Giant Fish 

Blenders:

How Power Plants 

Kill Fish & Damage 

Our Waterways

(And What Can Be Done to Stop Them)
3 Ex

ecutive Summary

5 Introduction 6 Great Lakes

10 Gu

lf of Mexico 

12 M

ississippi River

14 hud

son River, 

Long Island Sound 

and New York Harbor

18 C

alifornia Coast

20 C

hesapeakeBay 

23 Conc

lusion

24 App

endix

27 end

Notes

Giant Fish Blenders: How Power Plant Intake 

Structures Kill Fish and Damage Ecosystems 

(and What Can Be Done to StopThem)

This report is a publication of the Sierra Club

Sierra Club recognizes the following people and 

organizations for their valuable work in researching, 

drafting, editing, and designing this report. 

We thank them for making this report possible: 

Dr. Peter A. Henderson, PISCES Conservation, Ltd

Dr. Richard M. H. Seaby, PISCES Conservation, Ltd

Reed Super, Super Law Group, LLC

Alexandra Hankovszky, Super Law Group, LLC

Dalal Aboulhosn, Sierra Club

Holly Bressett, Sierra Club

Oliver Bernstein, Sierra Club

Rebecca Troutman, Riverkeeper, Inc.

Steve Fleischli, Natural Resources Defense Council

Diane Dempsey Murray, Design (ddmurray.com)

July 2011

contents
2 Gian

t Fish Blenders Gian

t Fish Blenders3

Photo: PISCES Conservation, Ltd

A power plant with once-through cooling draws hundreds 

of millions, in some cases billions, of gallons of water each day 

from the closest lake, river or ocean and indiscriminately sucks in 

whatever aquatic life is near the intake pipe. In this process, fish 

and other aquatic life are smashed and mutilated against crude 

screens (known as “impingement”) or are sucked into the cooling 

system itself (known as “entrainment”). It is estimated that billions 

of fish and other aquatic organisms at all stages of life are killed 

each year by power plants’ water-intake systems. 

The full spectrum of aquatic species are impacted by oncethrough cooling, as are the other wildlife that rely on the complex 

food web—from phytoplankton to fish, birds, and marine 

mammals, including species that are threatened or endangered. 

Power plants’ intake structures kill billions of fish and destabilize 

wildlife populations. A single power plant can obliterate billions of 

fish eggs and larvae and millions of adult fish in a single year, and 

the heated water it discharges also alters surrounding ecosystems, 

compounding the damage. The death toll of wildlife from power 

plant intakes is staggeringly high. Some areas face devastating 

economic impacts as fisheries are threatened and recreational uses 

are diminished. 

This report looks at the impact of once-through cooling 

systems on some of the nation’s most iconic waterways: the Great 

Lakes; the Gulf of Mexico; the Mississippi River; the Hudson 

River, New York Harbor and Long Island Sound; the California 

Coast; and the Chesapeake Bay. These great American waterways 

are at risk of losing untold species and ecosystems that have shaped 

the history, economy and culture of the surrounding areas.

We also look at the history of and actions taken by 

decision makers in regulating once-through cooling systems. 

Almost 40 years after Congress identified cooling water intake 

as a threat to our waterways and the life sustained by them, the 

U.S. Environmental Protection Agency (EPA) has failed to force 

the owners of power plants—the nation’s largest water users—to 

reduce their destructive impact. 

Today, the EPA is proposing regulations that, unfortunately, 

fail to set a clear, consistent national policy and fail to modernize 

our electric sector by phasing out once-through cooling systems. 

Even though the EPA has identified cost-effective alternatives, 

which are already being used in new power plants across the 

country, industry lobbyists are fighting hard to prevent any 

modernization of the outdated cooling systems at power plants, 

many built more than 30 years ago. This report highlights why the 

EPA must move quickly to strengthen proposed regulations and 

phase out the most destructive water-cooling practices by putting 

in place common-sense protections for fisheries and waterways 

across the United States.

Executive

Summary

F

rom an airplane window, you might see power plants lining the banks of the Mississippi River, our coastal shores 

or the Great Lakes. It is no coincidence that power plants are located along some of our mightiest rivers and most 

treasured waterways: steam-electric power plants using older technologies need an extraordinary amount of water 

to operate. The power industry uses more water than any other sector in the United States, withdrawing more 

than 200 billion gallons of water each day. Nearly all this water is used for “once-through cooling,” an antiquated 

technology were power plants suck enormous volumes of water to cool down their systems and then discharge it 

at an elevated temperature. 
4 Gian

t Fish Blenders Gian

t Fish Blenders5

P

ower plants use water—and lots of it. In the United 

States, more than 500 power plants withdraw billions of 

gallons of water each day to use in the most antiquated and 

destructive type of cooling system, known as “once-through 

cooling.” Once-through cooling systems draw water from 

a nearby waterbody and then discharge it at an elevated temperature, 

causing severe ecosystem destruction.

Collectively, steam-electric power plants have the capacity to withdraw 

more than 370 billion gallons per day—more than 135 trillion gallons 

per year—from our nation’s waters for cooling.

1

 Currently, those plants’ 

average withdrawal exceeds 200 million gallons each day.

2

 This accounts 

for 93 percent of the country’s total saltwater use, 41 percent of total 

freshwater use, and 49 percent of all water use. That’s more water than all 

irrigation and public water supplies combined.

3

One-through cooling systems use large pipes as water-intake structures. 

These pipes sit below the water’s surface and suck in not only water but 

also anything else in the vicinity. After the water is drawn through the 

power plant to help cool systems that have generated heat during the 

energy-making process, it is discharged at an elevated temperature back 

into the waterbody. This process affects the full spectrum of wildlife in the 

aquatic ecosystem at all life stages—eggs, larvae, juveniles and adults—

from tiny photosynthetic organisms to fish, shrimp, crabs, birds and 

marine mammals, including threatened and endangered species.

4

How Power Plant Intake Structures Harm Our Waterways

Power plants’ intake structures kill billions of fish and destabilize wildlife 

populations. Since intake structures sit well below the surface of the water, 

fish and other aquatic life are hit the hardest. A single power plant can destroy 

billions of fish eggs and larvae and millions of adult fish in a single year, and 

its heated discharges alter the surrounding ecosystems, compounding the 

damage. In addition to fish, these outdated intake structures also kill or 

harm sea turtles, seals, sea lions and numerous other larger animals.

5

This excessive mortality occurs despite rudimentary attempts to filter 

extraneous materials, including fish, from the cooling water stream. Fish 

eggs, larvae and other organisms are too small to be filtered out by even 

the best screens. The destruction is twofold: Larger fish and wildlife must 

fight against “impingement,” or getting trapped on intake screens. And 

aquatic organisms too small to be trapped against these screens become 

“entrained,” or sucked through plants’ heat exchangers, where most are 

smashed and boiled to death before being dumped back into a waterbody.

The EPA has found that the loss of large numbers of aquatic wildlife 

may affect the overall health of ecosystems.

6

 Once-through cooling not 

only reduces adult populations of the species, but also kills their eggs and 

larvae, causing disruptions to the food chain. These antiquated intake 

structures also reduce the species’ ability to survive other unfavorable 

environmental conditions such as drought and climate change.

7

The History of Once-through Cooling Destruction

In the late 1960s, Congress first considered the impacts of power plants’ 

massive water usage during extensive hearings on the effects of waste heat 

discharged from industrial facilities.

8

 Senator Warren Magnuson warned 

that “by 1980 thermal power plants throughout the nation will require an 

amount of cooling water greatly in excess of the average flow of the mighty 

Mississippi at St. Louis.”

9

 Around the same time, the White House issued 

a report explaining that “the large volumes of water withdrawn in oncethrough cooling processes [can have] as much or more effect on aquatic 

life than the waste discharges on which control measures are required.”10

In the early 1970s, a number of well-publicized massive fish kills occurred 

at intake structures around the country. In response to the fish kills and other 

threats to our waterways, Congress voted overwhelmingly to pass the Clean 

Water Act of 1972 into law. While it focuses mostly on the discharge of 

pollution, the law also specifically regulates cooling water intake structures. 

Section 316(b) of the Clean Water Act requires the EPA to issue 

regulations requiring that “the location, design, construction, and 

capacity of cooling water intake structures reflect the best technology 

available for minimizing adverse environmental impact.”11 Those adverse 

environmental impacts are primarily the entrainment and impingement 

of fish, shellfish and other forms of aquatic life, along with thermal 

pollution in the discharge of cooling water. 

In 2001, after decades of delay, the EPA took an important step 

forward by ordering new plants to use “closed-cycle cooling” and 

prohibiting once-through cooling for new projects except in extremely 

limited circumstances.12 In a closed-cycle cooling system, water 

withdrawn from a natural waterbody is circulated through condensers to 

remove the plant’s excessive heat, then circulated through cooling towers, 

and then recirculated (i.e., recycled) back to the condensers. Compared 

with a once-through system—in which water is drawn into the condenser 

and then sent back to the waterbody from which it came—closed-cycle 

cooling can reduce total water withdrawals by about 95 percent. Because 

closed-cycle cooling is a better and newer technology, Clean Water Act 

permits issued by states and the EPA’s regional offices for the construction 

of new power plants invariably require that it be installed.

However, the EPA has failed to follow through on its legal obligation 

to require existing power plants to modernize and phase out oncethrough cooling. Industry lobbyists have successfully stalled EPA action 

for a decade after it set new standards for new power plants. As a result, 

outdated power plants across the U.S. continue to kill billions of fish and 

other aquatic organisms annually on our nation’s most iconic waterways. 

