Alternative Water Supplies for Power Generation

2017 TECHNICAL REPORT

13553240
December 13, 2017

TO: Recipients of EPRI Technical Report 3002012045

FROM: EPRI Publishing

Subject: Corrections for 3002012045, Alternative Water Supplies for Power Generation

Our records indicate that you received the subject EPRI product by order or download prior to
December 13, 2017.

The following corrections have been made to this technical report:

Case studies added in Appendix B

13553240
 Alternative Water Supplies
for Power Generation

EPRI Project Manager

R. Goldstein

3420 Hillview Avenue

Palo Alto, CA 94304-1338
USA

PO Box 10412
Palo Alto, CA 94303-0813
USA

800.313.3774
650.855.2121

askepri@epri.com 3002012045
www.epri.com Final Report, December 2017
13553240
DISCLAIMER OF WARRANTIES AND LIMITATION OF LIABILITIES

THIS DOCUMENT WAS PREPARED BY THE ORGANIZATION(S) NAMED BELOW AS AN ACCOUNT OF

WORK SPONSORED OR COSPONSORED BY THE ELECTRIC POWER RESEARCH INSTITUTE, INC. (EPRI).
NEITHER EPRI, ANY MEMBER OF EPRI, ANY COSPONSOR, THE ORGANIZATION(S) BELOW, NOR ANY
PERSON ACTING ON BEHALF OF ANY OF THEM:

(A) MAKES ANY WARRANTY OR REPRESENTATION WHATSOEVER, EXPRESS OR IMPLIED, (I) WITH RESPECT
TO THE USE OF ANY INFORMATION, APPARATUS, METHOD, PROCESS, OR SIMILAR ITEM DISCLOSED IN
THIS DOCUMENT, INCLUDING MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, OR (II) THAT
SUCH USE DOES NOT INFRINGE ON OR INTERFERE WITH PRIVATELY OWNED RIGHTS, INCLUDING ANY
PARTY'S INTELLECTUAL PROPERTY, OR (III) THAT THIS DOCUMENT IS SUITABLE TO ANY PARTICULAR USER'S
CIRCUMSTANCE; OR

(B) ASSUMES RESPONSIBILITY FOR ANY DAMAGES OR OTHER LIABILITY WHATSOEVER (INCLUDING ANY
CONSEQUENTIAL DAMAGES, EVEN IF EPRI OR ANY EPRI REPRESENTATIVE HAS BEEN ADVISED OF THE
POSSIBILITY OF SUCH DAMAGES) RESULTING FROM YOUR SELECTION OR USE OF THIS DOCUMENT OR
ANY INFORMATION, APPARATUS, METHOD, PROCESS, OR SIMILAR ITEM DISCLOSED IN THIS DOCUMENT.

REFERENCE HEREIN TO ANY SPECIFIC COMMERCIAL PRODUCT, PROCESS, OR SERVICE BY ITS TRADE
NAME, TRADEMARK, MANUFACTURER, OR OTHERWISE, DOES NOT NECESSARILY CONSTITUTE OR IMPLY
ITS ENDORSEMENT, RECOMMENDATION, OR FAVORING BY EPRI.

THE FOLLOWING ORGANIZATION, UNDER CONTRACT TO EPRI, PREPARED THIS REPORT:

LimnoTech

NOTE

For further information about EPRI, call the EPRI Customer Assistance Center at 800.313.3774 or
e-mail askepri@epri.com.

Electric Power Research Institute, EPRI, and TOGETHER…SHAPING THE FUTURE OF ELECTRICITY are
registered service marks of the Electric Power Research Institute, Inc.

Copyright © 2017 Electric Power Research Institute, Inc. All rights reserved.

13553240
 Acknowledgments
The following organization, under contract to the Electric Power
Research Institute (EPRI), prepared this report:

LimnoTech
501 Avis Drive
Ann Arbor, MI 48108

Principal Investigator
L. Weintraub

This report describes research sponsored by EPRI.

EPRI would like to acknowledge the support of the following
organizations for their participation in case study development:

American Electric Power (AEP)

Alliant Energy
Entergy
Florida Power & Light (FPL)
Great River Energy
NRG Energy
PNM
Salt River Project (SRP)
Southern Company
WEC Energy Group
Water Environment & Reuse Foundation

This publication is a corporate

document that should be cited in the
literature in the following manner:

Alternative Water Supplies for Power

Generation.
EPRI, Palo Alto, CA: 2017.
3002012045.
 iii 

13553240
13553240
Abstract
For some electric power facilities, water scarcity and/or water quality
may hinder or preclude freshwater use. Water scarcity may be the
result of local conditions, drought or increased competition for water.
Water quality concerns affecting freshwater use relate to poor source
water quality or receiving water impacts and regulations. Alternative
water supplies are a viable option for many facilities and have been
used in place of traditional freshwater sources by the electric power
sector for decades, either as a primary source or as a backup source
employed only in times of need. Alternative water supplies are varied
and include treated municipal wastewater effluent, industrial effluent,
produced water from oil and gas production, mine pool water,
agricultural runoff, stormwater, or brackish inland water. In some
regions, interbasin transfers of water may be an alternative to a local
freshwater supply. The objective of this project was to compile a set
of diverse case studies that showcase examples where alternative
water supplies are being used or were evaluated for use by electric
power facilities. The case studies summarize key information and
lessons learned to facilitate the evaluation and use of alternative
supplies by 17 other electric power facilities. Each case study
summarizes the drivers, benefits, challenges, lessons learned, and
other site-specific findings related to the use of an alternative water
source.

Keywords
Water risk
Alternate water supply
Reclaimed effluent
Degraded water
Water reuse

v

13553240
13553240
 EXECUTIVE SUMMARY

Deliverable Number: 3002012045

Product Type: Technical Report
Product Title: Alternative Water Supplies for Power Generation

PRIMARY AUDIENCE: This report is intended for electric power companies facing water-related challenges
and considering the use of an alternative water supply at an existing or future facility.
SECONDARY AUDIENCE: Suppliers of alternative sources of water (for example, municipal, agricultural, oil
and gas production, industrial, and mining) may consult this report to better understand the drivers, benefits,
and challenges associated with alternative water supply use at electric power generation facilities.

KEY RESEARCH QUESTION

The objective of this project was to facilitate the evaluation and use of alternative water supplies by the
electric power sector by documenting examples where alternative water supplies are being used or were
evaluated for use by electric power facilities. This report summarizes important characteristics of alternative
supplies, considerations for use, benefits, challenges, and lessons learned based on a set of diverse case
studies.

RESEARCH OVERVIEW
This project involved a literature review to first identify and characterize different alternative water supply
types and their usage by electric power facilities. Next, a catalog of candidate case study facilities was
developed, followed by development of targeted interview questions, interviews with facilities using or
considering alternative water sources, and case study development for 17 selected facilities. The case
studies summarize the drivers, benefits, challenges, lessons learned and other site-specific findings related
to the use of an alternative water source. This study focused on eight types of alternative water sources
relevant to the electric power industry: 1) municipal or sanitary effluent, 2) industrial effluent, 3) produced
water from gas and oil production, 4) mine pool water, 5) agricultural runoff, 6) stormwater, 7) saline
(brackish) inland surface or groundwater, and 8) interbasin transfers of freshwater.

KEY FINDINGS
This study found that a variety of alternative water supply types may provide a reliable source of sufficient
quality water to facilities, reducing water-related risks and in some cases providing regulatory and
reputational benefits. The compiled case studies relay information for eight alternative source types,
highlighting not only the drivers and benefits but also the costs, challenges, and lessons learned to pave the
way for other facilities considering an alternative source. Key findings from the case studies include the
following:
• Electric power facilities have used alternative water supplies for decades. Case studies demonstrate
that alternative supplies can be a reliable and cost-effective option, supporting a range of uses. Neither
poor source water quality nor the need for long-range pipeline transport precludes successful
implementation. Alternative water supplies are successfully being used to meet a variety of plant needs
(for example, cooling and process water) and may provide 100% of the facility’s supply needs or be
blended with other water sources prior to use.

 vii 

13553240
 EXECUTIVE SUMMARY

• Alternative supply use requires a strong driver. In the case studies, the most common drivers were a
lack of a traditional freshwater supply and/or water quality-related constraints. Reputational reasons
were not identified as a strong driver in any of the case studies. In some cases, the lack of a driver
and high costs for conveyance and treatment prohibited implementation of an alternate water supply
in place of a traditional freshwater source.
• Benefits of alternative water supply use are varied. Alternative water supply use in water scarce
areas has allowed plants to be sited in a preferred location. Alternative supply use has also provided
regulatory, quality-related benefits to the water supplier as well as quantity and quality benefits to the
electric power facility. In many examples, facilities realized additional benefits beyond those directly
related to the primary driver. Additional benefits were most commonly related to reputation and water
quality, although cost and regulatory benefits were also noted.
• Common factors for successful use of alternative supplies included good planning, establishment of
well-defined conditions with the water supplier, and the availability of backup supplies. Facilities that
rushed the process of using an alternative supply experienced greater challenges and costs.
• Water quality-related issues were the most commonly identified challenge of alternative supply use,
but case studies demonstrated that these challenges are manageable. Additional treatment is
typically needed regardless of the water source.
• Treated municipal effluent was the most common supply type identified and is the most promising due
to quantity and quality reliability. Brackish inland water, stormwater, mine pool water, agricultural
runoff, and interbasin transfer are also being successfully used. Stormwater and agricultural runoff
have challenges related to variable quantity and quality, but may be viable alternatives when there is
a water quality-related driver (for example, regulatory, financial or reputational incentives to reuse
degraded water rather than discharge to vulnerable receiving waters). Mine pool water, brackish water
and industrial effluent have variable water quality and require treatment; however, careful planning,
well-defined agreements, and a backup source can support successful use of these sources.
Interbasin transfers and produced water appear to be the least promising supplies for the future.

WHY THIS MATTERS

This study will serve as a resource for electric power facilities that are facing water supply challenges and are
considering the use of an alternative water supply at either an existing or future facility. The case studies
cover diverse geographies, plant types, and water supply types. For facilities considering an alternative
supply, it may be unclear what opportunities or potential pitfalls lay ahead. The case studies provide insight
on potential drivers for successful implementation as well as potential challenges.

 viii 

13553240
 EXECUTIVE SUMMARY

HOW TO APPLY RESULTS

The case studies describe the experience of facilities that have used or investigated the use of alternative
supplies, and this information can help other facilities identify key considerations for alternative supply use.
Project findings may be used to educate facility personnel on the viability of alternative supplies or may provide
documented justification for pursuing an opportunity. Review of successful examples and resulting benefits
may increase confidence in using an alternative supply, while leading to broader support within a power
generation company to invest the necessary resources for implementation. In addition, the importance of
communication, partnerships, and water service agreements between the alternative supplier and the power
generator may be better understood by reviewing successful examples as well as less successful
experiences.

LEARNING AND ENGAGEMENT OPPORTUNITIES

Other resources related to this report that readers may find useful:
• Use of Degraded Water Sources as Cooling Water in Power Plants. EPRI, Palo Alto, CA, and
California Energy Commission, Sacramento, CA: 2003. 1005359.
• Water Use for Electric Power Generation. EPRI, Palo Alto, CA: 2008. 1014026.
• Use of Alternate Water Sources for Power Plant Cooling. Palo Alto, CA: 2008. 1014935.
• Evaluation of Stormwater as a Resource for Power Plant Cooling. Palo Alto, CA: 2010. 1021124.
• The Potential for Using Stormwater in Power Plants: Lessons Learned from Case Studies at Two
Great River Energy Plants. Palo Alto, CA: 2012: 1023774.
• Evaluation of Water Management Metrics for the Electric Power Sector. EPRI, Palo Alto, CA: 2015.
3002006245.
EPRI CONTACTS: Robert Goldstein, Senior Technical Executive, 650.855.2154, rogoldst@epri.com;
Nalini Rao, Technical Leader, 650.855.2044, nrao@epri.com
PROGRAM: Program 55 – Water Availability and Resource Risk Management

 ix 

13553240
13553240
Table of Contents
Abstract ................................................................ V

Executive Summary ............................................. VII

Section 1: Introduction ....................................... 1-1

1.1 Value to EPRI Members ......................................... 1-2
1.2 Research Approach .............................................. 1-2
1.3 Background on Alternate Water Supply Use ........... 1-3
1.4 Catalog of Facilities using Alternative Water
Supplies .................................................................... 1-7

Section 2: Alternative Water Supply Case Studies

for Power Generation Facilities ........... 2-1
2.1 Reclaimed Municipal Effluent ................................. 2-2
2.1.1 Opportunities .............................................. 2-3
2.1.2 Challenges.................................................. 2-5
2.2 Industrial Effluent .................................................. 2-7
2.2.1 Opportunities .............................................. 2-7
2.2.2 Challenges.................................................. 2-7
2.3 Produced Water .................................................. 2-8
2.3.1 Opportunities .............................................. 2-8
2.3.2 Challenges.................................................. 2-9
2.4 Mine Pool Water ............................................... 2-11
2.4.1 Opportunities ............................................ 2-11
2.4.2 Challenges................................................ 2-12
2.5 Agricultural Runoff.............................................. 2-12
2.5.1 Opportunities ............................................ 2-13
2.5.2 Challenges................................................ 2-14
2.6 Stormwater ........................................................ 2-14
2.6.1 Opportunities ............................................ 2-15
2.6.2 Challenges................................................ 2-15
2.7 Brackish inland water ......................................... 2-16
2.7.1 Opportunities ............................................ 2-16
2.7.2 Challenges................................................ 2-17
2.8 Interbasin transfer .............................................. 2-17
2.8.1 Opportunities ............................................ 2-18
2.8.2 Challenges................................................ 2-18

 xi 

13553240
 Section 3: Summary of Key Findings ................... 3-1

Section 4: Looking Forward................................ 4-1

4.1 Current State of Reuse .......................................... 4-1
4.2 Opportunities ...................................................... 4-2
4.3 Challenges .......................................................... 4-2
4.4 Supplier Recommendations for Successful
Implementation .......................................................... 4-3

Section 5: References ......................................... 4-1

Appendix A: Catalog of Power Plants using

Alternative Water Supplies ................. A-1

Appendix B: Compendium of Case Studies .......... B-1

Appendix C: Interview Questions for Case Study

Development...................................... C-1

 xii 

13553240
List of Figures

Figure 1-1 Steps in the evaluation of alternate water sources

for power plant cooling (Source: EPRI, 2008b) .............. 1-5
Figure 1-2 Alternative supply use distribution within the
catalog ..................................................................... 1-8
Figure 1-3 Geographic distribution of catalogued facilities ... 1-9
Figure 2-1 Location and alternative water source type for
case study facilities..................................................... 2-2
Figure 2-2 Municipal wastewater generation as a
percentage of the potential water demand associated
with new electricity generation forecast for 2025
(Source: EPRI, 2008b). ............................................... 2-4
Figure 2-3 Oil and gas production and coal-fired power
plant locations (Source: Arthur, 2011). ......................... 2-9
Figure 2-4 Locations of abandoned coal mines and coal-
fired power plant locations (Source: Arthur, 2011). ..... 2-12
Figure 2-5 Agricultural return flow generation as a
percentage of the potential water demand associated
with new electricity generation forecast for 2025
(Source: EPRI, 2008b). ............................................. 2-14
Figure 2-6 Locations of saline aquifers and coal-fired power
plant locations (Source: Arthur, 2011). ....................... 2-17
Figure 2-7 Texas interbasin transfers (source: TWDB,
2002) ..................................................................... 2-19

 xiii 

13553240
13553240
List of Tables

Table 2-1 Minimum suggested regulatory guidelines for

reuse of domestic wastewater in recirculating cooling
towers (source: adapted from USEPA, 2012). ............... 2-6
Table B-1 Summary of Case Studies................................... B-2

 xv 

13553240
13553240
Section 1: Introduction
Most thermoelectric power generating facilities require a large, reliable supply of
cooling water as well as smaller quantities of high quality process water (e.g.,
demineralization). As a result, power plants are frequently sited near traditional
freshwater sources such as rivers, lakes, reservoirs or groundwater aquifers. These
sources are often preferred over alternative supplies for their higher quality and
lower cost.

For some facilities, the continued or future use of freshwater is hindered or

precluded by water scarcity (e.g., local conditions, drought, or increased
competition for water) or water quality (poor source water quality, or receiving
water impacts and regulations). Issues related to freshwater supply and quality
can impact power generation and lead to power plant curtailment. One study
identified 43 water-related power plant curtailment incidents in the United Sates
from 2000 to 2015 due to four possible factors: water intake water too warm,
discharge water too warm, both intake and discharge water too warm, and/or
inadequate intake water volume (McCall et al, 2016). The majority of these
incidents occurred in the eastern U.S.

A facility’s desire to improve their public reputation through water stewardship

activities may also affect the desirability of a traditional freshwater source. A
decreased dependence on freshwater sources (surface or groundwater) may reduce
a facility’s physical and reputational risks, provide ecosystem benefits, and/or
sustain freshwater supplies to support uses by other sectors (e.g., municipal
drinking water).

The use of an alternative water supply in place of freshwater is an option for

some electric power facilities. Alternative water supplies are varied and may
include municipal wastewater effluent, industrial effluent, produced water from
oil and gas production, mine pool water, agricultural runoff, stormwater, or
brackish inland water. In some regions interbasin transfers of water may be an
alternative to a local freshwater supply. Alternative water supplies have been used
in place of traditional water sources by electric power facilities for decades, either
as a primary source, or as a back-up source used only in times of need. For
example, the 4,000 MW Palo Verde Nuclear Power Plant near Phoenix, AZ
utilizes reclaimed municipal effluent from several area municipalities for cooling,
and it has been doing this since it was commissioned in 1986 (Veil, 2007;
Schumerth, 2006). As challenges related to freshwater supply and management
continue to grow, alternative supplies have the potential to serve the water
demands for electric power generation.

 1-1 

13553240
 1.1 Value to EPRI Members

The objective of this project was to compile a set of diverse case studies that
showcase examples where alternative water supplies are being used or were
evaluated for use by electric power facilities. The case studies summarize key
information and lessons learned to facilitate the evaluation and use of alternative
supplies by other electric power facilities. In some cases, the implementation was
successful and multiple benefits were realized. In other cases, implementation
resulted in challenges that may have led to discontinuation of use of this supply.
Additionally, some case studies explain how after investigation of using an
alternative supply, it was determined that implementation was not justified due
to cost or other factors.

This study is a resource for electric power facilities that are facing water
challenges and are considering the use of an alternative water supply at either an
existing or future facility. The case studies cover diverse geographies, plant types,
and water supply types. For facilities considering an alternative supply, it may be
unclear what opportunities or potential pitfalls may lay ahead. The case studies
describe the drivers for successful implementation of an alternative supply, as well
as challenges faced by some facilities. For facilities at the initial stage of exploring
alternative water supply use, example case studies may provide documented
justification for pursuing an opportunity. Review of successful examples and
resulting benefits may lead to broader support within a power generation
company to invest in the necessary resources for implementation of an alternative
supply. Also, the importance of communication, partnerships and water service
agreements between the alternative supplier and the power generator may be
better understood by reviewing successful, as well as less successful, examples.
The case studies also highlight challenges and lessons learned which may help
facilities understand critical components of planning and implementing the use
of an alternative water supply.

1.2 Research Approach

This project involved a literature review to first identify and characterize different
alternative water supply types and their usage by electric power facilities. Next, a
catalog of candidate case study facilities was developed, followed by development
of targeted interview questions, interviews with facilities using alternative sources,
and case study development for 17 selected facilities. The case studies summarize
the drivers, benefits, challenges, lessons learned and other site-specific findings
related to the use of an alternative water source.

This study focused on eight types of alternative water sources relevant to the
electric power industry:
 Municipal or sanitary effluent;
 Industrial effluent;
 Produced water from gas and oil production;
 Mine pool water;

 1-2 

13553240
  Agricultural runoff;
 Stormwater;
 Saline (brackish) inland surface or groundwater; and
 Interbasin transfers of freshwater.

Although it is recognized that many power facilities utilize saline/brackish water

from an ocean or estuary, this study did not evaluate this type of source water as a
potential alternative supply in place of freshwater.

This study synthesizes information on eight alternative water supply types,

describing characteristics, as well as opportunities and challenges related to use.
The organization of this report allows the reader to review a specific alternative
supply type of interest (Section 2), understand the general opportunities and
challenges with this supply type, and quickly read highlights of case studies
relevant to the alternative supply type. Additional detail is provided in the full
case studies assembled in Appendix B. Section 3 provides a synthesis of key
findings identified across the set of 17 case studies, and Section 4 provides a
forward looking perspective on alternate supply use, with emphasis on
perspectives from the municipal wastewater research community.

1.3 Background on Alternate Water Supply Use

Alternative water supplies have been evaluated and proven to be a viable option
for electric power facilities to decrease dependence on freshwater sources. The
evaluation of alternative water supplies to support power generation is not a new
topic of research. For example, in 1977 the California Department of Water
Resources recommended that wastewater, brackish water, or agricultural runoff
be used for power generation in place of freshwater when it is available (CA
DWR, 1977).

Due to cooling water requirements, thermoelectric Rankine-cycle steam power

plants (e.g., coal, nuclear, gas, solar thermal, biofuel) require significantly more
water than those using combustion turbine, combined-cycle, solar PV or wind
(EPRI, 2008a). Veil (2007) identified cooling tower make up water as a common
use of reclaimed water supplies. The quantity of the alternate supply is an
important consideration for facilities requiring large volumes of water. For
example, once-through cooling system facilities withdraw much larger volumes of
water (e.g., 25,000 to 45,000 gal/MWh) than recirculating (closed-cycle) cooling
plants (e.g., 550-800 gal/MWh) (EPRI, 2008a); therefore, it is unlikely that an
alternative water supply could provide sufficient quantities for a once-through
cooling system. Other opportunities for alternative supply use include cooling
pond supplemental inflow, air scrubbers (i.e., FGD systems), boiler feed water,
water for gas turbine inlet cooling, bottom and fly ash systems, and dust
suppression (Veil, 2007; EPRI, 2010). Alternate water supplies can also be used
as a water source to maintain underground pressure in geothermal fields (Veil,
2007).

 1-3 

13553240
 The quality of the alternate supply is also an important consideration. To use the
alternative water supply in cooling towers, certain criteria should be met related
to mineral constituents that could potentially affect cooling tower operations
through scaling, corrosion and fouling as well as any constituents that may be
regulated for public health via aerosol emissions from the tower. Specific
constituent of potential concern include Na, Ca, Mg, Alkalinity, Cl, SiO2, pH,
B, NO3, Ba, Sr and TOC (EPRI, 2008b).

Previous EPRI work identified and provided background on the electric power
sector’s use of degraded and alternative water supplies as well as key issues that
should be considered. With a focus on California, EPRI and the California
Energy Commission (CEC) investigated technological and environmental issues
associated with the use of degraded water for power plant cooling (EPRI and
CEC, 2003). The study focused on water quality requirements to minimize
operating problems, technical feasibility and economics of using degraded water,
potential environmental impacts through cooling tower operation, and
commercially available as well as emerging treatment options for successful use of
degraded water. Hypothetical case studies evaluated these factors against a range
of alternative water sources (e.g., municipal effluent, agricultural return water,
produced water) for power plant cooling.

EPRI (2008b) further evaluated the topic and developed a roadmap for
evaluating a variety of alternative water supply types (Figure 1-1), including
municipal effluent, agricultural drainage, saline groundwater, produced water and
industrial process water. The report identified a number of key potential
challenges: supply reliability over the lifetime of the power plant; quality of the
water and additional treatment needed for power plant use; transportation of
water from the source to the power plant; and additional regulatory requirements
related to the formation and transport of aerosols from cooling towers. All of
these challenges may translate to a higher cost for using an alternative supply,
compared to a freshwater source. The study recognized the need for site-specific
data collection and cost estimation before determining the feasibility of
alternative water supply use for power plant cooling; however, the multi-step
framework provides a pathway for general evaluation and screening. The study
also contains a table of county-level estimates of alternative water supplies
(municipal effluent and irrigation return flow) potentially useful for power plant
cooling.

 1-4 

13553240
 Figure 1-1
Steps in the evaluation of alternate water sources for power plant cooling (Source:
EPRI, 2008b)

NETL (2009) examined the use of non-traditional waters (i.e., municipal

effluent, produced waters, mine pool waters, saline groundwater, and recovered
plant discharges) for power plant applications. The study reviewed environmental
concerns associated with the untreated water, water quality considerations,
treatment technologies, performance goals and results, and other issues. Arthur
(2011) developed a nationwide catalog of publicly available data describing the
location, quantity and quality of non-traditional water sources (i.e., mine
discharge water, oil and gas produced water, saline aquifers, and municipal
effluent) relative to coal-fired power plants. Additionally, Vidic and Dzombak
(2009) describe the feasibility of using alternative sources including: secondary
treated municipal wastewater, passively treated abandoned mine drainage, and
ash sedimentation pond effluent for cooling water.

Additional research focused on specific alternative water supply types provides

relevant background information that informed this study. Treated municipal
effluent use for cooling and associated benefits, challenges, critical factors, and
life cycle costs are described by Dzombak et al. (2012), along with several case
studies. Vidic and Dzombak (2009) and Veil (2007) identified over 50 power
plants using reclaimed municipal effluent. ASME & WEF (2012) reported on a
workshop where experts identified best practices for the use of municipal
wastewater in electric utilities along with a number of case studies and common
barriers.

In 2012, USEPA issued an update to Guidelines for Water Reuse (USEPA, 2012).
The document is intended to facilitate further development of water reuse by
serving as an authoritative reference on water reuse practices. The guidelines
describe regional variations in water reuse, advances in wastewater treatment
technologies relevant to reuse, best practices for involving communities in
planning projects, international water reuse practices, and factors that will allow
expansion of safe and sustainable water reuse. The document also includes a
section focused on reuse of municipal effluent for industrial operations such as
cooling towers and boiler makeup water.

 1-5 

13553240
 The use of industrial effluent and agricultural runoff were reviewed by EPRI
(EPRI and CEC 2003; EPRI, 2008b); however, these potential alternate
supplies were not well documented in other reviewed literature. The feasibility of
using coal mine pool water for cooling is evaluated by Veil et al. (2003) and Veil
& Puder (2006), and power plants that have used this source are identified. Vidic
and Dzombak (2009) evaluated the regulations and water quality management of
this source. EPRI conducted a two part study to examine stormwater as an
alternative water supply for power plants (EPRI, 2010; EPRI, 2012). The study
focused on potential stormwater use at two power plants: Elk River Energy
Recovery Station in Minnesota and Coal Creek Generating Station in North
Dakota and also considered applicability at hypothetical facilities located in New
York, Illinois, and Southern California.

Brackish/saline groundwater is characterized by EPRI (2008b) and Stanton et

al., (2017), and saline water withdrawals are described by Maupin et al. (2014).
Harto et al. (2014) describes challenges and opportunities related to the use of
this source for power plant cooling. Produced water from gas and oil production
is well described by Veil, who reports on volumes and quality (Veil, 2015; Clark
and Veil, 2009) of this source. NETL (2009) also provides a review of potential
use of produced water at electric power plants. Harto et al. (2014) and EPRI
(2006) describe challenges related to the use of this source, and the Oklahoma
Water Resources Board (OWRB) led a Produced Water Working Group
(PWWG) to study and recommend alternatives for produced water disposal
(OWRB, 2017).

Interbasin transfers of freshwater are described in detail in NAP (2005), which

covers regulatory considerations, benefits and provides case study examples.

The above-mentioned research provided a general understanding of the benefits

and challenges associated with alternate water supply types, and helped identify
those that are most important to the electric power community. This background
informed the development of case study interview questions which focused on
the following topics:
 Drivers: A variety of drivers may lead to implementation of alternative water
supplies at power generation facilities.
 Reliability: The reliability of the supply is an important consideration. There
may be seasonal or annual variations and long-term trends of the source may
need to be considered. Onsite storage of the water supply may be required
and could be limited by available space at the plant site.
 Quality: The quality of the alternate supply is an important component of a
successful application of an alternative water use. Specific factors may include
the quality of the source water, additional treatment to make it usable by the
electric power plant, location and responsibility for additional treatment, and
discharge requirements for the power plant.
 Implementation: Additional infrastructure may be required to transport the
water from the source to the power plant. Water treatment systems and
piping within the power plant may require modification. There could be

 1-6 

13553240
 political or regulatory challenges related to alternate supply use. There may
be multiple water use sectors competing for an alternate water supply.
 Costs: Considerations may include capital costs to implement the project,
ongoing payment to the water supplier, additional treatment, and O&M
costs. Comparison of alternative supply costs with traditional freshwater
supply costs may be notable in some situations.
 Benefits: Both the electric power facility and the alternative water supply
entity may realize benefits such as supply reliability, regulatory relief, or
reputational risk reduction.
 Challenges: The use of an alternative water supply may present technical,
operational, economic, environmental, or political challenges.
 Secondary Impacts: The use of an alternate supply may result in secondary
impacts such as pollutant emissions with evaporative losses, health and safety
concerns, or unintended consequences to the ecosystem.

1.4 Catalog of Facilities using Alternative Water Supplies

Electric power facilities using alternative water supplies were tabulated and
catalogued to characterize the prevalence of alternative water supply use, and
identify candidate case study facilities. Information obtained through the
literature search was supplemented by an internet and database search to identify
candidate case studies.

Information from the U.S. Energy Information Administration (U.S. EIA,

2016) formed a primary basis for cataloging alternative water supply use by
electric power facilities, although information was also obtained from other
resources. U.S. EIA collects and publishes specific, generator-level information
about all U.S. electric power plants with 1 MW or greater of combined
nameplate capacity as part of their survey Form EIA-860. The cooling system
data for each power plant includes information on the type of cooling system,
type of water used, source of water, and quantity of water used.

Over 100 facilities were identified as using, having used, or considering use of
alternative water supplies (Appendix A). The catalog includes both successful
examples and failed attempts to implement alternative water sources. General
information regarding these facilities was catalogued, along with specific
characteristics including: plant name, power company, location, fuel type, plant
capacity, the plant’s use of water, type of alternative water supply, name of water
source, volume of alternative water used, and date that the alternative supply was
initiated.

The end result was a catalog of over 100 facilities located in 25 states using a
diversity of alternative water sources. Because the intent of the catalog was to
identify frequently used alternative supplies and candidate facilities for case study
development, the focus was on cataloging facilities and alternative water use, but
not on updating or verifying all facility details.

 1-7 

13553240
 The catalog includes facilities using ten types of alternative water sources. As
illustrated in Figure 1-2, reclaimed municipal effluent was the most common
alternative supply catalogued (68%), followed by brackish/saline inland water
(8%) and mine pool water (8%). Case studies were developed for eight of the ten
types of alternative water supplies; none of the case studies investigated landfill
leachate and grey water as potential alternate supplies.

Figure 1-2
Alternative supply use distribution within the catalog

The catalogued facilities using alternative sources are geographically distributed

throughout the U.S., although fewer are located in the Midwest (7%) compared
to other regions. As shown in Figure 1-3, the facilities are located in the
Southeast (30%), Southwest (22%), Northeast (19%), and West (19%). Sixty
percent of the catalogued facilities using reclaimed municipal effluent are located
in Florida, Texas and California. Several international examples were also
opportunistically catalogued; however, case studies were focused only on facilities
in the United States.

 1-8 

13553240
 Figure 1-3
Geographic distribution of catalogued facilities

 1-9 

13553240
13553240
Section 2: Alternative Water Supply Case
Studies for Power Generation
Facilities
Case studies were developed for 17 facilities including examples that were both
successful and unsuccessful in using alternative water supplies (Figure 2-1). The
full set of case studies are presented in Appendix B and all follow a similar
format. Each case study begins with an overview of the facility and background
information regarding alternative water use at the plant, followed by a discussion
regarding drivers for alternative supply use, information regarding
implementation of the alternative supply, and resulting benefits, challenges and
lessons learned.

The approach for selecting case study examples was to identify facilities from the
catalog (Appendix A) and prioritize selections to maximize diversity of
alternative source types and geography. Additional characteristics considered in
selecting case study facilities included: fuel type, facility size, the plant use of
water and whether the alternative source was originally planned or was retrofit,
with the goal of maximizing case study relevance to EPRI members.

A standardized suite of interview questions was developed to better understand

why an alternative supply was used or considered, how it was used, and the
outcomes of its use (Appendix C). Information was obtained through phone
interviews, and in some cases written responses to the interview questions and
follow-up exchanges with other knowledgeable staff. Interview questions covered
a range of topics including: general plant information, drivers for using an
alternative source, implementation of the alternative supply, and its reliability,
quality, cost, benefits and challenges. Information regarding secondary impacts,
where relevant, and lessons learned was also documented.

Each case study was based on information provided during the interview and in
some cases supplemented with additional information obtained from other
sources. To ensure accuracy, draft case studies were provided to the interviewees
for review and approval prior to incorporation in the final report.

This chapter includes subsections for each alternative water supply type. For each
supply type, the opportunities, benefits and challenges are first discussed on a
general level. Highlights from relevant case studies in each water source category

 2-1 

13553240

MUNICIPAL EFFLUENT
Comanche Power
Station, Oklahoma
(App. B1)
Comanche (235 MW NGCC)
has used reclaimed municipal
effluent to supply cooling pond
makeup water since first
operating in the 1970’s. The
driver was a lack of a local
freshwater supply, and the use
of municipal effluent provided
flexibility for siting the plant.
Revenue provided to the
POTW for purchase of the
water benefits the community
and supported POTW
treatment process upgrades.
Variable water quality of the
source has resulted in
occasional issues, specifically
high levels of TSS, TDS, algae,
and eutrophication in the
cooling pond.
13553240
are also presented. Additional detail for each facility mapped in Figure 2-1 can be
found in Appendix B, within the full case studies.
Figure 2-1
Location and alternative water source type for case study facilities
2.1 Reclaimed Municipal Effluent
Reclaimed municipal effluent is wastewater generated by a community that is
treated at a wastewater treatment plant (WWTP), or now more commonly called
a water reclamation facility (WRF), to secondary or tertiary levels. The reclaimed
effluent is then transported, often via a “purple pipe”, to support beneficial uses
such as direct or indirect potable reuse, community nonpotable use (e.g.,
irrigation of parks), agricultural irrigation, or industrial reuse (e.g., power
generation). Since 1990, WateReuse (https://watereuse.org/) has worked to
educate policymakers and the public about the benefits of water reuse and to
advocate for laws, policy and funding to increase water reuse. As compared to
other alternate water supplies examined in this study, reclaimed municipal
effluent is the most common alternative water source type used by the electric
power industry. Some power plants, such as the Palo Verde Nuclear plant in
Arizona, the CPS Energy plants in Texas and the Stanton Energy Center in
Florida, have been using reclaimed municipal effluent for decades (ASME &
WEF, 2012). Comanche Power Station in Oklahoma was evaluated in this
study, and is another example of long-term use of reclaimed municipal effluent.
 2-2 

MUNICIPAL EFFLUENT
Emery Generating
Station, Iowa (App. B2)
Emery (602 MW NGCC) has
used ~1 MGD of municipal
effluent from a nearby
sanitation district for cooling
tower makeup water since it
began operation in 2004. The
use of municipal effluent was
driven by restrictions on
groundwater in the area and a
lack of other viable surface
water supplies. Municipal
effluent comprises 40% of
Emery’s water needs and is
blended with groundwater
before use. Reputational
benefits have been noted from
the water use, with only minor
challenges occurring from the
quality of the water.
13553240
2.1.1 Opportunities
Reclaimed municipal effluent represents a potentially valuable alternative supply
due to its typically consistent quantity and quality. There are over 16,000
publically owned wastewater treatment systems in the United States that serve
approximately 75 percent of the population (USDHS, 2017). NETL (2009)
estimated that 81 percent of power plants proposed for construction could
potentially use a municipal effluent supply within a 10 mile radius of the plants.
EPRI (2008b) noted a high potential for municipal effluent use for
thermoelectric cooling in highly populated states such as California, Florida,
Illinois, Michigan and Ohio. The study also mapped the cooling water needed to
support projected new generation as a percent of the existing (2008) supply of
municipal wastewater (Figure 2-2). Veil (2007) identified 57 power plants using
reclaimed municipal effluent for cooling. The largest number of these facilities
are located in Florida, California, Texas and Arizona, which are regions known
to experience freshwater shortages. However, the study also identified power
plants using reclaimed municipal water in states in the Eastern U.S. and
Midwest, which are considered to be water abundant.
The use of reclaimed municipal effluent at a power plant may be driven by needs
of the reclaimed water provider (i.e., wastewater authority) and/or the needs of
the electric utility. An electric utility may wish to seek the use of reclaimed
municipal effluent because of lack of a reliable freshwater supply in terms of
quantity or quality. The quality of municipal effluent may be higher than the
locally available freshwater or brackish water sources.
 2-3 
 MUNICIPAL EFFLUENT

Harrison County Power

Project, Texas (App. B3)

Harrison (570 MW NGCC)

uses ~5 MGD of municipal
effluent for cooling tower
makeup and demineralization
water needs. The plant
intended to purchase raw
water from a nearby city, but
interbasin transfer and water
rights regulations prevented a
timely implementation. Instead,
municipal effluent was selected
as the water supply. The power
plant water treatment system
was modified and a pipeline
was built, resulting in
increased costs. Use of
municipal effluent has provided
Harrison with a stable water
supply that provides drought Figure 2-2
resilience. Municipal wastewater generation as a percentage of the potential water demand
associated with new electricity generation forecast for 2025 (Source: EPRI,
2008b).
MUNICIPAL EFFLUENT
In some cases, the primary driver for municipal effluent reuse may come from a
The Geysers Geothermal wastewater utility that is challenged to comply with NPDES discharge
Field, California (App. B5) requirements or which has a lack of effluent disposal options. In areas sensitive to
water quality issues, reuse of reclaimed water may help reduce eutrophication or
The Geysers (1,517 MW other water quality issues in receiving waterbodies. When municipal effluent
Geothermal Field) generates
would otherwise be discharged to seawater, there is a clear opportunity to
power by harnessing the steam
potentially reclaim and reuse this source of water. Some states, such as Florida,
produced by the field. A drop in
steam production and a lack of provide incentives to utilities that reuse reclaimed water in response to objectives
available surface and in state statues focused on “encouraging and promoting reuse” (FDEP, 2016).
groundwater sources led to use
of reclaimed municipal effluent to A joint workshop with wastewater and electric utility experts identified several
supplement water supply in the key characteristics of successful municipal effluent reuse projects at electric
field. This has successfully utilities that include: active collaboration between municipal wastewater
increased current and future treatment plants and electric utilities, clearly defined water quality and flow rates,
power production. A second optimal and adaptable system design, compliance with all regulations, and
driver relates to the needs of
ongoing education and outreach efforts (ASME & WEF, 2012).
nearby communities which now
have a safe and cost-effective
method for disposal of excess
A study that evaluated the costs of alternative water supplies in California
municipal effluent. Two large estimated a cost of municipal recycled (i.e., reclaimed) wastewater projects for
pipeline projects were nonpotable reuse to be approximately $1,500 per acre-foot, with approximately
constructed to transport 60% of those costs attributed to distribution of the water (Cooley and
reclaimed effluent from multiple
communities to the geothermal
 2-4 
field.

