only Nuclear Plant"
Last Thursday, three anti-nuclear environmental groups filed a petition questioning the National Pollutant Discharge Elimination System permit issued to Energy Northwest for Columbia Generating Station by EFSEC, a Washington state agency. The previous NPDES permit was issued in 2006.
In the petition there were many serious allegations, including "Petitioners believe the evidence shows that discharges from the plant will adversely impact water quality in the Columbia River." And this: "The cooling water intake structures that remove water from the Columbia River may have resulted and may continue to result in the impingement and entrainment of fish."
Generally, people use words such as "believe" and "may" when they are unsure, i.e. they don't know. That seems to be the case here. Even though more than 4,000 pages of documentation was submitted by the petitioners during the review process, none of the information relating to any existing, specific ecological harm made it into the appeal. Strange.
Fortunately, we can be certain we are in regulatory compliance because we monitor, test and validate our environmental impacts. So let's take these anti-nuke points one at a time.
-- Water Quality in the Columbia
Columbia Generating Station has no effect on the Columbia River. The anti-nuclear groups suing the state say Columbia Generating Station pulls 20 million gallons out of the Columbia River daily.
It's actually closer to 24 million, and it's insignificant. About 35 - 40 million gallons of water pass by our discharge point every minute. (After the Snake and Columbia join together, about 85 million gallons flow past The Dalles every minute).
Of the water we take from the river, an average of 1,700 gallons per minute is returned to the river. What's in that water?
All you have to do to find out is look at the monthly Discharge Monitoring Report that is submitted by Energy Northwest to EFSEC.
In the September 2014 report, pH levels were within limits; halogens were near undetectable at less than or equal to 0.1 micrograms per liter; Copper was at 8 micrograms/liter against a permit level of 345 micrograms/liter; and Chromium and Zinc were at 1.3 and 17 micrograms/liter, respectively. In the current permit, there are no requirement levels associated with these parameters. That actually changes in the new permit. The acceptable levels for both are 8.2 micrograms/liter for chromium and 53 micrograms/liter for zinc. So we are still well below even the new standards. The existing and the new permit set a zero standard for PCBs and a non-detection standard for 126 priority pollutants. (Note: both chromium and zinc are already present in the Columbia River.)
Energy Northwest remains in full compliance with all environmental regulations related to our circulating water discharge. Period.
So when Nina Bell, executive director of Northwest Environmental Advocates, says "This nuclear reactor is one of many sources of toxic chemicals that are contaminating the fish and wildlife of the Columbia River. . .", one has to wonder what scientific study is informing her opinion?
We have environmental testing that informs our opinion. We did biological assessment testing as part of our existing permit and will do even more with the new permit. That testing told us our circulating water outfall has no impact on the river ecology. The testing under the new permit will take place quarterly.
-- Intake Structure
Columbia Generating Station gets its cooling water from the Columbia River "through two 42-inch diameter inlets perforated with 3/8 inch diameter holes, each approximately 20 feet long and placed parallel to river flow approximately 350 feet offshore at low water. Water flows by gravity to the River Pumphouse. The intake structures for CGS were designed and constructed in the late 1970s." (CGS-NPDES Fact Sheet p.20).
As the fact sheet points out, the intakes were designed "to minimize the impact of make-up water from the Columbia River, with particular emphasis on salmonid fry." And that's what it has been doing for 30 years.
How do we know this? From the two studies that were conducted, pre- and post-operational.
In the 1985 study the monitoring program looked at both impingement and entrainment between April and September. No juvenile salmonids were found to be affected. None. This monitoring program was undertaken with study-plan review by the National Marine Fisheries Service.
Indeed, the anti-nuclear activists seem to hang a big part of their petition on the NMFS opinion, an opinion that has now been found to be without merit twice (the first time being Columbia's license renewal where the Nuclear Regulatory Commission found their argument uncompelling).
In part this is because the NMFS design criteria for intake structures pertains to models not utilized by Columbia Generating Station. As Dr. Charles Coutant wrote in his discussion paper prepared for a meeting with the agency in 2013: "NMFS does not have design criteria specifically for cylindrical screens oriented parallel with the current in flowing water. . ." That's a biggie.
Still, EFSEC wanted to address the NMFS concerns. So in the new permit (now in effect) a new study will be undertaken to update the entrainment data from the 1985 study that found zero impact on fish.
Again, the science will inform us.
Energy Northwest is currently evaluating its response option to the petition.
For more documents related to the Columbia Generating Station NPDES permit, visit the EFSEC website.
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