About This Report

In the pages that follow, we provide specific examples of how antiquated 

cooling water intake structures are directly impacting some of our nation’s 

most iconic waterways and their ecosystems: the Gulf of Mexico; the 

Mississippi River; the Hudson River, New York Harbor and Long Island 

Sound; the California Coast; the Great Lakes and the Chesapeake Bay. While 

we discuss only a handful of examples, there are many other waterways 

around the country being similarly harmed by antiquated power plants. 

We must stop the giant fish blenders that line our shores, lakes and 

rivers. By phasing out once-through cooling, the EPA can help begin the 

process to restore and preserve our waterways for generations to come.

Left: Just one outdated power plant can trap and kill millions of fish and other 

Pho

aquatic animals against crude water intake screens, like the ones shown here.

to: PISCES Conservation, Ltd

introduction
6 Giant Fish Blenders Giant Fish Blenders 7

THE

GREAT LAKES

T

he Great Lakes—Superior, Michigan, Huron, Erie and 

Ontario—and their connecting channels form the largest 

freshwater system on Earth. Covering more than 94,000 

square miles, and draining twice as much land area, these 

freshwater bodies hold about 6 quadrillion gallons of water, 

about one-fifth of the world’s fresh surface water supply and 90 percent 

of the U.S. freshwater supply. The Great Lakes provide drinking water to 

more than 40 million people.13

The Great Lakes region possesses a mosaic of connected ecosystems 

containing diverse communities of species, including about 180 native 

fish species such as brook trout, lake sturgeon, lake trout, lake herring, 

largemouth bass, northern pike, whitefish, smallmouth bass, walleye and 

yellow perch. 

Each species within the Great Lakes has its place within the food chain 

and is dependent on the abundance and health of the whole ecosystem. At 

the base of the food chain are the primary producers, like algae, that collect 

energy from light. Feeding on these are the small zooplankton amphipods 

and other organisms that are, in turn, eaten by larger invertebrates such 

as shrimp. The next link includes fishes such as alewives, shiners and lake 

herring, which provide sustenance to the predatory fish, like lake trout 

and bass. All these fish then provide food for birds, reptiles, amphibians 

and mammals that live by the Great Lakes, including humans.

The Great Lakes are linked to coastal wetland and bordering terrestrial 

ecosystems that support many threatened and endangered animals, 

including the whooping crane, Canadian lynx, gray wolf, bog turtle, 

as well as plants such as the dwarf lake iris. They also provide essential 

habitat to a symbol of our country, the once-endangered bald eagle. 

Because of the importance of these lakes, many underwater preserves 

and parks have been established throughout the area, and outdoor 

recreation is a major part of life in the region. With pristine wilderness 

in close proximity to major cities in eight states—Illinois, Indiana, 

Michigan, Minnesota, New York, Ohio, Pennsylvania and Wisconsin—

as well as the Canadian province of Ontario, the Great Lakes region 

provides abundant opportunities for fishing, boating, swimming, birdwatching and tourism. 

The Great Lakes states have about 3.7 million registered recreational 

boats, about a third of the nation’s total,14 and the commercial and sport 

fishing industry is collectively valued at more than $7 billion annually.15

A 2007 report by the Brookings Institution determined that a healthy, 

restored Great Lakes could generate some $50 billion in long-term 

economic benefits for the region, not only for industries like fishing, 

which rely on clean, healthy ecosystems, but also for the tourist industry 

and for homeowners, in the form of higher property values.16

Most lake ecosystems are dependent on their shores and shallows for 

their productivity, and the Great Lakes are no different. However, the 

Great Lakes are unique because of their size: Only a small proportion of 

their volume is within these productive shallow zones. The Great Lakes 

are therefore particularly vulnerable to any damage to their shallows, 

where shoreline power plant intake structures are located. 

How Power Plant Intake Structures Harm the Great Lakes

At least 42 power plants using once-through cooling systems ring the 

Great Lakes. Lake Michigan has the largest number of these plants, 

with 19, followed by Lake Erie’s 11, Lake Huron’s six, Lake Ontario’s 

five, and Lake Superior’s one. Thirty-three of the plants run on coal, six 

are nuclear, and the rest burn natural gas or oil. These plants withdraw 

massive volumes of water, ranging from the relatively small Harbor Beach 

plant on Lake Huron, which can withdraw 129 million gallons per day, to 

the behemoth D.C. Cook plant on Lake Michigan and the Monroe plant 

on Lake Erie, both of which can withdraw more than 2 billion gallons.17

The 42 Great Lakes plants have a combined intake flow of more than 

30 billion gallons per day. (See Appendix, Table 1, for a full list of Great 

Lakes plants and their intake flow rates.) 

These plants’ intake structures kill huge numbers of fish and shellfish 

of virtually every species present and at every life stage. All links in the 

Great Lakes food chain are adversely affected by these power plants. For 

example, when operating at full capacity, the Bayshore plant in Ohio 

sucks up more than 700 million gallons of water per day from the middle 

of Maumee Bay, in western Lake Erie, the most productive fishery in the 

Great Lakes. 

LEFT: Scenic Lake Erie has 12 antiquated power plants on its shores that 

use almost 10 billion gallons of water everyday.

above: Bayshore power plant in Ohio has been known to kill 60 million 

Pho

fish in just one year because of outdated water intake structures.

to: Lake Erie Waterkeeper 
8 Gian

t Fish Blenders Gian

t Fish Blenders9

A 2005–6 study conducted by Bayshore’s owner estimated that 

more than 60 million adult fish and more than 2.5 billion fish eggs 

and larvae were killed per year.18 A later study of the Bayshore plant 

by the University of Toledo put the number of fish eggs and larvae 

killed at more than 12 billion per year. The plant’s once-through cooling 

system also dumps hot water into western Lake Erie, contributing to 

foul-smelling, toxic algal blooms and causing further harm to fish 

populations in a vital but already heavily stressed ecosystem.

On the shores of Lake Michigan in Wisconsin, the Oak Creek power 

plant was estimated by its operator to impinge well over 2 million fish 

weighing 57-plus tons in a single year on its intake screens. In addition, 

between April and October of 2002, it entrained over 6 million larvae 

and over 9 million fish eggs.19

New York’s Huntley Generating station, located along the Niagara 

River, which connects Lake Ontario to Lake Erie near the world-famous 

Niagara Falls, is estimated to entrain over 105 million fish eggs and 

larvae per year, with annual impingement of well over 96 million adult 

and juvenile fish—the largest of any power plant in the state.20

A clear illustration of the ecological benefits that could be obtained 

by installing closed-cycle cooling at the 42 Great Lakes plants is 

evident from the experience of the Palisades nuclear power plant on 

Lake Michigan, which was built with once-through cooling and later 

installed closed-cycle cooling. When operating in once-through mode, 

the plant impinged almost half a million fish per year, but this figure 

was reduced by an astounding 98 percent once the plant switched to 

closed-cycle cooling. 21

Ecosystems in the Great Lakes face many other stresses, including 

pollution and destructive invasive species. This makes mortality from 

once-though intake structures more potentially detrimental to native 

species than it would be in healthy ecosystems. Since so many fish and 

other aquatic creatures are killed, their populations become smaller, 

weaker, and more vulnerable to collapse.

The Great Lakes are an important resource for the nation. The 

region’s unique environment includes wetlands, marshes, swamps and 

bogs that play a critical role in linking land with water. These lakes 

enrich the lives of communities around them and define the region. 

They are a haven for hunters, anglers and all outdoor enthusiasts, and 

also an economic driver of the nation. Updating the 42 power plants on 

the shores of the Great Lakes would help ensure that they remain clean 

and healthy for future generations.

Above: Endangered whooping cranes, 

like these, are dependent on healthy fish 

populations in the Great Lakes.

center: On Lake Michigan in Wisconsin, 

the Oak Creek power plant was estimated 

by its operator to impinge well over 2 

million fish weighing 57-plus tons in a 

single year. below: The Great Lakes communities have 

about 3.7 million registered recreational 

boats, about a third of the nation’s total.

Far right: A healthy Great Lakes, such as 

Lake Heron pictured here, could yield $50 

billion in long-term economic benefit for 

the region. 
10 Giant Fish Blenders Giant Fish Blenders 11

T

he Gulf of Mexico is the ninth-largest body of water 

in the world, covering 600,000 square miles, and it receives 

water from 33 major rivers, including the Mississippi and Rio 

Grande.22 More than half of the coastal wetlands within the 

continental United States are in the Gulf of Mexico, including 

15,316 square miles of estuarine habitat along the shoreline in the Gulf 

Coast states of Alabama, Florida, Louisiana, Mississippi and Texas. This 

important coastal habitat is essential for healthy fisheries, migrating 

waterfowl, seabirds and wading birds. Wetlands also play an irreplaceable 

role in protecting shoreline communities from increasingly dangerous 

storms. 

The Gulf’s estuaries, with their associated mangrove and seagrass 

habitats, are essential feeding and nursery grounds for large numbers of 

fish and other wildlife, including threatened and endangered species such 

as sea turtles, Gulf sturgeon and manatees. Mangroves defend coastlines 

from flooding and erosion and provide essential habitat for reptiles such 

as the American crocodile and American alligator; sea turtles such as the 

loggerhead; fish such as snapper and tarpon; crustaceans such as shrimp 

and crabs; and coastal and migratory birds, including pelicans, spoonbills 

and bald eagles. Seagrass beds are also fish nurseries, where manatees and 

sea turtles feed and thrive. Additionally, the Gulf of Mexico yields more 

shrimp and shellfish annually than the mid-Atlantic, Chesapeake and 

New England areas combined.23

Of the 28 species of marine mammals known to inhabit the Gulf of 

Mexico, three are protected species of dolphin (Atlantic spotted, Risso’s 

and bottlenose).24 A number of endangered fish live in the coastal and 

estuarine waters, including the Gulf sturgeon, Alabama shad, saltmarsh 

topminnow and mangrove rivulus. The Gulf’s threatened and endangered 

sea turtles include the loggerhead and leatherback, which thrive in the 

Gulf’s expansive and unique waterways.

