ENVIRONMENT

FISHING FOR POWER

By Timothy Lohner, Douglas A. Dixon, and Elgin Perry

hen most people familiar with the Ohio River think about fishing there, they imagine a hook and line baited with a dough-ball for catfish. But that is not how its done when youre studying the potential effects of power plant operation on fish populations.

plant in the country, these sh collection activities have become more frequent and involved than ever before. The U.S. Environmental Protection Agency (EPA) estimates that there are 550 once-through cooled power plants across the country that must conduct new sh sampling programs. Twenty-seven of those plants are along the Ohio River; and many of them are within the same river pool, some even within sight of each other. Since each facility must do sh studies, the Ohio River situation provides an excellent opportunity for a coordinated sampling program. It was not hard to convince most of the utility companies on

Researchers use hoop nets, gill nets, seines, and boats equipped with specialized collection gear, electric generators, and sampling probes to collect fish from the open waters of the river for study. Equipment with even more specialization is used to collect fish that might accumulate near plant intake systems. Now that new Clean Water Act Section 316(b) regulations require sampling at nearly every once-through cooled power
Tim Lohner is a principal environmental specialist with American Electric Power; Doug Dixon is a program manager with EPRI; and Elgin Perry is a statistical consultant.

Electroshing now occurs at night to be more consistent with Ohio EPA and other state agency sampling procedures.

the river to combine their resources and approach these studies in an organized and collaborative manner.
Regulation of Cooling Water Intakes

The original 316(b) amendments addressed concerns about losses to sh populations through entrainment and impingement. Entrainment occurs when small aquatic organisms, typically sh eggs, larvae, and smaller invertebrates, pass through the typical intake screens

and trash racks and into the plant, where some can suffer injury or death due to mechanical stresses, elevated water temperatures, and biocide treatments. Impingement occurs when larger organisms, typically larger sh and invertebrates, are drawn to and trapped against the trash racks or screens. Congress included section 316(b) as part of the Federal Water Pollution Control Act amendments of 1972. Under this portion of the act, a cooling system operator had to demonstrate that the location, design, construction, and capacity of [its] cooling water intake structures reect the best technology available for minimizing adverse environmental impact. Initially, EPA allowed section 316(b) to be implemented on a case-by-case or state-by-state basis. But, seeing inconsistency in compliance requirements across states, a coalition of environmental groups sued EPA for failure to promulgate national rules. As a result, the agency issued new regulations in three phases. The phase I rule came out in December 2001 and covers generating facilities built after January 2002. The phase II rule, issued in July 2004, covers all existing facilities that use at least 50 million gallons per day of cooling water. The phase III rule proposed in November 2004 and due to receive nal action in June 2006will cover all remaining existing facilities. The phase II rule has the most immediate impact on the electric power industry because of the cost associated with compliance at existing facilities. Presenting a signicant challenge to power plants, this rule contains national performance standards that require companies to reduce impingement 80-95 percent from baseline conditions and reduce entrainment at some facilities 60-90 percent. (See the sidebar, Calculating the Baseline.) (Facilities subject to entrainment control are those with intakes on oceans, estuaries, tidal rivers, and the Great Lakes, as well as any facility that withdraws more than 5 percent of a rivers mean annual

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Courtesy: Tim Lohner, AEP

ow for cooling.) In the case of the Ohio River, only one facility had to address both standardsthe rest focused only on impingement.
Power Plants on the River

The rst coal-red power plants were constructed in the Ohio River Valley during the late 1800s and early 1900s there was little concern then about the effects on local sh populations. At the same time, damming for navigational purposes had changed the Ohio from a free owing, clear-water river, to a series of impoundments, in which industrial and domestic wastewater discharges

A white bass from impingement sampling. Water quality on the Ohio River began to improve between 1950 and 1970, following the installation of sewage treatment facilities and greater regulation of industrial activities.

strongly inuenced water quality. Studies have shown that sh species (such as mooneye, stonecat, and grass pickerel, which prefer clear water or clear water with aquatic vegetation) saw declining populations during the 1800s in response to the river modications and increasing turbidity. Other species, such as black bullhead and channel catsh, which are more tolerant of degraded water quality, increased. Populations of skipjack herring and gizzard shad also increased during this period of declining river conditions. How the Ohios fossil-fuel power plants, which withdraw up to 500 million gallons of water a day, affect those populations through impingement or entrainment is less obvious. But it was only a matter of time before there was a concern about how these water withdrawals would affect sh populations in the river. While river conditions did initially decline, water quality began to improve between 1950 and 1970, following the installation of sewage treatment facilities and greater regulation of industrial activities. And there was a corresponding increase in the abundance of numerous sh species. American Electric Power (AEP) researchers conducted sh collections from 1973 through 1985 and noted that the abundance of 22 species, such as largemouth and spotted bass, had increased, while catches of seven typically pollution-tolerant species, such as black bullhead, had declined. Even with the ongoing concern about entrainment and impingement, the ndings indicated that the Ohio River shery had improved, while at the same time there was an increasing number of power plants along the river.
Courtesy: Tim Lohner, AEP