13553240

MUNICIPAL EFFLUENT
Crist Generating Plant,
Florida (App. B4)
Plant Crist (924 MW Coal)
initiated municipal effluent in
2010. Brackish surface water
is used in the once-through
units, but it was not high
enough quality for a new FGD
system. Municipal effluent
supplies 100% of the water for
the FGD system as well as the
recirculating cooling towers.
Plant Crist does not pay for the
effluent but does cover O&M,
pumping, and power costs.
The use of municipal effluent
also allowed the wastewater
utility to relocate their
operations and overcome
discharge permit issues.
13553240
Phurisamban, 2016). This cost was estimated to fall in between that of
stormwater capture and sweater desalination.
2.1.2 Challenges
An important factor for successful use of reclaimed municipal effluent is that the
source water be of sufficient quality. USEPA summarizes reclaimed water quality
and treatment requirements for industrial reuse of municipal effluent for a
number of key states (USEPA, 2012). Constituents of primary concern include
BOD5, chlorine, TSS, turbidity, bacterial indicators, and pathogens. Table 2-1
summarizes suggested USEPA guidelines for suggested treatment processes,
reclaimed water quality, monitoring frequency, and setback distances for reuse of
domestic wastewater in recirculating cooling towers.
From the perspective of the power plant, additional treatment beyond that
required at the wastewater treatment plant may be necessary to prevent scaling,
corrosion, biological growth, fouling and foaming. Constituents of potential
concern for power plant operations include Na, Ca, Mg, Alkalinity, Cl, SO4,
SiO2, pH, B, NO3, Ba, Sr and TOC (EPRI, 2008b; EPRI and CEC, 2003). In
addition, electric power facilities that receive an alternate supply may be subject
to power plant air emissions regulations that are difficult to meet given the
quality of the alternate supply (WEF, 2012).
 2-5 
 Table 2-1
Minimum suggested regulatory guidelines for reuse of domestic wastewater in
MUNICIPAL EFFLUENT
recirculating cooling towers (source: adapted from USEPA, 2012).

Rhode Island State Reclaimed Reclaimed

Setback
Energy Center (RISEC), Treatment Water Water Comments
Distances
Rhode Island (App. B7) Quality Monitoring
Windblown spray
RISEC (583 MW NGCC) uses
Variable, should not reach
~12 MGD of municipal effluent
for cooling tower makeup depends on areas accessible
water, demineralization water, recirculation to workers or the
and fire protection since it ratio: public.
began operation in 2002. The
pH: weekly
primary driver was a lack of Secondary pH = 6.0-9.0 Additional
local freshwater sources. Treatment BOD: weekly treatment by user
Initially, RISEC experienced 300 ft to areas
problems with poor quality ≤ 30 mg/l is usually provided
accessible to
effluent; however, issues have Disinfection BOD TSS: weekly to prevent scaling,
the public. May
since been resolved with (chemical corrosion,
be reduced if
treatment upgrades. In general, coagulation Fecal biological
≤ 30 mg/l high level of
the treated effluent provides and coliform: growths, fouling
RISEC with an affordable water TSS disinfection is
filtration daily and foaming.
supply and reputational provided.
may be
benefits. ≤ 200 fecal
needed) See USEPA 2004
coliform/100 Cl2 residual:
continuous water reuse
ml guidelines for
recommended
MUNICIPAL EFFLUENT 1 mg/l Cl2 treatment
residual (min.) reliability
Kyrene Generating requirements.
Station, Arizona (App.
B8) For most states, there are specific guidelines or regulations regarding the reuse of
treated municipal effluent (NETL, 2009). The level of flexibility for
Kyrene (415 MW NGCC)
implementation of alternate supply use may be depend on the region and
used 3 MGD of municipal
individual state. USEPA provides a summary of state regulatory programs for
effluent for cooling tower
makeup from 2002-2010. reuse and regional variations in reuse (USEPA, 2012). An important
Construction of an NGCC unit consideration is possible public exposure to reclaimed water, and possible human
in 2002 required a new, non- health risks related to cooling tower drift.
groundwater source. Use of
municipal effluent allowed the In regions with prior appropriation water rights, there may be situations that
new unit to be sited in a prohibit the reuse of effluent. For example, reuse may be discouraged or
preferred location, which was infeasible if it will affect downstream users, change the point of discharge or
supported by the public. Issues place of use, or jeopardize availability during times of shortage (NETL, 2009).
with a RO membrane
precluded use of the effluent
In some situations, implementation of municipal effluent reuse may result in
for demineralization water. In
2010, the supplier
unintended environmental impacts related to land use, stream flow, and
unexpectedly ceased groundwater quality (USEPA, 2012). For example, if a river typically maintains a
operation, resulting in Kyrene’s continuous flow during dry periods due to wastewater treatment plant return
transition to backup water
supplies.
 2-6 

13553240

INDUSTRIAL EFFLUENT
Spiritwood Station,
North Dakota (App. B9)
Spiritwood Station (99 MW
Coal Cogen) originally
planned to use reclaimed
industrial wastewater from a
nearby malt processing plant
for boiler feed, cooling tower
makeup, and other process
water. Drivers were to site
Spiritwood to facilitate delivery
of process steam to the malt
plant, a lack of local
freshwater sources, and fast-
tracked timing of the project.
The use of industrial
wastewater was never
implemented due to water
quality (TDS) and reliability
concerns. Instead, Spiritwood
temporarily (~1 year) used
reclaimed municipal
wastewater. Then, due to
O&M costs and challenges
with the quality of the
municipal wastewater, the
power plant switched to a fresh
groundwater source supplied
by a rural water district.
13553240
flows, extensive reuse programs could reduce dry weather flows in a river and
potentially impact habitat or other parties downstream.
A variety of technical, regulatory, communication and public perception barriers
can make wastewater reuse projects by electric utilities slow and difficult to
launch (ASME & WEF, 2012). Challenges can relate to the absence of
dedicated regulatory framework, lack of information sharing and best practices,
risk aversion and resistance to change, or inability of stakeholders to work
cooperatively and collaboratively.
2.2 Industrial Effluent
Industrial effluent is treated effluent from an industrial (non-municipal) facility,
and may include food or product manufacturing facilities. This category excludes
reclaimed industrial wastewater generated by oil and gas production as well as
mining, which are covered separately as individual categories of potential
alternate supplies.
2.2.1 Opportunities
As indicated in Appendix A, only a few examples of industrial effluent use for
power generation were identified. These included, a malt plant (see Spiritwood
Station case study) and a gun powder manufacturing facility. Geographic
proximity between the source water and the power plant using the supply is a
critical factor for success. Given the low number of examples identified, it is
presumed that there are limited opportunities for industrial (manufacturing)
effluent reuse at power plants, likely related to the challenges outlined below.
2.2.2 Challenges
Similar to municipal wastewater treatment plants, manufacturing facilities may
need to comply with challenging discharge permit requirements and therefore
have a driver to deliver their wastewater to a third party interested in reuse.
However, a variety of challenges may limit the opportunities for industrial
effluent reuse at power plants.
First, there may be a lack of strong driver for external reuse of industrial effluent.
Delivery and reuse of effluent to a third party is likely not of interest to
manufacturers that already deliver their wastewater to a local municipal
wastewater treatment plant. Also, for some manufacturers, it is logical for them
to first look for opportunities to internally capture and reuse water to the extent
possible before seeking third parties to receive their effluent. (WE&RF, 2017a;
WRRF, 2016; USEPA, 1980).
For those that wish to deliver effluent to a third party, there may be challenges
related to the quantity and/or quality of effluent produced. Unlike municipal
wastewater treatment plants that generally operate under a steady flow condition
and tend to produce effluent of a predictable quality, manufacturing facilities may
experience seasonal or year-to-year fluctuations in operations and water use.
 2-7 

PRODUCED WATER
San Juan Generating
Station, New Mexico
(App. B10)
San Juan (1,848 MW Coal)
participated in an EPRI study to
investigate the potential use of
produced water as a
supplemental water supply. The
investigation was driven by
concerns of water scarcity,
drought, and potential effects
of climate change. The study
assessed the volume and
quality of produced water
available, the infrastructure
required, costs, and regulatory
requirements. While multiple
benefits of produced water
were acknowledged (improved
drought resistance,
conservation of surface water
sources, benefits for oil and
gas producers), several
challenges were identified
which led to produced water
not being implemented at San
Juan. The main barrier to
implementation was that use of
produced water would be
extremely costly yet only
provide a small volume of
water and mitigate a relatively
small risk.
13553240
Also, manufacturing facilities produce effluent with varying quality characteristics
when considering the variety of industries. Variability in volumes and quality of
effluent would result in uncertainty and reliability issues for a power plant
wishing to use this water as an alternative supply.
Finally, there may be uncertainty regarding whether or not a manufacturing
business will be a viable long term supplier of water. A manufacturing facility
could be affected by outside variables such as the economy or regulations which
may lead to an unanticipated shut down and the elimination of this alternative
water supply.
2.3 Produced Water
Produced water is water from underground formations that is brought to the
surface during oil or gas production. In conventional oil and gas wells, produced
water consists of naturally occurring brine present in the reservoir and water
injected nearby to push the hydrocarbon deposit into the production wells. In
unconventional resources (e.g., fracking), produced water is a mixture of the
injected fluids and the formation brines in the reservoir (USGS, 2014).
The quality of produced water quality is influenced by the parent formation and
the associated hydrocarbons. Physical and chemical properties of produced water
can vary significantly across plays, within plays, and even from the same well over
time (Argonne, 2014). Produced water is generally characterized as having total
dissolved solids/salinity, oil and grease, inorganic and organic toxic compounds,
and naturally occurring radioactive material (Veil, 2015). TDS can range from
near freshwater levels to more than 300,000 ppm (USBR, 2011). The USGS
Produced Waters Geochemical Database (Blondes et al., 2016) provides data for
more than 165,000 produced water samples, and is expected to be updated with
new data as provided and needed. A number of previous studies have evaluated
the potential use of produced water electric power facilities (NAS, 2016a; Veil,
2015; Harto et al., 2014; Clark and Veil, 2009; NETL, 2009; EPRI 2006).
2.3.1 Opportunities
There are nearly 1 million actively producing oil and gas wells in the U.S. The
volume of produced water generated from these wells is very large, but because
monitoring and reporting is conducted at a state level, it is not documented
regularly or consistently within the United States (Veil, 2015). Clark and Veil
(2009) estimated the produced water volume for all U.S. oil and gas production
in 2007 was approximately 882 billion gallons per year. In 2012, this volume rose
~1%, to approximately 890 billion gallons per year, with roughly 97% generated
onshore, and 3% generated from offshore wells (Veil, 2015).
Produced water is the largest volume waste stream associated with oil and gas
exploration and production. In 2012, the states with the largest produced water
volumes were Texas, California, Oklahoma and Wyoming, comprising 71% of
the total (Veil, 2015); roughly half of that volume (35%) was generated in Texas.
Arthur (2011) mapped the geographic coverage of oil and gas production in
 2-8 
 relation to coal-fired power plant locations (Figure 2-3). The production rate of
produced water is variable over the lifetime of a well and play (Argonne, 2014).
Because of the potentially large volumes involved, and the considerable variability
in water chemistry, the management of produced water is an important and
complex issue (USGS, 2014).

Figure 2-3
Oil and gas production and coal-fired power plant locations (Source: Arthur,
2011).

Produced water is most commonly injected into a formation or reused to produce

additional gas or oil, injected into a formation for disposal. Nationally, about 93%
of produced water is disposed of by injection (Veil, 2015). Less commonly,
produced water is discharged to surface water, evaporated, shipped off-site for
disposal, or reused for other purposes. Veil (2015) reports a small proportion
(0.6%) of produced water from onshore wells is reused for beneficial reuse,
primarily reuse for fracking. Other options for beneficial use of produced water
include industrial use (cooling, vehicle washwater, process water), roadway use
(dust, snow and ice control), injection for hydrological purposes (subsidence
control, salt water intrusion control, flow augmentation), agricultural use
(irrigation, livestock watering, wetlands management), drinking water and
domestic uses (Veil, 2015). The feasibility of produced water reuse depends on
the quantity generated, the duration and rate at which it is generated over time,
and the quality of the produced water.

2.3.2 Challenges

The beneficial reuse of produced water to support electric power generation is

uncommon and a case study illustrating successful implementation was not

 2-9 

13553240
 identified for this study. There are significant technical, economic, policy, and
social barriers to beneficial reuse of produced water for industrial, agricultural or
municipal uses (Veil, 2015).

Produced water is typically high in salinity and silica and may include moderate
to high hardness and trace levels of ammonia and sulfide (EPRI and CEC,
2003). Total suspended solids, scale-causing compounds (calcium, magnesium,
barium, sulfate) and bacteria can all affect reuse feasibility (Veil, 2015).
Treatment of produced water may include removal of metals and inorganics
through pH adjustment, clarification, electrocoaglulation, or membrane processes
(e.g., nanofiltration); removal of salt through reverse osmosis, thermal
distillation, forward osmosis, or membrane distillation; and removal of oil, grease
and organics through filtration, settling, flotation, coalescence, adsorption or
oxidation (Veil, 2015). Generally, the variability in production rate and quality,
as well as the transportation cost make reuse an expensive option.

From an economic perspective, removal of salt prior to reuse is typically necessary

and is very expensive. It is also technically challenging and expensive to transport
produced water long distances. The Oklahoma Water Resources Board (OWRB)
led a Produced Water Working Group (PWWG) to study and recommend
alternatives for produced water disposal (OWRB, 2017). This study found that
reuse by the oil and gas industry is the most viable cost-effective alternative due
to minimal treatment requirements and costs. Relevant to the electric power
sector, the study found that although desalination of produced water for use at
power plants, industrial plants or discharge to rivers is technically implementable,
it is impractical. Several case studies found the costs of treating produced water to
near freshwater levels for reuse or disposal far outweigh current disposal costs by
over four times (OWRB, 2017). Potential solutions to address economic barriers
include continuing development of cost-effective desalination technologies and
developing databases to connect sellers and buyers of produced water.

Additional policy barriers may be a concern. Water rights become complicated

when produced water is treated as a resource rather than a waste, and sellers of
produced water (oil and gas companies) may be concerned about potential
lawsuits when water is provided to end users. Potential solutions for these
challenges include educating lawmakers and reducing liability by establishing
third-party entities to accept and distribute the produced water.

Produced water is considered a waste byproduct of oil and gas production and is
subject to challenging regulations. Typically it is de-oiled, filtered and disposed
of via injection wells (EPRI, 2006). When produced water is reused and defined
as a “beneficial use” by a state regulatory agency, it often leads to additional
regulatory requirements as compared to injecting the water. In New Mexico, it
would be necessary to obtain rights for this water use, its use must comply with
all applicable environmental regulations, and it must be demonstrated that the
produced water has no hydrologic connection to other waters of the state that are
appropriated to others.

 2-10 

13553240

MINE POOL WATER
Westwood Generating
Station, Pennsylvania
(App. B11)
Westwood (30 MW Coal
Refuse) uses mine pool water
as the primary water source for
the plant (cooling tower
makeup, boiler makeup, and
fire protection). Westwood
was constructed on the site of
a closed coal mine in 1988 to
assist in the reclamation
process and use the coal
mining refuse as a fuel source.
Westwood’s use of mine pool
water provides the plant with a
reliable, low cost water source
of adequate quality. External
benefits include reducing the
potential for acidic mine pool
water to contaminate nearby
surface and groundwater
sources. Potential quantity
issues arise during dry periods,
when the rate of recharge of
the mine pool is slower, which
is why a second mine pool,
which has poorer water quality
and requires more treatment, is
reserved as a backup source.
13553240
2.4 Mine Pool Water
Mine pool water is defined as water that accumulates in abandoned underground
mines. Underground mining was the main method of extracting coal prior to
World War II, but as underground mines closed they also stopped the pumping
that was needed to keep the mines dry. Over time, massive amounts of
groundwater have accumulated in these abandoned mines (Veil et al. 2003).
2.4.1 Opportunities
Utilizing mine pool water for cooling provides a potential solution for inland
plants during times of low water availability. The use of mine pool water may
result in improvements in power plant cooling efficiency due to the cool, constant
temperature of this water source (~50º F) (NETL, 2009). In addition to
providing water for cooling, the withdrawal and drawdown of mine pool water
may reduce the risk of the mine pool water overflowing and contaminating
surface water with iron, manganese, and low pH (Veil et al. 2003). Many mine
pool locations are already overflowing or almost full, requiring the water to be
pumped to prevent surface water contamination from occurring, so utilizing this
water provides a win-win situation by using a potential pollutant source as a
resource.
Arthur (2011) mapped the geographic coverage of oil and gas production in
relation to coal-fired power plant locations (Figure 2-4). Power plants in
Pennsylvania and West Virginia by far have the most opportunities for use of
mine pool water due to the number of abandoned mines. It has been estimated
that these two states have about 250 billion gallons of water stored in abandoned
mines. In addition to being available in adequate quantities in these areas, mine
pool water has a relatively low temperature year-round, which is advantageous for
cooling operations (Veil et al. 2003). As of 2006, Pennsylvania was the only state
that had power plants that used mine pool water, with another project being
proposed on the border between Pennsylvania and West Virginia (Veil & Puder
2006). NETL (2009) summarized considerations for the potential use of mine
pool water at power plants. Veil et al. (2003) and Veil & Puder (2006) evaluated
the feasibility of using coal mine pool water for power plant cooling in
Pennsylvania and West Virginia and provided a number of case studies of plants
that were using mine pool water. Donovan et al. (2004) also studied the technical
and economic feasibility of using mine pool water for power plant cooling needs
in Pennsylvania.
 2-11 
 Figure 2-4
Locations of abandoned coal mines and coal-fired power plant locations (Source:
Arthur, 2011).

2.4.2 Challenges

Mine pool water is only available in coal and metal mining regions, limiting the
accessibility of this water source for other regions (Vidic & Dzombak 2009).
Potential challenges may include technical issues related to effectively collecting,
treating and distributing the water (NETL, 2009). Mine pool water may have
high concentrations of dissolved solids, metals, and particulates, and treatment is
required prior to use. Levels and costs of treatment are site-specific and can vary
significantly because water quality is variable between mines based on the
chemistry of the coal seam, residence time in the mine, and mining method.
Pumping and piping costs can also vary and be substantial. Regulatory issues can
also occur since discharge from mines or power plants to surface water requires a
NPDES permit (NETL, 2009; Veil et al. 2003).

Land subsidence following the withdrawal of mine pool water is another

potential challenge that should be considered (NETL, 2009). Vidic & Dzombak
(2009) provides an evaluation of water availability, relevant regulations, and water
quality management for using passively treated abandoned mine drainage as
makeup water in recirculating cooling water systems. They also discussed and
tested specific treatment options to prevent corrosion, scaling, and biofouling.

2.5 Agricultural Runoff

Agricultural runoff includes both irrigation runoff as well as agricultural runoff

resulting from rain events. Irrigation runoff is defined as surface and subsurface
water leaving the field following application of irrigation water. In non-irrigated
agricultural areas, agricultural runoff occurs via overland runoff and subsurface

 2-12 

13553240

AGRICULTURAL RUNOFF
Indiantown
Cogeneration Power
Plant, Florida
(App. B12)
Indiantown (330 MW Coal
Cogen) has used surface water
that is degraded by agricultural
runoff as its primary water
source since 1995. A lack of
freshwater sources drove the
decision to use this source as
makeup water for the plant’s
cooling towers. Use of this
water provides major benefits to
the area by reducing nutrient
loadings to Lake Okeechobee.
Initial issues with corrosion and
cost from high levels of silt and
nutrients in the water were
remedied through the
installation of an Integrated
Membrane System in 2011.
Tertiary-treated municipal
effluent and brackish
groundwater provide
supplementary sources of water
during severe droughts.
13553240
drainage. Subsurface drainage tiles transport agricultural runoff, helping soils
drain to improve productivity.
2.5.1 Opportunities
Irrigation water use includes all water artificially applied to farm, orchard,
pasture, and horticultural crops. In 2010, irrigation withdrawals accounted for 38
percent of total freshwater withdrawals. Of the total irrigation in the US, 83% of
withdrawals and 74% of the acres irrigated were in the 17 conterminous western
states (Maupin et al., 2014). In 2010, California, Idaho, Colorado, Arkansas,
Montana, Texas, Nebraska and Oregon had the highest volume irrigation
withdrawals (Maupin et al., 2014), indicating these states may offer a higher
opportunity for reuse of irrigation runoff. EPRI (2008b) estimated that on a
national level, agricultural return flow is comparable, in terms of quantity, to
sources of municipal effluent. The study also mapped the cooling water needed to
support projected new generation as a percent of the existing (2008) supply of
agricultural return flow (Figure 2-5).
Agricultural runoff typically contains high levels of salts, nutrients, pesticides,
herbicides and solids. Historically, agricultural runoff has been considered a
nonpoint source, and is generally exempt from state and federal regulation
requiring load reductions. In the Central Valley of California, the cumulative
flow of tailwater from many farms has historically posed significant
environmental problems as it was discharged to surface waters, and these
discharges are now prohibited (CAWSI, 2017). Recent developments, including
uncertainty around the Waters of the United States (WOTUS) rule and the Des
Moines Water Works lawsuit1 in Iowa may influence the management of
agricultural runoff in the future. This may result in more stringent discharge
quality requirements and potentially expanded interest in the use of agricultural
runoff as an alternative water supply for power generation.
Advantages to reuse of agricultural runoff may include ecosystem benefits
resulting from pollutant load reduction.
1
The Des Moines Water Works lawsuit claims the governments of three highly agricultural
counties should be held accountable for allowing high amounts of nitrates to enter Raccoon River, a
major water source to Des Moines.
 2-13 

STORMWATER
Parish Electric
Generating Station,
Texas (App. B13)
Parish (3,724 MW Natural Gas
& Coal) uses a mix of surface
water, stormwater runoff, coal
pile runoff, and reclaimed
sanitary effluent as makeup
water for the plant’s man-made
cooling lake and cooling tower
makeup water. Stormwater
provides supplemental flow into
the cooling lake and accounts
for approximately 10-12% of
the water entering the lake.
Alternative water use at Parish
has provided cost savings,
improved cycles of
concentration, and upstream
and downstream benefits.
13553240
Figure 2-5
Agricultural return flow generation as a percentage of the potential water demand
associated with new electricity generation forecast for 2025 (Source: EPRI,
2008b).
2.5.2 Challenges
Poor water quality and variability in water quantity, including the sometimes
seasonal nature of the runoff, make this a challenging source for use in cooling.
Potential constituents of concern include high levels of dissolved salts, hardness,
and silica and moderate to high levels of phosphate (EPRI and CEC, 2003).
2.6 Stormwater
Stormwater is runoff generated through precipitation events and/or snowmelt.
This water can flow over a land surface until it reaches a surface water body or
enter a groundwater aquifer through infiltration. In areas with developed land,
stormwater is often channeled through storm sewers prior to reaching a
waterbody or discharged to retention ponds. In the past, stormwater was rarely
thought of as a resource; instead, the goal was to move water away from
structures and roadways to reduce the risk of flooding. In recent years, the focus
has shifted to the capture and management of stormwater to help improve the
resiliency of freshwater sources. Green infrastructure projects (e.g., bioswales,
rain gardens, permeable pavement) promote the infiltration of stormwater to
groundwater to improve water quality and help maintain baseflows in streams.
The collection and direct reuse of stormwater is also growing attention. The
National Academy of Sciences published a recent study to evaluate the risks,
 2-14 
STORMWATER
Ormond Beach Station,
California (App. B14)
In 2015, Ormond Beach
(1,516 MW NGCC) adapted
water use processes to collect
and reuse onsite stormwater.
The plant continues to use
Pacific Ocean water for once-
through cooling but now uses
stormwater for demineralization
and service water. Runoff
collected from 37 acres of
industrial property flows into
stormwater vaults and is treated
prior to blending with municipal
water. Benefits include reduced
dependency on municipal water
and elimination of stormwater
discharge.
STORMWATER
Coal Creek Station,
North Dakota (App. B15)
Coal Creek (1,100 MW Coal)
studied the feasibility of
indirectly using stormwater
collected at the facility in a
nearby slough via three
stormwater outfalls. Drivers
were related to research interest
rather than operational
challenges. The analysis found
no clear benefits to using
stormwater and estimated that
implementation would be costly
yet provide only 2.4% of the
water needs. In the end, a lack
of strong drivers and benefits as
well as multiple challenges led
to no action being taken
regarding stormwater use at
Coal Creek.
13553240
costs, and benefits associated with various uses of stormwater and graywater
(untreated wastewater from sinks, showers, tubs and laundry) for both small scale
and larger scale urban environments (NAS, 2016b).
2.6.1 Opportunities
In 2010, EPRI conducted a broad-scale examination of issues related to
stormwater use by power plants (EPRI, 2010). The study evaluated the potential
to use stormwater runoff in lieu of freshwater withdrawals to meet the needs of
different power plant processes. Primary constraints associated with the use of
stormwater included the volume and timing of water as compared to demand,
water quality needed for use and eventual discharge, and the location of the
source relative to the point of use. Two sources of stormwater could potentially
be useful at a power plant: 1) stormwater collected onsite that is likely a small
volume, or 2) a larger offsite supply transported from a municipal separate
stormwater system (MS4). Smaller, onsite sources may not require treatment
prior to use because the small volume would be diluted with another water
source. Larger offsite sources may have unknown or inconsistent quality and
require treatment due to the large volume and less (or no) dilution with other
water sources. Stormwater supplies vary by season and by year; therefore, facilities
using stormwater will need to have onsite storage to ensure a consistent supply.
The feasibility of offsite stormwater collection depends on proximity to larger
communities with a stormwater collection system. Power plants located near
large urban areas and in water scarce regions where stormwater is typically routed
to an estuary or ocean may provide the best opportunities for the reclaimed use of
stormwater. All types of thermoelectric facilities may find opportunities to utilize
stormwater for cooling tower make up. Depending on volumes available,
stormwater may be blended in with other water sources to meet all needs at the
plant. It is unlikely that stormwater would be used for boiler feedwater (i.e.,
demineralized water) without additional treatment, because even low levels of
impurities could cause operational problems.
When considering the use of stormwater collected onsite, coal plants typically
have more opportunities for stormwater collection and reuse (e.g., FGD and ash
systems) as compared with natural gas or nuclear facilities.
2.6.2 Challenges
Potential water quality issues related to the use of stormwater include: sediments,
metals, nutrients, oxygen demanding substances, bacteria, petroleum
hydrocarbons, and synthetic organic compounds. Land use is a primary factor
related to the quality of stormwater runoff.
Costs associated with the use of stormwater may include purchase from an MS4;
infrastructure to collect, pump and store the stormwater; monitoring costs, and
treatment costs. However, a study that evaluated the costs of alternative water
supplies in California estimated that large stormwater capture projects are among
the least expensive options to expand water supplies (median cost of $590 per
 2-15 

BRACKISH INLAND
WATER
Oklaunion Power
Station, Texas (App. B16)
Oklaunion (692 MW Coal) has
used brackish surface water as
its primary water source for 30
years without significant
challenges. Some challenges
have occurred with low cycles
of concentration from poor
water quality during droughts.
Still, this source has been
reliable and cost-effective in a
region where traditional
freshwater sources are not
readily available and water
rights can be an issue during
times of drought.
13553240
acre-foot) as compared to brakish desalination, nonpotable reuse and seawater
desalination (Cooley and Phurisamban, 2016).
As a follow up to the 2010, EPRI further evaluated two Great River Energy
facilities for feasibility of using stormwater as a supplement to freshwater sources
(EPRI, 2012). Neither plant incorporated stormwater into the power plant water
supply management operations due to cost and lack of clear benefits. One of
these cases, Coal Creek Station, was developed into a case study for the current
project.
2.7 Brackish inland water
Brackish (saline) inland water (surface and groundwater) is a widely distributed
potential alternative source for electric power generation. The USGS generally
defines brackish water as having a concentration of total dissolved solids between
1,000 and 10,000 mg/L. In general, this type of water tends to have higher
dissolved solid concentrations than freshwater, but less compared to seawater
(Stanton et al., 2017; Maupin et al., 2014).
2.7.1 Opportunities
Due to its large quantity, brackish groundwater can be a promising alternative to
freshwater in water scarce regions such as Texas and Arizona (EPRI, 2008b).
USGS data suggests that the use of brackish groundwater has been increasing
since 1985. According to USGS water use data from 2010, Hawaii (50.8 MGD),
California (48.4 MGD), and Nevada (11 MGD) accounted for 82% of all saline
groundwater withdrawals for thermoelectric power. Other states with major
withdrawals of saline groundwater for thermoelectric use include Florida (6.54
MGD), Mississippi (7.05 MGD), and Utah (10.5 MGD). These uses were all
for recirculating cooling, with the exception of Hawaii which used 46.9 MGD
for once-through and 3.83 MGD for recirculating cooling (Maupin et al. 2014).
Arthur (2011) mapped the geographic coverage of saline aquifers in relation to
coal-fired power plant locations (Figure 2-6). Additionally, advances in
desalination technologies continue to make the treatment and use of saline water
more feasible.
 2-16 
BRACKISH INLAND
WATER
Indiantown
Cogeneration Power
Plant, Florida
(App. B12)
Indiantown (330 MW Coal
Cogen) uses brackish
groundwater as a back-up
source, to ensure sufficient
supply during severe droughts.
Although mixed with reclaimed
municipal effluent, high TDS
levels do present some
challenges related to
blowdown. While this source
has rarely been used, it
provides a crucial back-up
supply that keeps the plant from
forced stoppages and costly
13553240
Figure 2-6
Locations of saline aquifers and coal-fired power plant locations (Source: Arthur,
2011).
2.7.2 Challenges
The location, depth and quality of brackish groundwater can vary greatly and
depends mainly on geology (EPRI, 2008b). The use of brackish water is mainly
limited by the availability and quality of the water, which drives the cost of
treatment and use. The high levels of dissolved solids tend to limit the number of
cycles of concentration that can be achieved compared to freshwater sources. In
general, water with lower concentrations of dissolved solids tend to be less costly
for cooling. Brackish water is typically most useful and viable when freshwater
and reclaimed water sources are not available. Although water quality may pose a
challenge due to high TDS levels, the case studies showed that the long term use
of brackish water is possible with proper plant design.
Disposal of power plant wastewater (e.g., blowdown) may pose a challenge for
this supply type. The principal method, which is not suitable in all areas due to
geological issues, is to inject it into permitted wells (Harto et al., 2014).
Secondary methods include evaporating the blowdown or discharging the water
into the ocean. The amount of water that needs to be disposed of can be
minimized by maximizing the number of cycles of concentration of the cooling
tower (Harto et al. 2014). Harto et al. (2014) further discusses the challenges and
opportunities of using brackish/saline water for power plant cooling.
2.8 Interbasin transfer
Interbasin transfers involve man-made diversions of water from one river basin to
another. These transfers are typically from a basin with an actual or perceived
surplus to one where water is less abundant, or in higher demand. Water
 2-17 

INTERBASIN TRANSFER
Case Study – Henry W.
Pirkey Power Plant,
Texas (App B17)
Pirkey (721 MW Coal) utilizes
the man-made Brandy Branch
Reservoir as a recirculating
cooling pond. The plant
provides makeup water to the
reservoir through an interbasin
transfer where water is pumped
from Lake O’ the Pines in the
Cypress Creek Basin to the
Brandy Branch Reservoir in the
Sabine River Basin. The use of
an interbasin transfer was
driven by a lack of water
availability in the basin. More
restrictive interbasin transfer
regulations that were
implemented after Pirkey
initiated their interbasin transfer
make it more difficult to
commence an interbasin
transfer in Texas today.
13553240
transfers are administered by various federal, State, and local agencies and other
entities. Regulations regarding interbasin transfers may exclude groundwater
(e.g., Texas). The discharge of treated wastewater effluent to a basin different
from the source watershed would be considered an interbasin transfer.
2.8.1 Opportunities
A benefit of interbasin transfers is the facilitation of economic development in
relatively water-poor areas. Population centers, industrial uses including power
generation, and some agricultural uses depend on water and produce enough
economic value to compensate for the expense of constructing infrastructure to
transport the water (NAP, 2005). A few well-known examples of large-scale
interbasin transfers include the Colorado River, the Central Arizona Project and
the California State Water Project.
The Colorado River watershed drains part of seven states and Mexico. Almost all
of the Colorado River is exported to other watersheds. In Colorado, water is
transported through tunnels under the Rocky Mountains, to population cities
east of the Continental Divide. Colorado River water is transported to California
farmers and cities, through huge aqueducts. As a result, the Colorado River flow
is greatly diminished when it reaches the Mexican border, and flow infrequently
reaches the Pacific Ocean. Construction of the Central Arizona Project aqueduct
system was approved in 1968, and is engineered to divert and deliver an average
of 1.5 million acre-feet/year of Colorado River water to central and southern
Arizona through a 336 mile water delivery system. The California State Water
Project is the nation’s largest state-built water and power development and
conveyance system. The project includes 34 storage facilities, reservoirs and lakes;
20 pumping plants; 4 pumping-generating plants; 5 hydroelectric power plants;
and about 701 miles of open canals and pipelines. Water is moved within
California, and also imported from Colorado, Oregon and Mexico
(www.water.ca.gov/swp).
2.8.2 Challenges
Challenges to interbasin transfers recognize that diversions can cause negative
economic, social and environmental impacts on the basin of origin. Using the
Colorado River as an example, these can include the decline and extinction of
nearly all native fish species, salinity increases making the water unsuitable for
irrigation, limits on community growth due to insufficient supply, and impacts
on wildlife, wetlands and indigenous communities in the Colorado River Delta.
There are many other smaller scale examples of interbasin transfers within the
U.S.; however, the political and regulatory landscape around water is changing.
These changes can result in challenges as described in examples described below
from Texas, the Great Lakes and the southeastern U.S.
In the western US, the prior appropriation system, also referred to as “first in
time, first in right”, does not restrict interbasin transfers; however, because
western water has been fully allocated for over a century, interbasin transfers
 2-18 
 require the transfer of existing water rights (e.g., via purchasing of water rights).
Older, senior water rights holders have priority to water over newer, junior water
rights holders. In 1997, Texas Legislature Senate Bill 1 changed the landscape
for interbasin transfers in Texas, by reducing the legal status of water rights
transferred out of their basin of origin. Specifically a new section was added to
the Texas Water Code providing that “any proposed transfer of all or a portion of
a water right (in an interbasin transfer) is junior in priority to water rights
granted before the time application for transfer is accepted for filing.” Because
Texas relies heavily on interbasin transfers (Figure 2-7), the Texas Water
Development Board funded a Socioeconomic Analysis of Selected Interbasin
Transfers in Texas (Beck, 2006) to examine the effect of SB1. The conclusion of
this report was that the junior priority provision has not had a negative effect on
the consideration of interbasin transfers in the regional planning process;
however, further study was recommended to determine whether the junior
priority provision has impacted the implementation of interbasin transfers.