Besides being home to all types of wildlife, the Gulf supports major 

fishing industries.25 Gulf fisheries are among the most productive in 

the world, with commercial fish and shellfish valued at $661 million 

annually.26 In 2008, recreational fishers took more than 24 million trips, 

catching 190 million fish, in the Gulf of Mexico and surrounding waters.27

The Gulf of Mexico’s shores and beaches, an ideal location for swimming, 

sun and all water sports, support a $20 billion tourism industry.28

How Power Plant Intake Structures Harm the Gulf of Mexico

The Gulf coastal region has at least 17 power plants that use once-through 

cooling systems: seven in Florida, seven in Texas, two in Louisiana, and 

one in Mississippi. Four of the plants—the Big Bend, Crystal River 

and Lansing Smith plants in Florida, and the Jack Watson plant in 

Mississippi—burn coal; the Crystal River plant site also has a nuclear 

reactor. The rest of the plants along the Gulf burn natural gas or oil. 

These plants withdraw billions of gallons of water each day from the Gulf 

of Mexico and its coastal bays, entraining and impinging huge numbers of 

fish and shellfish of virtually every species present—at every life stage—and 

discharging heated water back into the Gulf. The largest-flow plants are the 

Anclote plant, north of St. Petersburg, Florida, at more than 2.8 billion 

gallons per day; the Crystal River plant complex, just 50 miles up the west 

coast of Florida from Anclote, at more than 2.1 billion gallons per day; 

and the P. H. Robinson power plant in Galveston Bay, Texas, which is 

designed to take in more than 1.7 billion gallons per day. Combined, the 

17 Gulf plants can withdraw nearly 13 billion gallons of water per day, 

and there are many other power plants withdrawing even larger volumes 

of freshwater from the rivers that feed the Gulf, killing aquatic life and 

discharging heated water back into the ecosystem as well. (See Appendix, 

Table 2, for a full list of Gulf plants and their intake flow rates.)

In the Gulf especially, thermal pollution can directly impact plants 

and animals, degrading habitat and reducing biodiversity. Both mangrove 

and seagrass beds are sensitive to power plants’ thermal pollution. For 

example, the Thalassia seagrass beds in Florida estuaries are drastically 

affected when contacted by discharges 41 degrees Fahrenheit or more 

above the ambient summer temperature. These overly warm discharges 

on the seagrass beds can result in total destruction of this plant life and in 

turn damage the populations of wildlife that depend on it.29

 A number of protected fish and sea turtle species live in waters 

impacted by power plants and are impinged or trapped on intake 

screens. For example, the Crystal River plant has impinged five species of 

endangered sea turtles—loggerhead, green, Kemp’s ridley, leatherback and 

hawksbill.30 At the Big Bend generating station in Tampa Bay, Florida, the 

annual impingement from 1976 to 1977 was estimated to be more than 

a quarter of a million fish.31

Entrainment of young species is a major problem in productive coastal 

and estuarine waters. At the Big Bend plant, the annual entrainment of 

a single species, the bay anchovy, was estimated at more than 68 billion 

from 1976 to 1977.32 The Big Bend power plants still uses that same 

once-through cooling system today, 30-plus years later. 

The Gulf of Mexico is one of the most biodiverse bodies of water on 

the planet and one of the most economically productive regions in the 

world.33 It is home to a range of sea life including dolphins, oysters and 

coral reefs. Its coastline encompasses wetlands and includes tidal flats, 

mangrove swamps, estuaries and bays. Power plants along the Gulf should 

be required to update their cooling system technologies to protect aquatic 

life, coastal communities, tourism and commercial fishing in the region.

clockwise from upper left: The Gulf of Mexico yields more shrimp and 

shellfish annually than the mid-Atlantic, Chesapeake and New England areas 

combined. However, outdated water intake structures can trap and kill them, as 

shown here. Not only fish are killed by power plants. Turtles, like the endangered 

loggerhead shown here can become trapped on crude intake screens. The Gulf 

is not only known for its wildlife, but also as a destination for many outdoor 

enthusiasts such as beach combers and boaters.

GULF 

OF MEXICO

Photo: PISCES Conservation, Ltd
12 Giant Fish Blenders Giant Fish Blenders 13

One of the most famous rivers in the world, the 

Mississippi is the largest river system in North America, 

draining almost one-third of the total U.S. land mass. At 

approximately 2,350 miles long, the Mississippi is the 

third-longest river in North America,34 is the fifth largest 

river in the world by volume and has the third largest drainage basin in the 

world,35 covering more than a million square miles.36 The river basin drains 

all or parts of 31 states and two Canadian provinces, and flows through 

ten states: Arkansas, Illinois, Iowa, Kentucky, Louisiana, Minnesota, 

Mississippi, Missouri, Tennessee, and Wisconsin. 

By virtue of its great size and other geographic factors, the Mississippi 

river system is one of North America’s most important environmental 

resources, containing a variety of habitats and an extraordinarily great 

aquatic biodiversity. The river basin supports at least 375 species of native 

fish, which are rather evenly distributed across the region.37 

The Mississippi is noted for its numerous large river fish, which 

include the shovelnose sturgeon, gar, and bowfin. Other native fish of the 

Mississippi are the shad, chub, perch and bass.38 Migratory birds visiting 

the river include Canadian geese, swans, bluebirds, and pelicans, many 

types of songbirds, and mallard, widgeon, pintail and ring - necked ducks. 

The upper river valley contains large wetland areas, magnificent 

hardwood forests and some of the richest soils and most pristine habitats 

for wildlife found in the United States. Species living within the upper river 

valley’s catchments include white-tailed deer, wild turkeys, mink, muskrats 

and otters—all of which depend on a healthy Mississippi River.

The Lower Mississippi, below the Ohio River confluence, lies within 

the lowland gulf coastal plain, a basin between the Appalachians to the east 

and the Ozark and Ouachita Mountains to the west. The Lower Mississippi 

is distinguished by its extraordinary richness of species, particularly fish, 

shellfish and crayfish. It is also home to nearly 70 species of amphibians 

and aquatic reptiles, including the American alligator and two common 

turtles—the ringed map turtle and yellow-blotched map turtle. Among the 

numerous marine species commonly recorded in the Mississippi’s lower 

reaches, where it meets the saltwater environment of the Gulf of Mexico, 

are minnows, catfish, killifish and darters.

Because of its rich diversity and beautiful scenery, the Mississippi River 

has seven National Park sites along its banks; in 1997, two portions of 

the Mississippi were designated as American Heritage Rivers. In 2009, the 

Upper Mississippi River floodplains, which include the 240,000-acre Upper 

Mississippi River National Wildlife and Fish Refuge, were designated as a 

Wetland of International Importance.

In addition to its ecological and social values, the Mississippi has 

significant economic value as the nation’s chief navigable water route for 

commerce. It provides many states with drinking water and has spurred the 

growth of the its neighboring cities and economies. The Mississippi provides 

abundant hunting, fishing, canoeing, camping and other recreational 

MISSISSIPPI

RIVER

opportunities for millions of Americans. Its riverside parks and trails are 

popular spots for hiking, biking, fishing and bird-watching. A healthy 

Mississippi River is vital to the quality of life in its nearby communities.

How Power Plant Intake Structures Harm the Mississippi River

At least 28 power plants still using once-through cooling systems are 

located on the Mississippi River. Louisiana is home to six of these plants; 

Iowa has five; Minnesota, Missouri and Wisconsin each have four; Illinois 

has two; and Arkansas, Mississippi and Tennessee each have one. Seventeen 

of these plants burn coal; seven burn natural gas or oil; three are nuclear; 

and one, the Waterford plant in Louisiana, has a nuclear unit as well as oil 

or gas units. These 28 plants have a combined cooling water withdrawal 

capacity of more than 15 billion gallons per day, and their massive water 

withdrawals entrain and impinge enormous numbers of fish and shellfish 

of virtually every species and at every life stage. (See Appendix, Table 3, for 

a full list of Mississippi River plants and their intake flow rates.) 

Mississippi power plants using once-through cooling range from the 

relatively small Burlington plant in Iowa, which can withdraw 116 million 

gallons per day, to the behemoth Nine Mile Point plant in Illinois and the 

Quad Cities plant in Louisiana, which each withdraw well more than a 

billion gallons per day.39

As just one example of the impact of these power plants on fish, consider 

the coal-fired Meramec power plant, located 16 miles south of St. Louis, 

Missouri, at the confluence of the Mississippi with the Meramec Rivers. 

Impingement and entrainment studies conducted there in the 1970s, 

when the plant’s maximum flow was about 550 million gallons per day, 

an estimated annual impingement of almost a million fish, including the 

vulnerable shovel-nosed sturgeon. 

Meramec’s entrainment of fish eggs was greatest in July, when an average 

of 70.7 fish eggs was entrained per 100,000 gallons. Given that the plant 

utilized more than 9.5 billion gallons of cooling water in July 1974 during the 

study period, the estimated entrainment for that one month alone was well 

over a half a million eggs.40 Since Merrimac’s intake capacity has increased to 

675 million gallons per day, with no change to its outdated intake structures, 

the impingement and entrainment impacts are likely even worse today. 

The Mississippi River, from the small headwaters in the Northwoods of 

Minnesota to the large ecosystem of the Gulf of Mexico, is a true national 

treasure that has played a large role in shaping American culture and history. 