Calculating the Baseline

he calculation baseline of impingement, as defined by the phase II rule, is an estimate of the impingement mortality that would occur assuming 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 technologies 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 conditions; current biological data collected in the water-body in the vicinity of the facilitys cooling water intake structure; and current impingement mortality and entrainment data collected at the facility. For example, historical 316(b) information may be used, provided it is representative of current conditions and was collected with adequate quality controls in place. Impingement can also be extrapolated from one facility to another similarly designed facility, or new impingement studies can be conducted.

Historical Data

There is a large amount of historical sh impingement data that researchers can use to assess similarities in sh
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populations and impingement rates at the various Ohio River facilities. The major source of data is the original impingement studies, which were conducted at most of the plants between 1977 and 1979, with some being done as late as 1986. Most of these studies followed a weekly or biweekly sampling schedule, involving 24- or 32-hour collection periods. A second source of data is the Ohio River Sanitation Commission (ORSANCO) Lock Chamber sh study program, wherein ORSANCO staff, as well as other state agency shery staff, collect sh from the dam lock chambers. Perhaps the largest data source is the Ohio River Ecological Research Program (ORERP), a utility-sponsored program in

place since 1970 for the study and collection of sh and aquatic invertebrates upstream and downstream of generating facilities along the river. Utility companies originally designed the program to evaluate the effects of discharging heated cooling water on river sh populations. Fourteen power plant locations, from river mile 53 through 946 (of the 981mile Ohio) representing nine electric companies, have participated during ORERPs 35-year history. Some facilities have been sampled nearly every year; others have been in the program only for a year or two; still others have been in and out of the program over the entire period.
Multi-Facility Impingement Sampling Approach

The phase II rule allows the use of historical data to estimate impingement rates and also recognizes the efcacy of apply-

ing that data to similar plants on similar First of all, in most cases, the data were water bodies. So, with all the available nearly 30 years old. In addition, makhistorical data and the close proximity ing baseline impingement estimates on and similarity of the Ohio River power the basis of sh populations in the river plants, why conduct is not feasible without Wouldnt it be betseparate 316(b) studies long-term, concurrently at all 27 facilities, when ter to coordinate the collected impingement and the results are likely to be sampling effort and population data, which are similar? Since the plants take advantage of the not available for any of the are likely to impinge the facilities on the Ohio River. exibility allowed by Still, it was possible to same species and numthe phase II rule? bers of sh, wouldnt it develop a hybrid approach, be better to coordinate which involves new the sampling effort and take advantage of impingement studies as well as the use of the exibility allowed by the phase II rule data from nearby facilities. Working with to estimate baseline impingement rates? their consultants, 12 Ohio River utility Knowing that there could be signicant companies are now working together to cost savings by using historical data in cost-effectively collect required informasome form made such an approach that tion that will support 316(b) compliance much more desirable. Moreover, the activities from each participating facility. Originally, electroshing (stunning sh ORERP framework could easily be used for around a boat with an electric current), phase II rule purposes. Despite the historical data, there were restrictions on how much could be used.

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Estimating According to the Model seining (dragging long, ne-meshed The group developed an impingement nets through the water toward the shore), mortality sampling program based on trawling (dragging a net behind a boat), model-based estimation, a survey hoop netting (trapping sh in a framework design tool used by net), and gill netting (catch(among others) the If you observe that ing in a net by the gills) Department of Energy, were used to collect sh for a specic plant imORERP, but to reduce costs, pinges twice as many Department of Labor, and the Federal Reserve this has been limited to sh on average as System. electroshing and seining. another plant, you The basic concept is ORERP sampling involves can use this informa- that you can predict the sh collection at three key variablethe varition to improve the upstream and three downstream locations at each estimate of impinge- able of interest, in this participating plant, three ment at both plants. case, power plant sh impingementbased times a year (spring, sumin part on context and in part on sample mer, and fall). Electroshing, originally information. Factored into the context done during the day, now occurs at night of a sample are the location and surto be more consistent with Ohio EPA and rounding conditions at the time of sample other state agency sampling procedures. collection. For example, if you know that Habitat measurements are also taken impingement tends to be high in August according to ORSANCO procedures. and September, when the young of the year grow to impingeable size, you can

use this information to improve the estimate of late summer impingement. If you observe that a specic plant impinges twice as many sh on average as another plant, you can use this information to improve the estimate of impingement at both plants. This is in contrast to other methods, which assume that the only information on the variable of interest comes from observations in the sample. That is to say, only the mean from the sample is used to quantify the impingement estimateeven if it seems to be an extreme outlier for a particular plant at a particular time of year. Most utilities in the Midwest use traditional impingement studies, which involve biweekly or weekly sampling, according to a stratied approach (that is, increasing the sampling frequency during periods of high impingement, as characteristically occur on the Ohio River from mid-July

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Impingement monitoring. An advantage of this program is that one consultant conducts all the sampling, ensuring consistent methodology at each facility.

