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In 1975, the US Environmental Protection Agency issued State Pollution Discharge Elimination System 

(SPDES) permits for four power plants in the southern portion of the Hudson River--Bowline Point 

Units 1 and 2; Roseton; and Indian Point--that required these plants to be retrofitted with cooling towers. 

All these plants used the "once-through" system of drawing a continuous volume of water through the 

plants for cooling purposes and discharging the heated water back into the river. Cooling towers use a 

closed cooling system wherein water is pumped through the plant and then allowed to cascade down 

within a tall tower, losing its heat load, whereupon it is cycled through the plant again. The power 

companies appealed this expensive requirement and negotiations between EPA the power companies 

dragged on for 5 years. In 1981, the Hudson River SettlementAgreement (HRSA) was signed. It 

allowed the power companies to continue operating these plants without cooling towers but imposed 

upon them extensive operating restrictions or modifications (e.g., scheduled plant outages, fine-tuning of 

water withdrawals, protective hardware on intake screens) as well as mandating that the companies 

institute hatchery-based stocking of striped bass, the funding ($12 million) of a long-term research 

program on the Hudson River @.e.,the Hudson River Foundation for Science and Research), and the 

establishment of a biological monitoring program to evaluate the impacts of power plants on the 

ecosystem of the Hudson River, especially fish populations. Over the ensuing decade, this agreement 

and its provisions were implemented. 

In 1991, the HRSA expired and was renewed for one year, but environmental groups party to the 

original agreement immediately sued. This litigation was suspended in 1992 by a consent order which 

was extended each year through 1998. During this entire period, the monitoring programs established 

under the original HRSA continued. In 1992, the DEC declared that the applications of the power 

companies for renewal of their SPDES permits were incomplete and that the companies must prepare a 

full Environmental Impact Statement (EIS) for permit renewal as part of the State Environmental 

Quality Review (SEQR) process. Eventually, in 1999, the power companies submitted an EIS which the 

DEC considered complete enough to submit to the public for review and comment. The official public 

http://www .msrc.sunysb.edu/mrac/pages/Bv9n4s03.html 2/16/2004 
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comment period for this EIS ends on 24 June 2000. 

All the research information developed by the power companies clearly indicated that with the existing 

plants, using once-through cooling systems, the more power produced, the more water is used, and the 

greater the impact on fish stocks from impingement and entrainment mortalities. However new, more 

efficient (closed-cycle) technologies that will be required in proposed new plants have significantly less 

impact because these technologies draw very little water from the river. The conditional entrainment 

mortality rate (CEMR), the percent reduction in year class strength of Hudson River fish as a result of 

power plants-related entrainment mortality, is estimated at 20-30% for most species examined based on 

short-term survival rate (30-55% if 100% mortality is assumed from latent injuries.) For example, the 

population of American shad in the river might as much as double if the entrainment mortalities caused 

by the operation of a single plant in the Albany area could be eliminated. Data presented by Mr. 

Colquhoun on New York Harbor area power plants show entrainment in large numbers for many finfish 

species. 

The federal Clean Water Act requires that "the location, design, construction, and capacity of cooling 

water intake structures, in connection with point source thermal discharges, shall reflect the best 

technology available for minimizing adverse environmental impact." New York law is similar. The 

utility choice option recognizes that relicensing existing plants is the equivalent of building new plants; 

the utilities don't have to construct expensive cooling towers for an existing plant if the plant is to be 

taken off line in the next few years. However if they don't intend to rehabilitate an old plant, it must be 

shut down and its power production replaced by a new plant with cooling tower technology. 

Mr. Colquhoun stated that all the new power plants would have either cooling towers or some other 

means to greatly reduce impingement and entrainment mortality of fish. Councilor Schwab recalled an 

estimate by Dr. Philip Goodyear of Oak Ridge National Laboratory that the Indian Point 2 plant would 

kill 50%of each year class of striped bass spawned in the Hudson River; Mr. Colquhoun agreed that 

subsequent data confirmed this. 

Mr. Colquhoun concluded that the excellent utility monitoring data collected over the past 25 years had 

created a unique ability to extrapolate and apply conclusions elsewhere. Mr. Colvin of DEC stated that 

the agency was interested in expanding and applying this information on estimated Hudson River 

impingement and entrainment mortalities of fish to other states and areas in the Mid-Atlantic region 

beyond New York. For example, American shad are in trouble not just in the Hudson River but along 

the entire East Coast. ASMFC is very interested in considering power plants as a source of fish 

mortality. The DEC made a presentation to the Commission, which subsequently created a working 

group to generate a set of scientific approaches to be used on a coast-wide basis for shad and similar 

estuarine spawners when considering utility applications in coastal states. 

http://www.msrc.sunysb.edu/mrac/pages/Bv9n4sO3.html 2/16/2004