Figure 2-7
Texas interbasin transfers (source: TWDB, 2002)

The well-publicized Waukesha, Wisconsin case to obtain permission to

withdraw from Lake Michigan, demonstrates that interbasin transfers can be
contentious in water-rich areas. Waukesha is located 17 miles west of Lake
Michigan, just outside the Great Lake Basin. Because the Great Lakes Compact
generally prohibits diversion of Great Lakes water outside the basin, Waukesha
 2-19 

13553240
 had to obtain approval by the governors of the eight Great Lakes States. The
request was ultimately approved, but the process took many years, and the plan
ultimately included a discharge back to Lake Michigan, the basin of origin. In
the southeast, a tri-state dispute between Georgia, Alabama and Florida began in
1990 over water from the Chattahoochee and Flint Rivers. Alabama (1990) and
Florida (2014) brought suit against the Corps of Engineers and Georgia,
respectively, regarding the storage of water in two upstream reservoirs, and
attempted to restrict Georgia’s water use to 1992 levels.

 2-20 

13553240
Section 3: Summary of Key Findings
Electric power facilities have used alternative water sources for decades, for
various uses within a power plant. Based on the facility catalog and case studies,
the most commonly used alternative supply type is reclaimed municipal effluent.
The use of alternative supplies is primarily driven by water scarcity issues and
water quality-related regulatory drivers. This study found that alternative
supplies, including interbasin transfers, can provide a reliable source of sufficient
quality to the facilities, reducing supply-related risks, and in some cases providing
regulatory and public relations benefits. As competition for water increases, the
use of alternative supplies may increase. These compiled case studies relay
information for a range of alternative supplies, and highlight not only the drivers
and benefits, but also costs, challenges and lessons learned to pave the way for
other facilities considering an alternative source.

A number of key findings from the case studies are highlighted in this section.

Many electric power facilities successfully use a variety of alternative water

supplies.

The successful use of alternative water supplies by electric power facilities

demonstrates that these supplies can be a reliable and cost effective option,
supporting a range of uses. Treated municipal effluent has the longest track
record of use (25+ years), and was the most common supply type identified.
Brackish inland water, stormwater, mine pool water, agricultural runoff, and
interbasin transfer are also being successfully used. Neither poor water quality,
nor the need for long range (20+ miles) pipeline transport, precludes successful
alternative supply use. Water supplies with these characteristics are successfully
being used to meet a variety of plant needs which include: 100% of the facility’s
supply needs, cooling only, or process water only. Alternative supplies are also
successfully being blended with other freshwater or alternative sources prior to
use. The case studies illustrate that facilities have successfully navigated a
hierarchy of water supply options and in many cases chose to use an alternate
supply when the economics were favorable.

Alternative supply use requires a strong driver, and the most common drivers
were lack of a traditional freshwater supply and water quality-related constraints.

Fresh water scarcity was the most common driver for securing an alternative
supply. Water availability doesn’t necessarily limit plant siting. Alternative water
supply use in water scarce areas allowed plants to be sited in a preferred location

 3-1 

13553240
 based on power demand, fuel and transmission lines (many examples including
Comanche), or to continue operating (Kyrene).

Several Florida case studies highlight water quality, in combination with

incentives as the driver behind alternative water supply use. The use of alternative
supplies provided regulatory, quality-related benefits to the water supplier, and
quantity and quality benefits to the electric power facility. Water quality (i.e.,
stormwater) discharge concerns drove stormwater reuse at a California facility,
and the switch to this alternative source provided both regulatory and
reputational benefits. Reputational reasons were not identified as a strong driver
in any of the case studies.

In the absence of a strong driver, the use of an alternative supply is not justified
by the cost. Three case studies describe facilities that investigated alternative
supplies but did not follow through with implementation (SJGS - produced
water, Spiritwood - industrial effluent, and Coal Creek - stormwater). In each of
these examples, high costs related to poor and variable water quality (industrial
effluent) and conveyance (produced water and storm water), were not justified
given the availability of a traditional freshwater supply.

Alternative supply use can provide benefits beyond the primary driver.

The case studies provide examples of alternative supplies providing benefits

directly related to the driver. In many cases, alternative supply use addressed
quantity-related issues (14 facilities), and in other examples alternative supply use
addressed water quality-related challenges (Harrison, Indiantown), or provided
regulatory relief (Plant Crist, Spiritwood, The Geysers).

In many examples, the facilities realized additional benefits beyond those directly
related to the primary driver. These additional benefits were most commonly
related to reputation and quality, although cost and occasionally regulatory
benefits were also noted.

Reputational benefits were most commonly reported, although none of the

facilities pursued alternative supplies for reputational reasons. Electric utilities
implementing alternative water supply use have an opportunity to showcase these
practices in their water risk assessment reports and water use disclosure reporting.
The use of an alternative supply allowed one plant to highlight that they were not
contributing to water-related issues in the region. Other plants reported
publically on their alternative water supply use through a variety of
communications including: Carbon Disclosure Project (CDP) Water; Dow Jones
Sustainability Index (DJSI), corporate sustainability reporting or other company
reporting and communication. Two plants noted that alternative supply use was a
likely reason there were no public challenges regarding facility citing or water use.
Specific water metrics, as researched by EPRI (2015), may provide a useful way
for electric utilities to quantify their use of alternative water supplies in relation to
their freshwater use. Articulating these practices through internal reporting and
external disclosure can support broader efforts aimed at addressing operational or
reputational water risk and promoting water stewardship activities.

 3-2 

13553240
 Both municipal and mine pool water providers benefited from reuse of their
supply by electric power facilities. The benefits were related to water quality in
the form of NPDES discharge permitting relief, such as reduction of an NPDES
discharge (Plant Crist, Plant Smith, The Geysers) or elimination of a storm
water discharge (Ormond Beach). Additional benefits to the water providers
included increased revenue, upgraded treatment systems, and facilitation of
WWTP siting in a preferred location.

A few electric power facilities realized a cost benefit related to using an

alternative supply instead of a freshwater source (Comanche, Plant Crist, Plant
Smith, WA Parish). In one example, the company’s experience using reclaimed
water at one plant better positioned them to acquire a plant using reclaimed
water in another state.

Successful implementation requires good planning, defined conditions, and

back-up supplies.

Common factors for successful use of new or retrofit alternative supplies are good
planning, establishment of well-defined conditions (i.e., agreements) with the
water supplier, and the availability of back-up supplies. Facilities that rushed the
process of using an alternative supply experienced technical challenges and
increased costs (Harrison and Spiritwood).

Successful planning considers a variety of factors, including pipeline siting,

construction and pumping costs, use for the water, and any additional treatment
requirements. It is important for the electric utility to understand how the quality
of water received will impact discharge quality, whether the water is discharged
to a nearby waterbody or to a wastewater treatment plant. Water conveyance to
the site is an important consideration which affects the cost of alternative water
use. Water is transported over 20 miles in several successful case studies.
However, in two produced water and storm water case studies, conveyance-
related costs hindered the use of these supplies.

Many of the case study facilities have long-term agreements for alternative water
supply use. These agreements are varied with regards to the supply type, cost (for
infrastructure, operation & maintenance, and treatment) and water fees
(sometimes there is a fee for the water, but sometimes there is no charge).
Agreements between the water supplier and electric utility should clearly define
the quantity and quality of the water being provided to ensure the electric utility
will have a reliable supply of water that meets necessary quality requirements.
Any agreements should clearly describe fees for the water, and may also describe
cost-sharing arrangements for pipelines, additional storage and treatment.

Contingency planning is an important component of successful planning, to

protect the plant from supply interruption related to quantity or quality. Kyrene
provides an example of a facility that effectively navigated an interruption in
supply when the municipal effluent supplier ceased operation because they had an
established plan for the use of other water supplies/back-up supplies.

 3-3 

13553240
 Quality is the biggest challenge but can be overcome.

Water-quality related issues were the most commonly identified challenge of

alternative supply use, but case studies demonstrated that utilities can adapt.
Water quality challenges typically appeared during plant start-up and were noted
for nine of the case studies. Six facilities overcame the challenge of poor water
quality by providing additional treatment, and these facilities continue to
successfully use alternative supplies. Inconsistent quality was identified as a
challenge in three case studies (mine pool, industrial effluent, and produced
water). Additional treatment is almost always needed before use, regardless of the
water source. Water quality issues can be overcome with the proper planning and
adaption; however, these same issues can also be insurmountable, if the use of an
alternative supply is not carefully planned (Spiritwood).

Some alternate supplies are more promising than others.

Treated municipal effluent has been successfully reused by electric power facilities
for decades and examples are geographically distributed throughout the U.S. This
is the most promising alternative supply, due to its ability to provide a reliable
supply of water with a predictable quality. Nutrient discharge regulations in
combination with incentives in Florida further drive municipal effluent reuse.

Stormwater and agricultural runoff have challenges related to variable quantity

and quality, but the Ormond Beach and Indiantown case studies show that these
are viable supplies when there is also a water quality-related driver (e.g.,
regulatory, financial or reputational incentives to reuse degraded water rather
than discharge to vulnerable receiving waters). There are very few sites using
these supplies, but future use is promising, especially in areas where the use of
stormwater or agricultural runoff provides water quality-related benefits to a
discharger or to the receiving water.

Mine pool water, brackish water and industrial effluent typically have poor or
variable water quality, which can increase the treatment costs, or limit the cycles
of concentration. Brackish ground or surface water is the second most common
alternative source identified. Several interviewed facilities shared that the salinity
of this source did not preclude its use, although salinity did affect the cycles of
concentration in some facilities. With careful planning, well-defined agreements,
and a back-up sources, these supply types can be successfully used, although use
may not occur unless there is significant site-specific driver, or treatment costs are
reduced.

Interbasin transfers and produced water appear to be the least promising supplies
for the future. Although interbasin transfers are commonly used today, new
transfers are less likely to occur in the US in the future due to regulatory and
stakeholder challenges. Recent regulations in Texas, for example, result in
interbasin transfers losing their water right seniority and instead carry a junior
priority. The result is a disincentive for interbasin transfers. Additionally,
interbasin transfers can impact the donor basin, and the resulting supply,
economic, or environmental impacts concerns raised by stakeholders may make

 3-4 

13553240
 interbasin transfers less promising. Produced water has been investigated as an
alternative supply, but does not currently appear to be a viable source, due to
issues related to quantity, quality, transportation and potential regulatory
disincentives.

 3-5 

13553240
13553240
Section 4: Looking Forward
Electric power generating facilities have successfully used alternative water
sources to meet cooling and process water demands for decades. Notably,
reclaimed municipal effluent is the most common supply type. This supply can
provide a sufficient, reliable quantity of water that has predictably good quality,
availability and cost. Regulatory drivers and incentives have also made this a
preferred source in some areas.

The drivers, benefits and challenges of using reclaimed municipal effluent have
been described previously, focusing on the perspectives of electric power-
generating facilities. This section describes the provider perspective regarding
municipal effluent reuse, relying heavily on information obtained from Water
Environment and Reuse Foundation (WE&RF) 2 through review of the Water
Reuse Roadmap Primer (WEF, 2016) and a phone interview (WE&RF, 2017b).

4.1 Current State of Reuse

Within the U.S., between 1 and 10% of wastewater is currently being recycled,
occurring more frequently in the sunbelt states and arid southwest. There is a
general trend of decreasing wastewater effluent flows due to implementation of
water conservation activities, although regional differences exist. For example,
wastewater flows have decreased roughly 30% in arid regions, but have remained
flatter in other areas such as Chicago.

At this time, there is little competition for reclaimed wastewater due to its
abundance. However, WE&RF indicated that even if there were competition for
this source, it is unlikely that the effluent would be sold to the highest bidder,
because the focus is more on what’s good for the community.

From the perspective of WE&RF, municipal reuse is easiest if it is provided for

other municipal uses, with the most convenient reuse projects being irrigation of
street medians and reservoir augmentation. These are straight forward primarily
due to ease of communication. Other uses are a bit more difficult due to water
quality and acceptability issues, in addition to the need to educate users on issues
related to water quality and reliability.

2
WE&RF (http://www.werf.org/) recognizes that all water has value, and conducts research on
renewable resources from wastewater, recycled water and stormwater while maintaining the quality
and reliability of water for the environment and communities.

 4-1 

13553240

DESIGNER WATER
West Basin Municipal
District, CA
To meet the unique needs of
commercial and industrial
customers, the West Basin
Municipal District in Los Angeles
provides “designer water.”
Effluent is treated beyond
tertiary levels using tailored
treatment methods for uses such
as irrigation, cooling towers,
seawater barrier and
groundwater replenishment,
and low- and high-pressure
boiler feed supplies (WEF,
2016).
MUNICIPAL EFFLUENT
Smith Generating
Plant, Florida (App.B6)
Plant Smith (556 MW NGCC)
is in the process of securing
their future use of reclaimed
municipal effluent from multiple
utilities in the area. Planning to
transition to this new source
from brackish surface water
began in response to water
quality issues with the current
source and Florida’s new
numeric nutrient standards. The
effluent will comprise 100% of
the plant’s cooling tower
makeup water. It is expected
that the use of this source will
be operation by late 2018 or
early 2019, improve
operations, and reduce nutrient
loading discharges to the bay,
cost, and water consumption.
13553240
4.2 Opportunities
WE&RF sees wastewater treatment plants increasingly becoming water resource
recovery facilities (WRRFs) in order to improve sustainability/resiliency of
supply. Furthermore, WE&RF expects municipal effluent reuse to increase in
the future. One reason is that wastewater utilities are willing to take on the
regulatory/compliance requirements (e.g., discharge and monitoring
requirements), benefitting the users of the reclaimed effluent which don’t have to
deal with discharge-related compliance issues. Secondly, water reuse is regulated
at a state level, and state regulators have been very open to reuse projects.
Although reuse is easier if there is a state plan (e.g., CA, AZ and TX), the
absence of a plan or regulations regarding reuse does not necessarily impede
reuse. The existence of a state plan may facilitate the adoption of state policies
and funding. For example, in California, proposition 84 was used to fund reuse.
In Florida, there has been an investment in reuse projects through the water
management districts.
The Water Reuse Roadmap primer (WEF, 2016), provides a matrix of best
practices for reuse and describes two themes supporting successful reuse, both of
which are relevant to the end-users of reclaimed effluent. The first, “fit for
purpose”, is defined as “the right water for the right use”. WE&RF sees a strong
opportunity for the “fit for purpose” concept, which involves WRRFs being
aware of the end use of their product and ensuring the water is treated to
sufficient quality for the use. The second theme, “legitimacy”, means that
WRRFs must be able to address concerns of the user that relate to user benefits,
user involvement in decision-making, guarantees regarding safety and quality,
past performance of the utility, and whether reuse is essential given other
alternatives. A final Water Reuse Roadmap is planned for publication in late 2017
and will serve as a guidance document to help decision-makers quickly
understand the strategic issues inherent in a water reuse effort (WEF, 2016).
Case studies and additional resources will also be included in the roadmap.
The evolution of wastewater treatment plants into water resource recovery
facilities that can provide “the right water for the right use” and which address
the concerns of the users, may facilitate communication and contracting
regarding reuse, and minimize some of the challenges described in the case
studies. These changes may make municipal effluent an increasingly viable
alternative source for electric power facilities and others in the future.
4.3 Challenges
There are several barriers to reuse of municipal effluent from the perspective of
the wastewater treatment plant. First, is the need to communicate the benefits of
reuse and educate people on its economics and reliability. Second, reuse requires
adoption of a new mindset and may also require a culture change for the
WWTPs, changing their focus from discharge to the sale/reuse of effluent.
Third, challenges may occur when there is absence of dedicated regulatory
framework, lack of information sharing and best practices, risk aversion and
 4-2 
 resistance to change, or inability of stakeholders to work cooperatively and
collaboratively (ASME & WEF, 2012). Successful reuse projects are noted to
have active collaboration between municipal wastewater plants and electric
utilities, clearly defined water quality and flow rates, optimal and adaptable
system design, compliance with all regulations, and ongoing education and
outreach efforts (ASME & WEF, 2012).

Technology and cost are not necessarily barriers to implementation. There may
be more upfront costs related to reuse; however, there may be additional
secondary benefits to the water supplier, as well as the power plant, ecosystem
and/or community.

4.4 Supplier Recommendations for Successful Implementation

The following recommendations were developed for electric utilities and

municipal wastewater utilities focused on collaborating to deliver municipal
effluent to power plants as an alternate water supply (ASME & WEF, 2012).
These recommendations are uniformly applicable to all alternate water supplies
that were explored within this study:
 A concerted effort to foster collaboration between the alternate supply
provider and the electric power utility will provide benefit. Each party should
have clear understanding of each other’s needs, expectations and capabilities.
 Development of a formal, long-term (e.g., 30+ years) contract between water
supplier and electric utility to ensure good practice collaboration.
 The reclaimed water provider should provide a sufficient history (e.g., 2
years) of water quality data to the electric utility prior to implementing the
water delivery. This will provide confidence to the electric utility that the
water quantity and quality will remain within acceptable tolerances for the
power plant to operate.
 Both parties should work closely with regulators, city and regional planners,
and the general public during the design and implementation of the system.
This will help ensure compliance with water and air regulations and
minimize potential resistance from third-parties.

The case studies highlighted in this study demonstrate several successful

examples of effluent reuse at electric power facilities. Many incorporate the
recommendations listed above. These case studies may serve as a useful resource
to educate WWTPs/WRRFs and help them better understand the benefits,
address the challenges and effectively implement use of an alternative water
supply.

 4-3 

13553240
13553240
Section 5: References
Argonne National Laboratory (Argonne), 2014. Saline Water for Power Plant
Cooling: Challenges and Opportunities. ANL/EVS-14/15. November.

Arthur, J. D. 2011. Internet Based, GIS Catalog of Non-Traditional Sources of

Cooling Water for Use at America’s Coal-Fired Power Plants. Final
Scientific/Technical Report. Prepared for U.S. Department of Energy, National
Energy Technology Laboratory, Office of Fossil Energy. DOE Award Number
DE-NT0005957.

American Society of Mechanical Engineers and Water Environment Federation

(ASME & WEF). 2012. Municipal Wastewater Reuse by Electric Utilities: Best
Practices and Future Directions, Workshop Report, September 12, 2012.
Available at
http://files.asme.org/Committees/K&C/TCOB/BRTD/WMT/33220.pdf

Beck, R.W. Inc., 2006. Socioeconomic Analysis of Selected Interbasin Transfers

in Texas. Draft Report prepared for Texas Water Development Board.
November.

Blondes, M.S., K.D. Gans, E. L. Rowan, J.J. Thordsen, M.E. Reidy, M.A.
Engle, Y.K. Kharaka, and B. Thomas, 2016. U.S. Geological Survey national
produced water geochemical database v2.2 (provisional) 02/16/2016: U.S.
Geological Survey Web page accessed September 23, 2016 at
http://energy.usgs.gov/EnvironmentalAspects/EnvironmentalAspectsofEnergyPr
oductionandUse/ProducedWaters.aspx#3822349-data

California Department of Water Resources (CA DWR), 1977. Water for Power
Plant Cooling, State of California, Department of Water Resources, Bulletin No.
204, July 1977.

California Agricultural Water Stewardship Initiative (AWSI), 2017. Reuse of

Agricultural Wastewater, California Ag Water Stewardship Initiative. Available
at: http://agwaterstewards.org/practices/reuse_of_agricultural_wastewater/

Clark, C.E., and J.A. Veil, 2009, Produced Water Volumes and Management
Practices in the United States, ANL/EVS/R‐09/1, prepared for the U.S.
Department of Energy, National Energy Technology Laboratory, September, 64
pp.

 4-1 

13553240
 Cooley and Phurisamban, 2016. The Cost of Alternative Water Supply and
Efficiency Options in California, Pacific Institute, October, 2016.

Donovan J.J., Duffy B., Leavitt B.R., Stiles J., Vandivort T., Ziemkiewicz P.
2004. WRI 50: Strategies for Cooling Electric Generating Facilities Utilizing
Mine Water: Technical and Economic Feasibility Project. DOE Award Number
DE-FC26-03NT41908.

Dzombak, D. A., Vidic, R. D., and A. E. Landis. 2012. Use of Treated

Municipal Wastewater as Power Plant Cooling System Makeup Water: Tertiary
Treatment versus Expanded Chemical Regimen for Recirculating Water Quality
Management. Submitted to U.S. Department of Energy, National Energy
Technology Laboratory. Cooperative Agreement Number DE-NT0006550.

Electric Power Research Institute and California Energy Commission (EPRI

and CEC), 2003. Use of Degraded Water Sources as Cooling Water in Power
Plants, EPRI, Palo Alto, CA, and California Energy Commission, Sacramento,
CA: 2003. 1005359.

EPRI, 2006. Program on Technology Innovation: Water Resources for

Thermoelectric Power Generation: Produced Water Resources, Wet-Surface Air
Cooling, and WARMF Decision Support Framework. EPRI, Palo Alto, CA
and USDOE, Morgantown, WV: 2006. 1014487.

EPRI, 2008a. Water Use for Electric Power Generation. EPRI, Palo Alto, CA:
2008. 1014026.

EPRI, 2008b. Use of Alternate Water Sources for Power Plant Cooling. Palo
Alto, CA: 2008. 1014935.

EPRI, 2010. Evaluation of Stormwater as a Resource for Power Plant Cooling,

Palo Alto, CA: 2010. 1021124.

EPRI, 2012. The Potential for Using Stormwater in Power Plants: Lessons
Learned form Case Studies at Two Great River Energy Plants, Palo Alto, CA:
2012: 1023774.

EPRI, 2015. Evaluation of Water Management Metrics for the Electric Power
Sector. EPRI, Palo Alto, CA: 2015. 3002006245.

Florida Department of Environmental Protection. 2016. Water Reuse. Last

updated June 15, 2016. URL: http://www.dep.state.fl.us/water/reuse/ [Accessed
11/11/2016].

Harto, C., Finster, M., Schroeder, J., and C. Clark. 2014. Saline Water for
Power Plant Cooling: Challenges and Opportunities. ANL/EVS-14/15.
Argonne National Laboratory, Environmental Science Division.

 4-2 

13553240
 Maupin, M.A., Kenny, J.F., Hutson, S.S., Lovelace, J.K., Barber, N.L., and K.
S. Linsey. 2014. Estimated use of water in the United States in 2010: U.S.
Geological Survey Circular 1405, 56 p., http://dx.doi.org/10.3133/cir1405.

McCall, J., J. Macknick, and D. Hillman. 2016. Water-Related Power Plant

Curtailments: An Overview of Incidents and Contributing Factors. NREL/TP-
6A20-67084. Golden, CO: National Renewable Energy Laboratory.
http://www.nrel.gov/docs/fy16osti/67084.pdf.

National Academies Press (NAP), 2005. Water Conservation, Reuse, and

Recycling: Proceedings of an Iranian-American Workshop. Chapter: Interbasin
Water Transfers in the Western United States: Issues and Lessons – David H.
Getches. Available at https://www.nap.edu/read/11241/chapter/17.

National Academies of Sciences (NAS), Engineering, and Medicine. 2016a.

Flowback and Produced Waters: Opportunities and Challenges for Innovation:
Proceedings of a Workshop. Washington, DC: The National Academies Press.
doi:https://doi.org/10.17226/24620.

NAS, Engineering, and Medicine. 2016b. Using Graywater and Stormwater to

Enhance Local Water Supplies: An Assessment of Risks, Costs, and Benefits.
Washington, DC: The National Academies Press. doi: 10.17226/21866.

National Energy Technology Lab (NETL), 2009. Use of Non-Traditional

Water for Power Plant Applications: An Overview of DOE/NETL R&D
Efforts, National Energy Technology Laboratory, DOE/NETL-311/040609.

Oklahoma Water Resources Board (OWRB), 2017. Oklahoma Water for 2060
Produced Water Reuse and Recycling, Oklahoma Produced Water for 2060
Produced Water Working Group (PWWG), April 26, 2017, Available at
https://www.owrb.ok.gov/2060/pwwg.php.

Schumerth, D.J., 2006. Gray and Impaired Water Cooling in Surface

Condensers and Heat Exchangers, Proceedings of PWR2006, ASME Power,
May 2-4, 2006. Atlanta, GA.

Stanton, J.S., Anning, D.W., Brown, C.J., Moore, R.B., McGuire, V.L., Qi,
S.L., Harris, A.C., Dennehy, K.F., McMahon, P.B., Degnan, J.R., and Böhlke,
J.K., 2017, Brackish groundwater in the United States: U.S. Geological Survey
Professional Paper 1833, 185 p., https://doi.org/10.3133/pp1833.

Texas Water Development Board (TWDB), 2002. State Water Plan, Water for
Texas – 2002, Texas Water Development Board, January, 2002.

United States Department of Homeland Security (USDHS), 2017. Critical

Infrastructure Sectors. Water and Wastewater Systems Sector, available at
https://www.dhs.gov/water-and-wastewater-systems-sector

 4-3 

13553240
 United States Energy Information Administration (EIA). 2016. Form EIA-860
detailed data. Early Release of 2015 data, June 17, 2016. Compressed data files
available at https://www.eia.gov/electricity/data/eia860/.

United States Environmental Protection Agency (U.S. EPA), 1980. Industrial

Reuse and Recycle of Wastewaters: Literature Review, EPA/600/2-80-183,
September 1980.

U.S. EPA, 2012. Guidelines for Water Reuse. United States Environmental
Protection Agency, EPA/600/R-12/618, September 2012.

United States Geological Survey (USGS). 2014. USGS Investigations of Water

Produced During Hydrocarbon Reservoir Development. Fact Sheet 2014-3104.
November 2014. Available at http://pubs.usgs.gov/fs/2014/3104/pdf/fs2014-
3104.pdf

Veil, J. A. 2007. Use of Reclaimed Water for Power Plant Cooling. Prepared for
the U.S. Department of Energy, National Energy Technology Laboratory.
ANL/EVS/R-07/3.

Veil J. 2015. U.S. Produced Water Volumes and Management Practices in 2012.
Prepared for the Ground Water Protection Council. Available at
http://www.veilenvironmental.com/publications/pw/prod_water_volume_2012.p
df

Veil, J., J. Kupar, and M. Puder. 2003. Use of Mine Pool Water for Power Plant
Cooling. Prepared by Argonne National Laboratory for the U.S. Department of
Energy, National Energy Technology Laboratory, September, 62 pp. Available at
http://www.netl.doe.gov/technologies/coalpower/ewr/pubs/mine%20pool%20rep
ort%20FINAL_1.pdf.

Veil, J., and M. Puder. 2006. Update on Use of Mine Pool Water for Power
Generation. Prepared by Argonne National Laboratory for the U.S. Department
of Energy, National Energy Technology Laboratory, September, ANL/EVS/R-
06/6, 26 pp.

Vidic, R. D. and D. A. Dzombak. 2009. Reuse of Treated Internal or External

Wastewaters in the Cooling Systems of Coal-Based Thermoelectric Power
Plants. Final Technical Report to US DOE/NETL, project DE-FC26-
06NT42722, 2009.

Water Environment Federation (WEF), 2012. Municipal Wastewater Reuse by

Electric Utilities: Best Practices and Future Directions, Workshop Report,
Water Environment Federation (WEF) and American Society of Mechanical
Engineers (ASME), September 12, 2012.

WEF, 2016. Water Reuse Roadmap Primer: Essential practices to make water
reuse an element of a diverse and resilient water management strategy, Water
Environment Federation (WEF), Water Environment & Reuse Foundation
(WE&RF), the National Water Research Institute (NWRI), and WateReuse,
 4-4 

13553240
 November, 2016. Available at: http://news.wef.org/water-reuse-roadmap-
primer-describes-best-practices/

Water Reuse Research Foundation (WRRF), 2016. Drivers, Successes,

Challenges, and Opportunities of On-Site Industrial Water Reuse: A Path
Forward for Collaboration and Growth, Water Reuse Research Foundation,
Project Number: 13-04, 2016.

Water Environment & Reuse Foundation (WE&RF), 2017a. A Framework for

the Successful Implementation of On-site Industrial Water Reuse, Water
Environment & Reuse Foundation, Reuse-14-04, 2017.

WE&RF, 2017b. Personal communication with Chief Research Officer, Water

Environment & Reuse Foundation (WE&RF), February 27, 2017.

 4-5 

13553240
13553240
Appendix A: Catalog of Power Plants
using Alternative Water
Supplies

 A-1 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)
Agricultural Runoff (primary)
Florida Power &
/ Brackish Groundwater Taylor Creek (agricultural
Indiantown Cogeneration Light (developed by
(secondary) / Reclaimed FL Coal 330 Cooling Tower(s) runoff); Brackish groundwater; 3 1995
Plant** Indiantown
Municipal Effluent City of Indiantown, FL (WWTP)
Cogeneration L.P.)
(secondary)
Solana Generating Arizona Solar One
Brackish Groundwater AZ Solar 280 Cooling Tower(s) On-Site Groundwater 108 2013
Station LLC
AltaGas Sonoran
Brackish Groundwater Sonoran Energy Project CA NGCC 535 Cooling Tower(s) Wells 186.5 2018
Energy Inc
Treasure Coast Energy Florida Municipal
Brackish Groundwater FL Natural Gas 412 Cooling Tower(s) Well Water & Treated Effluent 1.5 2008
Center Power Agency

Brackish Groundwater AES Hawaii AES Hawaii HI Coal 203 Cooling Tower(s) Wells 11.8 2000

Quantum Choctaw Tennessee Valley

Brackish Groundwater MS NGCC 760 Cooling Tower(s) Deep Wells 3.6 2006
Power LLC Authority (TVA)
Red Hills Generating Choctaw
Brackish Groundwater MS Coal 514 Cooling Tower(s) Wells 5.4 2002
Facility Generation L.P
Portsmouth
Brackish Groundwater Portsmouth Genco LLC Operating Services VA Coal 115 Cooling Tower(s) Wells 1.3 1988
LLC
American National
Brackish Surface Water Hays Energy Project TX NGCC 989 Cooling Tower(s) San Marcos 0.3 2002
Power

Brackish Surface Water Oklaunion Power Plant** AEP/SWEPCO TX Coal 692 Cooling Tower(s) Lake Diversion 6.9 1986

Grey water from three nearby

Grey water Walter Higgins Station NV Energy NV NGCC 530 Dry cooling
casinos
Concentrated
Hualapai Valley Solar Hualapai Valley
Interbasin Transfer AZ Solar Power 340 Cooling Tower(s) Kingman WWTP Not in use Project on hold
Project Solar LLC (HVS)
(CSP)
Denver's Water Recycling Plant
Coal (natural
Interbasin Transfer Cherokee Power Plant Xcel Energy CO 717 Cooling Tower(s) & Metro Wastewater Treatment 4.7 2004
gas as backup)
Plant

Interbasin Transfer Plant Washington Power4Georgians GA Coal 850 Cooling Tower(s) Project on hold

Interbasin Transfer Lamar Energy Center NextEra TX NGCC 1309 Cooling Tower(s)

Lake O' The Pines (Big Cypress

Interbasin Transfer Pirkey Power Plant** AEP/SWEPCO TX Coal 721 Cooling Pond 13 1985
Basin)

 A-2 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)
Landfill leachate Babylon Covanta NY Biomass 17 Old town landfill leachate 1989
Sierra Pacific Power
Mine Pool Valmy Power Plant Company and Idaho NV Coal 500 Cooling Tower(s) Lone Tree Mine 7.2 1996
Power Company
John B. Rich Memorial Gilberton Power Coal (waste
Mine Pool PA 80 Cooling Tower(s) Gilberton Mine pool 1.37 before 1985
Power Station Company coal)
Limerick Nuclear Exelon Generation
Mine Pool PA Nuclear 2317 Cooling Tower(s) Wadesville Mine Pool Up to 14.4 2003
Generating Station Company LLC
Northeastern Power Northeastern Power Drainage tunnel for Silverbrook
Mine Pool PA Waste Coal 50 Cooling Tower(s) 0.14 1989
Company Company mine
Panther Creek Constellation Wet Cooling
Mine Pool PA Waste Coal 83-94 Lausanne mine tunnel 1.1 1992
Generating Station Energy/Exelon (auxiliary)
Schuylkill Energy Schuylkill Energy Coal (waste
Mine Pool PA 80 Cooling Tower(s) Maple Hill mine 1.58 1989
Resources Inc. Resources Inc. coal)
Wisconsin Public New Lincoln mine pool (Lyken
Westwood Generating Coal (waste
Mine Pool Service Resources PA 30 Cooling Tower(s) mine); Westwood mine pool 1.12 1988
Station** coal)
(WPSR)/Integrys (backup)
Wheelabrator
Wheelabrator Frackville Coal (waste
Mine Pool Frackville Energy PA 42 Cooling Tower(s) Morea mine 0.58-1.01 1988
Power Plant coal)
Co.
WMPI PTY., LLC
Coal Cooling Tower(s)
Mine Pool gasification and WMPI PTY., LLC PA 41 Gilberton mine pool 7
Gasification & Process Water
liquefaction facility

Condamine CCGT Power Queensland Gas Recycled wastewater from coal

Produced Water Australia NGCC 140 Cooling Tower(s)
Station Company seam methane production

San Juan Generating Investigated available water

Produced Water PNM NM Coal 1848 Cooling Tower(s) Not in use
Station** from oil and gas production
Sam O. Purdom
Reclaimed Industrial Effluent City of Tallahassee FL IGCC 250 Cooling Tower(s) St. Marks Powder 0.75 2002
Generating Station
Steam Dora creek wastewater
Reclaimed Municipal Effluent Eraring Power Station Origin Energy Australia Coal 2880
Generation treatment works
2002-2010 (no
Kyrene Generating Salt River Project Kyrene Water Reclamation
Reclaimed Municipal Effluent AZ NGCC 415 Cooling Tower(s) 3.1 longer in
Station** (SRP) Facility
operation)
Palo Verde Generating Arizona Public 91st Avenue and Tolleson
Reclaimed Municipal Effluent AZ Nuclear 3875 Cooling Tower 90 1990
Station Service (APS) WWTPs

 A-3 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)
Arizona Public Tolleson WWTP & Palo Verde
Reclaimed Municipal Effluent Redhawk Power Plant AZ NGCC 1060 Cooling Tower(s) 3.9 2001
Service (APS) Nuclear Generating Station
Delta and Los Medanos Delta Diablo Sanitation District
Reclaimed Municipal Effluent Calpine CA NGCC 857 Cooling Tower(s) 7.7 2001
Energy Centers reclamation plant
El Segundo Energy
Reclaimed Municipal Effluent NRG Energy CA NGCC 550 Dry Cooling 2013
Center
Etiwanda Generating
Reclaimed Municipal Effluent NRG Energy CA Natural Gas 23.9 Cooling Tower(s) 1963
Station
Middletown, Southeast
Calpine/Northern
Geysers Geothermal Steam Injection Regional, Northwest Regional,
Reclaimed Municipal Effluent California Power CA Geothermal 1517 20 1997
Field** Wells Clearlake Oaks, and Laguna
Agency
WWTP's
Glendale Public Natural Gas &
Reclaimed Municipal Effluent Grayson Plant CA 301 Cooling Tower(s) Glendale WWTP 0.3 1979
Service Landfill Gas
Southern California
Reclaimed Municipal Effluent Magnolia Power Project Public Power CA NGCC 310 Cooling Tower(s) Burbank WWTP 1.0-1.4 2005
Authority (SCPPA)
Southern California
Mountainview WWTP and non-potable
Reclaimed Municipal Effluent Edison Company CA NGCC 1056 Cooling Tower(s) 6.2
Generating Station groundwater (50-50 blend)
(SCE)
1967 (Olive
Olive and Lake One Burbank Power & 45 (Lake
Reclaimed Municipal Effluent CA Natural Gas Cooling Tower(s) Burbank WWTP 5 Plant); 2002
plants Water One)
(Lake One Plant)

Reclaimed Municipal Effluent Pacific Oroville Power Covanta CA Biofuel/waste 18 Cooling Tower(s) Oroville Region WWTP 0.05 1989