Power plants along the Mighty Mississippi should use the best and most 

modern technology to protect the wildlife and the economy the river provides.

clockwise from upper left: Meramec power plant, located 16 miles south 

of St. Louis, Missouri, at the confluence of the Mississippi with the Meramec 

Rivers, impinges and entrains almost a million fish per day. The Mississippi River 

needs healthy fish populations for the next generation of anglers. The 28 power 

plants on the mighty Mississippi have a combined cooling water withdrawal 

capacity of more than 15 billion gallons of water per day. A healthy Mississippi 

River is vital to the quality of life in its nearby communities and wildlife.
14 Giant Fish Blenders Giant Fish Blenders 15

Hudson River

Known as “America’s First River,” the Hudson begins at Lake Tear of 

the Clouds in the Adirondack Mountains and flows more than three 

hundred miles before emptying into New York Harbor at the southern tip 

of Manhattan. Called Muhheakantuck (“the river that flows both ways”) 

by Native Americans and now named for the British explorer Henry 

Hudson, the historic Hudson River played a starring role in the American 

Revolution and provided a crucial transportation link from the eastern 

seaboard through the Erie Canal to the country’s interior.

The lower Hudson’s unique configuration as a narrow, 154-mile-long 

estuary creates a huge, diverse nursery that supports a mix of freshwater 

and saltwater fish. The river’s marshes and tidal flats contribute essential 

minerals and nutrients to the food chain, allowing its quiet backwaters 

clockwise from left: Long Island Sound, pictured here has eight 

outdated power plants that use over 5 billion gallons of water per day. At the Indian Point power plant, situated in a narrow section of the 

Hudson River estuary and pictured here, has entrained 1.2 to 1.3 billion 

fish eggs and larvae in a year. Ospreys, like these in Long Island, depend 

on healthy fish populations for survival. The Long Island Sound isn’t 

only a sanctuary for wildlife, like the starfish pictured here, but also for 

people and communities who enjoy the outdoors. The Hudson River, 

pictured here has four outdated power plants on its shores that use well 

over 4 billion gallons of water per day. 

HUDSON RIVER, 

LONG ISLAND

SOUND AND

NEW YORK HARBOR

to become an essential nursery habitat for many types of wildlife. In fact, 

the Hudson is one of the two principal spawning grounds for aquatic life 

in the East Coast. 

More than two hundred species of fish are found in the Hudson and its 

tributaries, which make up one of the most biodiverse temperate estuaries 

on the planet. The river is a refuge for rare and endangered species such 

as the shortnose sturgeon and heartleaf plantain.41 The Hudson is also 

part of the great Atlantic flyway for migratory birds; and ducks, geese and 

osprey, among others, stop to feed in its shallows. 

The ecological influence of the Hudson estuary extends far into 

the Atlantic Ocean and along the coast. For vast schools of migratory 

sturgeon, herring, blue crab, mackerel and striped bass, the Hudson is a 

nearly unimpeded corridor from the Atlantic to their ancestral spawning 

grounds. These fish support a 350-year-old recreational and commercial 

fishery along the Atlantic coast that’s worth hundreds of millions of 

dollars.42 

In 1998, the Hudson River was designated as one of the nation’s first 

American Heritage Rivers, a much-deserved recognition of its central 

place in American history and culture. The New York State Legislature has 

declared the estuary “of statewide and national importance as a habitat for 

marine, anadromous, catadromous, riverine and freshwater fish species,”43

and two federal agencies—the U.S. National Oceanographic and 

Atmospheric Administration and the U.S Fish and Wildlife Service—

have designated the Hudson as an Essential Fish Habitat because it 

sustains large numbers of commercially important fish species.44 Indian Point Photo: riverkeeper, Inc.
16 Giant Fish Blenders Giant Fish Blenders 17

Long Island Sound

The Long Island Sound is a 110-mile-long estuary bordered by the 

Connecticut coastline and the north shore of Long Island, New York. 

It receives the flow of several major rivers that drain freshwater from 

Massachusetts, New Hampshire, Vermont and other states. The Sound 

is a unique estuary in that it has two connections to the sea: to the east, 

it opens to the Atlantic Ocean, and to the west, it connects to New York 

Harbor and the Hudson and East Rivers. The Sound provides feeding, 

breeding, nesting and nursery areas for a broad diversity of plant and 

animal life, including marine fish and shellfish species such as winter 

flounder, Atlantic menhaden, blue crab, shrimp and lobster. 

The extensive tidal marshes bordering the sound are some of the most 

productive biological systems in the world. They produce between three 

and seven tons per acre per year of vegetation; much of this eventually 

enters the waters of the sound to support fish and shellfish habitat.

More than eight million people live in the Long Island Sound 

watershed, which contributes an estimated $8 billion per year to the 

regional economy through boating, commercial fishing and sportfishing, 

swimming and tourism.45 Long Island Sound was designated as an Estuary 

of National Significance, and some of its harbors have been designated 

as a Significant Coastal Fish and Wildlife Habitat Area or Essential 

Fish Habitat under the Magnuson-Stevens Fishery Conservation and 

Management Act. 

New York Harbor

In the shadow of Manhattan’s skyscrapers, New York Harbor and the 

East River connect the metropolitan area’s two major estuary systems, the 

Hudson and Long Island Sound. The National Marine Fisheries Service 

has noted that four species of sea turtles may inhabit the vicinity of New 

York: Kemp’s Ridley, green, leatherback and loggerhead; the first three are 

listed as endangered.

How Power Plant Intake Structures Harm the Hudson River, 

Long Island Sound and New York Harbor

A total of 17 power plants using once-through cooling are located in the 

region: four on the Hudson River, eight on the Long Island Sound and five 

in New York Harbor. New York has 12 of these plants, and Connecticut 

five. Two of these plants are nuclear, and the rest burn natural gas or oil, 

with the exceptions of the Bridgeport Harbor plant in Connecticut and 

Danskammer plant in New York, both of which have coal-fired units. All 

these plants use exorbitant amounts of water. The two nuclear plants, the 

Indian Point plant on the Hudson and the Millstone plant on the Sound, 

can withdraw 2.5 billion and 2.19 billion gallons per day, respectively. 

The Hudson River plants have a combined intake capacity of nearly 

5 billion gallons per day; the Long Island Sound plants have a combined 

intake capacity exceeding 5 billion gallons per day; and the New York 

Harbor and East River plants have a combined intake capacity of more 

than 3.5 billion gallons per day. Altogether, the 17 plants can withdraw 

almost 14 billion gallons per day from the two estuaries and the harbor. 

(See Appendix, Table 4, for a full list of the Hudson River, Long Island 

Sound and New York Harbor plants and their intake flow rates.) 

Because of these waters’ importance as spawning and nursery grounds, 

it is unsurprising that entrainment of eggs and larvae occur in astronomic 

numbers. 

According to Soundkeeper’s calculations, based on available data, the 

Millstone plant is responsible for killing 154 billion fish in all life stages 

over the span of more than three decades.46 These calculations are very 

conservative, considering that the data only include seven species found in 

the Sound—winter flounder, cunner, bay anchovies, tautog, menhaden, 

grubby and American sand lance—and do not include lobsters, crabs, 

shellfish and other area fish.47 In particular, Millstone killed nearly 42 

billion tautog eggs and larvae between 1979 and 2002 and well over 4 

billion winter flounder between 1976 and 2003.48

Huge numbers of fish are also entrained at the Indian Point power 

plant, situated in a narrow section of the Hudson River estuary just 

south of Peekskill. As reported by the New York State Department of 

Environmental Conservation, 1.2 to 1.3 billion fish eggs and larvae 

are entrained at Indian Point each year.49 Further, an average of 1.18 

million fish per year was impinged by Indian Point from 1986 to 1990.50

The Indian Point plant impinges the endangered shortnose sturgeon 

and the Atlantic sturgeon, a candidate for threatened species status, 

thereby negatively contributing to the already low populations of these 

fish.51 These devastating impacts were understood decades ago: In the 

1970s, the Atomic Energy Commission, and its successor, the Nuclear 

Regulatory Commission, directed the owners of Indian Point to install 

closed-cycle cooling because of the anticipated damage to the Hudson’s 

fisheries and ecosystem.52

Indian Point and the other three power plants using once-through 

cooling on the Hudson have a huge, detrimental impact on the ecology of 

the estuary—and this impact goes well beyond the loss of large numbers 

of individual fish. In a 2007 report, New York State found that the 

cumulative impact of multiple facilities on the river substantially reduces 

the population of young fish in the entire river. In certain years those 

plants have entrained between 33 and 79 percent of the eggs and larvae 

spawned by striped bass, American shad, Atlantic tomcod and five other 

important species.53 Over the time the plants have been operating, the 

ecology of the Hudson River has been altered, with many fish species 

in decline and populations becoming less stable. Of the 13 key species 

subject to intensive study, ten have declined in abundance, some greatly.54

Power plants have played a considerable role in that decline. 

The power plants that rely on outdated once-through cooling to generate 

electricity affect the full spectrum of wildlife in the aquatic ecosystem at all 

life stages. New York’s iconic Hudson River, New York Harbor and Long 

Island Sound are not only home to countless wildlife species but are also 

vital waterways for the cities and communities around them.

left: New York Harbor, pictured here, has five antiquated power plants on its 

shores that use well over 3 billion gallons of water per day. 

right: Outdated coal power plants on our rivers, like Danskammer on the 

Hudson River, suck in almost half a billion gallons of water per day. PHoto: Giles Ashford
18 Giant Fish Blenders Giant Fish Blenders 19

T

he spectacular 840-mile Pacific Coast of California, 

legendary to surfers and beachcombers around the world, 

offers an incredible variety of shoreline habitats—exposed 

rocky shores, kelp forests, sandy beaches, sheltered muddy 

estuaries and hypersaline lagoons. The Pacific Ocean supports 

a rich diversity of species and habitats, including populations of seabirds 

and shorebirds; marine mammals like humpback whales, elephant seals 

and sea lions; and fish such as barracuda, mackerel, salmon, albacore, 

bluefin and yellowfin tuna, and sardine and rainbow trout, to name 

just a few. A number of threatened and endangered fish species live in 

California’s coastal waters.