Courtesy: EA Engineering Science and Technology

through February). A traditional approach typically requires that at least 39 to 52 impingement samples be collected at each power plant. Under the proposed model-based approach, however, only 22 samples will be collected at each facility. In fact, despite the reduction in sampling frequency, this will improve the precision over a standard approach: In the multifacility design, the companies pool all the information, allowing a better estimate of the extent of variation and tighter condence intervals around sample means. To verify that the model-based approach would work, the group tested it in simulations using the historical

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impingement data for the Ohio River power plants. The result was that if only eight power plants participated in the study, they would nd an improved level of precision, even if the sampling frequency were as low as once in four weeks. Because the proposed design includes fteen power stations and biweekly sampling during the high impingement season, the group anticipates even better results. Moreover, costs would be less: The savings estimate for AEP is more than 60 percent of what the utility would have spent by itself.
Road Trip to Real World

It was time to hit the road and explain the program to state agencies. Since the program proposes reducing the frequency of monitoring, the group was concerned that regulatory agencies would not accept it. Utility representatives met with agency staff in all the Ohio River statesthere were also two meetings with ORSANCO, the multistate agency that regulates water quality activities for the entire Ohio River main stem. Indeed, staff members in each state were initially skeptical of the program but ultimately agreed that, on the basis of economic savings, administrative efciencies, and technical merit, the program was worth pursuing. Fish impingement monitoring at the Ohio River facilities began in July 2005 and will continue through December 2006. EA Engineering, Science and Technology conducts the testing and has had to establish two eld ofcesone in Ohio and one in Kentuckyto handle the logistics of such a large program. Sampling involves 24-hour coverage at each facility and includes day and night estimates of impingement mortality. EA collects the sh and identies, counts, and notes them as either live, fresh dead, or long dead. Up to 50 individuals of each species and size class (young of the year and adult) are individually weighed and measured. An advantage of this program is that one consultant conducts all the sampling, ensuring consistent method-

ology at each facility. This is in contrast to the variety of consultants conducting studies independently at other facilities throughout the country. When it is all done, the result will be a database of in-river sh assemblage and population data, along with nearly simultaneous collection of impingement data. Such a comprehensive spatial and temporal database has never existed before. It will allow the analysis of the relationship between eld data and plant impingement rates, as well as the analysis of the relationship between impingement rates and intake structure design characteristics. Such relationships could provide an approach to establish a theoretical impingement mortality baseline for each participating plant according to the phase II rule denition of the baseline. This could lead to obtaining credit for intake features that protect the environment,

reduce the impingement rate, and thereby reduce the impingement mortality performance standard and the plant-specic nancial liability associated with complying with the rule.
Catching Fish

The ORERP multi-facility program is an excellent example of cooperation among Ohio River utilities to help meet regulatory requirements and study the sh populations of the Ohio River. To that extent, it is a model for similar programs on other major U.S. river systems and water bodies. So next time you think of shing on the Ohio River, remember that power companies are also catching sh. But they are interested in much more than sport. They want to know how those sh are doing and whether or not power plants will affect their overall well-being. It may not be traditional shing, but the companies are out there, shing for power.

Environmentally-friendly, Economically-sound.
any states are imposing new requirements to tighten emissions controls, establish renewable portfolio standards, and regulate reductions and/or mitigation of carbon dioxide emissions. This is a new challenge for many, but familiar territory for IUEP, which has led the way in environmentally-friendly energy project development, including more than 60 million metric tons of CO2 reductions since our inception in 1995. Please contact Ron Shiett to discuss how we can help you identify investments that may assist you in meeting new regulations and secure these investments with proper planning and documentation.

IUEP proudly leads the International Power Partnerships initiative, an important part of President Bushs voluntary climate change program. IUEP supports the Administrations Methane to Markets and Asia Pacic Partnerships initiatives.

Ronald C. Shiett, Jr. International Utility Efciency Partnerships, Inc. 2000 L Street, NW Suite 805 Washington, DC 20036 USA +1 (202) 293-7992 www.iuep.org An Afliate of EEI

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