Water Use
Electricity Production. 

The Indian Point reactors produce about 2,000 megawatts of electricity. The New York City/Westchester grid uses 9,000 to 13,000 megawatts daily, depending on the temperature. Elementary school division reveals Indian Point provides 15 to 22 percent of the region’s electrical power at most.  Check the Con Ed web site and you will see that 30 percent of the electricity they purchase comes from nuclear power.  However, this includes all of the reactors in New York and two in New Jersey - not just Indian Point.

Water Usage

Indian Point is the single largest user of water in the state. The twin, 40-foot-wide intake conduits to the two power plants take in 2.5 billion gallon of Hudson River water daily.  At 10 feet a story that makes the pipe as wide as a four story building is tall. Every year the once through cooling system at Indian Point uses the equivalent of twice the volume of the river from the Battery to Troy, a distance of 183 mile. This is documented in the Environmental Impact Study published by the New York Department of Environmental Conservation in 2003. Other power plants use a lot of water also, but not as much as Indian Point. Despite Entergy’s claims, the DEC is not singling out Indian Point for special treatment. The DEC web site documents a clear intention to regulate all large users of river water and bring them into compliance with the law.  They are already in discussion with Domino's Sugar in Yonkers. The difference is that most other companies are working with the DEC while Entergy is waging an expensive public relations campaign, trying to influence legislators, and hoping to avoid spending the money necessary to come into compliance with the law.


Fish Kill and the Thermal Plume

Every year 1.5 billion fish are sucked into the plant’s intake system. This figure does not include the fish eggs, larvae or plankton which are also drawn in through the 40 foot wide intake pipe. Entergy’s propaganda to the contrary, the death of two billion fish each year is not “well within the bounds of the ecosystem’s ability to replace the loss.” This argument has lost at every judicial proceeding to date. There is no comparison between 1.5 billion fish that fail to reach maturity because they are eaten by other fish and nourish the food chain and 1.5 billion fish vacuumed out of the food chain by the intake pipes, killed, and then dumped back into the Hudson River as decaying organic matter. Removing so much from the bottom of the food chain has an adverse impact on the entire ecosystem. 

As part of the environmental impact assessment, the New York State Department of Environmental Conservation counted the number of 5 species of fish – two surface dwellers, one mid level swimmer and two bottom dwelling fish over the course of a year and found that an additional 500 million fish died when they encountered the thermal plume from the hot water dumped back into the river as part of once-through cooling.  The water in the thermal plume from the plant is returned to the river 30 degrees hotter than river water. This and more is detailed in the Environmental Impact Study released by the NY State Department of Environmental Conservation in 2003. Entergy has filed appeals at every step of the way but these findings have been upheld in every succeeding court proceeding.


Closed Cycle Cooling

There is a difference between closed cycle cooling and cooling towers. The terms are not interchangeable.  As the name implies, closed cycle cooling reduces the need for water by reusing the same water over and over again. Water usage is reduced by average of 95 percent. It also eliminates 95 percent of fish killed from entrainment and impingement and 100% of those killed by the thermal plume. 

There are several different methods of closed cycle cooling.  One is cooling towers another is mechanical draft or a smaller, cheaper radiator type of closed cycle cooling. The DEC has not required Entergy to use cooling towers.  It has required them to go to closed cycle cooling which is common in the industry. Vermont Yankee, a reactor owned by Entergy, already has the radiator type closed cycle cooling in place. Industry web sites put the cost of this type of closed cycle cooling at about $300 to $400 hundred million. Cooling towers are much more expensive and it is highly unlikely that Entergy would elect to use them because of this.

 Entergy is deliberately obscuring the difference between closed cycle cooling and cooling towers. They are painting a picture of towers despoiling the view scape and creating a perpetual fog over Buchanan, lengthy shutdowns for installation and rising electricity rates.  They are making a worst case scenario for both cost and aesthetics which allows them to generate  fear in the public mind of higher electricity bills as the costs of construction are passed on to consumers. There are no known problems with pollution from cooling towers despite Entergy claims to the contrary.  It would be highly unproductive for EPA to set standards for the Clean Water Act that would violate the Clean Air Act. For more details on closed cycle cooling please read the section on the DEC at the bottom of this paper.