The northern portion, stretching from the Oregon border to San 

Francisco, is a landscape of rugged coastlines and towering majestic 

redwoods at or near the water’s edge, with incredible vistas and opportunities 

for hiking, kayaking, river rafting, mountain biking, wildlife-watching, 

rock climbing, fishing and camping. Tidelands and marshes in this area 

provide important habitat for many species of waterfowl, shorebirds and 

marine invertebrates, as well as nursery areas for fish and crustaceans. The 

Point Reyes peninsula alone supports 45 percent of North American bird 

species and almost 15 percent of Californian plant species, including 23 

threatened and endangered species.55

The San Francisco Bay and Delta is one of the largest estuarine systems 

on the West Coast and a highly dynamic and complex environment. 

The delta is a maze of river channels and diked islands covering over 

1,000 square miles, including 78 square miles of water, formed by the 

confluence of the Sacramento and San Joaquin Rivers, which ultimately 

drain into San Francisco Bay.56

San Francisco Bay is made up of deepwater channels, tidelands, 

marshlands, freshwater streams and rivers that provide a wide variety of 

habitats that sustain a highly biologically diverse ecosystem. More than 

half of the endangered species in San Francisco Bay depend on wetlands 

to survive, including the California clapper rail and salt marsh harvest 

mouse. Local fish species on the federal endangered and threatened 

species list include the winter-run chinook salmon and the Sacramento 

splittail. Nearly all of the San Francisco Bay region beaches form part 

of the Golden Gate National Recreation Area, one of the most visited 

National Parks, with more than 13 million visitors each year.57

The central and southern coasts extend from the Monterey Peninsula 

to the Mexican border. Here one finds wildlife refuges, state parks and 

pristine beaches popular for surfing, hiking and camping. There are 

graceful, towering sand dunes that protect bays, coastal lagoons, harbors 

and coves popular for kayaking and fishing. 

The angle of the Southern California coastline creates a huge 

backwater eddy in which equatorial waters flow north near the shore, and 

subarctic waters flow south offshore. The mixing of these waters creates a 

highly diverse system that supports about 500 fish and more than 5,000 

invertebrate species.58 This scenic and diverse region contains numerous 

wilderness areas, nature reserves, wildlife preserves and open-space areas. 

California’s commercial fishing operations rank higher than any other 

state in the nation. Tuna is the most valuable fish caught, followed by 

swordfish. Halibut, herring, mackerel, rockfish, sablefish, salmon and sole 

are also important to the fishery, as are crabs, shrimp and squid.59

As a mark of this waterway’s importance, the California Coastal National 

Monument, encompassing the entire coastline, was created by presidential 

proclamation in 2000 to ensure the protection of all islets, reefs and rock 

outcroppings from the coast to a distance of 12 nautical miles. 

How Power Plant Intake Structures Harm the California Coast

There are 17 coastal Californian power plants using once-through cooling 

systems. These plants can withdraw more than 14 billion gallons per day from 

the Pacific Ocean. Nearly 5 billion gallons of that flow is withdrawn by two 

nuclear plants: the San Onofre Nuclear Generating Station near San Clemente 

and the Diablo Canyon plant near San Luis Obispo. (See Appendix, Table 5, 

for a full list of California plants and their intake flow rates.) 

These power plants kill an astounding number of fish. The annual 

entrainment of larval fish at the Diablo Canyon plant at average flow 

is estimated to be over 1.5 billion individuals.60 At the San Onofre 

Nuclear Generating Station on the Southern California coast, 121 tons of 

midwater fish are entrained, causing a 34 to 70 percent decline in Pacific 

Ocean fish populations within about two miles (three kilometers).61 Unit 

3 of the San Onofre plant alone is estimated to entrain an average of over 

3.1 billion individual aquatic organisms. 

The Pittsburg and Contra Costa plants in the San Francisco Bay Delta 

impinge and entrain more than 300,000 endangered and threatened 

fish per year, including the Sacramento splittail, Chinook salmon and 

steelhead trout.The Contra Costa and Pittsburg power plants entrain and 

impinge threatened Delta smelt and endangered Longfin smelt.62

In addition to the entrainment of young life stages, Californian 

coastal plants impinge and kill huge numbers of older fish on their filter 

screens. At average flow rates, San Onofre’s Units 2 and 3 combined 

were estimated to impinge 1.3 million fish with a total weight of over 14 

tons.63 This is the worst example on the California coast, but other plants 

also impinge significantly large numbers of fish. Units 6 and 7 at the Moss 

Landing plant were estimated to annually impinge a quarter of a million 

fish weighing 4,060 pounds, even though the plant’s average intake flow 

is a relatively modest 387 million gallons per day.64

 In May 2010, California adopted a strong state policy requiring 

most coastal power plants to upgrade over the next decade to achieve 

protections equivalent to those offered by closed-cycle cooling. However, 

the dirty energy industry continues to fight these requirements. 

When contemplating the beauty of the Golden State, admirers 

invariably point to the breathtaking shoreline that has shaped California 

both culturally and historically. Power plants must help protect the 

beauty and economic vitality of the California Coast by using modern 

cooing system technologies.

clockwise from left: On the California coast, there 17 antiquated power plants 

that suck in over 15 billion gallons of water every day. While smaller aquatic life is 

killed by outdated power plants, the affects move up the food chain to larger animals 

like whales that pass the California coast. California’s shores are known not only for its 

amazing wildlife, but also its outdoor activities like scuba diving and surfing. Healthy 

San 

tuna shoals, like the one shown here, are vital to economy of California. 

Onofre photo: © 2010 Darrell Clarke, courtesy Sierra Club Library 

CALIFORNIA

COAST
20 Giant Fish Blenders Giant Fish Blenders 21

Famous for its blue crabs, the fishing communities around the Chesapeake Bay are 

dependent on healthy populations for their livelihoods. The Chesapeake creates 

opportunities for recreational and commercial fishing; is a beautiful place to swim, 

hike and boat. Once endangered bald eagles living in the Bay, like the ones shown 

here, are reliant on strong healthy fish populations. The 13 antiquated power plants 

on the Bay can withdraw more than 8 billion gallons of water per day.

S

tretching 200 miles across Maryland and Virginia—and 

with a watershed also encompassing Pennsylvania, Delaware, 

West Virginia, New York and the District of Columbia—

Chesapeake Bay is the largest estuary in the United States and 

the third-largest in the world. The Chesapeake was formed 

about 12,000 years ago, as glaciers melted and flooded the Susquehanna 

River valley. The Chesapeake Bay watershed is 64,000 square miles 

and includes more than 10,000 miles of tidal shoreline, including tidal 

wetlands and islands. 

The Chesapeake Bay is fed by five major rivers: the Susquehanna, 

Potomac, Rappahannock, York and James. The Chesapeake holds more 

than 15 trillion gallons of water and, although its length and width are 

dramatically expansive, its average depth is only about 21 feet, making 

it sensitive to temperature changes and discharges.65 Approximately 17 

million people live in the watershed, 10 million of them along its shores 

or near them.66

Together with the rivers, creeks and streams that feed it, the Chesapeake 

Bay provides a vital habitat for many aquatic species. Within the sheltered 

waters of the Chesapeake, underwater seagrass beds support the base of 

the food chain. These beds offer food and protection for a large number 

of small animals and a nursery for young fish. More than 300 species of 

fish, 170 species of shellfish and 2,700 species of plants are found in the 

Chesapeake.67

The Chesapeake’s fish species include striped bass, trout, flounder, 

bluefish, Spanish mackerel, channel bass, yellow and white perch, herring 

and American shad. The Chesapeake is a key component in the Atlantic 

flyway: More than a million ducks, geese and swans spend winters here 

each year and it provides stopover habitat to thousands of other migrating 

birds.68 This delicate, complex ecosystem is home to a number of plant and 

animal species that are currently designated as threatened or endangered, 

including the peregrine falcon, loggerhead and Atlantic Ridley turtles 

and the shortnose sturgeon. The once-endangered bald eagle lives in the 

region, too, appropriately in close proximity to our nation’s capital.

Along with being a vital ecosystem with a rich diversity of species, 

the Chesapeake offers wonderfully scenic places to visit. The shallow, 

protected waters of the Chesapeake Bay and its tributaries are ideal 

for canoeing and kayaking. The region offers opportunities for water 

recreation sports, including fishing, boating and swimming, as well as 

excellent trails along the water for bird-watching, hiking and mountain 

biking.

One of the Chesapeake’s most significant contributions to the region’s 

economy is its seafood industry. The Chesapeake is especially renowned 

for its blue crabs, clams, oysters and striped bass. More than 500 million 

pounds of seafood are harvested from the Chesapeake every year.69 A 

2008 U.S. National Oceanic and Atmospheric Administration report 

indicated that the commercial seafood industry in Maryland and Virginia 

contributed $3 billion and more than 41,000 jobs to the local economy.70

How Power Plant Intake Structures Harm Chesapeake Bay

At least seven power plants in Maryland and six in Virginia use oncethrough cooling systems on the shoreline of the Chesapeake Bay or on 

saline or brackish waters in immediate proximity to the bay. Of these 

13 plants, two are nuclear (Calvert Cliffs in Maryland and Surry in 

Virginia), four are coal-fired (the Chesapeake, Chesterfield and Potomac 

River plants in Virginia and the Morgantown plant in Maryland), and 

seven burn natural gas or oil. The Calvert Cliffs nuclear plant is the 

largest cooling water user in the Chesapeake, with a design intake flow 

rate of more than 2.2 billion gallons per day. It is followed by Virginia’s 

Surry and Yorktown plants and Maryland’s Morgantown and Herbert A. 