Puente Hills Energy Sanitation Districts

Gas from
Reclaimed Municipal Effluent Recovery from Landfill of Los Angeles CA 46 Cooling Tower(s) San Jose Creek WRP 0.5 1984/1997
landfill
Gas (PERG) Facility County (LACSD)
Russell City Energy
Reclaimed Municipal Effluent Calpine CA NGCC 619 Cooling Tower(s) City of Hayward WWTP 4 2013
Center
Sanitation Districts
Spadra Gas-to-Energy Gas from
Reclaimed Municipal Effluent of Los Angeles CA 5 Cooling Tower(s) Pomona WRF 0.03 1991
Plant landfill
County (LACSD)

Reclaimed Municipal Effluent Walnut Creek NRG Energy CA Natural Gas 500 Cooling Tower(s) Rowland water district 2006

Calgary, Bonnybrook Wastewater

Reclaimed Municipal Effluent Shepard Energy Centre ENMAX NGCC 800 Cooling Tower(s) 3.7 2015
Alberta Treatment Plant

 A-4 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)
Platte River Power Coal & Natural
Reclaimed Municipal Effluent Rawhide Energy Station CO 668 Cooling Tower(s) Drake WRF 3.8 1984
Authority Gas
Once-through
Reclaimed Municipal Effluent Bartow Plant Duke Energy FL Coal 1133 Bartow WWTP 2
Cooling Pond
Hillsborough Co. South County
Reclaimed Municipal Effluent Big Bend Plant Tampa Electric Co. FL Coal 1700 Cooling Tower(s) Regional Facility and 2-3.5 1984
Falkenburg WRF
Lakeland WWTP (intermediate
Reclaimed Municipal Effluent C.D. McIntosh, Jr. Lakeland Electric FL Coal 364 Cooling Tower(s) 5.4 1983
disinfection)
Kissimmee Utility South Bermuda WRF and
Reclaimed Municipal Effluent Cane Island Plant FL NGCC 700 Cooling Tower(s) 1.0-2.3 1990s
Authority Camelot WRF

Cooling Tower(s)
Reclaimed Municipal Effluent Crystal River Duke Energy FL Coal 2295 City of Crystal Springs 0.75 2015
& Cooling Pond

Coal, NGCC,
Curtis Stanton Energy Orlando Utilities Natural Draft Orange County's Eastern
Reclaimed Municipal Effluent FL Nuclear, & 1262 8-11 1987
Center Commission Cooling Tower(s) Wastewater Treatment Facility
Landfill
Hillsborough County High level disinfected
Municipal Solid
Reclaimed Municipal Effluent Resource Recovery Covanta FL 46.5 Cooling Tower(s) Hillsborough Co. Falkenbergy 0.7-1.0 Mid 1990s
Waste
Facility Rd WWTP

Reclaimed Municipal Effluent Hines Energy Complex Duke Energy FL NGCC 2000 Cooling Pond Bartow WWTP 1.8 1995

Cooling Tower(s) South Bermuda WRF and

Reclaimed Municipal Effluent Intercession City Plant Duke Energy FL NGCC 982 0.03-0.2 1990s
& Scrubbers Camelot WRF

Southern Emerald Coast Utility Authority's

James F. Crist Cooling Tower(s)
Reclaimed Municipal Effluent Company/Gulf FL Coal 924 Central Water Reclamation 6 2009
Generating Plant** & Scrubbers
Power Facility
Southern
Lansing Smith Not yet in
Reclaimed Municipal Effluent Company/Gulf FL NGCC 556 Cooling Tower(s) Bay County 4-6 (proposed)
Generating Plant** operation
Power
Lee County waste-to- Ogden Municipal Solid
Reclaimed Municipal Effluent FL 57.3 Cooling Tower(s) Ft. Myers City Central WWTP 0.6 1994
energy facility Martin/Covanta Waste
McKay Bay Refuse to Municipal Solid
Reclaimed Municipal Effluent Wheelabrator FL 500 Cooling Tower(s) Howard F. Curren WWTP 4.9 1985
Energy Facility Waste
North Broward Waste-to- Municipal Solid Broward County North Region
Reclaimed Municipal Effluent Wheelabrator FL 66 Cooling Tower(s) 1 1991
Energy Plant Waste Plant

 A-5 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)
Natural Gas,
Northside Generating Jacksonville Electric Fuel Oil, Coal,
Reclaimed Municipal Effluent FL 1300 Cooling Tower(s) JEA- District II WRF 1
Station Authority (JEA) & Petroleum
Coke
Natural Gas
Reclaimed Municipal Effluent Oleander Power Project Southern Company FL 791 Cooling Tower(s) Jerry Sellers WRF 0.013
Simple Cycle
Pasco County Resource Municipal Solid Pasco County Master Reuse
Reclaimed Municipal Effluent Pasco County FL 31 Cooling Tower(s) 0.2 Mid 1990s
Recovery Facility Waste System
Pinellas County Utilities Pinellas County Municipal Solid
Reclaimed Municipal Effluent FL 60 Cooling Tower(s) City of Largo WWTP 1.7 Early 1990s
Waste-to-Energy Plant Utilities Waste
Tampa
Lakeland Wetland Treatment
Reclaimed Municipal Effluent Polk Power Station Electric/TECO FL IGCC 260 Cooling Pond Up to 17
Area; City of Lakeland
Energy

Turkey Point Nuclear NextEra/Florida Nuclear & Cooling Tower(s) Miami-Dade Co South District
Reclaimed Municipal Effluent FL 1600 75-90 Expected 2017
Plant Power & Light (FPL) NGCC & Cooling Pond WWTP

University of FL Co-
Reclaimed Municipal Effluent Duke Energy FL Natural Gas 46 Cooling Tower(s) University of Florida WWTP 0.4 1994
Generation Plant
Vero Beach Municipal
Reclaimed Municipal Effluent City of Vero Beach FL Natural Gas 125.4 Cooling Tower(s) Vero Beach WWTP 0.1 1992
Power Plant
West County Energy NextEra/Florida Palm Beach County Water
Reclaimed Municipal Effluent FL NGCC 3750 Cooling Tower(s) 2011
Center Power & Light (FPL) Utilities Dept.
Emery Generating
Reclaimed Municipal Effluent Alliant Energy IA NGCC 602 Cooling Tower(s) Clear Lake Sanitary District 0.8-1.2 2004
Station**

Reclaimed Municipal Effluent Garden City Plant Sunflower Electric KS NGCC 256 Cooling Tower(s) Garden City; well water 0.5 2007

Brayton Point Power Energy Capital Somerset water pollution control

Reclaimed Municipal Effluent MA Coal 1125 Scrubbers 1.3 2008
Station Partners plant

Reclaimed Municipal Effluent Brockton Clean Energy Brockton Power MA Natural Gas 350 1.3 (proposed) In planning

Millennium Power Project

Reclaimed Municipal Effluent PG&E MA NGCC 360 Cooling Tower(s) Southbridge WWTP 0.4 2001/2004
/ Charlton Power Plant

North Andover Waste-to- Municipal Solid Greater Lawrence Sanitation

Reclaimed Municipal Effluent Wheelabrator MA 40 Cooling Tower(s) 0.5-0.65 1985
Energy Plant Waste District
Panda-Brandywine Power Panda Global 1996 (currently
Reclaimed Municipal Effluent MD NGCC 230 Cooling Tower(s) Mattawoman WWTP 1.5
Station Services being updated)

Reclaimed Municipal Effluent Mankato Power Plant Calpine MN NGCC 375 Cooling Tower(s)

 A-6 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)
Tennessee Valley Columbus Light and Water
Reclaimed Municipal Effluent Caledonia Plant MS NGCC 765 Cooling Tower(s) 0.5 After 2002
Authority (TVA) WWTP
Southern Company
Reclaimed Municipal Effluent Kemper Power Project MS IGCC 582 Cooling Tower(s) City of Meridian ~8 2016
(Miss Power)

Reclaimed Municipal Effluent Granite Ridge Plant Calpine NH NGCC 745 Cooling Tower(s) Manchester WWTP 4 2002

Bergen County Utilities Authority

Reclaimed Municipal Effluent Bergen Station PSE&G NJ NGCC 1229 Cooling Tower(s) 0.33-0.58 2002
WWTP
Linden/Roselle Sewage
Reclaimed Municipal Effluent Linden Station PSE&G NJ NGCC 1220 Cooling Tower(s) 12 2006
Authority

Reclaimed Municipal Effluent Luna Energy Facility PNM NM NGCC 570 Cooling Tower(s) Deming WWTP <1 2006

Edward W. Clark Nevada Power Clark County Water

Reclaimed Municipal Effluent NV NGCC 1103 Cooling Tower(s) 0.15-2.7
Generating Station Company Reclamation District

Empire Generating Empire Generating Cooling Tower(s) City of Albany WWTP & well
Reclaimed Municipal Effluent NY NGCC 635 7.1 2010
Power Plant Co, LLC & Process Water water

Comanche Power
Reclaimed Municipal Effluent AEP/SWEPCO OK NGCC 235 Cooling Pond Lawton WWTP 3.5 1973
Station**
Municipal Solid
Reclaimed Municipal Effluent Delaware Valley Covanta PA 80-90 Cooling Tower(s) 1.3
Waste
Lancaster County
Municipal Solid
Reclaimed Municipal Effluent Resource Recovery Covanta PA 36 Cooling Tower(s) Elizabethtown WWTP 0.6 1991
Waste
Facility
Carlyle Power
Rhode Island State
Reclaimed Municipal Effluent Partners (previously RI NGCC 583 Cooling Tower(s) Town of Cranston, RI 12 2002
Energy Center (RISEC)**
Entergy & NextEra)
Suez Energy
Reclaimed Municipal Effluent Ennis-Tractebel Plant TX Natural Gas 418 Cooling Tower(s) Oak Grove WWTP 1.0-1.5 2001
Resources
Coal-fired steam
Reclaimed Municipal Effluent Harrington Plant Xcel Energy TX 1018 Cooling Tower(s) Amarillo WWTP 7.5
turbines
Harrison County Power
Reclaimed Municipal Effluent Entergy TX NGCC 570 Cooling Tower(s) City of Longview WWTP 2-5 2003
Project**

Reclaimed Municipal Effluent Hidalgo Energy center Calpine TX NGCC 477 Cooling Tower(s) City of McAllen's North WWTP

J.K. Spruce 2, Calaveras San Antonio Water System

Reclaimed Municipal Effluent CPS Energy TX Coal 750 Cooling Tower(s) 1960's
Power Station treatment plant/Calaveras Lake

 A-7 

13553240
 Approx.
Max Plant Starting Date
Electric Utility Volume of
Alternate Source Type Power Plant Name State Fuel Type(s) Capacity Use of Water Water Source of Alternate
Company Alternate
(MW) Water Supply
Water (MGD)

Reclaimed Municipal Effluent Jones Plant Xcel/SWEPCO TX Natural Gas 824 Cooling Tower(s) Lubbock WWTP 3-5 1970's

NGCC (can El Paso Water Utilities; Fred

Reclaimed Municipal Effluent Newman Power Station El Paso Electric TX 474 Cooling Tower(s) 2.4 1991
also use fuel oil) Hervey WWTP

Reclaimed Municipal Effluent Nichols Plant Xcel Energy TX NGCC 457 Cooling Tower(s) Amarillo WWTP 7.5 1960's

Spencer Road Garland Power &

Reclaimed Municipal Effluent TX Natural Gas 176 Cooling Tower(s) Pecan Creek WRF 1 Mid 1970s
Generating Station Light
San Antonio Water System
Reclaimed Municipal Effluent V.H. Braunig Power Plant CPS Energy TX Coal 847 Cooling Tower(s) 1966
treatment plant/Braunig Lake

Heart of the Valley Metropolitan

Reclaimed Municipal Effluent Fox Energy Center GE Energy WI NGCC 618.8 Cooling Tower(s) 0.8 2005
Sewerage District

Cargill grey water (proposed);

Reclaimed Municipal Effluent
Great River Energy Coal (lignite) Jamestown municipal 0.29-2.9 2010 (stopped
(discontinued); Reclaimed Spiritwood Station** ND 99 Cooling Tower(s)
(GRE) CHP wastewater (1 year); municipal (discontinued) in 2011)
Industrial Effluent (proposed)
potable water (current)

Natural Gas &

Stormwater Powerton Station NRG Energy IL 1786 Cooling Lake
Coal
South Texas Nuclear Reservoir; Colorado River as
Stormwater NRG Energy TX Nuclear 2760 Cooling Pond 1988
Project make-up
Smithers Lake (stormwater
W.A. Parish Electric Natural Gas & Cooling Tower(s)
Stormwater NRG Energy TX 3687 runoff; reclaimed effluent; 1958
Generating Station** Coal & Cooling Lake
Brazos River)
Demineralization
Ormond Beach Stormwater runoff from plant
Stormwater NRG Energy CA NGCC 1516 and Service 2015
Generating Station** property (37 acres)
Water
Elk River Energy Great River Energy Refuse Derived
Stormwater (proposed) MN 37 Not in use
Recovery Station (GRE) Fuel
Great River Energy
Stormwater (proposed) Coal Creek** ND Coal 1100 Cooling Tower(s) Not in use
(GRE)
** Examples of alternative water supply use documented as case studies (Appendix B).
Note that this is not a comprehensive list of all examples of alternate water use by electric power utilities. The information in this table was compiled from a review of openly available sources online, but a majority of the
information has not been verified and thus should be used with caution.

 A-8 

13553240
Appendix B: Compendium of Case
Studies
This appendix contains a compendium of 17 case studies summarizing both
successful and unsuccessful implementation of alternative water supplies at power
generation facilities. Each case study follows a similar format, beginning with an
overview of the facility and background information regarding alternative water
use at the plant, the case studies also present drivers for use of an alternative
supply, information regarding implementation of the alternative supply, and
resulting benefits, challenges and lessons learned. Table B-1 provides a summary
list of case studies and each case study write up follows, organized by a case study
code number.

 B-1 

13553240
Table B-1
Summary of Case Studies

Plant
Case Date of
Power Plant State Fuel Type Capacit Alternate Source Type
Study Supply Use
y (MW)
B1 Comanche Power Station OK NGCC 235 Municipal Effluent 1973 –
B2 Emery Generating Station IA NGCC 602 Municipal Effluent 2004 –
B3 Harrison County Power Project TX NGCC 570 Municipal Effluent 2003 –
B4 James F. Crist Generating Plant FL Coal 924 Municipal Effluent 2009 –
B5 Geysers Geothermal Field CA Geothermal 1517 Municipal Effluent 1997 –
B6 Lansing Smith Generating Plant FL NGCC 556 Municipal Effluent proposed
Rhode Island State Energy Center
B7 RI NGCC 583 Municipal Effluent 2002 –
(RISEC)
B8 Kyrene Generating Station AZ NGCC 415 Municipal Effluent 2002-2010
Coal (lignite) Industrial Effluent (proposed); 2010
B9 Spiritwood Station ND 99
CHP Municipal Effluent (discontinued) (municipal)
B10 San Juan Generating Station NM Coal 1848 Produced Water not implemented
Coal (waste
B11 Westwood Generating Station PA 30 Mine Pool 1988 –
coal)
Agricultural runoff (primary); brackish
B12 Indiantown Cogeneration Plant FL Coal 330 groundwater and municipal effluent 1995 –
(secondary)
Natural Gas
B13 W.A. Parish Electric Gen. Station TX 3687 Stormwater 1958 –
& Coal
B14 Ormond Beach Gen. Station CA NGCC 1516 Stormwater 2015 –
B15 Coal Creek ND Coal 1100 Stormwater not implemented
B16 Oklaunion Power Plant TX Coal 692 Brackish Surface Water 1986 –
B17 Pirkey Power Plant TX Coal 721 Interbasin Transfer 1985 –

 B-2 

13553240
 3.5 MGD
COMANCHE POWER 235 MW RECIRCULATING
B1 OKLAHOMA MUNICIPAL
STATION NGCC COOLING POND
EFFLUENT

Since Comanche began

operations in 1973, the
plant has used
reclaimed municipal
effluent from the
Lawton POTW to
supply make-up water
to the cooling pond
reservoir.

DRIVERS
The primary driver for
alternate water supply
use was a lack of local
freshwater supply. It
was determined that
groundwater in the
area would not provide
an adequate quantity of water and that there were
OVERVIEW
no reasonable surface water sources in the area.
The Comanche Power Station (Comanche), owned Municipal effluent from the Lawton POTW was then
and operated by American Electric Power (AEP), is a selected as the primary water source by necessity
235 MW NGCC plant located in Lawton, OK because it was the only suitable water source that
(population ~97,000). On average, Lawton receives AEP could locate.
~33 inches of rainfall each year. Summers are hot
and dry and average 21 days of >100°F
IMPLEMENTATION
temperatures. The contract between Comanche and the City of
This case study describes an “early adoption” Lawton began in 1972. The income stream that
example of alternate water supply given that Comanche provided to the Lawton POTW by
Comanche has used reclaimed municipal effluent purchasing their effluent was utilized to upgrade
for approximately 45 years. the treatment processes at Lawton to meet new
EPA regulations in the 1970’s.
BACKGROUND
Driver Benefit Challenge
Comanche provides electricity to the City of Lawton
Quantity
and surrounding communities. Fort Sill U.S. Army
Base was established in 1869, and the City of Quality
Lawton’s economy continues to depend on this Reputation
military post.
Regulatory
Cost

13553240

< B-3 >


COMANCHE POWER
B1 OKLAHOMA
STATION
The plant was initially designed and constructed to
use municipal effluent as make-up water for their
cooling pond. Because Comanche uses a cooling
pond rather than cooling towers, the design was
similar to facilities using a freshwater sources and
did not require major alterations. The combined
cycle system was a fairly new technology when
Comanche was constructed in the 1970’s, and this
design facilitated the use of municipal effluent
because of the ~40% smaller cooling water volume
required as compared to traditional steam-cycle
plants.
The Lawton POTW water is transported about 2.5
miles to Comanche. The original concrete cylinder
pipe was prone to leaks, so it was upgraded to a
high density polyethylene (HDPE) pipe, paid for by
AEP. Comanche chlorinates the reclaimed water on-
site and also conducts fairly standard monitoring of
the incoming water and water in the cooling pond
(e.g., flow, pH, temperature, chlorides, sulfates, and
TDS).
The water delivery contract states that Lawton
POTW is obligated to supply Comanche with up to
3.5 MGD of reclaimed effluent for 7.5 cents/1,000
gallons. This price has not changed since it was
established in 1972. Comanche can exercise use of
more than 3.5 MGD of water at a rate of 8.5
cents/1,000 gallons, but they have never exercised
that right.
Lawton supplied Comanche with about 3.5 MGD in
2014; however, the exact amount of water can vary
depending on the time of year, temperature, and
extent of evaporation (e.g., greater evaporation and
more makeup water needed in the summer).
The path for delivery of water from Lawton has
changed over time. Originally, Lawton discharged to
an onsite 500 acre-foot effluent reservoir and water
was pumped from the reservoir to Comanche’s
cooling pond. However, water quality issues in the
13553240
< B-4 >
3.5 MGD
235 MW RECIRCULATING
MUNICIPAL
NGCC COOLING POND
EFFLUENT
effluent reservoir led to a change about 5-10 years
ago. Currently, effluent from Lawton is pumped
directly to Comanche’s cooling pond.
The contract with Lawton specifies the following
required quality of delivered water: total
phosphorus less than 1 mg/L and BOD 20 less than
15 mg/L. Although Lawton uses tertiary treatment,
the facility has been challenged to meet their
NPDES permit limits and occasionally sends lower
quality water to Comanche.
BENEFITS & CHALLENGES
The main benefit of using reclaimed effluent at
Comanche is successful siting in a location that
supports both the City of Lawton and the local
military base. Without the use of reclaimed
effluent, it is unlikely the plant could have been
sited in its current location due to a lack of another
viable water source.
Another benefit of Comanche utilizing reclaimed
effluent from Lawton POTW was that it provided
Lawton with the money to upgrade the treatment
processes at the plant to meet new discharge
regulations in the 1970’s.
It is estimated that Lawton POTW water is less
expensive compared to surface water in the region,
providing a cost advantage to using reclaimed
effluent. Drawing from surface water would require
a permit and Comanche would have to continually
demonstrate use or else they could lose it.
AEP briefly mentions Comanche’s use of reclaimed
effluent in their CDP Water disclosure; however, it
has not been emphasized, possibly because it is not
a new water-related practice. Therefore, the
reputational benefit is currently small but there
may be potential to highlight this facility in future
water risk and sustainability reporting.
 3.5 MGD
COMANCHE POWER 235 MW RECIRCULATING
B1 OKLAHOMA MUNICIPAL
STATION NGCC COOLING POND
EFFLUENT

The main challenges associated with using VERIFICATION

reclaimed effluent at Comanche relate to variable
water quality. When Lawton initially discharged to a Information presented in this case study was
500 acre-foot reservoir prior to transport to provided through interviews with AEP staff in
Comanche, the water would occasionally have October 2016, who have reviewed this case study
issues with TSS, TDS, algae, and eutrophication. for accuracy.
Even though the City reservoir is no longer used,
the water supplied to Comanche has still had
occasional water quality issues. There have also
been instances of high algae levels and
eutrophication in Comanche’s cooling pond.

LESSONS LEARNED
A cooling pond system provides greater flexibility
for reclaimed water use with variable quality.

Because Comanche utilizes a cooling pond, it can

use water that is not as high of quality as would be
required for cooling towers. Towers more quickly
concentrate contaminants in the recirculating water
and high levels of pollutants can lead to problematic
scaling and biofouling.

Utilizing an alternate water source provided

flexibility for power plant siting.

Utilities in water stressed regions are used to not

having abundant water resources and thus site
plants primarily based on transmission and fuel
availability. The option to use a reclaimed effluent
source provided flexibility in siting the Comanche
power plant at a beneficial location.

REFERENCES
AEP. 2014. American Electric Power 2014 Corporate
Accountability Report- GRI Report.
URL: http://2014.aepsustainability.com/fastfacts/do
cs/2014-GRI.pdf [Accessed 10/25/2016].

Personal communication, AEP staff, 2016. Greg

Carter and Tim Lohner.

13553240

< B-5 >

 EMERY GENERATING 602 MW COOLING 0.8-1.2 MGD
B2 IOWA
STATION NGCC TOWERS MUNICIPAL EFFLUENT

DRIVERS
The decision to use
reclaimed municipal
effluent at Emery was
driven by
quantity/supply. The
Jordan Aquifer, which
provides groundwater
to Emery, is highly
regulated. Planners
knew that obtaining
enough groundwater
could be an issue;
therefore, the
requested groundwater
permits only accounted
for approximately half
of the water needs of
OVERVIEW the plant. A second water source was needed to
supply the other half of the water needs. One
The Emery Generating Station (Emery) is a 602 MW alternative was to withdraw from the Winnebago
NGCC plant located in Clear Lake, Iowa (population River, a small river about 20 miles away. This option
~7,700). The community of Clear Lake, which is was eliminated due to the distance from Emery and
named after the large nearby lake, receives on expectations that the volume of flow that Emery
average 35 inches of rain each year. Summer could obtain would be unreliable. Instead,
temperatures average in the low 80’s (°F). reclaimed municipal effluent from the Clear Lake
Sanitary District (CLSD) was identified as the most
Since 2004, Emery has utilized 0.8-1.2 MGD of
suitable source for Emery.
reclaimed municipal effluent from the Clear Lake
Sanitary District (CLSD) for cooling tower make-up IMPLEMENTATION
water. This was the first water reclaimed water use
application of its kind in Iowa. Utilizing reclaimed effluent for Emery’s recirculating
cooling water system was part of the initial design
BACKGROUND
Drivers Benefit Challenge
Emery was constructed in 2003 to meet increased
electricity demand in northern Iowa and increase Quantity
the dispatching flexibility of Alliant’s fleet. Emery Quality
became operational in 2004. Reclaimed effluent
Reputation
provides about 40% of the power plant’s water
needs and groundwater is used for the remaining Regulatory
60%. Cost

13553240

< B-6 >

 EMERY GENERATING
B2 IOWA
STATION
for the plant. Planning started in early 2002 and
construction in July 2003. Plant operations and
reclaimed effluent use at Emery began in 2004.
Emery currently uses 2-3 MGD of water when
operating, with 40% (0.8-1.2 MGD) of that coming
from CLSD. Emery does have access to up to 5.7
MGD from CLSD, which is 19.2% of CLSD’s dry
weather hydraulic treatment capacity. The
reclaimed effluent is only used for cooling tower
make-up; whereas, groundwater is used for both
cooling tower make-up and high quality
demineralization water.
Water from CLSD is transported approximately 10
miles to Emery via an underground pipe. There is
also a return pipe from Emery back to CLSD.
Easements were obtained from local land owners
and the Iowa Department of Transportation
because the pipelines go through farm fields and
below Interstate 35. Alliant paid for the
construction of the pipelines and is in charge of
maintaining them.
In order to ensure acceptable quality of the
reclaimed effluent, Alliant invested $3 million to
improve CLSD’s treatment system, including tertiary
filtration and disinfection. At CLSD, effluent water is
separated to either discharge directly to the
receiving water system or diverted to an additional
treatment system before transport to Emery. The
additional treatment system building contains
tertiary filter supply pumps, tertiary cloth gravity
filters, and an ultraviolet disinfection system for
biological growth. The cloth filters have an average
design capacity of 3 MGD with one filter out of
service but can handle a maximum flow of over 9
MGD with all three filters during storm flow
conditions.
In addition to funding the construction of the
treatment system, the 25-year agreement,
established in 2004, between Emery and CLSD
includes cost and responsibility sharing. CLSD
13553240
< B-7 >
602 MW COOLING 0.8-1.2 MGD
NGCC TOWERS MUNICIPAL EFFLUENT
maintains the treatment system but Alliant is
responsible for paying for any repairs to the
treatment equipment that Alliant constructed for
Emery at CLSD. This includes fixed costs of about
$23,000/month for CLSD’s treatment of the water
and $10,000/year for repairs to the treatment
system. Alliant pays the same fixed monthly fee to
CLSD each month regardless of the volume of water
used.
A one million gallon water tank at Emery receives
the treated water from CLSD. Emery further treats
the water using chlorination and blends it with
groundwater. Cooling water at Emery includes 60%
groundwater and 40% CLSD effluent. Staff at Emery
did not receive any specialized training related to
the use of reclaimed effluent.
Approximately 60-80% of water used by Emery is
evaporated. The remainder, with the exception of
sanitary water, is returned to CLSD for discharge to
their receiving stream. The return system at Emery
includes a chlorination system, pH probes, and a
pumping system. An inline probe monitors the
return water to determine if dechlorination is
required. All process water, with the exception of
cooling tower blowdown, is also treated with an
oil/water separator prior to discharge to CLSD.
Once the water returns to CLSD, sampling
determines whether it is discharged directly or
routed back to the treatment facility. This water is
blended with CLSD’s effluent to reduce the levels of
dissolved solids before discharge to Beaver Dam
Creek and the Cedar River.
It is expected that treatment costs will remain
constant, with the only uncertainty being whether
additional treatment of CLSD discharge may be
required by the state in the future. CLSD has no
issues currently with their NPDES permit and
believes that they would have no problem meeting
more stringent nitrogen and phosphorus limits.
 EMERY GENERATING
B2 IOWA
STATION
BENEFITS & CHALLENGES
The primary benefit of using reclaimed effluent at
Emery is that it provides the plant with a constant
supply of water for the cooling water system. The
restrictions on groundwater in the area and lack of
viable surface water forced planners to find an
alternate source, which CLSD was able to offer.
The use of reclaimed effluent also provides
reputational benefits for both Alliant and Clear
Lake. This project is included in Alliant’s corporate
sustainability report and has benefited all parties
involved (Alliant, CLSD, and the local community).
While there have been no major challenges, a few
minor issues have resulted from the use of
reclaimed effluent. Even with the treatment
upgrades at CLSD, some corrosion has taken place
throughout the years, with those parts being
replaced accordingly. The quality of the effluent
water has been consistent. However, to eliminate
scaling in the cooling towers and heat exchangers
and maintain pH levels, sulfuric acid is added. This
sometimes results in elevated sulfate levels and
thus more frequent blowdown cycles from the
cooling towers.
LESSONS LEARNED
Reclaimed water can be blended with freshwater
sources to reduce the dependency on highly
regulated or limited sources.
Emery was able to utilize reclaimed municipal
effluent to provide a consistent water source that
could be blended with groundwater, thereby
reducing their dependence on the highly regulated
aquifer.
13553240
< B-8 >
602 MW COOLING 0.8-1.2 MGD
NGCC TOWERS MUNICIPAL EFFLUENT
REFERENCES
Alliant Energy. 2016. Alliant Energy Corporate
Sustainability Report. 40 pp.
URL: http://www.alliantenergy.com/wcm/groups/w
cm_internet/@int/@ae/documents/document/md
aw/mjew/~edisp/210817.pdf [Accessed 2/9/2017].
Aqua-Aerobic Systems, Inc. Case Study: Clear Lake Is
First In Iowa To Provide Reuse Water For Power
Plant!
URL: http://www.wateronline.com/doc/clear-lake-
is-first-in-iowa-to-provide-reuse-0001 [Accessed
12/20/2016].
Personal communication, Alliant Energy staff, 2016.
Bill Skalitzky.
Wicker, Ken. 2005. Top Plants - Emery Generating
Station, Clear Lake, Iowa. POWER Magazine,
July/August 2005.
VERIFICATION
Information presented in this case study was
provided through interviews with Alliant Energy
staff November 2016, who have reviewed this case
study for accuracy.
 HARRISON UP TO 5 MGD
B3 COUNTY POWER TEXAS 570 MW NGCC COOLING TOWERS MUNICIPAL
PROJECT EFFLUENT

watershed group. A
change in state withdrawal
permitting related to
interbasin transfers and
water rights put the ability
of the city to provide
water in question (Caddo
Lake is located in the
Cypress River Basin to the
north of the Sabine River
Basin).

DRIVERS
Texas permitting
regulations relating to
interbasin transfers and
water rights prevented
Marshall from selling water to HCPP in a timely
OVERVIEW
manner. In combination with subsequent public
The Harrison County Power Project (HCPP) is a 570 opposition led by a national celebrity to the
MW NGCC plant located near Marshall, Texas interbasin transfer of water from the Caddo Lake
(population ~24,000) that began operation in 2003. watershed, this necessitated identification of a
On average, Marshall receives ~51 inches of rain different water source.
each year, and summer temperatures above 100
The potential use of groundwater was explored;
degrees F are not uncommon.
however, this was found to not be a viable option
HCPP currently purchases up to 5 MGD of reclaimed because the depth to groundwater was too great.
municipal effluent from the Longview WWTP (plant
After a roughly 1-year permitting delay, the plant
capacity 21 MGD), which comprises 100% of HCPP’s
decided to purchase reclaimed effluent from the
cooling and demineralization water.
Longview WWTP.
BACKGROUND
IMPLEMENTATION
During the early stages of plant development,
Driver Benefit Challenge
Entergy planned to purchase raw water from the
City of Marshall, which thought it had significant Quantity
excess water rights available to sell. Treated Quality
effluent from HCPP would have been discharged to
Reputation
the Sabine River.
Regulatory
Marshall draws its water from a tributary to Caddo
Cost
Lake, a highly valued resource with an active

13553240

< B-9 >

 HARRISON
B3 COUNTY POWER TEXAS 570 MW NGCC
PROJECT
The water treatment system at HCPP was initially
designed for raw water. It was modified during
plant construction to treat reclaimed effluent,
which travels to the plant through a 27-mile long
underground pipeline paid for and maintained by
the owners of HCPP. The effluent that the Longview
WWTP provides to HCPP is treated to the point
where it could be released to a tributary of the
Sabine River. The pipeline contains gates and valves
to isolate sections. Although ~95% of the pipeline is
located in right of ways, several properties had to
be condemned during pipeline construction,
causing angst to impacted parties.
Typical reclaimed effluent use ranges from 2 to 2.5
MGD. The onsite storage tank is similar in size to
what would be used for a freshwater source.
BENEFITS & CHALLENGES
The use of reclaimed effluent created benefits
related to quantity and reputation, and challenges
related to cost and quality.
During the 2011 drought, Caddo Lake water levels
reached record lows, affecting use of the lake. If
HCPP had used water from Marshall, which draws
from a tributary to Caddo Lake, it may have been
accused of contributing to the low lake levels.
Instead, during this period, the power plant
received a stable, piped water supply from
Longview. In addition, Entergy highlights the use of
reclaimed effluent in corporate sustainability
reporting (CDP water, Dow Jones Sustainability
Index [DJSI]), and recently received a perfect DJSI
score for water-related risks.
The additional capital investments needed to use
reclaimed effluent from Longview were roughly $7
– 8 million (Net Present Value over 20 years)
greater than would have been needed for the use of
water from Marshall. The higher cost is primarily
due to construction of a longer pipeline (~3 times
13553240
< B-10 >
UP TO 5 MGD
COOLING TOWERS MUNICIPAL
EFFLUENT
longer than the pipeline to Marshall), but is also due
to the ‘on-the-fly’ modifications needed to
accommodate reclaimed water instead of raw
water. For example, there is an unused clarifier on
the site, which was intended for a raw water
sources and constructed prior to the water supply
switch. Furthermore, the plant pays Longview
approximately $230,000/yr. for up to 5 MGD of
reclaimed effluent.
At the plant, there were initial concerns related to
fecal coliform bacteria in the water. These were
addressed by chlorinating (and subsequently
dechlorinating) the water and marking pipes to
identify those with raw treated effluent. The
company also provided additional education and
training to alleviate anxiety among employees at
the plant. There were no public concerns other than
plant noise.
HCPP discharges blowdown water to the Sabine
River. Interestingly, the NPDES discharge permit
requirements for HCPP are more stringent than the
Longview WWTP. If HCPP were to receive water,
but bypass the plant and discharge directly (e.g,
power plant temporally not operational), additional
treatment would be required.
The current transfer of reclaimed effluent may
contribute to an unintended consequence of
depleted flow in the Sabine River. Prior to
implementing the current water supply solution,
the plant explored a ‘bed and banks’ permit as an
alternative to piping reclaimed effluent. Under this
permit, the Longview WWTP would discharge all
effluent to the Sabine River, and HCPP would
withdraw water 15-20 miles downstream for use at
the plant. This alternative was not pursued because
withdrawals would be restricted during drought
conditions. Because effluent is piped to HCPP
instead of discharged to the Sabine River, a flow of
roughly 2.5 MGD is diverted for a 20 mile stretch of
 HARRISON UP TO 5 MGD
B3 COUNTY POWER TEXAS 570 MW NGCC COOLING TOWERS MUNICIPAL
PROJECT EFFLUENT

the river. The diverted flow may comprise almost
half of the instream flow during very low flow
periods 1. There has been no community concern
over impact to ecosystem; however, it is unknown if
HCPP’s water use is having an impact during
drought years.
LESSONS LEARNED
It is important to get all water permits in place
before starting construction.
HCPP is located in East Texas, which is relatively
water rich. However, because Marshall, the initial
water provider, was not aware of permitting
changes affecting their ability to withdraw and
provide water, HCPP had to go to the “Plan B”
water source. This switch occurred during
construction, necessitating ‘on-the-fly’ changes to
construction at the site, as well as new siting and
construction for a 27-mile pipeline, which added
significantly to initial costs.
Up-front costs were higher, but operational costs
are not significantly different.
An alternate supply can generate additional
benefits, including:
• Drought resilience. East Texas is a generally
water-rich; however, during a drought in 2011,
lake levels and river flows dropped significantly.
During this drought, HCPP was provided a
reliable supply of reclaimed effluent.
• Competitive advantages. Because of the
company’s experience using reclaimed effluent
at the HCPP, they were better positioned to
competitively pursue, and acquire, a plant in
Rhode Island which also uses reclaimed
municipal effluent.
• A nice story to tell. Entergy publically reports
on the use of reclaimed water, and also shares
that the water they return to the Sabine River is
cleaner than what would have been discharged
by the Longview WWTP. Furthermore, the
community of Longview benefits from
additional revenue (approximately $230,000
annually) and highlights this on their website.
ADDITIONAL NOTES

In order to minimize impacts on property owners, Entergy no longer owns HCPP, but does still operate
the pipeline to the Longview plant was constructed the plant.
primarily in state and city right-of-ways. This
Approximately 15% of City of Longview municipal
resulted in a longer pipeline and higher up-front
source water originates in Lake O’ The Pines (within
costs. Once the plant was in operation, there was
the Cypress River Basin); therefore, the use of the
essentially no difference in operating a plant that
reclaimed effluent from City of Longview is partially
uses reclaimed effluent compared to a freshwater
an interbasin transfer. The majority of City of
source. Intake water monitoring and treatment (i.e.,
Longview water comes from Lake Cherokee and the
chlorination) are similar between the two sources
Sabine River, both within the Sabine Basin.
and water costs, under the 20-year agreement, will
remain consistent.