Wedge Wire

Entergy fought closed cycle cooling until February 2010 when the draft discharge permit showed they would not get a new water quality certificate without it. At that point, they offered to install screens which would essentially cap the river end of the intake pipe.  This is the wedge wire system which they are proposing as an alternative to closed cycle cooling. The screens are far from the state of the art that Entergy has been advertising; they are designed for lake use, have not been widely tested and have not been tested in a fast moving river like the Hudson.  Entergy’s widely advertised offer to use these screens as a substitute for closed cycle cooling is a public relations dodge, not a solution to a real environmental problem. Wedge wire does not address the water usage problem or the thermal discharge which does so much documented damage to the ecosystem. It is important to note that Entergy, along with Riverkeeper, argued against wedge wire in a federal case decided by the Supreme Court Decision in  2009. This unusual turn of events came about because both Riverkeeper and Entergy used the same EPA data which showed that wedge wire was designed for small systems under 100 million gallons a day. At  that point, Entergy in its brief stated that  "wedge wire is not an option available to nuclear power plants" because they use more than two billion gallons of  water a day. 


Cost Benefit Analysis

Under the Bush Administration, all prospective environmental regulations had to go through the Office of Management and Budget for a Cost Benefit Analysis. If a proposed rule was deemed to cost corporations money to implement, it was rejected. The Environmental Protection Agency found that while the dead fish in the Hudson River could be valued at nearly one billion dollars, the commercial value was less than $50 million since there is no commercial fishing allowed in our PCB-laden river. It found that a closed cycle cooling system for Indian Point would cost about $300 million. Therefore, since the way they figured the commercial value of the fish was so much less than the cost of remediation, EPA did not require implementation of the best technology available.

In March 2010 this changed as a result of a suit brought by Riverkeeper and Assemblyman Richard Brodsky. The Supreme Court ruled that an agency mayconsider cost benefit analysis when a rule is being promulgated,  it is not requiredto do so. New York State DEC has said that it would take cost benefit analysis into account if Entergy would provide actual engineering specs of the type of closed cycle cooling system they plan to install and the actual construction permit. See the letter to Entergy spelling out all of this on the DEC web site. Entergy has declined to provide any documentation, preferring to mount a million dollar publicity campaign and outreach to legislators featuring 1.4 billion dollar cooling towers rather than the cheaper radiator or mechanical draft type closed cycle cooling.


New York State Department of Environmental Conservation Recommendations

In the policy document Best Technology Available for Cooling Water Intake structures dated  March 4, 2010 The New York State Department of Environmental Conservation  establishes cooling towers or "or dry closed cycle cooling" as the best technology available for new construction.  For retro fittingexisting plants "wet closed cycle cooling" or mechanical draft is recommended. 

Here's the difference: dry closed cycle cooling uses air to cool the water which is why towers are essential to the design. It eliminates water use by 97% and fish kill by 95% which is why it is gold standard for new construction. Wet closed cycle cooling uses some water but only 2 to 7% as much as the current once through system.  Fish kill is just as markedly reduced. Therefore, it still meets the criteria for best technology available. The wet closed cycle cooling or mechanical draft system operates much like a car radiator. It is standard in the industry, much cheaper than cooling towers and less obtrusive. The system is housed in  large industrial type buildings. Vermont Yankee, another somewhat smaller plant which Entergy owns, has had this system in place for years 

The EPA guidelines call for less than a 4% impact on company profits. Entergy calculates its revenue from Indian Point at 24 billion  dollars over the life of its 20 year license renewal.  The EPA has estimated that a mechanical draft system would cost three hundred to four hundred million dollars, That means it would cost about 1.25% of Entergy's profits over 20 years to install and operate a mechanical draft system. Even though the DEC does not recommend cooling towers for a retrofit, the cost, according to Entergy, is 1.4 billion dollars. This represents 5.9% of their profits over a 20 year period.  While this is slightly over the current federal guidelines, it is well within the DEC guidelines of cost benefit analysis.

The 23-page letter detailing the denial of the water quality certificate is posted on the DEC web site. It is well worth reading. The conclusions were arrived at through stringent scientific methodology by dedicated professionals who are charged with enforcing the Clean Water Act. These scientists and attorneys are acting in the public interest and protecting the common good for the benefit of us all. This sound science, not advertising and corporate propaganda, must be the basis for formulating our water usage policy and keeping the eco system of our heritage river, the Hudson, viable.

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