Wagner plants, each of which can withdraw between 1 and 1.5 billion 

gallons of water per day. Together, these 13 power plants can withdraw 

more than 8 billion gallons of water per day. (See Appendix, Table 6, for 

a full list of Chesapeake plants and their intake flow rates.) 

The removal of large volumes of water from a habitat as rich in wildlife 

as the Chesapeake Bay inevitably leads to environmental degradation. For 

example, Calvert Cliffs plant in Maryland was estimated to impinge an 

average of 1.3 million fish a year between 1975 and 1995 with a total 

weight of about 10 tons.71 The plant also impinges an average of 627,000 

blue crab per year.72 In certain environmental conditions, Calvert Cliffs 

has caused fish impingement incidents of staggering proportion: On 

August 28, 1984, the plant impinged 146,000 spot fish in just one hour, 

and on August 2, 1984, 12,650 blue crab were collected from its Unit 1 

screens in one hour.73 Such massive fish kills have also caused operational 

problems like blockages and damage to the screens.74

 Entrainment losses of Chesapeake populations are also considerable. 

The Chalk Point power plant on the Patuxent River estuary in Prince 

George’s County, Maryland, has two units that use once-through cooling, 

which together extract 500,000 gallons per minute from the estuary.75 The 

Power Plant Research Program of the Maryland Department of Natural 

Resources estimated that Chalk Point’s entrainment of bay anchovies 

could be as high as 76 percent of the local stock.76

The Chesapeake Bay and its tributaries are broadly recognized as a 

national treasure and vital resource. The Chesapeake creates opportunities 

for recreational and commercial fishing; is a beautiful place to swim, hike 

and boat; and is a world-class ecosystem for an untold number of species. 

The power plants along the Bay must upgrade their outdated systems to 

protect this iconic waterbody. 

CHESAPEAKE

BAY
22 Gian

t Fish Blenders Gian

t Fish Blenders 23

Photo: PISCES Conservation, Ltd

The Environmental Protection Agency is charged with 

implementing Section 316(b) of the Clean Water Act, which 

requires the use of the best available technologies to minimize the 

environmental impact of power plants’ cooling water withdrawals. 

The modern closed-cycle cooling technology reduces the 

impacts of cooling water systems, is cost-effective, and is in use 

at many power plants across the country. It reduces water intakes 

by approximately 95 percent, drastically reducing the amount 

of water needed for power plant operations, thus resulting in a 

corresponding reduction in their impact on fish and other species.

Unfortunately, the EPA, under intense pressure from 

powerful industry interests, has ducked its responsibilities by not 

requiring existing power plants to upgrade to closed-cycle cooling 

or similar systems. Instead, in March 2011, the EPA proposed 

a rule that largely maintains the status quo, mandating little to 

no improvement in the technologies necessary to protect our 

waterways and our wildlife. The EPA’s proposed rule sets a goal 

for impingement reductions that is already being achieved by 

75 percent of U.S. power plants, thus requiring only marginal 

improvement in fish impingement across the country, and fails to 

set a performance standard for entrainment of wildlife.

Worse yet, the EPA left decisions about modernizing 

existing power plants to already overstrained state permitting 

agencies. These are the same state permitting agencies that have 

been authorized to order improvements for more than 30 years 

but have instead done almost nothing to reduce the impact 

power plants have on aquatic ecosystems. Today, almost half of 

the water permits for existing coal-fired power plants are expired 

because state agencies have either abandoned their obligation to 

faithfully uphold and enforce our clean water protections or are 

too overburdened to comply.

Almost 40 years after Congress identified cooling water 

intake as a threat to our waterways, the EPA has failed to force the 

owners of existing power plants—the nation’s largest water users—

to reduce their destructive impact. With its recent proposed rule, 

the EPA perpetuates this missed opportunity by leaving decisions 

about technology improvements to overburdened states that have 

proven incapable or unwilling to require power plants to phase out 

once-through cooling.

A clear, consistent national policy that restores and protects 

our waterways by phasing out once-through cooling is long 

overdue. The simple and cost-effective step of phasing out this 

outdated and destructive technology would represent a huge step 

forward in the nation’s unfinished business of ensuring clean, safe 

and abundant waterways for all Americans.

T

he six examples in this report illustrate the real and immediate impacts of cooling water intake structures. 

The massacre caused by this antiquated technology is clear: The full spectrum of aquatic species and wildlife 

that rely on complex food chains in our lakes and rivers and on our shores—from phytoplankton to fish, birds, 

and marine mammals, and including species that are already threatened or endangered—is impacted by oncethrough cooling. Some areas face devastating economic impacts as fisheries are threatened and recreational uses 

are diminished. 

conclusion
24 Giant Fish Blenders Giant Fish Blenders 25

Table 3: Mississippi River Facilities

PLANT NAME STATE FUEL TYPE DAILYINTAKE CAPACITY

(millions of gallons)

Allen Steam Plant Tennessee Coal 497

Alma Wisconsin Coal 182

Baxter Wilson Mississippi Oil/Gas 592

Big Cajun 2 Louisiana Coal 362

Burlington Iowa Oil/Gas 116

Genoa Wisconsin Coal 244

High Bridge Minnesota Gas 202

John P. Madgett Wisconsin Coal 322

Lansing Iowa Coal 331

LaO Energy Systems Louisiana Gas 131

Little Gypsy Louisiana Oil/Gas 934

Meramec Missouri Coal 675

Milton L. Kapp Iowa Coal 175

Monticello Minnesota Nuclear 367

Muscatine, Unit 1 Iowa Coal 301

Nelson Dewey Wisconsin Coal 144

New Madrid Missouri Coal 956

Nine Mile Point Louisiana Coal 1,497

Prairie Island Minnesota Nuclear 911

Quad Cities Illinois Nuclear 1,353

Riverside Iowa Coal 247

Riverside Minnesota Coal 277

Robert E. Ritchie Arkansas Oil 443

Rush Island Missouri Coal 863

Sioux Missouri Coal 705

Waterford, 

Units 1,2 & 3 Louisiana Oil/Gas/Nuclear 2,021

Willow Glen Louisiana Gas 1,292

Wood River Illinois Coal 589

Total Mississippi River facilities (28) 16,428

Sources: U.S. Energy Information Administration, Form EIA-860, Annual Electric Generator Report, 2009; 

Environmental Directory of U.S. Power Plants, Edison Electric Institute, 1991.

Note: Includes plants located on the main stem of the Mississippi. Where there is more than one cooling 

system at a plant site, the table gives the intake capacity for the units using once-through cooling. The 

Monticello nuclear plant uses mechanical draft cooling towers from May through September.

Table 2: Gulf of Mexico Facilities

PLANT NAME STATE FUEL TYPE DAILYINTAKE CAPACITY

(millions of gallons)

A. B. Paterson Louisiana Oil/Gas 216

Anclote Florida Oil/Gas 2,864

Barney M. Davis Texas Oil/Gas 337

Big Bend Florida Coal 1,395

Crystal River, 

Units 1, 2 & 3 Florida Coal/Nuclear 2,168

Deepwater Texas Oil/Gas 125

Jack Watson Mississippi Coal 125

Fort Myers Florida Oil/Gas 563

Lansing Smith Florida Coal 274

Michoud Louisiana Oil/Gas 748

Nueces Bay Texas Oil/Gas 528

P. H. Robinson Texas Oil/Gas 1,715

P. L. Bartow Florida Oil/Gas 561

S. O. Purdom Florida Oil/Gas 62

Sabine Texas Oil/Gas 443

Sam Bertron Texas Oil/Gas 736

Webster Texas Oil/Gas 115

Total Gulf of Mexico facilities (17) 12,975

Source: U.S. Energy Information Administration, Form EIA-860, Annual Electric Generator Report, 2009.

Note: Includes plants located on the Gulf of Mexico or in coastal bays or other marine waters in immediate 

proximity.

Table 1: Great Lakes Facilities

PLANT NAME STATE FUEL TYPE DAILYINTAKE CAPACITY

(millions of gallons)

Lake erie

Ashtabula Ohio Coal 1,017

Avon Lake Ohio Coal 1,608

Bay Shore Ohio Coal 742

Conners Creek Michigan Coal 323

Dunkirk New York Coal 579

Eastlake Ohio Coal 1,158

J. R. Whiting Michigan Coal 308

Lake Shore Ohio Coal 623

Mistersky Michigan Oil/Gas 198

Monroe Michigan Coal 2,013

River Rouge Michigan Coal 648

Total Lake Erie facilities (12) 9,217

Lake Michigan

B. C. Cobb Michigan Coal 558

Bailly Indiana Coal 443

Crawford Illinois Coal 552

Dean H. Mitchell Indiana Coal 746

Donald C. Cook Michigan Nuclear 2,143

Edgewater Wisconsin Coal 407

Fisk Illinois Coal 302

J. H. Campbell Michigan Coal 886

Kewaunee Nuclear Wisconsin Nuclear 460

Michigan City Indiana Coal 230

Point Beach Nuclear Wisconsin Nuclear 1,025

Port Washington Wisconsin Gas 594

Pulliam Wisconsin Coal 565

South Oak Creek Wisconsin Coal 1,137

State Line Indiana Coal 606

Trenton Channel Michigan Coal 516

Valley Wisconsin Coal 162

Waukegan Illinois Coal 852

Will County Illinois Coal 1,292

Total Lake Michigan facilities (18) 13,476

APPENDIX

Lake Huron

Belle River Michigan Coal 950

Dan E. Karn Michigan Coal 465

Harbor Beach Michigan Coal 129

J. C. Weadock Michigan Coal 345

Marysville Michigan Coal 609

St. Clair Michigan Coal 1,344

Total Lake Huron facilities (6) 3,842

Lake ontario

Ginna New York Nuclear 490

Huntley New York Coal 846

James A. Fitzpatrick New York Nuclear 596

Nine Mile Point New York Nuclear 490

Oswego Harbor Power New York Oil/Gas 1,399

Total Lake Ontario facilities (5) 3,821

Lake Superior

Presque Isle Michigan Coal 415

Total Great Lakes facilities (42) 30,771

Sources: U.S. Energy Information Administration, Form EIA-860, Annual Electric Generator Report, 2009; 

New York State Department of Environmental Conservation, Best Technology Available (BTA) for Cooling 

Water Intake Structures, draft policy, March 4, 2010, App. A, Table 1; Environmental Directory of U.S. Power 

Plants, Edison Electric Institute, 1991.