1
The USGS gage on the Sabine River below Longview has a
drainage area of 3,155 mile2 and flows range from 2.7 cfs to
over 38,000 cfs (average ~ 1,700 cfs).

13553240

< B-11 >

 HARRISON UP TO 5 MGD
B3 COUNTY POWER TEXAS 570 MW NGCC COOLING TOWERS MUNICIPAL
PROJECT EFFLUENT

REFERENCES
Personal communication, Entergy staff, 2016. Rick
Johnson and Andrew Rosenlieb.

TCEQ. 2012a. Water Rights Database and Related

Files.
URL: http://www.tceq.state.tx.us/permitting/water
_rights/wr_databases.html [Accessed 8/10/2012].

Longview, 2016.
URL: https://longviewtexas.gov/2406/Wastewater-
FAQs [Accessed 9/28/16].

VERIFICATION
Water use information presented in this case study
was provided through interviews with Entergy staff
in September 2016, who have reviewed this case
study for accuracy.

13553240

< B-12 >

 6 MGD
924 MW COOLING TOWERS &
B4 PLANT CRIST FLORIDA MUNICIPAL
COAL SCRUBBER
EFFLUENT

scrubber system was

installed on the active
units. Since then,
reclaimed water has
been used at the plant
for the FGD system as
well as for recirculating
cooling towers on Units 6
and 7. Brackish water
from the Escambia River
is used for once-through
cooling in Units 4 and 5.

Prior to 2009, ECUA was

OVERVIEW
The James F. Crist Generating Plant (Plant Crist) is a
924 MW coal-fired plant located in Pensacola,
Florida (population ~52,000). It is located on
Governor’s Bayou, where the Escambia River feeds
into Escambia Bay. Pensacola receives ~65 inches of
rainfall each year. Summers are hot and humid,
with highs in the low-90’s (°F) and lows in the mid-
70’s. Temperatures above 100°F are rare.
This award winning plant began using reclaimed
municipal effluent in 2010. Approximately 6 MGD of
reclaimed municipal effluent from the Emerald
Coast Utility Authority’s (ECUA) Central Water
Reclamation Facility is currently used at the power
plant.
BACKGROUND
discharging up to 18
MGD of treated effluent
into Pensacola Bay from
an aging wastewater
treatment facility (Main
Street Wastewater Treatment Plant). The Main
Street Wastewater Treatment Plant was located in a
storm flood zone in downtown Pensacola and had
been severely damaged by Hurricane Ivan in 2004.
ECUA was attempting to build a new treatment
plant outside of the floodplain to prevent damage
from future storms, but was unable to obtain a
discharge permit to Escambia River due to nutrient
impairments in the river.
DRIVERS
Water quality was the biggest driver behind the
decision to utilize reclaimed municipal effluent at
Plant Crist, and this was important for both the
power plant and the wastewater utility. The FGD
Driver Benefit Challenge
Quantity

Plant Crist began operations in 1945 and currently Quality

operates four units (Units 4-7). Units 1-3 were Reputation
previously retired. In 2009, a $650 million FGD
Regulatory
Cost
13553240

< B-13 >


924 MW
B4 PLANT CRIST FLORIDA
COAL
scrubber system installed at Plant Crist in 2009
requires a high quality water source and the
Escambia River was found to not be suitable due to
high levels of chlorides during the summer.
Reclaimed municipal effluent was identified as a
possible source with a consistent low level of
chlorides.
Concurrently, ECUA wanted to construct a new
wastewater treatment plant to replace their current
plant, located within a floodplain and susceptible to
challenges with aging infrastructure. However, due
to nutrient impairments in Escambia Bay, they were
unable to secure discharge permits for a new plant.
Providing municipal effluent to Plant Crist resulted
in benefits to both parties; ECUA was able to
relocate their operations without a discharge
permit and a reliable source of high quality water
was available to Plant Crist.
IMPLEMENTATION
Discussions between ECUA and Gulf Power in 2007
led to an arrangement to share effluent from a new
wastewater plant with Plant Crist rather than
discharge it. ECUA used FEMA and other federal
funds to construct the new Central Water
Reclamation Facility (CWRF), a 22.5 MGD advanced
wastewater reclamation facility. Negotiations,
planning, and construction phases all moved very
quickly due to ECUA’s initial requirement to provide
water by 2009. Plant Crist started receiving
reclaimed water in late 2010. In the interim, the
power plant used potable water from a three
million gallon backup tank to operate the new
scrubber.
Effluent is piped approximately 2 miles from ECUA’s
CWRF to Plant Crist. In order to transport and utilize
reclaimed water, piping and treatment upgrades
were required at Plant Crist. Pipe was installed
beneath an existing transmission line, which
13553240
< B-14 >
6 MGD
COOLING TOWERS &
MUNICIPAL
SCRUBBER
EFFLUENT
eliminated the need to negotiate right-of-ways or
work with landowners. An emergency three million
gallon tank of potable water was installed at Plant
Crist as a backup to the reclaimed supply. Units 6 &
7 have been utilizing Escambia River water for
cooling water since the 1970’s; therefore, the
change to reclaimed water required some changes
to the treatment process (e.g., chemicals to prevent
scaling in the towers and redundant
dechlorination).
Plant Crist uses an average of approximately 6 MGD
of reclaimed water from ECUA for their cooling
towers (Units 6 and 7) and scrubber (Units 4-7). The
contract requires Plant Crist to take at least 2.5
MGD, but is flexible and allows the plant to request
additional water if needed. Water is sent directly to
Plant Crist after being treated at ECUA, but some is
also stored in a large storage pond to level out rain
events with drought periods. The cooling towers
occasionally transition from reclaimed water to
Escambia River water during short maintenance
periods.
Reclaimed water supplies 100% of the water for the
scrubber at Plant Crist. The scrubber is designed to
remove up to 95% of sulfur dioxide emissions and
80% of oxidized mercury emissions. The reclaimed
water cools the emissions from the coal units and is
then sent into a bath of crushed limestone. Gypsum
that is produced during the scrubber process is sold
for commercial use in cement production and other
manufacturing processes. Most of the water that is
used in the scrubber system is evaporated through
the processes.
Blowdown from the cooling tower is reused in the
scrubber system. Scrubber water that remains is
then ultimately disposed of via underground
injection control (UIC). Plant Crist has a NPDES
permit to use some reclaimed water in the Units 4
& 5 once-through system. This water is then

924 MW
B4 PLANT CRIST FLORIDA
COAL
discharged to the Escambia River based on the
allowable waste load allocation (WLA), which was
determined by a TMDL (total maximum daily load)
process supported by hydraulic and hydrodynamic
modeling. Additionally, a portion of Plant Crist’s
spent reclaimed water is returned to ECUA to be
dispersed over spray fields or retreated.
Plant Crist does not pay for the water they receive
from ECUA; however, they do pay for O&M,
pumping, and power costs for the equipment in
proximity to the power plant. The most significant
costs are related to the O&M, but it is cheaper
overall to use the reclaimed water from ECUA as
compared to withdrawing Escambia River water and
treating it to remove to remove chlorides, tannins,
and organics.
In addition to Plant Crist, International Paper also
receives reclaimed municipal effluent from CWRF;
this facility started accepting water after Plant Crist.
There have been no issues with the use of
reclaimed water at Plant Crist, even though the
planning and implementation of the alternate water
supply were conducted over a relatively short time
frame.
BENEFITS & CHALLENGES
The use of reclaimed municipal effluent has created
benefits for both Plant Crist and ECUA related to
quality, reputation, and cost.
The reclaimed water provides superior water
quality compared to the brackish water from the
Escambia River due to requirements for residual
chlorine and other compounds in the treated
effluent. This results in less treatment and lower
chemical costs for Plant Crist. The water Plant Crist
receives is also of ideal temperature for power
generation, which improves efficiency and reduces
the amount of water used by the plant. The higher
13553240
< B-15 >
6 MGD
COOLING TOWERS &
MUNICIPAL
SCRUBBER
EFFLUENT
quality water also supports the ability of Plant Crist
to produce and sell gypsum from their scrubber
processes. The quality and quantity of the reclaimed
source is fairly consistent, whereas water from the
Escambia River would have an inconsistent quality
and the quantity of groundwater would not be
reliable over the long-term.
The use of reclaimed water at Plant Crist has
provided reputational benefits. Southern Company
has prominently highlighted Plant Crist’s use of
reclaimed water in their Water Action Report and
have received positive feedback from the
community and other groups. Southern Company
and Gulf Power representatives have spoken about
this project throughout Florida, which has increased
awareness of the benefits of using reclaimed water
for power generation and helped other plants use
similar technologies to utilize reclaimed water.
Plant Crist’s reclaimed water use also facilitated
International Paper to receive reclaimed water from
CWRF.
The reclaimed water use partnership provides
major benefits for ECUA. ECUA was able to close an
aging facility that was at risk from storm floods and
build a new facility (CWRF) in an area of need. ECUA
has improved their reputation because CWRF is a
zero-discharge facility. With no discharge, there are
benefits to the water quality of Pensacola Bay,
where ECUA had previously been discharging
millions of gallons of effluent each day.
The main challenge with the process was acquiring
a NPDES permit for the Plant Crist discharge. USEPA
initially stated that the plant would not be allowed
to discharge any nutrient load into the Escambia
River. This would have created a barrier for Plant
Crist’s utilization of reclaimed water and for ECUA’s
construction of CWRF. Fortunately, hydraulic and
hydrodynamic modeling indicated there would be

924 MW
B4 PLANT CRIST FLORIDA
COAL
no significant impacts to the river and a discharge
permit was issued.
Another minor challenge was the initial concern of
Plant Crist staff regarding the safety of working with
reclaimed effluent. However, education of the staff
to clarify that CWRF’s advanced treatment produces
high quality water that is disinfected to the level
required for unrestricted exposure to the public
helped resolve the issue.
LESSONS LEARNED
Using reclaimed water can provide flexibility in
wastewater treatment plant siting.
Many treatment plants may be limited in their
ability to discharge treated municipal effluent based
on regulatory constraints from receiving bodies of
water. Utilizing treated municipal effluent for power
generation can remove the need for a WWTP to
discharge to surface water, thus providing flexibility
in the location of the treatment facility and a win-
win partnership for all parties involved. Preventing
discharge can also improve surface water quality,
conserve water, and provide a high-quality,
relatively cheap source of water for power
generation.
This multi-party success story was externally
recognized.
All parties involved (Plant Crist, ECUA,
environmental groups, public, and state) have fully
supported this use of reclaimed water since the
beginning of the effort. The positive outcomes have
resulted in the project receiving multiple awards:
2010 Sustainable Florida Award for the partnership
between Gulf Power and ECUA, 2011 Industry
Excellence Award from the Southeastern Electric
Exchange, and 2012 York Reuse Award from the
Florida Water Environment Association for Reuse
Customer of the Year.
13553240
< B-16 >
6 MGD
COOLING TOWERS &
MUNICIPAL
SCRUBBER
EFFLUENT
REFERENCES
ECUA. 2016. Wastewater Services.
URL: http://www.ecua.fl.gov/services/wastewater-
services [Accessed 11/8/2016].
Gulf Power. 2015. Partnership recycles 10 billion
gallons of reclaimed water. June 19, 2015.
URL: http://www.gulfpowernews.com/partnership-
recycles-10-billion-gallons-of-reclaimed-water/
[Accessed 11/8/2016].
Gulf Power. 2016. Gulf Power.
URL: http://www.gulfpower.com/ [Accessed
11/7/2016].
Personal communication, Southern Company and
Gulf Power staff, 2016. Ashley Jansen, Andrue
Gregory, Donna Hill, Howard Shelnutt, Mike
Markey, and Robert Jernigan.
Southern Company. 2016. 2016 Water Action
Report. May 2016.
URL: http://www.southerncompany.com/what-
doing/pdf/WaterActionReport2016.pdf [Accessed
11/7/2016].
VERIFICATION
Information presented in this case study was
provided through interviews with Southern
Company and Gulf Power Company staff in October
2016, who have reviewed this case study for
accuracy.
 20 MGD
THE GEYSERS 1,517 MW STEAM INJECTION
B5 CALIFORNIA MUNICIPAL
GEOTHERMAL FIELD GEOTHERMAL WELLS
EFFLUENT

renewable energy
project in the world.
The Geysers has a
maximum capacity of
1517 MW, with an
average production of
955 MW. Calpine owns
and operates 13 of the
22 geothermal power
plants in the complex
and has a net
generating capacity of
725 MW.

OVERVIEW
The Geysers is a geothermal field located in the
Mayacamas Mountains along the Sonoma and Lake
County border, approximately 72 miles north of San
Francisco. On average, Lake County receives 31.5
inches of rain each year, with 66 days a year
experiencing precipitation. Daytime temperatures
are hot in the summer, with average highs around
90 °F, but nighttime temperatures remain cool year-
round.
This case study describes a geothermal field that
utilizes reclaimed municipal effluent from multiple
communities and treatment plants to supplement
the water supply for steam production.
Unique geologic
conditions of heat
close to the surface
and fractured deep
rock layers that allow
water percolation support the production of
geothermal energy at The Geysers. The complex
includes 327 steam wells and 56 injections wells,
with an average depth of 8,500 feet. Thermal
energy in the form of pressurized steam flows out
of the steam wells and into the power plants
through a network of pipelines. The steam enters
the turbines at 40-100 pounds/square inch and is
converted into mechanical shaft energy. The
turbine is directly coupled to the generator and
creates electrical energy. Cooling towers then cool
and reuse or evaporate the steam/water. To
complete the process and allow the continued
production of steam, injection wells inject either
power plant steam condensate or an external water
source into the ground.

BACKGROUND Driver Benefit Challenge

Quantity
The Geysers’ geothermal field has been in operation
since 1960. With 22 geothermal power plants Quality
covering a land area of 45 mi2, it is the largest Reputation
complex of geothermal plants and recycled water to
Regulatory
Cost
13553240

< B-17 >


THE GEYSERS
B5 CALIFORNIA
GEOTHERMAL FIELD
Electricity generated at The Geysers meets the
needs of Sonoma, Lake, and Mendocino counties, as
well as part of Marin and Napa counties. It is one of
the most reliable energy sources in California and
accounts for one-fifth of the green power produced
in the state.
DRIVERS
The use of reclaimed water at The Geysers was
primarily driven by a drop in steam production at
the geothermal field. In the 1970’s and 1980’s, The
Geysers was unsustainably producing more steam
than was being replaced by the injection of power
plant steam condensate. Only 20% of the steam
captured and sent through the generators is
returned to the ground as water. The result was a
severe decline in steam pressure and electrical
production by 1989. In order to sustain the
reservoir pressure and steam production, it was
determined that The Geysers needs a large, reliable
supply of water to supplement the injection.
The Geysers operators, Lake County, and the
California Energy Commission conducted a survey in
1990-91 to identify potential injection water
sources in the area. The results suggested that
potential surface and groundwater sources in the
area were already committed to other uses and
thus not viable. The study suggested that municipal
effluent from the southeast regional collection
system could provide a continuous supply of
streamfield recharge water for The Geysers.
A second driver was related to excess wastewater
disposal needs of nearby communities. Due to
growth pressures, the Lake County Sanitation
District (LACOSAN) faced treatment upgrades and
the need for additional disposal methods for
municipal effluent. Supplying their effluent to The
Geysers provided an opportunity to dispose of
excess water and put it to good use.
13553240
< B-18 >
20 MGD
1,517 MW STEAM INJECTION
MUNICIPAL
GEOTHERMAL WELLS
EFFLUENT
The City of Santa Rosa (population >150,000) also
required new solutions for disposing municipal
effluent due to increased urbanization, which
resulted in increased quantities of wastewater that
needed to be disposed of. Previously, effluent had
been used to irrigate crops, with excess supplies
being discharged to the nearby Russian River.
However, the river is prone to flooding during the
winter and discharge of effluent to the river or its
tributaries is prohibited during the summer (May
15th-September 30th). A severe storm in 1985
resulted in the release of treated wastewater from
the Santa Rosa system’s storage ponds, which
exceeded the discharge permit. This initiated Santa
Rosa’s search for a weather-independent way to
dispose of their effluent. In the end, the City
decided to send their effluent to The Geysers.
IMPLEMENTATION
Two separate projects have been implemented to
pipe reclaimed effluent from several WWTP’s to an
above-ground reservoir adjacent to the geothermal
field. The first project, the Southeast Geysers
Effluent Pipeline (SEGEP), began operation in 1997
from Lake County while the second, the Santa Rosa
Geysers Recharge Project (SRGRP), began operation
in 2003 from the City of Santa Rosa. Reclaimed
water is injected underground into production wells
in the steam reservoir where it is heated by the
underground rocks and produces new steam to
supplement the original production of reservoir
steam.
The reclaimed water system includes a total of 69
miles of injection water lines and sends
approximately 20 MGD of reclaimed water into The
Geysers reservoir. The network includes water from
the Middletown WWTP, Southeast Regional WWTP,
Northwest Regional WWTP, Clearlake Oaks WWTP,
and Laguna WWTP. A public/private partnership
was formed between key stakeholders, including

THE GEYSERS
B5 CALIFORNIA
GEOTHERMAL FIELD
the wastewater providers and the geothermal
operators at The Geysers, to implement the project.
SEGEP, the initial project to bring secondary treated
municipal effluent to The Geysers, began
construction in 1995 and commenced delivery of
reclaimed water in October 1997. Phase 1 of SEGEP
included approximately 20 miles of 20-inch
diameter ductile iron pipe connecting Lake County
to the southeast portion of The Geysers at a cost
$45 million ($37 million for the pipeline and $8
million for wastewater system improvements). This
phase connected the Southeast Regional (6,500
gpm) and Middletown (100 gpm) treatment plants
to The Geysers and increased the generating
capacity of The Geysers by 70 MW. Costs were
shared by the core participants, with additional
funding from the California Energy Commission,
California Water Resources Control Board, U.S.
Department of Energy, U.S. Department of
Commerce, U.S. Department of the Interior, and
U.S. Environmental Protection Agency. The
geothermal operators also invested several million
dollars to distribute the effluent from the main
pipeline to the injection wells at the steamfield.
Phase 2 of SEGEP lengthened the original pipeline
to include treated effluent from the Clearlake Oaks
treatment plant (275-500 gpm) in 1999 and the
Northwest Regional treatment plant (1,420 gpm) in
2003. This phase lengthened the pipeline by
approximately 25 miles, used 16-inch diameter
pipe, and cost $30 million. The effluent injection
volume was increased by 20% in normal weather
years and as much as 150% in drought years.
In total, SEGEP currently delivers approximately 9
MGD of secondary treated municipal effluent to The
Geysers Reservoir. A 25-year agreement is in place
for LACOSAN to operate the pipeline to
Middletown. Operators at The Geysers are
responsible for operations from Middletown to the
13553240
< B-19 >
20 MGD
1,517 MW STEAM INJECTION
MUNICIPAL
GEOTHERMAL WELLS
EFFLUENT
terminus in the power plant steamfield. LACOSAN
pays an annual O&M cost share equivalent based
on expected costs for conventional effluent
disposal, with the rest being covered by The
Geysers based on the quantity of water received.
Based on the success of SEGEP in maintaining
reservoir pressure at The Geysers, SRGRP was
initiated to bring tertiary treated effluent from
Santa Rosa to The Geysers. Planning by the City of
Santa Rosa and Calpine began in 1993 and the first
pipe was laid in 2000. Construction cost $200
million, involved 9 companies and 735 people, and
finished in 2003. A 41-mile pipeline transports 11
MGD of reclaimed municipal effluent to The
Geysers. In addition, four pump stations, a terminal
reservoir at the steamfields, discharge surge tanks,
and an advanced computer control/communication
system were constructed. Calpine spent an
additional $45 million to construct an 18-mile
network of pipes, a million-gallon storage tank, a
3,000 HP pump station, and to convert eight steam
wells to injection wells.
Water transported by the SRGRP originates at the
Laguna Wastewater Treatment Plant, which uses
filtration and UV-disinfection to treat municipal
water from the City of Santa Rosa to tertiary
standards. The water meets or exceeds the highest
level of California water recycling regulations (Title
22) and is monitored by state, local, and federal
agencies. Thus, the reclaimed water can be used for
irrigation, industry, and agriculture, but not for
drinking. The pipeline goes through Santa Rosa,
Windsor, and Healdsburg before traveling 3,300
feet up the Mayacamas Mountains to the terminal
tank at the steamfields.
In total, the SRGRP cost $250 million and supports
the generation of an additional 100 MW of power
at The Geysers. Calpine established a 30-year
contract with Santa Rosa to receive up to 7 billion

THE GEYSERS
B5 CALIFORNIA
GEOTHERMAL FIELD
gallons of recycled water per year. This agreement
was amended in 2008, and runs through 2038, to
account for increased flows from additional
communities (i.e., Windsor) that joined into the
system to contribute treated municipal effluent.
Windsor, one of the communities that joined the
system after SRGRP began operations, had issues
with storing and disposing its excess treated
municipal effluent, and connecting to The Geysers
was an environmentally superior and cheaper
option compared to building a massive storage
pond. The storage pond would have also required
the removal of 2,200 trees. Windsor connected
their water reclamation treatment plant to the
nearby SRGRP pipeline in 2011 by constructing
1,700 feet of 12-inch diameter pipeline. An
automated pump station in Windsor, controlled
remotely from the Santa Rosa Geysers Operation
Center, sends 0.5 MGD of tertiary treated recycled
water, with the potential to send up to 1 MGD. As
part of the agreement, Windsor agreed to pay Santa
Rosa more than $28 million over 27 years to dispose
of their water.
BENEFITS & CHALLENGES
Reclaimed water use at The Geysers provides
benefits related to power production, surface water
quality, treatment costs, reputation in the
community, water reliability, and effluent disposal.
The Geysers had previously experienced declining
power production due to steam/water depletion.
The addition of reclaimed water helped restore the
steam reservoir and allows it to sustainably produce
energy without being depleted, thereby increasing
both the current power production and the life of
The Geysers.
The effluent is higher quality than previous water
sources, thus producing less contaminants and
13553240
< B-20 >
20 MGD
1,517 MW STEAM INJECTION
MUNICIPAL
GEOTHERMAL WELLS
EFFLUENT
reducing treatment costs at The Geysers power
plants. For example, the amount of non-
condensable gases in the steam have dropped
significantly since reclaimed water began being
used. Hydrogen sulfide, which is expensive to
remove and recycle, has been reduced in the steam,
causing abatement costs to go down.
Reclaimed effluent use at the Geysers benefits
nearby communities by allowing them to discharge
excess treated effluent in an environmentally safe
and cost-effective manner. Sending water to The
Geysers provides flexibility and reduces the
regulatory burden for cities/treatment facilities
related to discharging treated effluent.
It also reduces the amount of effluent discharged in
the area, thereby improving surface water quality.
For example, the Santa Rosa pipeline reduces the
quantity of municipal effluent discharged to the
Russian River by 60% (2 billion gallons/year). This is
important because several community and
environmental groups have expressed concerns in
the past with discharging effluent to the Russian
River, citing drinking water quality and possible
impacts on aquatic life and the river ecosystem. Use
of excess reclaimed water by farmers also reduces
the amount of freshwater withdrawn from the
Russian River, improving spawning habitat for the
endangered coho salmon and steelhead trout.
There have been reputational benefits to both the
electric utility and the wastewater providers. This
unique public-private partnership resulted in
multiple awards for Calpine, including the 2008
WateReuse Customer of the Year, and has been
advertised as a success by all parties involved.
For the SRGRP part of the program, there were
several challenges including high costs, construction
time, legal issues, and political opposition. A lengthy
seven year construction time for the Santa Rosa

THE GEYSERS
B5 CALIFORNIA
GEOTHERMAL FIELD
pipeline included planning, design, environmental
studies, legal issues, and contracting. During the
planning, changing goals of the different cities,
updated topographic studies, lawsuits, and
neighborhood opposition resulted in delays and
changes to the size and path of the pipeline. Once
construction began, challenges arose with costs,
timing, and public opposition. Initially planned to
take two years and cost $102 million, construction
lasted four years and cost $200 million. Although
the pipeline was planned to primarily run along
public roadways to minimize impacts to private
properties and the environment, the pipeline faced
political and legal opposition from businesses,
property owners, and farmers impacted by the
construction. The construction affected 624 parcels
of land and required 200 property owners to
provide right-of-way for the pipeline to cross their
land. The pipeline also passes under the Russian
River in two locations and through the
environmentally sensitive Mayacamas Mountains
Audubon Sanctuary. The river crossings required
construction of 90 ft. deep by 600 ft. long tunnels.
Earthquakes in the area also present potential
challenges for the pipeline. Over the next 30 years,
there is a 70% chance that a 7.0 or greater
earthquake could occur in the area along the
Rodgers Creek/Hayward fault. This has the potential
to cause a rupture of the pipeline and subsequent
flooding. This issue was resolved by constructing
eight automatic isolation valves in the pipeline that
close when an earthquake of 5.5 or greater occurs,
thereby preventing flooding if the pipeline breaks.
LESSONS LEARNED
Large-scale water reuse projects are expensive and
complicated but can still be effective and beneficial
for all parties involved.
13553240
< B-21 >
20 MGD
1,517 MW STEAM INJECTION
MUNICIPAL
GEOTHERMAL WELLS
EFFLUENT
The presence of drivers for both the electric utilities
and surrounding communities helped push the use
of reclaimed water at The Geysers and allowed this
complex project to be implemented. While
construction of the pipeline was costly, time-
consuming, and faced public opposition, the project
was still able to be completed and has resulted in
benefits for all stakeholders.
REFERENCES
Calpine. 2008. Calpine Named 2008 WateReuse
Customer of the Year. Sept. 8, 2008.
URL: http://investor.calpine.com/news/press-
release-details/2008/Calpine-Named-2008-
WateReuse-Customer-of-the-
Year/default.aspx [Accessed 12/20/2016].
Calpine. 2016. Calpine: Committed to Sustainable
Water Reuse Programs. April 2016.
Calpine. 2016. The Geysers.
URL: http://www.geysers.com/ [Accessed
12/22/2016].
City of Santa Rosa, California. Geysers Project.
URL: http://ci.santa-
rosa.ca.us/DEPARTMENTS/UTILITIES/IRWP/GEYSER
S/Pages/default.aspx [Accessed 12/27/2016].
Clutter, T. 2003. Recharging The Geysers- Calpine
Corp. and Santa Rosa Celebrate Completion of the
World’s Largest Wastewater-to-Energy Project.
Geothermal Resources Council Bulletin, Nov/Dec.
Volume 32, Number 6: pp. 221-259.
URL: https://geothermal.org/PDFs/Articles/Rechargi
ngGeysers.pdf [Accessed 12/27/2016].
Crook, James. 2007. Innovative Applications in
Water Reuse and Desalination. Chapter 2: Case
Studies. WateReuse Association, Alexandria, VA.
 20 MGD
THE GEYSERS 1,517 MW STEAM INJECTION
B5 CALIFORNIA MUNICIPAL
GEOTHERMAL FIELD GEOTHERMAL WELLS
EFFLUENT

Kidd, D. 2013. Water-Powered Electricity Flows

Through Santa Rosa. Governing. May 2013.
URL: http://www.governing.com/topics/transportat
ion-infrastructure/gov-poop-powered-electricity-
flows-through-santa-rosa.html

Lake County, California. Effluent Pipeline.

URL: http://www.co.lake.ca.us/Government/Direct
ory/Special_Districts/Wastewater_Systems/Effluent
_Pipeline.htm [Accessed 12/27/2016].

Town of Windsor. A Powerful Connection: An

Environmentally Friendly and Sustainable Solution
that is Generating Clean Energy.
URL: https://www.townofwindsor.com/DocumentC
enter/View/13461

Mason, C. 2011. Windsor now sending its

wastewater to The Geysers. The Press Democrat.
June 10, 2011.
URL: http://www.pressdemocrat.com/news/23016
82-181/windsor-now-sending-its-
wastewater?ref=related [Accessed 12/22/2016].

VERIFICATION
Information presented in this case study was pulled
from sources accessible online, with no interviews
or input from Calpine or anyone associated with
The Geysers.

13553240

< B-22 >

 556 MW 4-6 MGD
B6 PLANT SMITH FLORIDA COOLING TOWERS
NGCC MUNICIPAL EFFLUENT

Two coal units (1 & 2) were

retired in 2016 and
previously used brackish
water from the bay for once-
through cooling. The plant
also contains a backup 32
MW diesel fired combustion
turbine (CT) unit. Plant Smith
currently has a permit to
discharge effluent to West
Bay, which includes water
from the once-through
system and cooling tower
blowdown.

Planning for a transition to

OVERVIEW
The Lansing Smith Generating Plant (Plant Smith) is
a 556 MW NGCC plant located in Bay County,
Florida. The plant is situated in the central
panhandle of Florida about 15 miles north of
Panama City (population ~37,000). Panama City
receives ~61 inches of rainfall each year. Summers
are long, hot, and humid. About half of the days in
the summer have highs in the 90’s (°F), but
temperatures rarely get above 100°F.
Plant Smith is currently in the process of securing
their future use of reclaimed municipal effluent
from Bay County, and possibly Panama City and/or
Lynn Haven.
reclaimed municipal effluent
began in 2009 and has
resulted in a partnership
between Gulf Power, Florida’s legislature, Bay
County, and several state agencies.
DRIVERS
Drivers behind the planned change to reclaimed
water include water quality, Gulf Power’s past
experiences with using reclaimed water, and
Florida’s nutrient regulations.
The primary driver for Gulf Power was the poor
water quality of the existing source. Significant
corrosion and scaling was occurring on the natural
gas unit due to the use of brackish water. It was
determined that a reclaimed municipal effluent
source would provide improved water quality,
thereby preventing these and other issues.

BACKGROUND Driver Benefit Challenge

Quantity
Plant Smith’s natural gas Unit 3 began operations in
Quality
2002 and currently uses brackish water from the
North Bay of St. Andrew Bay to supply water to the Reputation
cooling tower. A groundwater supply is used for Regulatory
condensate makeup and other in-plant processes.
Cost

13553240

< B-23 >

 556 MW
B6 PLANT SMITH FLORIDA
NGCC
Gulf Power’s past experiences using reclaimed
municipal effluent at Plant Crist in Pensacola also
helped drive this decision (see Plant Crist case
study). The Crist project has been successful and
confirmed the benefits of using reclaimed water for
power generation.
Another key driver was increased regulations for
the wastewater facilities. Florida adopted statewide
numeric nutrient standards in 2011 with the
objective of eventually having numeric nutrient
standards for all waters in the state. In 2012,
standards were approved for both St. Andrew Bay’s
(0.019 mg/L TP, 0.34 mg/L TN, and 3.7 µg/L
chlorophyll a) and North Bay (0.014 mg/L TP, 0.28
mg/L TN, and 3.1 µg/L chlorophyll a). These
standards have costly implications for dischargers to
Florida waters, forcing wastewater utilities to
upgrade their treatment processes to meet these
requirements if they continue to discharge to
bodies of water. Sending effluent to power plants
like Smith provides an avenue by which wastewater
utilities can dispose of their effluent without
sending it to a receiving water.
IMPLEMENTATION
Planning for this project started around 2009 when
a wastewater utility on the fringe of the project
approached Gulf Power about using reclaimed
municipal effluent. It was eventually determined
that this wastewater utility could not guarantee a
specific quantity of water or compliance in terms of
water quality. By this time other wastewater
utilities had become involved and Gulf Power
decided to move on with Bay County as a primary
source.
Bay County currently discharges their effluent into
rapid infiltration basins. Water in the basins
eventually filters through the soil and into St.
Andrew Bay.
13553240
< B-24 >
4-6 MGD
COOLING TOWERS
MUNICIPAL EFFLUENT
The project is still in the process of construction and
permitting. Bay County and Gulf Power have
worked together to plan the work, with the
potential for other utilities/cities, like Lynn Haven
and Panama City, to tie into the system and send
their treated municipal effluent to Plant Smith.
The conceptual plan for the use of reclaimed water
is in place. Once active, the plant is expected to use
an estimated 4-6 MGD of reclaimed municipal
effluent for 100% of Plant Smith’s cooling needs.
Condensate makeup and other in-plant processes
will continue to use groundwater. The water will be
pumped about 6 miles underground from a Bay
County wastewater treatment plant and will not
require the pipeline to go through the bay.
About 75% of the equipment needed for the
transition has been installed at Plant Smith and the
reclaimed source is expected to be operational by
late 2018 or early 2019. Plant Smith is unable to
discharge their blowdown or utilize spray irrigation
because of shallow groundwater levels and nutrient
regulations. Therefore, the plant will use injection
wells to dispose of the blowdown from the cooling
tower. Plant Smith is also in the process of
upgrading their pond system to provide an
emergency supply of reclaimed water. The facility
will maintain the ability to return to the original
water supply from St. Andrew Bay if there are issues
with the reclaimed source.
It is expected that Gulf Power will pay a fee for the
effluent received, but the parties are still
negotiating the exact amount. The funding for the
majority of the pipeline and pumping costs to bring
the water from the wastewater utilities to Plant
Smith has been secured. The State of Florida
(Florida Department of Environmental Protection)
recently began providing incentives to utilities that
reuse reclaimed water as part of their objective of
“encouraging and promoting reuse” in Sections
373.250 and 403.064, Florida Statutes (FDEP 2016).
 556 MW
B6 PLANT SMITH FLORIDA
NGCC
Currently, this project has received funding from
three different government agencies that promote
reuse and is continuing to gather funds from
different entities to help pay for everything involved
with the transfer of the reclaimed water from Bay
County to Plant Smith. In March of 2016, the
Governor of Florida approved $2.5 million for Bay
County projects, with $1.0 million intended to go to
projects that would reroute treated effluent to
Plant Smith. The Northwest Florida Water
Management District has also approved the
contribution of $0.5 million for design work on the
pipeline from Bay County.
BENEFITS & CHALLENGES
Anticipated benefits of reclaimed water use include
superior water quality for the cooling processes,
improved surface water quality, reduced costs, and
reduced water consumption.
It is assumed that Plant Smith will experience
operational benefits (e.g., reduced corrosion,
increased cycles of concentration) because the
reclaimed water is higher quality than the current
brackish water source. It is expected that the cycles
of concentration at Plant Smith will increase from
1.5 to 10 cycles with the use of reclaimed water,
thereby requiring less water to be pumped and less
blowdown. Because the effluent is chlorinated at
the wastewater treatment plant, Plant Smith will
not have to chlorinate and treatment costs will be
reduced. Additionally, Plant Smith projects the
effluent water will have a more consistent quality
and temperature than the current source, which
will improve efficiency.
Plant Smith expects the use of reclaimed water will
be more cost effective than the current source due
to reduced treatment costs, improved efficiency,
and incentives provided by the State of Florida.
13553240
< B-25 >
4-6 MGD
COOLING TOWERS
MUNICIPAL EFFLUENT
The use of reclaimed water is also predicted to
benefit surface waters in the area. It will allow
wastewater utilities to reduce nutrient loading
discharges to the bay, and will also reduce Plant
Smith’s withdrawals from the bay or groundwater,
thereby conserving surface water and groundwater
sources for future uses.
The wastewater utilities will benefit because they
will not have to aggressively adapt to the numeric
nutrient criteria. This may have included restricting
their discharge to surface waters, upgrading their
treatment processes, or building additional
infiltration basins as the amount of effluent
increases.
No challenges have occurred with the use of
reclaimed water, in part because the project has
not been fully implemented yet. Due to the
incentives provided by the state and the numeric
nutrient standards for surface bodies of water,
there is a potential for competition over reclaimed
water use in certain areas of Florida. While some
areas have allocated all reclaimed water to specific
uses and industries, there is currently limited
competition in Bay County that would prevent Plant
Smith from obtaining enough reclaimed water.
LESSONS LEARNED
Regulations or incentives may help promote
reclaimed water use at power plants.
When wastewater treatment plants are limited by
numeric nutrient standard in receiving water
bodies, it is advantageous for them to instead send
effluent to industrial water users like electric power
plants. Also, incentives for water reuse, such as
those offered by the State of Florida, provides
funding to initiate reuse. Both of these external
drivers can lead to opportunities for electric power
utilities to receive and implement reclaimed water
 556 MW 4-6 MGD
B6 PLANT SMITH FLORIDA COOLING TOWERS
NGCC MUNICIPAL EFFLUENT

supplies in a cost-effective manner that benefits
multiple parties as well as the environment.
Prior use of an alternate source may support
opportunities at other facilities.
Gulf Power has been using reclaimed municipal
effluent at Plant Crist since 2010. This successful
operation provided a strong foundation for
reclaimed use at Plant Smith.
REFERENCES
Florida Department of Environmental Protection.
2012. 62-302.532 Estuary-Specific Numeric
Interpretations of the Narrative Nutrient Criterion.
Effective on 12/20/2012.
Southern Company. 2016. 2016 Water Action
Report. May 2016.
URL: http://www.southerncompany.com/what-
doing/pdf/WaterActionReport2016.pdf [Accessed
11/7/2016].
VERIFICATION
Information presented in this case study was
provided through interviews with Southern
Company and Gulf Power Company staff in October
2016, who have reviewed this case study for
accuracy.