Note: Includes plants located on the shore of a Great Lake or on a tributary in close proximity. 

Power Plants Using Once-Through Cooling
26 Giant Fish Blenders Giant Fish Blenders 27

Endnotes Table 5: California Coast Facilities

PLANT NAME FUEL TYPE DAILYINTAKE CAPACITY

(millions of gallons)

Alamitos Oil/Gas 1,273

Contra Costa Units 6 & 7 Oil/Gas 440

Diablo Canyon Nuclear 2,528

El Segundo Oil/Gas 399

Encina Oil/Gas 857

Harbor Gas 108

Haynes Oil/Gas 968

Huntington Beach Oil/Gas 514

Mandalay Oil/Gas 253

Morro Bay Oil/Gas 668

Moss Landing 

Units 1, 2, 6 & 7 Oil/Gas 1,226

Ormond Beach Oil/Gas 685

Pittsburg Units 5, 6 &7 Oil/Gas 462

 Redondo Beach 

Units 5, 6, 7 & 8 Oil/Gas 892

San Onofre Units 2 & 3 Nuclear 2,438

Scattergood Oil/Gas 495

South Bay Oil/Gas 601

Total California facilities (17) 15,038

Source: Water Quality Control Policy on the Use of Coastal and Estuarine Waters for Power Plant Cooling, 

Final Substitute Environmental Document, State Water Resources Control Board, California Environmental 

Protection Agency, May 4, 2010, pp. 36–38, Section 2.4, Table 4. http://www.swrcb.ca.gov/water_issues/

programs/ocean/cwa316/docs/cwa316may2010/sed_final.pdf

Note: The following plants were not included because they are retiring or repowering with dry cooling:. 

Hunters Point plant (retiring); South Bay plant (retiring); Humboldt Bay (repowering).

Table 6: Chesapeake Bay Facilities

PLANT NAME state FUEL TYPE DAILYINTAKE CAPACITY

(millions of gallons)

Calvert Cliffs Maryland Nuclear 2,233

Chalk Point Maryland Oil/Gas 731

Chesapeake Virginia Coal 514

Chesterfield Virginia Coal 846

Gould Street Maryland Oil/Gas 99

Herbert A. Wagner Maryland Oil/Gas 1,098

Morgantown Maryland Coal 1,442

Possum Point Virginia Oil/Gas 224

Potomac River Virginia Coal 450

Riverside Maryland Oil/Gas 54

Sparrows Point Maryland Gas 297

Surry Virginia Nuclear 1,550

Yorktown Virginia Oil/Gas 1,445

Total Chesapeake Bay facilities (13) 10,983

Sources: U.S. Energy Information Administration, Form EIA-860, Annual Electric Generator Report, 2009; 

Environmental Directory of U.S. Power Plants, Edison Electric Institute, 1991.

Note: Includes plants located on Chesapeake Bay or on other saline or brackish waters in immediate 

proximity to the bay.

Table 4: Hudson River, Long Island Sound, 

and New York Harbor Facilities

PLANT NAME STATE FUEL TYPE DAILYINTAKE CAPACITY

(millions of gallons)

Hudson River

Bowline New York Oil/Gas 912

Danskammer New York Coal 457

Indian Point New York Nuclear 2,500

Roseton New York Oil 926

Total Hudson River facilities (4) 4,795

Long Island Sound

Bridgeport Harbor Connecticut Coal/Oil 541

Devon Connecticut Oil 262

Glenwood New York Oil/Gas 179

Millstone Connecticut Nuclear 2,190

New Haven Harbor Connecticut Oil/Gas 404

Northport New York Oil/Gas 939

Norwalk Harbor Connecticut Oil 298

Port Jefferson New York Oil/Gas 399

Total Long Island Sound facilities (8) 5,212

New York Harbor

Arthur Kill New York Oil 713

Astoria Generating New York Oil/Gas 1,254

Brooklyn Navy Yard New York Gas 55

East River Generating New York Oil/Gas 369

Ravenswood New York Oil/Gas 1,391

Total New York Harbor facilities (5) 3,782

Total River, Sound & Harbor facilities (19) 13,789

Sources: New York State Department of Environmental Conservation, Best Technology Available (BTA) 

for Cooling Water Intake Structures, draft policy, March 4, 2010, App. A, Table 1; U.S. Energy Information 

Administration, Form EIA-860, Annual Electric Generator Report, 2009; Environmental Directory of U.S. 

Power Plants, Edison Electric Institute, 1991; Dominion Nuclear Connecticut Millstone Power Station, 

NPDES permit, Revised Fact Sheet, December 10, 2007. http://www.ct.gov/dep/lib/dep/public_notice_

attachments/draft_permits/071210_millstone_revised_fact_sheet.pdf (last visited May 11, 2011)

Note: Includes plants on the tidal estuary portion of the Hudson River, the shoreline of the Long Island 

Sound or on saline or brackish waters in immediate proximity to the Sound, and on the East River and 

Arthur Kill. 

Introduction

1 U.S. EPA, Technical Development Document for the Proposed Section 316(b) Phase II

Existing Facilities Rule (2011), at 4-4, Exh. 4-1.

2 J.F. Kenny et al., Estimated Use of Water in the United States in 2005, U.S. Geological 

Survey Report, Circular 1344 (2009), at 38, http://pubs.usgs.gov/circ/1344/pdf/

c1344.pdf (last visited May 2011)

3 Ibid.

4 U.S. EPA, Final Regulations to Establish Requirements for Cooling Water Intake 

Structures at Phase II Existing Facilities, 69 Fed. Reg. 41,576, 41,586 (July 9, 2004)

5 California Environmental Protection Agency, Draft Final Policy on the Use of Coastal 

and Estuarine Waters for Power Plant Cooling, State Water Resources Control 

Board, May 4, 2010, http://www.waterboards.ca.gov/board_info/minutes/2010/

may/050410_5_staffpresentation.pdf (last visited May 2011).

6 66 Fed. Reg. at 65,292.

7 69 Fed Reg. at 41,587–88.

8 Thermal Pollution, Hearings Before the Subcommittee on Air and Water of the 

Senate Committee on Public Works, 90th Cong., Parts 1–4 (1968); Environmental 

Effects of Producing Electric Power, Hearings Before the Joint Committee on Atomic 

Energy, 91st Cong., Part 1, 341–45, 375–76 (1969).

9 113 Cong. Rec. 30129 (1967). 

10 Office of Science and Technology of the Executive Office of the President, 

Considerations Affecting Steam Power Plant Site Selection, 46 (1968).

11 United States Code, Title 33, Section 1326(b).

12 Code of Federal Regulation, Title 40, Part 125, Subpart I, Requirements Applicable 

to Cooling Water Intake Structures for New Facilities Under Section 316(b) of the 

Act.

13 http://www.great-lakes.net/lakes (last visited May 2011).

Great Lakes

14 http://www.great-lakes.net/tourism/#overview (last visited June 2011).

15 American Sportfishing Association, Economic Impact of Great Lakes Fishing by 

State in 2006. http://www.asafishing.org/statistics/saleco_trends/2006ei_glakes_

state.html (last visited June 2011).

16 John C. Austin, Soren Anderson, Paul N. Courant and Robert E. Litan, Healthy 

Waters, Strong Economy: The Benefits of Restoring the Great Lakes Ecosystem, 

Brookings Institution, Great Lakes Economic Initiative, September 2007, http://

www.brookings.edu/metro/pubs/20070904_gleiecosystem.pdf (last visited June 

2011).

17 Applicant’s Environmental Report Operating License Renewal Stage, Appendix E, 

Donald C. Cook Nuclear Plant, October 2003.

18  Kinetrics, Bay Shore Power Plant Cooling Water Intake Structure Information and 

I&E Sampling Data (January 2008), http://www.epa.state.oh.us/portals/35/permits/

bayshore_IE_data_collection.pdf (last visited May 2011).

19 Wisconsin Department of Natural Resources, Final EIS for the Elm Road power 

plant, Chapter 8, Public Service Commission.

20 New York State Department of Environmental Conservation, Best Technology 

Available (BTA) for Cooling Water Intake Structures, DEC Policy Issuing Authority: 

Alexander B. Grannis, Commissioner March 4, 2010.

21 R. S. Benda et al. “Comparison of Fish Impingement at the Palisades Nuclear Power 

Plant for Once-Through and Closed-Cycle Cooling,” Indiana Academy of Science, 

155–60.

Gulf of Mexico 

22 EPA General Facts about the Gulf of Mexico http://www.epa.gov/gmpo/about/

facts.html and http://www.epa.gov/gmpo/edresources/watrshed.html (last visited 

May 2011).

23 http://www.epa.gov/gmpo/about/facts.html (last visited May 2011).

24 National Oceanic and Atmospheric Administration Fisheries Service, An Overview 

or Protected Species Commonly Found in the Gulf of Mexico (revised December 

2006), Southeast Regional Office Protected Resources Division, http://www.

offshoreoperators.com/marinedebris/Protected-Species-In-GOM-NOAA.pdf (last 

visited May 2011).

25 EPA General Facts about the Gulf of Mexico http://www.epa.gov/gmpo/about/

facts.html (last visited May 2011).

26 U.S. EPA, “General Facts about the Gulf of Mexico,” http://www.epa.gov/gmpo/

about/facts.html (last visited May 2011).

27 Ibid.

28 Ibid.

29 A. Thorhaug, N. Blake and P. B. Schroeder, “The Effect of Heated Effluents From 

Power Plants on Seagrass (Thalassia) Communities Quantitatively Comparing 

Estuaries in the Subtropics to the Tropics,” Mar. Pollut. Bull. 9, 1978, pp. 181–87.

30 Florida Power & Light Co., Assessment of the Impacts of the St. Lucie Nuclear 

Generating Plant on Sea Turtle Species Found in the Inshore Waters of Florida, 

August 1995, p. 5.

31 U.S. EPA, Large Existing Electric Generating Plants, Proposed Rule: Case Study 

Analysis for the Proposed Section 316(b) Phase II Existing Facilities Rule , Part D: 

Tampa Bay Watershed Case Study, Table D3-2, http://water.epa.gov/lawsregs/

lawsguidance/cwa/316b/phase2/upload/chd1.pdf (last visited May 16, 2011).

32 Ibid., Table D3-5.

33 Darryl L. Felder and David K. Camp, eds., Gulf of Mexico Origin, Waters, and Biota, 

Volume 1: Biodiversity, Texas A&M University Press, 2009.

Mississippi River 

34 http://www.nps.gov/miss/riverfacts.htm (last visited May 2011).

35 Ibid.

36 http://www.tn.gov/environment/watersheds/guide/mississippi_river_basin.shtml 

(last visited May 2011).

37 Burr, B.M. and R.L. Mayden. 1992. Phylogenetics and North American freshwater 

fishes. Pages 287-324 In: R.L. Mayden, (ed)Systematics Historical Ecology, and 

North American FreshwaterFishes. Stanford University Press, Stanford, California.

38 “Annual Status Report: A Summary of Fish Data in Six Reaches of the Upper 

Mississippi River System,” 2007, http://www.umesc.usgs.gov/reports_publications/

ltrmp/fish/2007/table01species_list.html (last visited May 2011).

39 These numbers come from our appendix, which cite EIA 2009 data.

40 Equitable Environmental Health, “Meramec Power Plant Entrainment and 

Impingement Effects on Biological Populations of the Mississippi River,” July 1976.

Hudson River, Long Island Sound and New York Harbor 

41 Governor George E. Pataki, American Heritage River nomination, 1998 § II, http://

www.epa.gov/rivers/98rivers/hudsonplan.html (last visited October 2003). 

President Clinton approved the application and proclaimed the Hudson an 

American Heritage River on July 30, 1998. See 63 Fed. Reg. 41949 (August 5, 1998). 

42 John Cronin and Robert F. Kennedy, Jr., The Riverkeepers, 1997. p. 21. 
28 Gian

t Fish Blenders Gian

t Fish Blenders3

Endnotes, cont’d.

43New York State Laws, 1987, ch. 612, §2. 

44 “Extraordinary Estuary,” Clearwaters, spring 2002, Vol. 32, No. 1, http://www.nywea.

org/clearwaters/321000.html (last visited July 2003).

45 $8 billion is an inflation-adjusted estimate based on the $5 billion estimate in 1992 

by Dr. Marilyn A. Altobello (“The Economic Importance of Long Island Sound’s 

Water Quality Dependent Activities”) on behalf of the Environmental Protection 

Agency.

46 Letter to Mr. Charles Nezianya, Bureau of Materials Management and Compliance 

Assurance, Connecticut Department of Environmental Protection, Water Permitting 

and Enforcement Division, from Terry Backer, Long Island Soundkeeper, January 28, 

2008, http://www.soundkeeper.org/uploads/2008.01.28.Comments_Millstone_ Draft_NPDE.pdf (last visited May 2011). The Soundkeeper calculations are based 

on the Nuclear Regulatory Commission, Supplemental Environmental Impact 

Statement for License Renewal of Nuclear Plants at the Millstone Power Station 

(NUREG 1437, Supplement 22), July 2005, http://www.nrc.gov/reading-rm/doccollections/nuregs/staff/sr1437/supplement22/index.html (last visited May 2011).

47Ibid.

48Ibid.

49 New York State Notice of Intention to Participate and Petition to Intervene, In re: 

License Renewal Application Submitted by Entergy Nuclear Indian Point 2, LLC, 

Entergy Nuclear Indian Point 3, LLC, and Entergy Nuclear Operations, Inc., U.S. 

Nuclear Regulatory Commission Docket Nos. Docket Nos. 50-247-LR and 50-286-

LR, ASLBP No. 07-858-03-LR-BD01, DPR-26, DPR-64 (Nov. 30, 2007), p. 286 available 

at http://www.dec.ny.gov/permits/40237.html (last visited June 2011)

50 Central Hudson Gas & Electric Corp. et al., “Draft Environmental Impact Statement 

for State Pollutant Discharge Elimination System Permits for Bowline Point, Indian 

Point 2 & 3, and Roseton Steam Electric Generating Stations,” December 1999.

51Ibid.

California coast 

52 See Final Environmental Impact Statement Related to the Operation of Indian 

Point Nuclear Generating Plant Unit No. 2., Consolidated Edison Company of New 

York, September 1972, Docket No. 50-247 (AEC, Directorate of Licensing); and Final 

Environmental Statement Related to Operation of Indian Point Nuclear Generating 

Plant Unit No. 3, Consolidated Edison Company of New York, February 1975, 

Docket No. 50-286 (NUREG-75/002).

53 NYSDEC, New York State Water Quality Report 2006 (published 2007).

54 PISCES Conservation, The Status of Fish Populations and the Ecology of 

the Hudson, April 2008, 37–38; see also PISCES Conservation, Entrainment, 

Impingement and Thermal Impacts at Indian Point Nuclear Power Station, 

November 2007, 43–44.

55 National Parks Conservation Association, Point Reyes National Seashore, “State of 

the Parks: AResource Assessment,” http://www.npca.org/stateoftheparks/point_

reyes/ptReyes.pdf (last visited May 2011).

56 The Water Quality Control Plant (Basin Plan) for the California Regional Water 

Quality Control Board, Central Valley Region, 4th edition, “The Sacramento River 

Basin and the San Joaquin River Basin,” I-1.00, http://www.swrcb.ca.gov/rwqcb5/

water_issues/basin_plans/sacsjr.pdf (last visited May 2011).

57 http://www.everytrail.com/destination/golden-gate-national-recreation-area (last 

visited May 2011).

58 http://mapping2.orr.noaa.gov/_old/coastalstorms/habcharactersc.html (last 

visited May 2011).

59 http://www.netstate.com/economy/ca_economy.htm (last visited May 2011).

60 “Compilation of California Power Plant Entrainment and Impingement Estimates 

for California State Water Resources Control Board Staff Issue Paper on OnceThrough Cooling,” http://waterboards.ca.gov/water_issues/programs/ocean/

cwa316/docs/erp2008/ca_powerplant_steinbeck070208.pdf (last visited May 

2011).

61 67 Fed. Reg., 17139, citing S. Swarbrick and R. F. Ambrose (1988).

62 State Water Resources Control Board, “Water Quality Control Policy on the 

Use of Coastal and Estuarine Waters for Power Plant Cooling,” Final Substitute 

Environmental Document, California Environmental Protection Agency, May 4, 

2010. Numbers of fish expressed as age 1 equivalent.

63 “Compilation of California Power Plant Entrainment and Impingement Estimates 

for California State Water Resources Control Board Staff Issue Paper on OnceThrough Cooling,” http://waterboards.ca.gov/water_issues/programs/ocean/

cwa316/docs/erp2008/ca_powerplant_steinbeck070208.pdf (last visited May 

2011).

64Ibid.

Chesapeake Bay 

65 http://www.cbf.org/Page.aspx?pid=683 (last visited May 2011).

66 http://www.cbf.org/Page.aspx?pid=433 (last visited May 2011).

67 https://allianceforthebay.org/?page_id=127 (last visited May 2011).

68 http://pubs.usgs.gov/circ/circ1316/html/circ1316chap14.html (last visited May 

2011).

69 http://www.cbf.org/Page.aspx?pid=433 (last visited May 2011).

70 http://www.chesapeakebay.net/cbfeconomicreport10.aspx?menuitem=54929 

(last visited May 2011).

71 “Investigations of Impingement of Aquatic Organisms at the Calvert Cliffs Nuclear 

Power Plant,” 1975-1995 (EPADCN 10-5444).

72Ibid.

73Ibid.

74Ibid.

75 “Effectiveness, Operation and Maintenance, and Costs of a Barrier Net System for 

Impingement Reduction at the Chalk Point Generating Station” (DCN 10-5497).

76 “State of Maryland Perspectives on Cooling Water Intake Technologies to 

Protect Aquatic Organisms,” presentation given by Richard McLean, Senior 

Administrator, Power Plant Research Program, Maryland Department Natural 

Resources, May 6–7, 2003, http://water.epa.gov/lawsregs/lawsguidance/cwa/316b/

upload/2008_06_10_316b_meetings_symposium_mclean.pdf (last visited May 

2011).