Florida Department of Environmental Protection.

2016. Water Reuse. Last updated June 15, 2016.
URL: http://www.dep.state.fl.us/water/reuse/
[Accessed 11/11/2016].

Gulf Power. 2016. Gulf Power and Bay County

partner to reuse water. April 20, 2016.
URL: http://www.gulfpowernews.com/gulf-power-
bay-county-partner-reuse-water/ [Accessed
11/11/2016].

Gulf Power. 2016. Plants.

URL: http://www.gulfpower.com/about-
us/background/plants.cshtml [Accessed
11/7/2016].

Markey, Mike. 2014. Sustainability: AWMA 50th

Annual Conference & Expo. Gulf Power Company.
October 30, 2014.
URL: http://floridasection.awma.org/Conference_Fil
es/2014%20Conference%20Presentations/Markey.
pdf [Accessed 11/9/2016].

Personal communication, Southern Company and

Gulf Power staff, 2016. Ashley Jansen, Andrue
Gregory, Donna Hill, Howard Shelnutt, Mike
Markey, and Robert Jernigan.

13553240

< B-26 >

 583 MW ~12 MGD
B7 RISEC RHODE ISLAND COOLING TOWERS
NGCC MUNICIPAL EFFLUENT

DRIVERS
The use of reclaimed
municipal effluent at
RISEC was driven by the
lack of suitable surface
water sources and costs
associated with other
non-surface water
sources.

Surface waters in the

OVERVIEW
The Rhode Island State Energy Center (RISEC) is a
583 MW NGCC plant located in Johnston, Rhode
Island (population ~29,000), about five miles from
Providence (population ~178,000). Providence
receives ~103 inches of rainfall each year. Summers
are warm and humid, with highs rising to 90°F or
higher.
RISEC has used reclaimed municipal effluent (~12
MGD) from the City of Cranston Wastewater
Treatment Plant (WWTP) since it began operation.
This treated effluent supplies water for RISEC’s
cooling towers, demineralization water, and fire
protection.
area were not adequate
based on both quantity
and quality. The surface
waters near RISEC are
highly polluted due to
stormwater runoff and
leakage from the nearby
Rhode Island Resource Recovery Corporation
Landfill. This pollution also impacts the
groundwater in the area, making it unsuitable for
cooling.
The plant was constructed in an undeveloped
industrial area of Johnston that did not have
connection to city water. Thus, potable water from
the city was not a feasible option. If it were made
available, the cost was estimated to be four times
more expensive than treated municipal effluent.
Due to the lack of available freshwater sources, the
plant owner approached the City of Cranston, the
closest reclaimed water source, about using treated
effluent. The firm constructing RISEC was also

BACKGROUND
Driver Benefit Challenge
RISEC began operations in 2002 and is positioned
Quantity
near some of New England’s largest demand
centers. Cranston’s WWTP is operated by Veolia Quality
and located on the Pawtuxet River, about seven Reputation
miles from RISEC.
Regulatory
Cost
13553240

< B-27 >

 583 MW
B7 RISEC RHODE ISLAND
NGCC
instrumental in promoting the use of treated
effluent at the plant.
IMPLEMENTATION
The planning and construction of the RISEC plant
incorporated the use of reclaimed municipal
effluent. Treated municipal effluent is used at RISEC
for cooling tower makeup water, demineralization
water, and fire protection.
A thirteen-mile pipeline was constructed to connect
Cranston’s WWTP to RISEC. The pipeline passes
through public right-of-ways of a populated area.
Cranston is able to provide a constant supply of high
quality water (~12 MGD) to meet the needs of
RISEC.
A supplemental treatment facility was constructed
next to the Cranston WWTP specifically to treat the
water provided to RISEC with Disk and Xenon filters,
chlorination, and pH adjustment. This facility was
built and is currently operated by RISEC. In addition,
RISEC further treats a portion of the water onsite to
create high quality demineralization water.
Staff at RISEC received additional training focused
on handling municipal effluent. Additional
monitoring of the water, beyond typical, is also
conducted including online analyzers for TSS, pH,
turbidity, and chlorine. These data are tied into a
SCADA system at the plant and have helped the
plant understand the quality of the water in real-
time and better manage their use of the reclaimed
effluent.
RISEC does not have a formal backup supply in the
event that Cranston WWTP cannot provide water,
however, two onsite tanks (0.5M gallon and 4M
gallon) provide storage for excess treated effluent.
The smaller tank was built during initial
construction, and the larger tank was built in 2005.
These tanks provide flexibility for RISEC to take
excess water when high quality water is available;
however, because they hold less than one day of
13553240
< B-28 >
~12 MGD
COOLING TOWERS
MUNICIPAL EFFLUENT
cooling water, long-term issues with incoming
water would cause challenges.
RISEC pays the City of Cranston for the water. They
also pay for the treatment at the supplemental
treatment facility, the pipeline from Cranston, and
the return of cooling tower blowdown water back
to the City of Cranston WWTP. The blowdown
water is treated through an industrial pretreatment
permit. Approximately 75% of the effluent water
received from Cranston is returned as blowdown
water. RISEC pays the city approximately $400,000-
500,000 per year, based on the quantity of water
used and returned for treatment and discharge. The
pipeline that returns water from RISEC to Cranston
is owned and maintained by the City and receives
water from other customers. Because the Cranston
WWTP requires a steady flow of incoming
wastewater, RISEC continues to provide flow even
during maintenance outages.
BENEFITS & CHALLENGES
The use of municipal effluent provides cost,
reputational, and regulatory benefits to RISEC.
The use of reclaimed effluent allowed the plant to
be sited in a preferred location and it provides a
more affordable supply than connecting to a
potable water source.
RISEC sees reputational benefits because the plant
is not relying on freshwater resources and is
therefore not contributing to water issues in the
region. Alternate water supply use at RISEC has
been mentioned in multiple corporate sustainability
reports over the years.
There are also regulatory benefits to RISEC. Because
they discharge their blowdown to the City, rather
than waters of the state, the facility does not need
an NPDES permit defined by State and federal
requirements.
The use of reclaimed effluent from Cranston
reduces the amount of polluted water discharged to
 583 MW
B7 RISEC RHODE ISLAND
NGCC
the Pawtuxet River, which provides water quality
benefits to the river. RISEC also generates revenue
for the City of Cranston as they pay for returning
wastewater. Additionally, the extra capacity in the
return pipeline allowed the city to take water from
other users on the route, supporting growth and
development in the region.
While the Cranston WWTP (23 MGD) is able to
reliably provide a sufficient quantity of water to
RISEC, challenges with the quality of the reclaimed
effluent have occurred. RISEC is adjacent to a
landfill (Rhode Island Resource Recovery Corp.).
Previously, landfill leachate was directed to the
Cranston WWTP for treatment and high levels of
heavy metals (e.g., arsenic) in the leachate and
polluted stormwater runoff in the area resulted in
variable quality of the treated effluent sent to
RISEC. The issues occurred mainly during the first
few years that RISEC used reclaimed effluent.
During that time, the supplemental treatment
facility also experienced issues treating the water
because the power plant was operating at low (5-
50%) capacity and RISEC employees were
inexperienced with running the treatment facility.
When the effluent has poor quality, it impacts the
number of cycles of concentration that the plant
can achieve due to the buildup of metals in the
cooling tower. This situation reduces the efficiency
of the power plant and can lead to air discharge
permit challenges (e.g., TSS and fecal coliform
limits).
The City of Cranston has the authority to set a
pretreatment limit on wastewater received. When
the Cranston WWTP effluent delivered to RISEC is of
poor quality, cooling towers concentrate the
pollutant levels in the water and RISEC may return
wastewater with heavy metal concentrations over
the limits. However, RISEC has not been fined by
the WWTP when this occurs. Recognizing their role
in the situation, the Cranston WWTP responded by
installing an ultra-filtration system and more
recently (~2013-2014) sending landfill effluent to
13553240
< B-29 >
~12 MGD
COOLING TOWERS
MUNICIPAL EFFLUENT
the City of Providence WWTP rather than treating it
themselves. This has improved the quality of the
water sent to RISEC.
Overtime, the return pipeline to Cranston has
experienced issues with over-pressurization, leading
to fractures in some lines that RISEC had to repair.
LESSONS LEARNED
Ensure that operational challenges with treating
the reclaimed water source are resolved before
implementing use at the power plant.
During the initial years of operation, RISEC
experienced issues with poor water quality because
both the Cranston WWTP and the supplemental
treatment facility were unable to adequately treat
the water source. This led to costly upgrades in
treatment and reduced plant efficiency. Both RISEC
and Cranston WWTP eventually improved their
processes and now the power plant efficiently uses
the reclaimed effluent.
REFERENCES
Gill, Elizabeth. 2015. The Carlyle Group to Acquire
Rhode Island State Energy Center. The Carlyle
Group. October 8, 2015.
URL: https://www.carlyle.com/media-room/news-
release-archive/carlyle-group-acquire-rhode-island-
state-energy-center [Accessed 11/23/16].
Personal communication, Entergy staff, 2016. Rick
Johnson and Andrew Rosenlieb.
Personal communication, NextEra staff, 2017. Paul
Aronian.
Reynolds, Mark. 2013. Cranston fines landfill
operator for toxic wastewater. Providence Journal.
April 3, 2013.
URL: http://www.providencejournal.com/article/20
130403/News/304039924 [Accessed 3/8/17].
 583 MW ~12 MGD
B7 RISEC RHODE ISLAND COOLING TOWERS
NGCC MUNICIPAL EFFLUENT

VERIFICATION
Water use information presented in this case study
was provided through interviews with Entergy and
NextEra staff in September 2016 and February
2017, who have reviewed this case study for
accuracy.

13553240

< B-30 >

 KYRENE GENERATING COOLING 3.1 MGD
B8 ARIZONA 415 MW NGCC
STATION TOWERS MUNICIPAL EFFLUENT

since 2003), three

combustion turbine units
(165 MW total) built in the
1970s, and one combined-
cycle unit with recirculating
cooling (250 MW) built in
2002. This newer unit (K7
unit) was designed to use
reclaimed KRF effluent for
cooling.

OVERVIEW
The Kyrene Generating Station (KGS) has a
generating capacity of 415 MW and is located near
Tempe, Arizona, a highly urban area with a
population ~162,000. On average, Tempe receives
approximately 9 inches of rain each year, and
average temperatures between June and
September exceed 100 degrees F.
From 2002-2010, KGS used 3.1 MGD of reclaimed
municipal effluent from Tempe’s Kyrene Water
Reclamation Facility (KRF) for cooling. The KRF is no
longer in operation; therefore, KGS currently
obtains water from a combination of surface water
and groundwater sources made available through
complex water storage and recovery mechanisms.
BACKGROUND
Salt River Project (SRP) is public power utility that
provides both electricity and water to people in
Central Arizona. SRP owns and operates KGS, which
has six units: two steam units with once-through
cooling (106 MW total) built in the 1950s (inactive
13553240
DRIVERS
The primary driver for SRP
to use reclaimed effluent
was the need for a legally
available cooling water
supply for the expanded K7
unit at the existing Kyrene Generating Station.
There was a need to provide new generation in the
Phoenix metropolitan area and expansion at the
existing site was preferred over other locations
because this site had access to existing transmission
lines and would not require any new off-site
transmission. Building generation or purchasing
power outside the Phoenix metropolitan area
would have required construction of new
transmission lines.
With little flexibility for siting location, a water
supply plan had to be developed using sources
other than groundwater due to limitations of
Arizona’s 1980 Groundwater Management Act
(“Code”). The Code requires a water right for new
uses of non-renewable groundwater, and
compliance with stringent conservation
Driver Benefit Challenge
Quantity
Quality
Reputation
Regulatory
Cost

< B-31 >

 KYRENE GENERATING
B8 ARIZONA
STATION
requirements. SRP opted to find renewable water
supplies for the expansion, which included
reclaimed effluent and local surface water supplies.
A 2001 Environmental Assessment examined
several water sources, and documented that
reclaimed effluent from the KRF would be the
primary water source.
IMPLEMENTATION
As part of the power plant siting, KGS established a
water exchange agreement with the City of Tempe
for four water supply options that can be accessed
depending on availability. These are: 1) reclaimed
municipal effluent from KRF; 2) physical
groundwater which is reclassified as surface water
through a three-way exchange; 3) City of Tempe
surface water from the Salt/Verde Rivers stored in
aquifers during excess years; and 4) Central Arizona
Project (CAP) water from the Colorado River that is
stored in the local aquifer and later recovered.
A 0.7-mile (16- to 24-inch-diameter) buried pipeline,
carried water from KRF to the Kyrene power plant.
An existing canal right-of-way was used to run the
waterline to KGS. The facility used approximately
3.1 MGD of effluent water for cooling tower make-
up water. Prior to use for cooling, the reclaimed
effluent received additional chlorine treatment and
filtered through multimedia filters. Occasional high
phosphate concentrations were treated with
additional chemicals.
KGS attempted to use reclaimed municipal effluent
for the demineralization process, but had issues
with the RO membranes, which had to be replaced
every two weeks. As a result, existing onsite
groundwater wells owned and operated by SRP
were instead used to supply demineralization water
and serve as a back-up raw water source.
Effluent from KGS is monitored and discharged, via
pipeline, to an existing KRF discharge pipe, which
13553240
< B-32 >
COOLING 3.1 MGD
415 MW NGCC
TOWERS MUNICIPAL EFFLUENT
drains to the storm drain, and eventually to the Salt
River.
Since the K7 unit was originally designed to use
reclaimed effluent, no general operational changes
were necessary when implementing the use of
reclaimed effluent. However, after the K7 unit was
operating, it was necessary to replace an existing
onsite storage tank with a larger, 5 million gallon
tank to regulate the volume of water provided to
KGS (for example, when there were temporary
shut-downs at KRF) and provide surge protection.
KGS paid for water-related transportation and
infrastructure costs. However, KGS did not pay to
acquire the reclaimed effluent. Reclaimed effluent
from KRF provided a reliable water source to KGS
from 2002 to 2010. In 2010 the City of Tempe
decided to mothball KRF and send wastewater to
the 91st Avenue Wastewater Treatment Plant
(WWTP), which is located in Phoenix and supplies
reclaimed effluent to the Palo Verde Nuclear Power
Plant. This change was related to the economic
recession; it was less expensive to pump water to
the alternate WWTP than continue operation of the
KRF. It was an unforeseen circumstance for KGS.
After the KRF was mothballed, KGS transitioned to
using water from the other sources outlined in the
water exchange agreement. The facility is currently
using Tempe surface water stored underground and
then recovered (pumped) to KGS.
Recognizing that other water sources may be
necessary over the long-term, KGS purchased over
100,000 acre-feet of CAP water in anticipation of
future demands. The CAP water is similar to an
inter-basin transfer. The project is a 336 mile
diversion canal that required the construction of
significant infrastructure for water transportation.
Water is transferred from the larger Lower
Colorado River Basin (Lake Havasu) and is used
within the Gila River Basin, which is a tributary that
 KYRENE GENERATING
B8 ARIZONA
STATION
feeds the Lower Colorado River downstream of Lake
Havasu. The CAP water is stored in the local aquifer
via artificial recharge and is available to withdraw as
needed in the future (e.g., aquifer bank account). A
capital account was created and KGS operators are
able to debit the account at a cost of $144/AF,
which represents the total acquisition cost and
transportation cost amortized over the life of the
plant use. The CAP water costs more than the
reclaimed water, but the infrastructure costs and
treatment costs are less for CAP water.
The remaining two water supply options, City of
Tempe’s surface water supply from the Salt/Verde
rivers stored in aquifers and physical groundwater
reclassified as surface water through a three-way
exchange, are available if the CAP water supply is
no longer a viable supply for KGS.
BENEFITS & CHALLENGES
The use of reclaimed municipal effluent provided a
water quantity and public relations benefit to KGS.
The plant expansion required a significant public
process and the options for renewable water
sources were supported by the public and
organizations who provided comment.
In addition, the City of Tempe benefitted because
the delivery of reclaimed water to KGS freed up Salt
and Verde River water that could be delivered to
the water treatment plant. This saved Tempe from
pumping groundwater for potable supply for
customers and also benefited the aquifer.
Another benefit was that SRP was successful in
siting a much needed new unit at an existing power
generation site that did not require new
transmission lines to provide a local power source.
The primary challenge of using the reclaimed
effluent was related to water quality because the
reclaimed water was not suitable for
demineralization water. Secondary challenges were
13553240
< B-33 >
COOLING 3.1 MGD
415 MW NGCC
TOWERS MUNICIPAL EFFLUENT
related to water quantity due to closure of KRF, and
cost, which increased when KRF closed and KGS had
to switch to its other water sources. It should be
noted that when KGS stopped using reclaimed
water, they received no push-back from the public
on switching to different water supply. This is likely
because the public had already been informed of
the alternatives in the Certificate of Environmental
Compatibility process and as described in the water
exchange agreement.
LESSONS LEARNED
A reclaimed source may not provide a long
term supply and contingency supplies are
important
The decommissioning of KRF was not foreseen and
could have posed a challenge to KGS. Water source
diversity is key to a stable, long-term water supply
and forethought in developing the alternate water
supplies for KGS with a 30-year agreement in place
with the City of Tempe allowed for the relatively
easy transition when KRF ceased operation.
Implementation of alternative water supplies are
most successful if conditions are well defined
through contracts, discussions, and negotiations.
Ensuring sustainability of the source is crucial to the
continued use of an alternative source.
REFERENCES
Personal communication, SRP staff, 2016. Sharon
Morris, Greg Kornrumph, Tom Murray, Robert
Woods, and Brian Harbin.
ENSR, 2001. Environmental Assessment Salt River
Project Agricultural Improvement and Power
District Kyrene Expansion Project Tempe, Arizona.
Prepared for U.S. Environmental Protection Agency
Region IX. January 2001.
 KYRENE GENERATING COOLING 3.1 MGD
B8 ARIZONA 415 MW NGCC
STATION TOWERS MUNICIPAL EFFLUENT

VERIFICATION
Water use information presented in this case study
was provided through interviews with SRP staff in
December 2016, who have reviewed this case study
for accuracy.

13553240

< B-34 >

 <2.9 MGD
SPIRITWOOD NORTH 99 MW COAL COOLING
B9 INDUSTRIAL/
STATION DAKOTA CHP TOWERS
MUNICPAL EFFLUENT

natural gas prices in 2005

threatened a plant shut-
down unless the Malt
Plant could acquire an
affordable, stable energy
supply. The Governor’s
office worked with GRE,
which was looking for a
long-term asset to meet a
growing demand for
electricity in their service
area, to construct SWS
next to the Malt Plant to
cost-effectively supply
steam heat to the Malt
Plant. As a result, a
cooperative agreement
was established to co-
OVERVIEW locate SWS and the Malt Plant.

Spiritwood Station (SWS) is a 99 MW lignite coal
combined heat and power (CHP) plant owned and
operated by Great River Energy (GRE). It is located
near Jamestown, North Dakota (population
~15,500). On average, Jamestown receives ~19
inches of rain each year, with average high
temperatures of ~80°F in the summer months.
SWS has had a complex history of water supply
strategies. The power plant originally planned to
use reclaimed industrial wastewater, temporarily
used reclaimed municipal wastewater, but currently
uses fresh groundwater from a rural water district.
This case study describes the two reclaimed water
options and summarizes the challenges and
limitations.
BACKGROUND
Prior to the construction of SWS, the nearby Malt
Processing Plant (Malt Plant) used natural gas to
generate heat for their processes on site. High
SWS, the Malt Plant, and the Dakota Spirit AgEnergy
corn-ethanol biorefinery are part of the Spiritwood
Energy Park. In addition to electricity, SWS produces
steam which is used by the Malt Plant and Dakota
Spirit AgEnergy.
DRIVERS
Lack of a local freshwater supply (groundwater and
surface water), timing, and regulatory constraints
were the key drivers in the selection of an
alternative water source. It is important to note
that because the Malt Plant needed steam as soon
as possible, there was a fast track schedule to
Driver Benefit Challenge
Quantity
Quality
Reputation
Regulatory
Cost

13553240

< B-35 >


SPIRITWOOD NORTH 99 MW COAL
B9
STATION DAKOTA CHP
construct SWS and secure an adequate source of
water.
Initially, groundwater from a nearby confined
aquifer was considered, but because the constraints
of the aquifer were not well understood and the
project was accelerated, there wasn’t enough time
to obtain a groundwater permit.
Surface water options were evaluated too, but
sufficient appropriation rights were also not
available.
Given the challenges associated with groundwater
and surface water sources, GRE decided to reuse
industrial water from the Malt Plant based on the
proximity and availability of the Malt Plant’s
industrial wastewater, and their preference for
reuse. Thus, the plan to reuse wastewater from the
Malt Plant’s industrial operations became the
preferred option.
IMPLEMENTATION
Industrial Wastewater: SWS was intentionally sited
near the Malt Plant to supply process steam for the
Malt Plant’s operations. This led to the
consideration to use water from the Malt Plant’s
wastewater lagoons for 100% of the boiler feed
water, cooling water and other process uses at
SWS. However, the power plant never used the
Malt Plant wastewater mainly due to water quality
and reliability concerns (further described in the
Benefits and Challenges section below). Rather than
send wastewater to SWS, the Malt Plant continued
to discharge water, after biological treatment, from
the wastewater lagoons to the James River via an
NPDES permit.
Municipal Wastewater: In the absence of a viable
freshwater alternative, GRE decided to use
reclaimed wastewater from the City of Jamestown
POTW (Publicly Owned Treatment Works). SWS,
13553240
< B-36 >
<2.9 MGD
COOLING
INDUSTRIAL/
TOWERS
MUNICPAL EFFLUENT
City of Jamestown and Stutsman Rural Water
District (SRWD) signed a Water Supply and
Discharge Agreement in 2009 to describe the
conditions of use. SWS was commissioned in 2010
and began using reclaimed municipal wastewater
from the Jamestown POTW for boiler feed water,
cooling tower makeup water, and auxiliary uses.
A pipeline was constructed to transport wastewater
from the Jamestown POTW to SWS. The pipeline
and pump station cost $5.5 million (4% interest rate
over 20 years) and SWS paid the POTW and SRWD
fixed prices for interconnection facilities. SWS was
also equipped with a dedicated water treatment
plant to further treat the reclaimed water to meet
water quality levels necessary for the various water
uses at SWS. SWS paid Jamestown POTW
$0.40/1,000 gallons of water used. The agreement
allowed for a minimum of 200 gpm (0.288 MGD)
and a maximum of 2,000 gpm (2.88 MGD) of
Jamestown POTW effluent to be delivered to SWS.
Transportation costs varied ($0.37-0.75/1,000
gallons) based on the average monthly flow of
water supplied to SWS. The agreement also gave
Jamestown the authority to adjust the cost of the
water supply annually in proportion to the annual
change in the Consumer Price Index. Additionally,
SWS incurred costs to operate its onsite clarifier
that was needed to use the reclaimed water.
This arrangement continued for just under a year
before SWS temporarily ceased operations for
economic reasons tied to low power prices and
weak demand. The pause in SWS operations did not
affect the Malt Plant because natural gas prices had
fallen significantly from the historic highs from 2005
to 2008.
Fresh Groundwater: SWS reopened and became
fully operational in late 2014. Due to O&M costs
(transport, treatment, and cost of water) as well as
challenges with the quality of the Jamestown

SPIRITWOOD NORTH
B9
STATION DAKOTA
treated wastewater, SWS transitioned to using
groundwater from the Stutsman Rural Water
District (SRWD). Although direct use of groundwater
was not originally an option for SWS, the facility was
able to receive groundwater via SRWD because
rural water districts tend to have higher priority
water rights compared to industrial users. This
allowed SRWD to more easily obtain a groundwater
permit than SWS. SRWD provided higher quality
water than Jamestown, and the higher water
quality reduced SWS’s onsite treatment
requirements and costs.
SRWD owns and operates the wells and pipelines
that provide 0.5 MGD to SWS. SWS continues to
send wastewater to the Jamestown POTW for
treatment and discharge. SWS pays more for the
SRWD groundwater than it did for the Jamestown
WWTP effluent ($35,000/month which includes a
variable cost of $2.38/1000 gallons plus a fixed fee).
It should be noted that SWS uses less water from
SRWD than would be required if water from
Jamestown POTW continued to be used because
the higher water quality allows for greater recycle
rates in the cooling tower and less water treatment,
which reduces water losses in the onsite treatment
plant.
Additional Efforts for Reclaimed Use: In 2015, there
was an additional initiative to promote reclaimed
water use in the region. A proposed wastewater
treatment plant near the Spiritwood Energy Park
would receive used water from the Malt Plant and
others and then supply water to a planned
ammonia fertilizer plant. Unfortunately, the
ammonia fertilizer plant was not built and the plan
did not proceed.
BENEFITS & CHALLENGES
The main benefit of using alternative sources at
SWS was the ability to site the plant quickly in a
13553240
<2.9 MGD
99 MW COAL COOLING
INDUSTRIAL/
CHP TOWERS
MUNICPAL EFFLUENT
location where they could provide heat to the Malt
Plant. GRE felt that it would have taken too long to
acquire a groundwater permit due to the regulatory
environment. Thus, the alternative sources were
the only viable options that could supply the
required quantity of water in the desired
timeframe.
A benefit of using reclaimed water from the
Jamestown POTW was the relative ease of the
construction. A pipeline was already being
constructed from SWS to the Jamestown POTW for
wastewater treatment, and it was convenient to
construct a parallel pipeline in the same pathway to
send treated effluent from Jamestown to SWS for
cooling and process use.
Although SWS attempted to use industrial and
municipal reclaimed water, both sources presented
challenges regarding their use. Challenges in
securing a reliable and affordable water supply cost
SWS additional staff time and iterations in
permitting and contracting, higher costs, and losses
of potential revenue.
Challenges that precluded the use of the Malt Plant
wastewater included high solids content, high
treatment costs, and seasonal variability in the
water quality. Additionally, SWS was concerned
about the long-term viability of the water supply
from the Malt Plant, the variability of the malt
market, and whether they could produce a
sufficient volume of wastewater for SWS. A study of
available water levels in pumping wells suggested
that current groundwater pumping rates from the
confined aquifer could result in water supply issues
in 12-15 years. Finally, there were also challenges
that came up during the contract negotiations
between SWS and the Malt Plant, which made the
process more difficult.
< B-37 >

SPIRITWOOD NORTH 99 MW COAL
B9
STATION DAKOTA CHP
The primary challenge that ended SWS’s use of
Jamestown POTW reclaimed wastewater was the
poor quality of the water. Analysis of the system by
CH2M HILL determined that the onsite water
treatment plant had experienced reduced
production capacity, chemical scaling from calcium
phosphate precipitation, problems with silica in the
treatment filters, and fouling of the water
treatment system. These issues created significant
operational challenges and resulted in high O&M
costs for SWS, especially related to treatment of
effluent for boiler feed water which requires high
quality water. In the end, the high costs associated
with the initial purchase of the water,
transportation, operational challenges, and
treatment led to SWS seeking alternative water
sources.
LESSONS LEARNED
Effective use of reclaimed water requires adequate
planning.
The fast-tracked schedule to construct SWS and
identify a viable water source and the lack of
industry experience with reusing wastewater
streams led to challenges that resulted in switching
water sources. Additional feasibility studies prior to
construction might have identified the technical
issues involved with using the Malt Plant and
Jamestown POTW sources. Power plants that want
to use an alternative source should learn from
industry experience (as laid out by this EPRI project)
and carefully consider potential issues with the
source (quality, consistency, contractual relations,
etc.).
The quality and variability of the alternative water
source is a major variable in determining whether
it is usable.
13553240
< B-38 >
<2.9 MGD
COOLING
INDUSTRIAL/
TOWERS
MUNICPAL EFFLUENT
Both opportunities to use alternative water supplies
at SWS failed because of water quality and
reliability issues. The alternative sources required
high levels of treatment and created operational
concerns.
REFERENCES
Advanced Engineering and Environmental Services,
Inc. (AE2S). 2007. Draft Spiritwood Industrial Park
Water Source Investigation. December 2007. For
Spiritwood Industrial Park Partners. P00554-2007-
03.
CH2M HILL. 2013. Great River Energy- Spiritwood
Station Technical Memorandum. April, 9, 2013.
GRE. 2015. Plant efficiencies spark Spiritwood
Station energy park concept. October 15, 2015.
URL: http://greatriverenergy.com/plant-
efficiencies-spark-spiritwood-station-energy-park-
concept/ [Accessed 10/13/2016].
GRE. 2015. Spiritwood Station. October 16, 2015.
URL: http://greatriverenergy.com/wp-
content/uploads/2016/03/FINAL-spiritwood-fact-
sheet-101615.pdf [Accessed 10/13/2016].
Larson, Aaron. 2015. Top Plants: Spiritwood Station,
Spiritwood, North Dakota. Power. 10/1/2015.
URL: http://www.powermag.com/spiritwood-
station-spiritwood-north-dakota/?printmode=0
[Accessed 10/13/2016].
Lydersen, Kari. 2014. Prospects turning around for
embattled Spiritwood coal plant. Midwest Energy
News. 5/13/2014.
URL: http://midwestenergynews.com/2014/05/13/
prospects-turning-around-for-embattled-
spiritwood-coal-plant/ [Accessed 10/13/2016].
Personal communication, GRE staff, 2016. Erik
Heinen and Mark Strohfus.
 <2.9 MGD
SPIRITWOOD NORTH 99 MW COAL COOLING
B9 INDUSTRIAL/
STATION DAKOTA CHP TOWERS
MUNICPAL EFFLUENT

SRWD, GRE, and City of Jamestown, ND. 2009.

Spiritwood Station Water Supply and Discharge
Agreement. 5/13/2009.

VERIFICATION
Information presented in this case study was
provided through interviews with Great River
Energy staff in August and October 2016, who have
reviewed this case study for accuracy.

13553240

< B-39 >

 SAN JUAN COOLING PRODUCED WATER
B10 NEW MEXICO 1,848 MW COAL
GENERATING STATION TOWERS (INVESTIGATED)

implements efficient water

use and reuse practices,
and is a zero liquid
discharge facility.

SJGS currently operates

four units; however, two
of the units will be shut
down in December 2017
due to a federally-
mandated decision in
2015.

DRIVERS
The primary driver for
consideration of produced
water as an alternate
source is water scarcity,
OVERVIEW drought and the potential effects of climate change.
Tree ring studies suggest that alternating wet and
San Juan Generating Station (SJGS) is a 1,848 MW
dry periods in this region occur on an approximately
coal-fired power plant owned and operated by
60 to 80 year cycle. A recent wet period coincided
Public Service of New Mexico (PNM). It is located
with economic development in the region such as
about 15 miles northwest of Farmington, New
expansion of agriculture, oil and gas production,
Mexico, population ~45,000. The climate of
and construction and operation of two large coal-
Farmington is very dry with an average yearly
fired power plants. Produced water was one of the
precipitation (rainfall) of 8.59 inches and average
alternative sources evaluated for its potential to
annual snowfall of 12 inches. In summer the
serve as a supplemental back-up source to SJGS’s
average high temperature is 90 degrees F.
current fresh water supply during droughts.
In 2006, PNM participated in a detailed study with
Although insufficient supply is a relatively small risk
EPRI to investigate the potential use of water
to SJGS, it has the potential to have significant cost
produced with oil and gas production as a
implications. A reduction in water supply at SJGS
supplemental supply at SJGS (EPRI, 2006). Due to
would result in a direct reduction in annual power
several challenges identified through this study, the
generation. Also, SJGS has a ‘take-or-pay’ coal
approach was not implemented.

BACKGROUND Driver Benefit Challenge

Quantity
SJGS provides approximately 1/3 of the power
Quality
generated for New Mexico. The facility withdraws
approximately 22,400 acre-feet of water per year Reputation
(20 MGD) from the San Juan River. Most of the Regulatory
water is used for cooling tower make-up. SJGS Cost
13553240

< B-40 >

 SAN JUAN
B10 NEW MEXICO
GENERATING STATION
contract; therefore, if the plant must reduce load
due to reduced water supply, the unused fuel must
still be purchased. Fuel is the largest expense for
SJGS, and PNM estimated that a one-year 30%
shortage in regional water supply could be very
costly in terms of fuel contract penalties and lost
generation.
IMPLEMENTATION
Although produced water was ultimately not used
at SJGS, the assessment of its use is informative.
This assessment examined the volume and quality
of available produced water, the infrastructure
needed to transport and treat the water, the costs
associated with use of the water, and regulatory
requirements for produced water reuse.
Sources and Volume
The SJGS is located near western boundary of the
Fruitland Petroleum System, which is a geologic
system within the San Juan Basin that generates
produced water. Produced water is generated
through both conventional/continuous oil and gas
extraction and coal bed methane (CBM) production.
Conventional and continuous wells are deep (3,500
– 8,000 feet), whereas CBM wells are shallower
(1,000 – 3,000 feet).
At the time of the study, approximately 19,090
active oil and gas wells were generating
approximately 68,500 barrels per day (BPD) of
produced water across a 3,200 mi2 land area of the
San Juan Basin. Three areas with high-volume
produced water generation were identified: “Close-
In” in the Kirkland area, “Tri-City” in the Aztec-
Bloomfield-Farmington area, and “Fairway”, located
at the New Mexico-Colorado border.
This assessment estimated the supply of produced
water was sufficient to meet ~8 to 10 percent of
SJGS’s water needs and could prevent SJGS from
reaching the take-or-pay coal contract threshold
during a time of water scarcity.
13553240
< B-41 >
COOLING PRODUCED WATER
1,848 MW COAL
TOWERS (INVESTIGATED)
Transportation and Treatment
The assessment identified transportation as the
largest obstacle to produced water reuse in the San
Juan Basin. Most of the produced water is stored in
tanks at oil and gas well head locations before being
transported by truck to a salt water disposal facility
for subsurface injection. Transportation of
produced water from the well heads to SJGS would
require modification of existing infrastructure or
construction of new infrastructure.
The proposed implementation plan was multi-
phased and complex, and described transportation,
treatment, and regulatory issues that would need to
be considered for produced water reuse at SJGS.
The plan assumed that producers would provide
infrastructure to gather and deliver the water and in
doing so would benefit by minimizing their disposal
costs. Phase 1 of the plan was to build an 11 mile
pipeline to collect water from Close-In producers.
Phase 2 would extend the pipeline an additional
17.5 miles to Bloomfield, within the Tri-City area.
Two existing, but abandoned, natural gas pipelines
were identified as potentially useful for gathering
produced water from the Tri-City and Fairway areas.
Compared to San Juan River water, produced water
has very high levels of TDS, chloride, and boron, and
moderate levels of silica. A 30-day sampling
program in the study area found TDS
concentrations ranging from 6,400 mg/L to 22,600
mg/L, with lower TDS water coming from CBM
production and higher TDS water coming from
conventional gas production. The 2006 EPRI study
evaluated a range of potential uses for produced
water within SJGS (cooling towers, absorbers, ash
system, brine concentrator) and showed that
produced water would require treatment to justify
its use in any reasonable quantity at SJGS. The use
of untreated produced water would not be practical
at SJGS because small amounts of high-TDS
produced water would generate excess wastewater
that could not be handled by the plant.
 SAN JUAN
B10 NEW MEXICO
GENERATING STATION
To address treatment needs, the study assumed
PNM would build a collection center in Bloomfield
to accept and pretreat water from the Tri-City and
Fairway areas. The collection center would remove
oil and grit using a three-step process (API
gravity/coalescing separation, dissolved air
flotation, and walnut shell filtration), equalize
chemistry via storage to reduce variations in
produced water salinity, and monitor water quality
prior to charging the conveyance pipeline. Produced
water collected from the Close-in Area would
originate from CBM production, which typically has
no measurable free oil content; therefore, only
simple filtration would be necessary to pretreat the
water before injection into the pipeline.
The study examined several off-the-shelf
technologies that could be implemented at SJGS to
economically lower chloride and TDS
concentrations in the produced water: reverse
osmosis (RO), evaporative processes, and
combinations of processes.
Cost
The 2006 study estimated a total cost of $43.1M to
reuse produced water. This included $37.9M of
capital costs incurred by PNM for the collection
center, pipeline, and treatment systems. The plan
proposed a cost sharing arrangement where the
remaining $5.2M would be paid by the oil and gas
producers.
Regulatory Requirements
In addition to transportation, treatment and cost,
regulations related to produced water disposal
were also evaluated. In New Mexico, produced
water is designated as a byproduct of oil and gas
production, is regulated by the Oil Conservation
Division (OCD), and is typically disposed of through
injection. Classifying produced water as a beneficial
reuse changes the regulatory framework. The water
would then be regulated by the Office of the State
Engineer (OSE) and subject to additional compliance
13553240
< B-42 >
COOLING PRODUCED WATER
1,848 MW COAL
TOWERS (INVESTIGATED)
requirements. The user would need to demonstrate
no hydrologic connection to other waters of the
state. This potential loss of regulatory and
environmental protection offered by the OCD is a
sometimes a disincentive to reusing produced
water. To avoid expected regulatory challenges,
PNM proposed and succeed at passing a 2004 bill to
allow for disposal of produced water at SJGS. The
law states that produced water could be used for
cooling tower makeup, scrubber makeup, and ash
wetting, and residual produced water would be
discharged to evaporation ponds.
Other Supplemental Water Sources
In addition to produced water, SJGS also considered
City of Farmington WWTP effluent as a possible
supplemental water source. The City was looking
for opportunities to give away effluent. An
engineering study was conducted and it was
concluded that the effluent would not be a viable
supplemental source for SJGS during droughts for
two reasons. First, an upgrade to the treatment
system would be needed. Secondly, the WWTP
wanted to deliver effluent all the time; however,
SJGS only wanted to use the water as a
supplemental source during drought. Therefore,
there were not additional efforts to implement the
use of City of Farmington WWTP effluent at SJGS.
Instead of using produced water or reclaimed
municipal effluent, the facility purchased additional,
unused water rights from the Navajo, Apache, and
Jicarilla tribes as a supplemental back up water
source. To date, SJGS has not needed to exercise
these additional water rights.
BENEFITS & CHALLENGES
Investigation of the potential use of produced water
at SJGS identified some benefits and challenges.
The use of produced water as a supplemental
supply would make SJGS more drought resistant
and could help the facility avoid costly fuel-delivery
 SAN JUAN COOLING PRODUCED WATER
B10 NEW MEXICO 1,848 MW COAL
GENERATING STATION TOWERS (INVESTIGATED)

penalties and power purchase costs during times of REFERENCES

water scarcity and generation curtailment. Another
external benefit identified would be the
conservation of San Juan River water for other
beneficial uses, particularly during times of drought.
Oil and gas producing companies would benefit
from a reduced volume of produced water that
would need to be handled and injected, creating
cost savings for those companies.
There were several challenges that presented
barriers to implementation. There was general
conclusion that the start-up, collection, transport
and operating costs were too high given the project
would only provide a small volume of water and
mitigate a relatively small risk (i.e., supplemental
backup water source).
EPRI, 2006. Program on Technology Innovation:
Water Resources for Thermoelectric Power
Generation: Produced Water Resources, Wet-
Surface Air Cooling, and WARMF Decision Support
Framework. EPRI, Palo Alto, CA and USDOE,
Morgantown, WV: 2006. 1014487.
DiFilippo, M. 2004. Use of Produced Water in
Recirculating Cooling Systems at Power Generating
Facilities: Deliverable Number 2, Infrastructure
Availability and Transportation Analysis, DOE Award
No. 41906, August 2004.
Personal communication, PNM staff, 2016. Mike
Greene.

Other significant challenges were related to

uncertainty regarding the reliability of the supply
and variability in the quality of the water over time,
which could result in additional costs to adapt
treatment processes.

LESSONS LEARNED
Supply and reputational water risk may not be
enough to justify cost for alternate source
implementation

Given the challenges and lack of strong economic or

stewardship drivers, there were no further efforts
to implement the use of produced water at SJGS.
The costs were very high, the source volume was
small and other options for supplemental supply
were available. There were no strong public or
reputational drivers to move forward with the
effort. Also to note, the planned shutdown of two
of the four SJGS units was not a deciding factor in
abandoning the concept of using produced water at
the power plant.

13553240

< B-43 >

 30 MW COAL COOLING 1.12 MGD
B11 WESTWOOD PENNSYLVANIA
REFUSE TOWERS MINE POOL WATER

for power generation at

Westwood. Culm from
nearby refuse piles is also
transported to Westwood
to ensure an adequate fuel
supply. Beneficial use of
the waste coal supports
the restoration of the site
to usable land, reduces
leaching of acid mine
drainage (AMD), and
decreases environmental
damage from these waste
coal piles.

Westwood utilizes state-of-

the-art circulating fluidized
bed (CFB) boiler technology
OVERVIEW to efficiently burn the culm.

During active coal mining, extensive pumping is

The Westwood Generating Station (Westwood) is a
conducted to lower the groundwater level and free
30 MW coal refuse power plant located in Tremont,
the mine of water. When a mine is closed,
Pennsylvania. Tremont receives on average 47
groundwater returns to the voids, creating the
inches of rainfall and 31 inches of snowfall annually.
alternate source of mine pool water. Mine pool
The average high temperature in July is 83°F.
water may represent water from a single mine or
Westwood was constructed at the site of an old multiple mines (e.g., mine complexes), often
coal mine and has utilized the on-site mine pool connected by fractures, shafts, and tunnels.
water from the Lykens mine (New Lincoln mine
pool) as the primary water source for the DRIVERS
recirculating cooling water system, boiler makeup,
Water availability was the primary driver for using
and fire protection. Water from the Westwood
mine pool water at Westwood. Nearby surface
mine pool is used as a backup source.
water sources (e.g., Lower Rausch Creek) do not
BACKGROUND have sufficient flow to provide cooling water. The
mine pool provides enough water and is in close
Westwood, which began operation in 1988, is
located in the anthracite coal mining region of Driver Benefit Challenge
Pennsylvania. The plant was sited at the location of Quantity
the closed Lykens and Westwood coal mines in Quality
order to assist in the reclamation process. Coal
Reputation
mining refuse (culm), which is available from
Regulatory
decades of mining at the site, provides a fuel source
Cost

13553240

< B-44 >

 30 MW COAL
B11 WESTWOOD PENNSYLVANIA
REFUSE
proximity to the coal refuse pile (less than 100 yards
from Westwood’s water treatment building).
IMPLEMENTATION
Westwood was initially designed and constructed to
utilize mine pool water as the primary cooling water
source. Therefore, no major design modifications or
changes were required to utilize mine pool water.
Additionally, since the mine pools are located on
plant property, there were no challenges with
installing infrastructure. The mine pool water is
used for the recirculating cooling water system,
boiler makeup, and fire protection. Westwood also
uses potable water obtained from Mountain Water
Authority of Joliet.
With multiple mine pool sources in the region, the
selection of which mine pool to utilize was based on
the water quality. The New Lincoln mine pool,
which is located on-site and was formed from the
Lykens mine, provides the primary water source for
cooling and plant processes. Westwood is
permitted to withdraw up to 1.12 MGD of water
from the New Lincoln mine pool. Mine pool water is
filtered and neutralized by adding chemicals to
reduce the acidity of the water. In addition, alkaline
CFB ash from Westwood’s processes is backfilled
into the culm pile to reduce acid mine drainage and
the pH of the mine pool water.
The Westwood mine pool is available as a backup
water supply. This water source has poorer quality
water as compared to the New Lincoln mine pool
and thus requires additional treatment prior to use.
It is only used if there are issues with the New
Lincoln mine pool and can be blended with water
from the New Lincoln mine pool.
In 2012, Westwood paid the Susquehanna River
Basin Commission, a regulating authority in charge
of water supply allocations within the basin,
$0.14/1,000 gallons of mine pool water used. This
13553240
< B-45 >
COOLING 1.12 MGD
TOWERS MINE POOL WATER
cost is lower than the estimated cost for a municipal
water source. Treatment of the water costs
approximately $75,000-100,000 per year for the
chemicals alone (Veil et al. 2003). Additional costs
include O&M of the treatment system, but specific
values are unknown at this time.
BENEFITS & CHALLENGES
Westwood’s use of mine pool water presents
several benefits. The use of mine pool water
provides a reliable source to Westwood and
protects the quality of the water in the watershed.
It offers good quality water at a low cost. Proximity
of the fuel source and water supply were significant
factors in siting the facility, and it is believed that
water purchases from a municipal supply would not
have been economical. Externally, the use of mine
pool water benefits surface and groundwater in the
watershed by reducing the quantity of acidic mine
pool water that could potentially contaminate
nearby freshwater sources. The plant also
contributes to the reclamation and restoration of
the land previously used for coal mining through
the consumption of waste coal and collected mine
pool water.
One challenge with using mine pool water at
Westwood is supply variability and the risk of an
inadequate quantity of water during dry periods.
When the rate of recharge of the New Lincoln mine
pool is slower during dry periods, the Westwood
mine pool is used as a backup source and a higher
level of water treatment is required due to the
poorer quality. However, use of this secondary
source is uncommon (e.g., in 2010 the Westwood
mine pool provided only 1% needed by the power
plant).
 30 MW COAL COOLING 1.12 MGD
B11 WESTWOOD PENNSYLVANIA
REFUSE TOWERS MINE POOL WATER

LESSONS LEARNED Cooling Systems of Coal-Based Thermoelectric

Power Plants. Final Technical Report to US
Water quality is a key consideration when using DOE/NETL, project DE-FC26-06NT42722, 2009.
mine pool water.
VERIFICATION
Water quality of mine pools can vary greatly, even
between two mine pools located in close proximity Information presented in this case study was
to each other. These varying qualities can alter provided through interviews with Integrys staff in
water treatment needs, and the associated costs, March 2017, who have reviewed this case study for
significantly. For example, treatment costs of mine accuracy. Westwood was owned by subsidiaries of
pool water at Westwood ($75,000-100,000 per year Integrys Energy Group from September 2000
for chemicals) differ significantly from other through October 2012.
Pennsylvania plants that are known to utilize mine
pool water (Gilberton Power Company:
$40,000/year; Northeastern Power Company:
$15,000/year; Veil et al. 2003). Thus, the quality of
each source and the treatment required should be
fully understood prior to implementation in order
to prevent future issues.

REFERENCES
Olympus Power LLC. 2017. Portfolio: Westwood
Generating.
URL: http://www.olympuspower.com/gallery?plant
=38 [Accessed 4/11/2017].

Personal communication, Integrys staff, 2017. Mark

Metcalf.

Veil, J., J. Kupar, and M. Puder. 2003. Use of Mine

Pool Water for Power Plant Cooling. Prepared by
Argonne National Laboratory for the U.S.
Department of Energy, National Energy Technology
Laboratory, September, 62 pp.

Veil, J., and M. Puder. 2006. Update on Use of Mine

Pool Water for Power Generation. Prepared by
Argonne National Laboratory for the U.S.
Department of Energy, National Energy Technology
Laboratory, September, ANL/EVS/R-06/6. 26 pp.

Vidic, R. D. and D. A. Dzombak. 2009. Reuse of

Treated Internal or External Wastewaters in the

13553240

< B-46 >

 ~3 MGD
330 MW COOLING
B12 INDIANTOWN FLORIDA AGRICULTURAL RUNOFF / BRACKISH
COAL COGEN TOWERS
GROUNDWATER / MUNICIPAL EFFLUENT

Taylor Creek drains from

the heart of Florida into
Lake Okeechobee and is
highly degraded by
agricultural runoff from
dairy farms and cattle
ranches. The primary
pollutant of concern is
phosphorus.

Treated municipal effluent

from the City of
Indiantown was introduced
as a secondary water
source for the power plant
roughly 10 years after
construction. As a third
alternate source, brackish
OVERVIEW groundwater, is used during droughts when Taylor
Creek flows are too low for withdrawal. Indiantown
The Indiantown Cogeneration Power Plant is a zero liquid discharge (ZLD) facility.
(Indiantown) is a 330 MW coal cogeneration plant
located in Indiantown, FL (population ~6,000), near DRIVERS
Lake Okeechobee. Indiantown receives ~53 inches
of rainfall each year. Summers are warm, with The primary drivers for the use of Taylor Creek were
average highs around 90°F. water availability and quality. More traditional
sources were considered, but were not viable. The
Indiantown began operation in 1995, and currently St. Lucie Canal, a freshwater canal that runs 2 miles
has the option of using water from three different from the plant, was considered but not selected
alternative supplies. These water sources are: because the South Florida Water Management
Taylor Creek; treated municipal effluent from the District (SFWMD) preferred the use of Taylor Creek
City of Indiantown; and brackish groundwater which to help with phosphorus removal. It was also
is used during droughts. Taylor Creek is considered determined that there were no adequate fresh
an alternative source because of its high nutrient groundwater sources in the area.
concentrations due to agricultural runoff.
Driver Benefit Challenge
BACKGROUND Quantity
Indiantown was developed and constructed to sell Quality
steam to an adjacent orange juice processing Reputation
company. The Indiantown plant was sited with the
intention of using Taylor Creek as a water supply. Regulatory
Cost

13553240

< B-47 >


330 MW
B12 INDIANTOWN FLORIDA
COAL COGEN
Several external drivers also contributed to
Indiantown’s sustainable water practices that
involve the use of alternate supplies. The SFWMD
promotes the use of alternative water sources to
protect and develop water supplies in a sustainable
manner. Taylor Creek contributes 4% of the water
but 29% of the phosphorus going into Lake
Okeechobee, so it was believed that use of Taylor
Creek water would help reduce the amount of
phosphorus going to the lake (Carr et al. 1990). This
expedited efforts to obtain a consumptive use
permit from the SFWMD and resulted in greater
acceptance of plant siting from Martin County.
In response to expected population growth in the
area, the Indiantown Company (ICO) water reuse
facility approached the power plant about taking
excess tertiary-treated effluent for no charge
because they anticipated insufficient disposal
capacity at their sprayfields. Additionally, the State
of Florida requires facilities to evaluate potential
alternate water sources every ten years, thereby
driving the decision to consider additional sources
like municipal effluent after plant construction.
Reclaimed municipal effluent is now an alternative
water source for Indiantown.
IMPLEMENTATION
A 19-mile pipeline and pump station were
constructed to withdraw and transport water from
Taylor Creek to Indiantown. The permit allows
Indiantown to withdraw up to 5.32 MGD, but they
usually use approximately 3 MGD when running at
full capacity. Taylor Creek water is primarily used as
makeup water for the cooling towers, and the
cooling system typically operates at 4 to 7 cycles of
concentration.
Indiantown pays for the treatment (chlorination),
infrastructure, electrical costs of the pumping,
monitoring, and disposal of the Taylor Creek water.
13553240
< B-48 >
~3 MGD
COOLING
AGRICULTURAL RUNOFF / BRACKISH
TOWERS
GROUNDWATER / MUNICIPAL EFFLUENT
There is no direct cost for the water because it is
considered a beneficial reuse of a degraded source.
Over time, electrical rates have escalated, leading
to increased pumping costs. In response,
Indiantown has switched to “time of use billing”
(i.e., just running the pumps off peak), which has
saved ~$40,000/year. Costs are expected to remain
constant in the future.
Beginning in 2007-2008, Indiantown began mixing
tertiary-treated municipal effluent from ICO’s water
reuse facility with Taylor Creek water during normal
operations. This water does not require any
additional treatment at the power plant and is a
higher quality source for make-up water (e.g., lower
TDS) as compared to the Taylor Creek and saline
groundwater sources.
Up to 2 MGD of municipal effluent is provided free
of charge to Indiantown, with the option to
purchase more. Traditionally, Indiantown has used
10-20 million gallons per year of reclaimed
municipal effluent. The pipeline from ICO to
Indiantown was paid for by ICO using grant money.
Indiantown conducts quarterly maintenance and
inspections of the pipeline from Taylor Creek, which
runs parallel to the CSX railroad. This pipeline has
been fairly reliable, only experiencing one leak in 12
years.
Brackish/saline groundwater is used as a back-up
water source during drought conditions.
Indiantown’s withdrawal permit prohibits Taylor
Creek withdrawals during drought conditions when
the Creek level falls below 17.5’ NGVD. During these
times, brackish groundwater is mixed with the
treated municipal effluent. Indiantown has utilized
saline groundwater a few times since 1999. The
facility is limited to 4.92 MGD of brackish
groundwater during a 90 day period.
 ~3 MGD
330 MW COOLING
B12 INDIANTOWN FLORIDA AGRICULTURAL RUNOFF / BRACKISH
COAL COGEN TOWERS
GROUNDWATER / MUNICIPAL EFFLUENT

When any of the three sources are brought to reclaimed municipal effluent, and there have been
Indiantown, they are first stored in a 30 million no reported issues.
gallon pond on-site that mixes the sources. This
pond is designed to hold enough water for a 10 BENEFITS & CHALLENGES
days of generation at full load. The water is
Indiantown’s use of alternative water sources
replenished during times of low pumping/electrical
provides several benefits. First, the Indiantown
costs.
plant was successfully sited in a desired location
Another aspect of Indiantown’s sustainable water even though it lacked access to more traditional
use practice is disposal of cooling tower blowdown water sources. The plant’s use of water also allowed
water with several methods resulting in it being a them to market it as an “environmentally friendly”
ZLD facility. Originally, blowdown was processed plant and helped them overcome initial opposition
with Spray Drier Absorbers (SDAs) and brine to the idea of siting the plant in the area.
concentrators. This allowed the plant to operate
The alternative sources also provide cost and
without discharging wastewater. However, issues
stability benefits. Indiantown is able to receive free
with stainless steel contamination, corrosion, and
water from three different sources even though
high electricity costs led the plant to convert to
water in the area is typically highly valued and
using microfiltration membranes in 2011. The new
regulated. The treated municipal effluent provides a
Integrated Membrane System (MF/RO) successfully
stable source that is exempt from year-round
generates high quality permeate for boiler feed
conservation measures and emergency water
from multiple sources of differing quality and has
shortage restrictions.
kept Indiantown a ZLD facility. A biocide was used
to treat biological fouling issues that were first Indiantown’s use of water from Taylor Creek
encountered. This system achieved a return on reduces the nutrient loadings entering Lake
initial investment within three years and saves Okeechobee, improving water quality. During the
Indiantown $1.2 million/year. In addition to the relicensing process, Indiantown was able to take
MF/RO system, wastewater is reused through the credit for phosphorus removal services rendered to
lime slaking process for SO 2 removal. SFWMD by self-certifying to the Federal Energy
Regulatory Commission (FERC) as a Qualifying
Staff at Indiantown received additional training to
Facility. Although it is not widely publicized,
address any health concerns regarding the use of
removal of phosphorus loading presents an
Table 1. Characteristics of typical feed water at Indiantown (Drake et
al. 2015). opportunity to showcase sustainable water use
Brackish Municipal Taylor practices at the plant and in the community.
Parameter Units
Groundwater Effluent Creek
Turbidity NTU 3-10 - 3-30
Conductivity µS/cm 6200 960 590
Indiantown has not experienced any major
Iron mg/L 0.13 0.05 0.56 challenges related to the use of alternative water
Total Organic
Carbon
mg/L - - 31 sources, likely because the plant was designed for
Ca Hardness mg/L 440 260 98 such use. However, there have been some
Mg Hardness mg/L 540 14 48
Sodium mg/L 850 76 55 challenges related to poor water quality of the
Aluminum mg/L <0.1 - 21 alternative sources and the high cost to treat the
Barium mg/L 0.4 2.0 0.03
Silica mg/L 15 21 9.7 water (Table 1). First, Taylor Creek has high levels of
Sulfates mg/L 300 31 58
Chlorides mg/L 2000 97 110

13553240

< B-49 >


330 MW
B12 INDIANTOWN FLORIDA
COAL COGEN
silt and nutrients from agricultural runoff, which
contributed to corrosion and cost issues with
blowdown water disposal. These problems were
solved with installation of the MF/RO system in
2011. A second challenge has been the periodic
occurrence of algal blooms in the on-site storage
pond. These unexpected blooms increased in
frequency in 2007; however, they have been
controllable and have not affected plant operations.
Finally, high TDS levels in the brackish groundwater
complicates blowdown processing during the rare
instances that this source is used.
LESSONS LEARNED
Multiple alternative water sources can facilitate
plant siting and provide reliable flow during
periods of water scarcity
Indiantown’s successful siting and reliable operation
relates to effective use of degraded surface water
from Taylor creek as well as their backup municipal
effluent and brackish groundwater sources.
Without these multiple supplies, the facility may
have experienced water supply issues during
droughts due to restrictions on Taylor Creek
withdrawals. Always having a reliable water source
is important because of the major economic
penalties that can occur when a utility is unable to
supply the power they promised due to shutdowns
from lack of water supply.
Algae control methods may be required if using a
supply high in nutrients.
One challenge the plant faced was algae blooms in
the storage pond, which required Indiantown to act
quickly to control them. It is uncertain whether the
addition of reclaimed municipal effluent is what
caused the blooms or if this was just coincidental.
Nonetheless, this situation has a greater potential
to occur when using sources that are high in
13553240
< B-50 >
~3 MGD
COOLING
AGRICULTURAL RUNOFF / BRACKISH
TOWERS
GROUNDWATER / MUNICIPAL EFFLUENT
nutrients, like agricultural runoff or municipal
effluent.
REFERENCES
Carr, J. E., E. B. Chase, R. W. Paulson, and D. W.
Moody. 1990. National Water Summary 1987:
Hydrologic Events and Water Supply and Use. U.S.
Geological Survey, Water Supply Paper 2350.
Drake, M., G. Willer, R. Venkatadri, S. Wise, and N.
Charan. 2015. Treatment of Cooling Tower
Blowdown Water with Membranes in a Zero Liquid
Discharge (ZLD) Power Plant. IWC 12-15. Pall
Corporation.
URL: https://www3.epa.gov/region1/npdes/merrim
ackstation/pdfs/ar/AR962.pdf [Accessed 3/10/17].
Indiantown Co. 2017. Reuse Water.
URL: http://indiantownco.com/Reuse-Water.html
[Accessed 3/10/17].
Patel, S. 2016. FPL to Buy and Phase Out Another
Florida Coal Power Plant. Power Magazine. 6/20/16.
URL: http://www.powermag.com/fpl-to-buy-and-
phase-out-another-florida-coal-power-
plant/?printmode=1 [Accessed 3/10/17].
Personal communication, Florida Power & Light
staff, 2017. Ron Hix and Meghan Pandya.
Personal communication, Indiantown Cogeneration
LP staff, 2017. Gary Willer, Chris Curry, and Nick
Laryea.
South Florida Water Management District. 2016.
Alternative Water Supply.
URL: https://www.sfwmd.gov/our-
work/alternative-water-supply [Accessed 3/10/17].
 ~3 MGD
330 MW COOLING
B12 INDIANTOWN FLORIDA AGRICULTURAL RUNOFF / BRACKISH
COAL COGEN TOWERS
GROUNDWATER / MUNICIPAL EFFLUENT

U.S. EPA. 2008. Final Total Maximum Daily Load

(TMDL) for Biochemical Oxygen Demand, Dissolved
Oxygen, and Nutrients in the Lake Okeechobee
Tributaries. Atlanta, GA: EPA Region 4.
URL: https://archive.epa.gov/pesticides/region4/wa
ter/tmdl/web/pdf/lake_o_tribs_nutrient_tmdl_final
_v03.pdf [Accessed 3/10/17].

VERIFICATION
Information presented in this case study was
provided through interviews with FPL and
Indiantown staff in February 2017, who have
reviewed this case study for accuracy.

13553240

< B-51 >

 3,687 MW NATURAL COOLING TOWERS
B13 W.A. PARISH TEXAS STORMWATER
GAS & COAL AND COOLING LAKE

Basin coal. Units 1-4, which

were constructed in the
1950s, are natural gas-fueled
and utilize Smithers Lake for
once-through cooling.

Smithers Lake is a man-made

lake that was initially
constructed in the mid-1950s
on Dry Creek to provide
once-through cooling water
at Parish. It has a volume of
19,000 acre-feet at normal
pool level. Dry Creek is the
primary tributary providing
water to the lake. Beginning
in the 1950s, when Dry Creek
flows were insufficient to
OVERVIEW satisfy Parish’s cooling water demand, additional
water from the Brazos River was purchased from
W.A. Parish Electric Generating Station (Parish) is a the Richmond Irrigation Company. This water was
natural gas and coal-fired power plant located in delivered to Smithers Lake by the irrigation
Thompsons, Texas, about 27 miles southwest of company via its pump station and canal system
Houston. This area is characterized by hot, humid initially constructed during the early 1930s for rice
summers and mild winters with an average yearly irrigation.
precipitation of approximately 50 inches. In summer
the average high temperature is 93°F. When four additional coal-fired units (Units 5-8)
were constructed between 1978 and 1982, the
Parish uses a mix of surface water, stormwater Parish water supply was revisited. Smithers Lake
runoff, and treated wastewater effluent for cooling. had adequate cooling capacity to meet Units 5 & 6
The treated effluent includes waste streams from demand. However, due to limited cooling capacity
onsite sanitary, low volume waste, and auxiliary in the lake, Units 7 & 8 were constructed with
cooling systems. Water from Smithers Lake is used recirculating cooling towers with their make-up
for both once-through cooling and cooling tower water needs delivered via Smithers Lake.
make-up water at the plant. In addition, six deep
groundwater wells provide water for demineralizer Driver Benefit Challenge
make-up and potable service at Parish.
Quantity

BACKGROUND Quality
Reputation
Parish currently has a maximum capacity of 3,687
Regulatory
MW, with approximately one-third of that total
firing natural gas and two-thirds firing Power River Cost

13553240

< B-52 >

 3,687 MW NATURAL
B13 W.A. PARISH TEXAS
GAS & COAL
To support these additions to the plant generating
capacity, Parish purchased and upgraded the Brazos
River pump station, canal, and water right permit
owned by the irrigation company. Whereas Parish
previously purchased water from irrigators, now the
plant delivers water to irrigators as needed.
Currently, the irrigators use between 10,000 and
12,000 acre-feet/year.
WATER MANAGEMENT
The amount of water diverted from the Brazos River
varies annually with plant demand and river flow.
Up to 77,000 acre-feet/year of Brazos River water is
allocated to Parish under a state permit and a
stored water contract with the Brazos River
Authority. In recent history, as much as 59,000 acre-
feet per year have been used by the plant.
In addition to Brazos River water, Parish has
another water right permit that authorizes
impoundment of runoff from the Dry Creek Basin
(approximately 30 square miles) in the lake for use
at the power plant. During wet conditions, less
water is pumped from the Brazos River because Dry
Creek inflows help meet plant demand.
Parish primarily uses Smithers Lake for cooling while
a small volume of water is used for plant service
water. Three once-through cooling intakes pull
water directly from Smithers Lake and the heated
discharge is returned to the lake. Approximately 13
MGD of water is utilized by the cooling towers.
DRIVERS
To supplement freshwater supplies from the Brazos
River and Dry Creek basin, Parish has configured
operations to direct alternate water sources to
Smithers Lake. These sources include stormwater
runoff from the plant island and property
surrounding Smithers Lake as well as reclaimed
treated effluent from the plant. Specific drivers for
13553240
< B-53 >
COOLING TOWERS
STORMWATER
AND COOLING LAKE
implementing these alternate water supplies,
starting in the late 1950s, include engineering
efforts for improved efficiencies. However, more
recently, there has been a corporate focus on, and
state regulatory interest in, water reuse and
reduction.
IMPLEMENTATION
Stormwater runoff has been used at Parish as
supplemental flow into Smithers Lake since initial
plant operations in the 1950s.
There are two distinct stormwater alternate
supplies which encompass 600 acres in total.
Rainfall runoff from approximately 300 acres close
to the plant island is collected, treated for solids
removal (i.e., clarified), and routed directly to the
Units 7 & 8 cooling towers as make-up. Additional
runoff accumulates from approximately 300 acres
of plant property surrounding Smithers Lake and is
directed into the lake.
Other alternate supplies are first discharged to
Smithers Lake and combined with Brazos River and
Dry Creek water before use. Most of the TPDES
permitted wastewaters from the plant are
discharged into Smithers Lake to provide a limited
supplemental supply. These include cooling tower
blowdown and treated waste streams such as plant
floor drains, sanitary wastewater, and boiler
blowdown which pass through on-site waste
treatment systems before discharge to the lake.
Smithers Lake is considered a “Water of the U.S.”;
therefore, treated effluent entering Smithers Lake
through 15 licensed outfalls is regulated and
requires routine monitoring. In addition to the
TPDES outfalls, there are 38 stormwater outfalls
outside the immediate area of plant operations that
are identified and monitored in accordance with the
Multi-Sector General Stormwater Permit.
 3,687 MW NATURAL
B13 W.A. PARISH TEXAS
GAS & COAL
BENEFITS & CHALLENGES
Benefits of Parish’s use of stormwater runoff and
other alternative water sources include cost
savings, reduced demand for freshwater, improved
quality of water used at the plant, and additional
supply available for upstream and downstream
users. Alternative sources are used in Smithers Lake
at no cost. These sources reduce the quantity of
water needed from the Brazos River, thereby
reducing electricity costs for pumping and the
plant’s use of freshwater from the river.
Stormwater usually provides superior water quality
compared to the Brazos River, specifically related to
TDS. This higher quality water helps the facility
meet targets for cycles of concentration in cooling
towers and provides savings in treatment costs.
Finally, the use of alternative water results in more
water retained in the Brazos River. This reduces
demand for upstream lake releases and supports
instream flows for recreation, municipal use,
environmental needs, and other water users both
upstream and downstream of the Parish diversion
point.
Challenges with Parish’s overall water use
management relate to the complexity of the overall
system of permits, contracts, stormwater collection
systems, treatment facilities, and flood mitigation
goals. Smithers Lake is maintained at near-constant
levels to optimize cooling through maximum water
surface areas. The target operating level does not
allow for the collection of large volumes of
stormwater that are generated during heavy rainfall
events. In addition, delivery time for contract water
from upstream Brazos River reservoirs and travel
time in the 10 mile long canal is significant. It can
take from several days up to two weeks for an
upstream reservoir release to ultimate arrive at
Smithers Lake. Therefore, the daily challenge of
balancing the competing goals of capturing
stormwater runoff, reclaiming wastewater effluent,
13553240
< B-54 >
COOLING TOWERS
STORMWATER
AND COOLING LAKE
managing water diversion and delivery, meeting
regulatory requirements, and dealing with large
local rainfall events is not insignificant.
LESSONS LEARNED
Alternative water supplies have allowed the plant
to adapt to demand and industry changes over
time.
Parish has operated and evolved for over 50 years,
while reacting to changes in demand and industry
practices. A complex mix of alternative water
supplies has allowed the plant to effectively adapt
to changing needs in a way that efficiently uses
water. Although alternative sources only provide a
small percentage of Parish’s overall water needs,
the amount of water reused is significant when
considering the benefits to other water users such
as municipalities, agriculture, and the ecosystem.
REFERENCES
Butler, Brett. 2004. W.A. Parish Electric Generation
Station, Thompson, Texas. Power Magazine, August,
15, 2004. S&P Global Platts.
URL: https://online.platts.com/PPS/P=m&s=102933
7384756.1478827&e=1092414376630.6340566021
74080316/?artnum=200vh40u811t1F30702VSa_1
[Accessed 4/25/2017].
Personal communication, NRG staff, 2017. Carl
Burch, Gene Fisseler, and Laura Scott.
VERIFICATION
Information presented in this case study was
provided through interviews with NRG staff in
March 2017, who have reviewed this case study for
accuracy.
 ORMOND BEACH 1,516 MW ONCE- STORMWATER
B14 CALIFORNIA
GENERATING STATION NATURAL GAS THROUGH 37 ACRES

Prior to 2015, Ormond

purchased municipal
potable water from the City
of Oxnard for 100% of other
plant water needs. This
water was routed to a
service water tank, polished
with a reverse osmosis (RO)
unit, and then utilized at the
facility. The original plant
design for stormwater
collected on the property
was to route it to natural
drainage channels and
eventually the ocean.

DRIVERS

OVERVIEW The use of stormwater at Ormond as an alternative

The Ormond Beach Generating Station (Ormond) is
a 1,516 MW natural gas steam power plant located
in Oxnard, California, located between Santa
Barbara and Los Angeles. This area is characterized
by mild, wet winters and warm, dry summers with
an average yearly precipitation of approximately 16
inches. The average high temperature throughout
the year is 70°F.
Ormond, which utilizes the Pacific Ocean for once-
through cooling, recently began using stormwater
runoff collected on-site to augment plant
demineralized water and service water demand.
BACKGROUND
plant water supply was driven by water quality,
reputational, and regulatory factors. Ormond also
investigated options to minimize offsite discharges
in conjunction with an update to the facility’s
general industrial stormwater permit in 2015.
IMPLEMENTATION
In 2015, Ormond implemented the use of onsite
stormwater for a portion of the needed
demineralized (steam makeup water) and service
water (pump seal water). With this practice,
Ormond eliminated offsite discharges of
stormwater during normal weather conditions.
Water from the Pacific Ocean is used for once-
through cooling at the plant.

Since 1959, Ormond has operated two natural gas-

fired steam electric units which utilize once-through Driver Benefit Challenge
cooling with water drawn through a single cooling Quantity
water intake structure 1,950 feet offshore in the Quality
Pacific Ocean. This system is designed to pump up
Reputation
to 678.2 MGD of water, yet typically withdraws less
(~241 MGD in 2006) due to the currently low Regulatory
generating capacity. Cost

13553240

< B-55 >

 ORMOND BEACH 1,516 MW ONCE- STORMWATER
B14 CALIFORNIA
GENERATING STATION NATURAL GAS THROUGH 37 ACRES

Stormwater is collected from a 37 acre industrial
area within the property and is routed to one of five
stormwater vaults. All stormwater from this
industrial area is captured and reused, resulting in
zero discharge of stormwater from Ormond except
during a significant storm event (e.g., 100-year
storm). Stormwater runoff from the undeveloped
portions of the property is not collected or
regulated by the stormwater permit and infiltrates
into adjacent natural areas.
Prior to implementation of stormwater use,
Ormond maintained a combination of stormwater
capture and stormwater treatment vaults. The
existing stormwater treatment vaults are utilized
for capturing stormwater and Ormond now has a
storage capacity of approximately one million
gallons.
Once in the vaults, stormwater is pumped to an on-
site stormwater treatment system that was
constructed in 2015. Solids that are captured from
the treatment system are tested and typically used
for sandbag material.
In addition to stormwater, Ormond continues to use
potable water from the City of Oxnard. After
treatment, stormwater is routed to a large service
water tank before being blended with the municipal
water. The combined water receives a final RO
polishing treatment to result in high quality water.
While the stormwater treatment unit was new, the
RO system was already in place prior to the
implementation of stormwater use at Ormond.
reducing risk and the cost of stormwater discharge
analysis.
Municipal water is available from Oxnard, and the
plant has not experienced any challenges with
acquiring adequate quantities of municipal water
during droughts or times of low rainfall. The use of
stormwater aligns with the California State Water
Conservation goal to reduce potable water use by
25%. Ormond contributed to the state water
conservation goal by using 465,000 gallons of
stormwater in 2016 for plant operation. Ormond
has flexibility to switch between using municipal
and treated stormwater due to their similar
qualities following treatment.
BENEFITS & CHALLENGES
Benefits of stormwater use include reduced
regulatory pressure and less dependency on
municipal water. Regulations in California are strict
regarding releases into the environment; therefore,
eliminating external stormwater discharge has
reduced regulatory risk for the plant. Ormond
maintains compliance and minimizes stakeholder
concerns with stormwater discharge. The
diversification of water sources for the plant has
also reduced Ormond’s dependence on municipal
potable water. No specific challenges were noted
related to Ormond’s stormwater use.

Ormond is required to sample any discharge of

water from the property. With the use of
stormwater at the plant, Ormond has not had to
discharge stormwater since the implementation of
stormwater collection in 2015. The plant internally
samples water leaving the stormwater treatment
system prior to blending with municipal water. The
number of stormwater samples has been reduced
due to no stormwater discharge, saving staff time,

13553240

< B-56 >

 ORMOND BEACH 1,516 MW ONCE- STORMWATER
B14 CALIFORNIA
GENERATING STATION NATURAL GAS THROUGH 37 ACRES

LESSONS LEARNED VERIFICATION

Stormwater use can reduce the environmental Information presented in this case study was
impact and reporting requirements of a plant. provided through interviews with NRG staff in April
and July 2017, who have reviewed this case study
By implementing stormwater capture and use,
for accuracy.
Ormond has successfully eliminated offsite
discharges. This has reduced both the regulatory
burden and environmental impacts of the plant.
Use of stormwater has proven to benefit the plant
related to liability, flexibility, and public perception
and increases the flexibility of stormwater
management.

REFERENCES
GenOn Energy, Inc. 2013. SEC Filings. Form 10-Q.
5/7/2013. URL: http://investors.nrg.com/phoenix.z
html?c=121544&p=irol-SECText&TEXT=aHR0cDov
L2FwaS50ZW5rd2l6YXJkLmNvbS9maWxpbmcueG1
sP2lwYWdlPTg5MDc2OTImRFNFUT0xJlNFUT0zNiZT
UURFU0M9U0VDVElPTl9QQUdFJmV4cD0mc3Vic2lk
PTU3 [Accessed 6/7/2017].

NRG Energy, Inc. 2015. Ormond Beach Fact Sheet.

URL: http://maps.nrg.com/media/attachments/
PLA.2015_Ormond_Beach_v5HR.pdf [Accessed
4/25/2017].

Personal communication, NRG staff, 2017. Scott

Warnock & Laura Scott.

Tetra Tech. 2008. K. Ormond Beach Generating

Station. In California’s Coastal Power Plants:
Alternative Cooling System Analysis. California
Ocean Protection Council, Oakland, CA.
URL: http://www.opc.ca.gov/webmaster/ftp/projec
t_pages/OTC/engineering%20study/CA_Power_Pla
nt_Analysis_Complete.pdf [Accessed 6/7/2017].

Wishtoyo Chumash Foundation. 2015. Clean Water

Act Enforcement: Sewage Spills and Waste Water
Treatment Plant Discharges. URL: http://www.wish
toyo.org/clean-water-act-enforcement/ [Accessed
6/5/2017].

13553240

< B-57 >

 COAL CREEK 1,100 MW COOLING
B15 NORTH DAKOTA STORMWATER
STATION COAL TOWERS

water. The cooling towers

and FGD treatment system
use about 90% of the volume
withdrawn. Coal Creek
Station is a zero liquid
discharge (ZLD) facility,
routing all wastewater to
evaporation ponds. Most of
the cooling tower blowdown
water is reused within the
ash system. The facility has
three permitted stormwater
outfalls that discharge to a
regional drain system, which
drains to the Missouri River.

Waste heat generated by

Coal Creek Station is used at
OVERVIEW the adjacent Blue Flint Ethanol Plant.

Coal Creek Station is a 1,100 MW coal-fired power DRIVERS

plant owned and operated by Great River Energy
(GRE). It is located about 50 miles north of
Bismarck, North Dakota. The climate of Bismarck is
dry with an average yearly precipitation of 16.8
inches. In summer the average high temperature is
84.5 degrees F.
In 2012, GRE and EPRI investigated the feasibility of
indirectly using stormwater at Coal Creek Station
(EPRI, 2012). The proposed approach was to
withdraw water via a new intake from a nearby
slough that receives stormwater from the site.
However, due to lack of drivers for implementation,
no further action was taken and the facility
continues to use a freshwater source.
BACKGROUND
Coal Creek Station withdraws 8,903 gpm (12.8
MGD) from the Upper Missouri River for use as
boiler feed water, service water, cooling tower
make up water, and flue gas desulfurizer (FGD)
13553240
The driver to consider stormwater use at Coal Creek
Station originated from research interest rather
than operational challenges. GRE agreed to
participate in a pilot case study to evaluate the
feasibility of using stormwater at their site, as a
follow-on study to a 2010 EPRI investigation.
Water quantity was a minor, potential driver for
participating in the study. The USACE controls
releases of deep, cool water from Lake Sakakawea
upstream of Coal Creek Station. However, GRE has
been concerned that that USACE might change their
release depth and timing to benefit threatened
and/or endangered species, potentially affecting
the quantity and temperature of water available to
Driver Benefit Challenge
Quantity
Quality
Reputation
Regulatory
Cost

< B-58 >

 COAL CREEK
B15 NORTH DAKOTA
STATION
Coal Creek Station. Another potential water
quantity driver related to occasional excess volume
in the onsite process water ponds at Coal Creek
Station in the past. At the time, stormwater reuse
was considered an opportunity to reduce excess
water onsite; however, the facility has since
installed injection wells to handle any excess
process water.
IMPLEMENTATION
Stormwater volume, quality, collection
opportunities and uses were investigated as part of
the feasibility study. Stormwater discharge volumes
were estimated using the Rational Method and the
NRCS Curve Number method for the entire plant
site (maximum available), the “plant proper”
portion of the site (most practical to collect) for a
period from 2001 to 2008.
For the entire site (about 3,500 acres), predicted
runoff ranged from 750 gpm to 1890 gpm, which is
approximately 20% of the current plant withdrawal
from the Missouri River. This area, however, was
determined too large for practical collection of
stormwater.
For the smaller “plant proper” site (approximately
640 acres), predicted runoff ranged from 21 to 742
gpm with an average of 212 gpm, equaling
approximately 2.4% of the current freshwater
withdrawal for the plant. The greatest volume of
runoff is expected in the summer.
The closest offsite urban stormwater source is
Underwood, ND. This community is located 5.5
miles from the plant, has a population of 778 (2010
Census), and covers a land area of 576 acres. It was
estimated that stormwater from Underwood would
only provide approximately 210 gpm to 420 gpm.
For this source of stormwater to be feasible, there
would need to be a stormwater collection system
that could be reasonably intercepted at one or two
13553240
< B-59 >
1,100 MW COOLING
STORMWATER
COAL TOWERS
discharge points. The cost of a pipeline to transport
this small amount of water was not justified;
therefore, the investigation of stormwater use
focused only on water collected at the immediate
plant site (plant proper).
Stormwater outfall quality data (general
constituents and metals) collected from 1994
through 2004 were assessed to identify potential
water quality issues. Chromium, cobalt and mercury
were not detected. The TDS concentration of
stormwater was estimated to be less than Missouri
River water (e.g., 80 mg/L vs. 443 mg/L), which
might provide a very small enhancement to the
performance of cooling towers.
Specific opportunities to collect stormwater on site
at Coal Creek Station include: coal pile runoff, FGD
system, the ash system, and the power block (area
incorporating the generating units). It was
recommended that stormwater runoff from the
coal pile not be used because of expected low pH,
high metals concentrations and sporadic volumes
due to the retention and later release of water after
rain events.
Potential uses of stormwater at the plant include
cooling tower makeup, FGD system and the ash
system. Because the FGD system uses cooling tower
blowdown, stormwater would automatically be fed
into the FGD system.
The study found that it would not be desirable to
use stormwater for road wetting or service water
because of potential health hazards associated with
human contact and inadvertent environmental
problems resulting from spraying stormwater on
large areas.
A decision tree approach was used to determine if
the available stormwater would be useable,
economically feasible to treat and present any
issues related to waste disposal. The analysis
determined that stormwater would not require
 COAL CREEK
B15 NORTH DAKOTA
STATION
treatment for use as cooling tower makeup water.
There would not be any metals issues because of
the significant dilution of stormwater with the
freshwater source (Missouri River). Required
treatment would include a clarification step.
Because Coal Creek is a ZLD facility, there would be
no waste disposal issues.
The 2012 EPRI study proposed an approach that
would pump water from the Lower Samuelson
Slough, where the facility currently discharges via
three stormwater outfalls. The volume pumped
would equal the volume of stormwater discharged.
This water would be passed through a clarification
system and transported to the Extended Basin to be
available for both the cooling towers and the ash
system. In 2012, the estimated costs for stormwater
conveyance and treatment system from Lower
Samuelson Slough to the Extended Basin were $5.5
million. Annual costs would include $4,000 for
chemicals (sodium hypochlorite and clarification
polymer) and $6,000 for power (pumping).
Note, the proposed approach is an indirect (rather
than direct) use of stormwater. The water used
would be withdrawn from a different water source.
It would require construction and permitting of a
new intake because the intake would be located in
a “Water of the U.S”.
A direct use of stormwater would involve
intercepting the three outfalls, construction of a
stormwater basin, and conveyance of stormwater
to the Extended Basin. However, this alternative
was not examined as part of the 2012 EPRI study.
BENEFITS & CHALLENGES
Investigation of potential stormwater use at Coal
Creek Station identified no benefits and several
potential challenges.
A direct reuse of stormwater collected onsite might
have eliminated the need for a stormwater
13553240
< B-60 >
1,100 MW COOLING
STORMWATER
COAL TOWERS
discharge permit. However, because the plan
proposed to discharge stormwater to the Lower
Samuelson Slough prior to withdrawal for use on-
site, a stormwater discharge permit would still be
required.
Implementing the proposed stormwater collection
and reuse system would require substantial capital
and annual costs and only provide approximately
2.4% of the water needs. In addition, it would
require constructing and permitting a new intake in
an existing water source. It is not clear this would
have any benefits over the existing source of
cooling water. Coal Creek’s current surface water
withdrawal permit meets their water needs and
withdrawal volumes are small compared to the
available water of the Missouri River. In the end,
there are no clear benefits to such a system that
would justify the costs.
LESSONS LEARNED
In some cases, the use of an alternate supply is not
justified.
Although the potential use of stormwater at Coal
Creek was considered, there were no further efforts
to implement this alternate source. There were no
strong operational or reputational drivers for
seeking an alternate source and no viable
alternatives to reusing stormwater were identified.
REFERENCES
EPRI, 2010. Evaluation of Stormwater as a Resource
for Power Plant Cooling, 1021124
EPRI, 2012. The Potential for Using Stormwater in
Power Plants: Lessons Learned form Case Studies at
Two Great River Energy Plants, 1023774
Personal communication, GRE staff, 2016. Erik
Heinen and Mark Strohfus.
 COAL CREEK 1,100 MW COOLING
B15 NORTH DAKOTA STORMWATER
STATION COAL TOWERS

VERIFICATION
Information presented in this case study was
provided through interviews with Great River
Energy staff in August and October 2016, who have
reviewed this case study for accuracy.

13553240

< B-61 >

 OKLAUNION 6.9 MGD
B16 TEXAS 692 MW COAL COOLING TOWERS
POWER PLANT BRACKISH

Water quality in both

Lake Kemp and Lake
Diversion improved as a
result, although TDS
remains high (~2,500-
3,000 mg/l).

Lake Diversion has a total

reservoir capacity of
35,324 acre-feet, and is
owned by the Wichita
County Water
Improvement District No.
2 and the City of Wichita
Falls. Under water right
permit No. 5123, Lake
Diversion is operated
together with Lake Kemp
as a system for
OVERVIEW municipal, industrial, mining, irrigation, flood
control and recreational purposes with a water right
Oklaunion Power Plant (Oklaunion) is a 692 MW
priority of October 2, 1920. Lake Diversion is the
coal plant located near Vernon, Texas (population
water supply for the City of Wichita Falls’ Reverse
~11,000). This zero discharge plant uses cooling
Osmosis Water Treatment plant and the local
towers and evaporation ponds, and began
irrigation district.
operation in 1986. On average, Vernon receives 28
inches of rain each year, and summer temperatures DRIVERS
average almost 100 degrees F.
The primary driver for using degraded water from
Oklaunion withdraws water from Lake Diversion, an
Lake Diversion was the need for a reliable water
impoundment with degraded water quality.
source. The main factor in siting the Oklaunion
Oklaunion has a contract for 20,000 acre-feet
plant at its current location was access to a main
annually, with the water used for cooling.
railroad line, along with the availability of a senior
water right. Dry cooling was initially investigated for
BACKGROUND
Both Lake Diversion and Lake Kemp are Driver Benefit Challenge
impoundments of the Wichita River, built in the Quantity
1920s. Both lakes have high total dissolved solids Quality
(TDS) due to naturally-occurring salt seeps. In the
Reputation
mid-1970s, the Army Corps of Engineers installed a
system upstream of Lake Kemp to divert the salt Regulatory
seeps into an artificial brine lake to reduce TDS. Cost

13553240

< B-62 >

 OKLAUNION
B16 TEXAS 692 MW COAL
POWER PLANT
the plant, but was not economical. The Red River
was also investigated as a freshwater source, but
was deemed not viable for multiple reasons,
including that it would have been a junior water
right (subject to the 1978 Red River Compact
between Texas, Oklahoma, Arkansas, and Louisiana)
that might be unavailable during times of droughts
and low flows. The configuration of the Red River
floodplain near Oklaunion (75 ft. bluff drop off to
the river) would have made construction
challenging, and the reliability of the flow may have
been affected because the Red River is braided and
susceptible to changing its course during floods.
IMPLEMENTATION
Water is piped approximately 23 miles from Lake
Diversion to Oklaunion. Because the influent has
high TDS, the Oklaunion condenser was constructed
with high nickel stainless steel, which is less
susceptible to corrosion from chlorides. The
contract allows Oklaunion to pump 20,000 acre-feet
annually (~17.9 MGD), but the facility typically
pumps approximately 6.9 MGD. The plant has a
1,172 acre-foot make-up water pond on-site that
has about a 60 day design capacity at full load.
Water from the make-up pond is used directly in
the cooling tower system. The cooling tower
normally carries 5 to 6 cycles of concentration,
cycling up to 25,000-30,000 mg/l TDS, before
discharging to evaporation ponds. Water is also
treated at Oklaunion to be used within the facility
as boiler make-up and other process water.
There is zero liquid discharge from Oklaunion,
which uses a series of 11 evaporation ponds to
evaporate wastewater. Average gross evaporation
in the region is ~65 inches/year, but evaporation
can be even higher during drought years. For
example, the adjusted gross evaporation rate at the
13553240
< B-63 >
6.9 MGD
COOLING TOWERS
BRACKISH
Lake Kemp weather station was almost 97 inches in
2011.
BENEFITS & CHALLENGES
The primary benefit of using Lake Diversion for a
water source is the availability of a reliable supply
of water to the plant with a very senior water right.
While evaporation rates can be extremely high at
Lake Diversion, reservoirs do provide storage to
help mitigate droughts that rivers and other water
sources do not.
The degraded water from this source does not pose
a challenge during normal conditions because the
plant was designed to handle the high TDS.
However, during the 2011-2015 drought, the worst
on record, water quality and water quantity were
both challenges to the plant. During the drought,
TDS in Lake Diversion reached 10,000 mg/l. As a
result, Oklaunion could only operate their cooling
tower at 2 to 2.5 cycles of concentration. The
increased blowdown rate at the lower cycles of
concentration resulted in the evaporation ponds
filling to near capacity. This latter challenge was
addressed by construction of another evaporation
pond.
Water quantity also became a challenge during the
2011-2015 drought when water levels in the Lake
Kemp-Lake Diversion system dropped due to high
evaporation rates and water use by farmers. In
2011, there were 92 days with 100°F or greater
temperatures and no rain. A major portion of the
water district’s water right is for irrigation purposes,
so a large amount of water was used by farmers in
an attempt to save their crops. The power plant
faced the potential of not having access to water for
the duration of the drought. The water district was
forced to discontinue supplying irrigation water as
the drought continued, but enough inflow was
 OKLAUNION
B16 TEXAS 692 MW COAL
POWER PLANT
received to the system to maintain the water supply
to Oklaunion and the City of Wichita Falls.
Other water sources were investigated during the
2011-2015 drought, either to supplement the
current supplies or provide all of the power plant’s
needs, but all were dismissed. Treated effluent from
the City of Vernon, which is located 7.5 miles from
Oklaunion, was dismissed because of insufficient
quantity (20% of plant’s need), and because the use
of this water would necessitate additional, costly
infrastructure. Grey water from a manufacturing
plant was dismissed as a potential source due to
high organics, which would foul the cooling tower.
Shallow alluvial groundwater was dismissed as a
source due to reliability concerns and the potential
for adverse impacts on local irrigation wells and
subsequent negative public perception of the plant.
Several deeper test wells were drilled in closer
proximity to the plant, but no water bearing sands
were encountered down to 800 feet. Finally, the
surface water options of the Red River, Pease River,
or Lake Kickapoo were investigated, but these
options were dismissed due to high cost of capital
investment, potential variability in supply
throughout the year, and other uncertainties.
LESSONS LEARNED
Brackish surface water can be a reliable, cost-
effective, long-term water source, even when the
TDS approaches 10,000 mg/l.
Water users in this region of Texas continually
manage their water use through cycles of drought.
Oklaunion chose to use brackish water from Lake
Diversion due to the reliability of the supply. The
plant has been using brackish water for 30 years
without any significant challenges, except during a
record-breaking drought.
13553240
< B-64 >
6.9 MGD
COOLING TOWERS
BRACKISH
REFERENCES
Freese and Nichols, Inc. 2013. Oklaunion Power
Station Water Supply Options: Technical
Memorandum. April 17, 2013, Updated May 29,
2013. AEP13184.
Nexstar Broadcasting. 2017. Oklaunion Power Plant
Looking at Alternative Water
Sources. http://www.texomashomepage.com/news
/local-news/oklaunion-power-plant-looking-at-
alternative-water-sources/147822815 [Accessed
3/7/2017].
Personal communication, AEP staff, 2016. Tim
Lohner and Greg Carter.
Texas Water Development Board. Lake Diversion
(Red River Basin).
URL: http://www.twdb.texas.gov/surfacewater/rive
rs/reservoirs/diversion/ [Accessed 1/19/2017].
Texas Water Development Board. Precipiation &
Lake Evaporation.
URL: http://www.twdb.texas.gov/surfacewater/con
ditions/evaporation/index.asp [Accessed
1/19/2017].
VERIFICATION
Water use information presented in this case study
was provided through interviews with AEP staff in
September 2016, who have reviewed this case
study for accuracy.
 PIRKEY COOLING INTERBASIN
B17 TEXAS 721 MW COAL
POWER PLANT POND/RESERVOIR TRANSFER

impoundment of Brandy
Branch, a small intermittent
creek with a drainage area of
4.1 miles2 and an average flow
of less than 5 cfs. Due to
these characteristics, Brandy
Branch Reservoir was
originally not subject to Clean
Water Act §316(a)
regulations; however, the
reservoir depends on a steady
source of makeup water to
account for natural and forced
evaporation.

OVERVIEW
The Henry W. Pirkey Power Plant (Pirkey) is a 721
MW lignite-coal fired power plant located in
Harrison County, TX (population ~67,000) that is
owned and operated by Southwestern Electric
Power Company (SWEPCO), a subsidiary of AEP. On
average, Harrison receives ~51 inches of rain each
year. Summers are hot and humid with average
high temperatures in the 90’s (°F). Summer
temperatures above 100°F are not uncommon.
Pirkey is located in the Sabine River Basin but
currently pumps up to 13 MGD of surface water
from Lake O’ the Pines in the Cypress Creek Basin.
This interbasin transfer water is used as make-up
water for the Brandy Branch Reservoir, which acts
as a recirculating cooling pond for Pirkey.
DRIVERS
Water supply was the main driver for the interbasin
transfer at Pirkey. With very little natural inflow,
Brandy Branch Reservoir requires makeup water to
replace evaporated water.
Initially, the Sabine River Authority was contacted
to determine the availability of using water released
from upstream reservoirs along the Sabine River,
which is approximately two miles away. An
economic comparison of water from the Sabine and
Cypress basins was then conducted by SWEPCO.
The analysis indicated that water from the Cypress
Basin was expected to be the more cost effective
source over the life of the plant.
Other potential water sources were identified and
assessed as well. The groundwater table in the area
is fairly high, but is not productive enough to be

BACKGROUND Driver Benefit Challenge

Quantity
Brandy Branch Reservoir was constructed in 1983 to
provide a cooling reservoir for Pirkey. This option Quality
was preferred over a cooling tower system due to Reputation
land availability and lower cost. The reservoir is an
Regulatory
Cost
13553240

< B-65 >

 PIRKEY
B17 TEXAS
POWER PLANT
used for cooling water, so it was not investigated as
an alternative. Lake Cherokee, a reservoir in the
Sabine River Basin that supplies water to the Knox
Lee Power Plant, is close; however, it was already
fully allocated. Several other impoundments on the
Sabine River were considered, but these options
were dismissed for economic and viability reasons.
Thus, Lake O’ the Pines was identified as the
preferred source because a sufficient quantity of
water was available, it was expected to be more
cost-effective than water from the Sabine basin,
and SWEPCO already had an existing 20-year
relationship with the Northeast Texas Municipal
Water District. The quality of the water is similar in
the Cypress and Sabine River Basins, which
suggested that there would be no operational
issues involving the water. In addition, the water
district agreed to absorb all conveyance losses
between the Lake O’ the Pines dam and Pirkey’s
pump station below the dam.
IMPLEMENTATION
Lake O’ the Pines provides a fairly close cooling-
pond makeup water source for Pirkey. The lake was
placed in operation in 1959 for flood control,
recreation, and water supply and is owned and
operated by the U.S. Army Corps of Engineers. The
storage capacity is 241,363 acre-feet and it
encompasses 17,638 acres. The water rights in the
conservation pool are held by the Northeast Texas
Municipal Water District.
After constructing the 3,560 foot long earth fill dam
in 1983 across Brandy Branch to create the Brandy
Branch Reservoir, SWEPCO installed and paid for a
19 mile pipeline north to Lake O’ the Pines. They
also built a supplemental pump station about one
mile downstream of Lake O’ the Pines.
Brandy Branch Reservoir was filled prior to Pirkey
beginning operations. Currently, approximately
13553240
COOLING INTERBASIN
721 MW COAL
POND/RESERVOIR TRANSFER
11,000 acre-feet/yr. (~9.81 MGD) of water is
transported from a supplemental pump station one
mile downstream of Lake O’ the Pines into the
Brandy Branch Reservoir. The water contract allows
for the consumptive use of all 18,000 acre-feet of
water and there is no required discharge of the
purchased water to the Sabine River Basin.
SWEPCO pays the Northeast Texas Municipal Water
District $15/acre-foot for the water diverted and
$20.43 for water stored. It is estimated that the
costs of the water would be similar if it was taken
from the Sabine River Basin. In addition to paying
for the installation of the pipeline and supplemental
pumping station, SWEPCO also pays for the
maintenance and pumping costs. SWEPCO has also
obtained a contractual permit from the State of
Texas that formally recognizes the contract
between SWEPCO and the water district and a
Corps of Engineers 404 permit for the intake
structure on Big Cypress Creek.
Water from the Brandy Branch Reservoir was
initially also used for potable water at Pirkey, but
around 2009 the plant switched to using a local
water supplier.
BENEFITS & CHALLENGES
Benefits of the interbasin transfer include feasibility
due to timing of interbasin transfer regulations,
providing Pirkey with a reliable supply of water,
reducing flow-related regulatory requirements, and
creating a reservoir that offers recreational benefits
for the community.
Regulations related to interbasin transfers in Texas
are more restrictive today as compared to when the
Pirkey plant transfer was established. In the 1980s,
interbasin transfers were defined by a 1960’s Texas
Supreme Court ruling stating that an interbasin
transfer permit would be denied if “the benefits
from the diversions were outweighed by detriments
< B-66 >
 PIRKEY
B17 TEXAS 721 MW COAL
POWER PLANT
to the originating basin.” This did not limit the use
of interbasin transfers except in extreme situations
where they would negatively impact the original
basin. These flexible regulations provided a benefit
to SWEPCO.
The 1997 Senate Bill 1 defined a number of new
restrictions to interbasin transfers, making it
difficult to initiate interbasin transfers in Texas. A
“junior-rights provision” requires that when water is
transferred from one watershed to another, it
becomes the most junior water right in the original
basin, thereby making it the first right to get cut
during a drought. This regulation has greatly
reduced initiation of interbasin transfers in Texas.
Due to the fairly senior water rights of Lake O’ the
Pines, it is well protected and provides a reliable
supply of water to Pirkey even during drought
conditions. The Sabine River Compact, an interstate
compact between Louisiana and Texas, allocates
waters of the Sabine River to ensure minimum
flows and equitable distribution. Hypothetically, this
could require the Brandy Branch Reservoir, a fairly
junior water user, to release water during times of
drought to ensure adequate flow in the Sabine
River. However, since a majority of the water in the
reservoir is from the Cypress basin rather than the
Sabine basin, there is a low likelihood that stored
water would have to be released from Brandy
Branch Reservoir during times of drought.
Texas Senate Bill 3, passed in 2007, requires
environmental flow criteria for all major basins that
flow into the Gulf of Mexico in the State of Texas;
however, it did not affect Pirkey’s water supply. The
Cypress Creek Basin was a lower priority in Senate
Bill 3 than the Sabine River Basin because the
Cypress does not flow into Texas’ coastal waters.
Therefore, because most of the Pirkey water
originates from Cypress and the water right was
permitted prior to 2007, releases for instream flow
13553240
< B-67 >
COOLING INTERBASIN
POND/RESERVOIR TRANSFER
requirements from the Brandy Ranch Reservoir are
not anticipated to be required.
Brandy Branch Reservoir also provides recreational
opportunities for the community and thus positive
reputational benefits for SWEPCO and Pirkey. The
Pirkey Environmental Park on the reservoir provides
opportunities for camping and nature viewing and
the reservoir is known for its recreational fishing.
Challenges involving the water use at Pirkey include
pipeline failures, additional water use to account for
natural evaporation from Brandy Branch Reservoir,
pumping station maintenance, and potential
challenges with local stakeholders from Caddo Lake.
The initial 36-inch concrete cylinder pipe that was
used to transport the water has experienced leaks
and some sections required repairs. Additionally,
high groundwater levels appear to have contributed
to the failure of the wire wrap for the pipe, which
exacerbated the leaks. In 2012, a surge tank with air
cushioning was installed at the intake to mitigate
surges and extend the life of the pipeline.
Challenges have also arisen because the dam at
Lake ‘O the Pines cannot be controlled to the
desired level of precision. This has caused the
Northeast Texas Municipal Water District to
sometimes release more water at Lake O’ the Pines
than desired to accommodate the supplemental
pump station that pumps the water for Pirkey and
other downstream users. It should be noted that
this additional water is beneficial to the
environment, especially during low flow periods.
Caddo Lake, downstream of Lake O’ the Pines, is a
highly valued resource with an active watershed
group. The Caddo Lake Institute has not directly
opposed the upstream diversion of water to Pirkey,
but SWEPCO noted different perspectives on water
needs between their organizations.
 PIRKEY COOLING INTERBASIN
B17 TEXAS 721 MW COAL
POWER PLANT POND/RESERVOIR TRANSFER

LESSONS LEARNED McCloud, S. 2015. SWEPCO’s Commitment to a

Cleaner Environment: Earth Day, Every Day.
Interbasin transfers employed in the past can be URL: https://www.swepco.com/info/news/viewRele
an effective solution because they predate current ase.aspx?releaseID=1749 [Accessed 11/29/2016].
regulations.
Northeast Texas Municipal Water District. 2016.
An interbasin transfer has the potential to provide URL: http://www.netmwd.com/ [Accessed
quality water to a power plant in need, but 11/30/2016].
understanding the pertinent laws and regulations in
the state is crucial. Pirkey was able to easily utilize Personal communication, AEP staff, 2016. Tim
water from a different basin, but subsequent Lohner and Greg Carter.
regulations would have severely limited, or blocked,
Schnier, W. 2014. The Politics of Interbasin Water
the ability of the plant to acquire an interbasin
Transfers. BRD Engineering and Consulting.
transfer for water supply.
8/18/2014. URL: https://bigreddog.com/the-
Seniority of water rights can be important in areas politics-of-interbasin-water-transfers/ [Accessed
that are susceptible to droughts and water 12/1/2016].
shortages.
Texas Water Development Board. River Basins.
Utilizing water from a source with senior water URL: http://www.twdb.texas.gov/surfacewater/rive
rights allowed Pirkey to maintain a water supply rs/river_basins/ [Accessed 11/30/2016].
with a low risk of being cut off or reduced during
USEPA. 1982. Henry W. Pirkey Power Plant, Unit-
droughts. Newer bodies of water with junior water
1/South Hallsville Surface Lignite Mine Project,
rights are more likely to be required to release
Harrison County, Texas. Draft Environmental Impact
water during times of drought to maintain
Statement. EPA 906/9-82-004, March 1982.
minimum flows downstream, thereby increasing the
risk that water would not be available for power VERIFICATION
plant cooling. Recently implemented regulations
(e.g., Texas 1997 Senate Bill 1) may remove the Water use information presented in this case study
senior water rights privileges of the original source was provided through interviews with AEP-SWEPCO
in the case of an interbasin transfer. staff in October 2016, who have reviewed this case
study for accuracy.
REFERENCES
Gooch, T. C. and M. J. Taylor. 1999. Comprehensive
Sabine Watershed Management Plan. Prepared for
the Sabine River Authority of Texas in Conjunction
with the Texas Water Development Board.
URL: http://www.sratx.org/srwmp/comprehensive_
plan/final_report/pdf/CSWMP.pdf [Accessed
11/30/2016].

13553240

< B-68 >

Appendix C: Interview Questions for Case
Study Development
During case study development, a standardized suite of interview questions was
developed to better understand why an alternative supply was used or considered,
how it was used, and the outcomes of its use. Information was obtained through
phone interviews, and in some cases written responses to the interview questions
and follow-up exchanges with other knowledgeable staff. Interview questions
cover a range of topics including: general plant information, drivers for using an
alternative source, implementation of the alternative supply, and its reliability,
quality, cost, benefits and challenges. Secondary impacts, where relevant, and
lessons learned were also addressed.

Interview Date:

Power Company:

Participants:

Relationship to
Name Title Contact info.
Facility(ies)

Plant Information:

The table below summarizes a list of your organization’s power generation

facilities identified to be using alternative water supplies. Please review the table
for completeness and accuracy. If there are additional facilities not mentioned in
the table that may be relevant to the study, please provide information.

 C-1 

13553240
 General Power Plant Information FACILITY 1 FACILITY 2

Plant Name

Location

Fuel Type(s)

Plant Capacity (MW)

Cooling Water System

Year Plant Began Operation

Year Plant Began Using Alternate Source

Alternate water source type & name

Quantity of Alternate Supply

Name & Quantity of Additional (e.g.,
freshwater) Supplies

Interview Questions:

Disclaimer: The list below includes a large number of questions. They are intended to
guide discussion under each major topic. We recognize that some questions may not be
applicable and could be disregarded.
 Are the power plants listed in the table actively using the alternate water
supply? If not, then why?
 Are there any additional power plants in your fleet that utilize an alternate
water supply?

Drivers
 What was the primary driver for using an alternate water supply? Supply
availability? Regulatory constraints/changes? Cost? Other?
 Were there any drivers for alternate water supply use that, looking back, you
miscalculated or put too much importance on?
 Anything you did not consider or factor into your decision that you should
have?

Implementation
 Describe any major operational changes at the plant that have affected water
use (i.e., unit addition or retirement; fuel type conversion; cooling water
system; air quality controls).
 Was alternate supply part original construction or retrofit?
 How far is the alternate supply from the plant and how does this compare to
the traditional water supply?

 C-2 

13553240
  How is the alternate water supply used at the plant (i.e., recirculating cooling
system, boiler makeup, other)? What percentage of your water is from
alternative sources? Is it a primary or secondary/backup source? Is it blended
with another source?
 For interbasin transfers only: Were there any challenges in initiating an
interbasin transfer (e.g., requirements for special studies such as
environmental assessments, CWA Section 404 review, ESA review, permits;
public/stakeholder outreach)
 Did you have challenges with installing the infrastructure to connect the
water (easements for pipes)? Did you have to update/modify existing
infrastructure, including pipes/coatings to accommodate the alternate supply?
 For reclaimed sources: What level of water treatment is provided by the
supplier (secondary, tertiary)? Did the supplier modify treatment for your
plant? Did you coordinate with regulators on treatment standards?
 For reclaimed source: Have your staff required additional expertise/training
related to the use of reclaimed water?
 Do you provide additional water treatment onsite? Did you modify your
treatment processes?
 Do you conduct additional water monitoring because of the alternate supply?

Costs
 What do you pay for your water from the alternate source? What are the cost
components: pumping, treatment, infrastructure, additional energy costs,
training, monitoring, disposal, financial payments or mitigation costs? Which
is most significant?
 Have costs price changed over time? Do you expect significant change in the
future?
 How does the cost (to the facility) of using an alternative water supply
compare to the cost of using a 'traditional' water supply? (i.e., did you pay for
a water right?)
 Do you have any cost sharing arrangements with the water supplier
(pumping, infrastructure maintenance)?
 Did you have any challenges acquiring sufficient capital, paying for O&M
costs?
 Do you receive any subsidies or incentives related to use of an alternative
water supply?

Benefits
 What are the primary benefits of alternate water supply use to your
company/plant (reliability reduced dependency on water transfers, improved
water quality of source, reputation as an environmental steward?)

 C-3 

13553240
  What important external benefits should be noted (freshwater supply
resilience, improved surface water quality, [for interbasin transfers] surface
water quality or increased instream flows due to the new/increased discharge
in your basin, [for reclaimed use] permit relief for water supplier, regional
economic vitality and growth)?
 Have you documented your use of alternate supply use in voluntary reporting
(e.g., CDP Water Disclosure) or a water stewardship plan or corporate
report? Does this benefit your organization?

Challenges
 What are the primary challenges of alternate water supply use to your
company/plant (quantity or quality of alternate supply, timing/storage of
water, public support/perception, regulatory issues with permitting or
disposal, water access/water rights issues)?
 For Reclaimed sources: Was a public health review needed to use the
alternate water source? Have there been any issues regarding public health
effects?
 For Reclaimed sources: Have there been any negative effects on the
watershed (e.g., depletion of downstream flows with no WWTP discharge,
water quality concerns)?
 For Interbasin transfers: Have there been any negative environmental effects
on the watershed of origin (e.g., depletion of instream flows, drying of
wetlands, diminished wildlife habitat, effect on environmental flows, water
quality concerns such as increased salinity)?
 For Interbasin transfers: Have there been any negative economic or social
effects on the watershed of origin? (e.g., increased treatment costs for
dischargers directly resulting from decreased stream flow; impacts to tourism
(fishing, boating, hunting, aesthetics; decreased opportunities for growth due
to limits on water supply as a result of export)
 For Interbasin transfers: Have there been any negative environmental,
economic or social effects on the receiving water region (e.g., species
impacted by change in hydrologic regime, change from intermittent to
perennial stream)?
 Interbasin transfers: Describe any other negative effects that you are aware
of, on either the watershed of origin or the receiving water region.

Lessons Learned
 Are there any lessons learned that you want to share?
 In hindsight, would you use an alternate source again?
 Are there other challenges related to the use of water from an alternate
source that we haven’t talked about yet?

 C-4 

13553240
13553240
Export Control Restrictions The Electric Power Research Institute, Inc. (EPRI, www.epri.com)
Access to and use of EPRI Intellectual Property is granted with the spe- conducts research and development relating to the generation, delivery
cific understanding and requirement that responsibility for ensuring full and use of electricity for the benefit of the public. An independent,
compliance with all applicable U.S. and foreign export laws and regu- nonprofit organization, EPRI brings together its scientists and engineers
lations is being undertaken by you and your company. This includes as well as experts from academia and industry to help address
an obligation to ensure that any individual receiving access hereunder challenges in electricity, including reliability, efficiency, affordability,
who is not a U.S. citizen or permanent U.S. resident is permitted access health, safety and the environment. EPRI members represent 90% of the
under applicable U.S. and foreign export laws and regulations. In the electric utility revenue in the United States with international participation
event you are uncertain whether you or your company may lawfully in 35 countries. EPRI’s principal offices and laboratories are located in
obtain access to this EPRI Intellectual Property, you acknowledge that it Palo Alto, Calif.; Charlotte, N.C.; Knoxville, Tenn.; and Lenox, Mass.
is your obligation to consult with your company’s legal counsel to deter-
Together...Shaping the Future of Electricity
mine whether this access is lawful. Although EPRI may make available
on a case-by-case basis an informal assessment of the applicable U.S.
export classification for specific EPRI Intellectual Property, you and your
company acknowledge that this assessment is solely for informational
purposes and not for reliance purposes. You and your company ac-
knowledge that it is still the obligation of you and your company to make
your own assessment of the applicable U.S. export classification and
ensure compliance accordingly. You and your company understand and
acknowledge your obligations to make a prompt report to EPRI and the
appropriate authorities regarding any access to or use of EPRI Intellec-
tual Property hereunder that may be in violation of applicable U.S. or
foreign export laws or regulations.

Program:
Water Availability and Resource Risk Management

© 2017 Electric Power Research Institute (EPRI), Inc. All rights reserved. Electric Power
Research Institute, EPRI, and TOGETHER...SHAPING THE FUTURE OF ELECTRICITY are
registered service marks of the Electric Power Research Institute, Inc.

3002012045

Electric Power Research Institute

3420 Hillview Avenue, Palo Alto, California 94304-1338 • PO Box 10412, Palo Alto, California 94303-0813 USA
800.313.3774 • 650.855.2121 • askepri@epri.com • www.epri.com
13553240