Tetra Tech, Inc.

10306 Eaton Place, Suite 340

Fairfax, VA 22030

phone 703-385-6000

TO: Paul Shriner, USEPA

FROM: Kelly Meadows

DATE: March 11, 2011

SUBJECT: Power Plants Located in 

Water-limited environments like the desert areas outside of Las Vegas can be challenging 

locations for construction of industrial facilities such as power plants, as these sites often 

require significant water resources. However, given the increasing demand for electricity 

in Las Vegas, power producers have recently constructed a number of new generating 

facilities in the vicinity. This memo documents the research into the construction of 

these facilities and the decision criteria used in selecting the facility’s design, particularly 

with respect to the cooling system.

Cooling Water System Design

Power plants generate a significant amount of waste heat that must be rejected

cooling systems often use once

limited areas are challenging locations to construct new power plants; surface water is 

usually not available (particularly in large enough quantities for a once

and competition for groundwater resources may be high (e.g., demand for drinking water 

supplies).

As a result, utility companies may opt to construct new facilities with dry cooling, a form 

of closed-cycle cooling that consumes very little water and rejects heat to the atm

through radiative cooling (instead of evaporative cooling, as in a wet cooling tower).

Dry cooling does have drawbacks, including an energy penalty to operate the fans and 

radiators.2 However, these drawbacks are greatly reduced when dry cooling is 

incorporated into the design of the power plant (as opposed to a retrofit application); for 

example, turbine systems can be designed to optimize the increased backpressure, 

 

1 Depending on the generating efficiency, as much as 50

generating power and must be rejected.

2

See the Technical Development Document for more information on dry cooling.

MEMORANDUM

10306 Eaton Place, Suite 340

, USEPA

Kelly Meadows

March 11, 2011

Power Plants Located in Water-Limited Environments

limited environments like the desert areas outside of Las Vegas can be challenging 

locations for construction of industrial facilities such as power plants, as these sites often 

water resources. However, given the increasing demand for electricity 

in Las Vegas, power producers have recently constructed a number of new generating 

facilities in the vicinity. This memo documents the research into the construction of 

s and the decision criteria used in selecting the facility’s design, particularly 

with respect to the cooling system.

Cooling Water System Design

Power plants generate a significant amount of waste heat that must be rejected

e once-through cooling. However, as discussed above, water

limited areas are challenging locations to construct new power plants; surface water is 

usually not available (particularly in large enough quantities for a once-through system) 

r groundwater resources may be high (e.g., demand for drinking water 

As a result, utility companies may opt to construct new facilities with dry cooling, a form 

cycle cooling that consumes very little water and rejects heat to the atm

through radiative cooling (instead of evaporative cooling, as in a wet cooling tower).

Dry cooling does have drawbacks, including an energy penalty to operate the fans and 

However, these drawbacks are greatly reduced when dry cooling is 

incorporated into the design of the power plant (as opposed to a retrofit application); for 

example, turbine systems can be designed to optimize the increased backpressure, 

 

Depending on the generating efficiency, as much as 50-70 percent of the heat generated is not used in 

generating power and must be rejected.

See the Technical Development Document for more information on dry cooling.

1

limited environments like the desert areas outside of Las Vegas can be challenging 

locations for construction of industrial facilities such as power plants, as these sites often 

water resources. However, given the increasing demand for electricity 

in Las Vegas, power producers have recently constructed a number of new generating 

facilities in the vicinity. This memo documents the research into the construction of 

s and the decision criteria used in selecting the facility’s design, particularly 

Power plants generate a significant amount of waste heat that must be rejected1and 

through cooling. However, as discussed above, waterlimited areas are challenging locations to construct new power plants; surface water is 

through system) 

r groundwater resources may be high (e.g., demand for drinking water 

As a result, utility companies may opt to construct new facilities with dry cooling, a form 

cycle cooling that consumes very little water and rejects heat to the atmosphere 

through radiative cooling (instead of evaporative cooling, as in a wet cooling tower).

Dry cooling does have drawbacks, including an energy penalty to operate the fans and 

However, these drawbacks are greatly reduced when dry cooling is 

incorporated into the design of the power plant (as opposed to a retrofit application); for 

example, turbine systems can be designed to optimize the increased backpressure, 

70 percent of the heat generated is not used in 
2

therefore reducing the loss of generating efficiency typically seen in closed-cycle 

systems.

New Power Plants

According to some estimates, Las Vegas has a power demand of approximately 4.8 

gigawatts.3 Given the growth in the area, generating capacity has been added to meet the 

demand. Some alternative energy (primarily solar and wind) capacity has been added but 

new power plants were still necessary. Through internet research and information from

the Department of Energy’s Energy Information Administration (EIA)], Tetra Tech was 

able to identify several power plants that are located in the Las Vegas area, with many

being constructed in recent years. Table 1 below lists these facilities.4

Table 1. New Power Plants in the Las Vegas Vicinity

Facility 

Name

Owner Generating 

Capacity 

(MW)

Fuel Type Operational 

Year

Cooling 

System 

Type1

Water 

Source

Chuck 

Lenzie

Nevada 

Power

1465 Natural gas 

combined 

cycle

2006 Dry 

cooling

Well

Clark Nevada 

Power

1377 Natural gas 

combined 

cycle and 

combustion 

turbines

1955 Mechanic

al draft

Munici

pal

Walter 

Higgins

Nevada 

Power

688 Natural gas 

combined 

cycle

2004 Dry 

cooling

Grey 

water

Silverhaw

k

Pinnacle 

West

664 Natural gas 

combined 

cycle

2004 Dry 

cooling

Well

Reid 

Gardner

Nevada 

Power

636 Coal 1965 Mechanic

al draft

Well, 

river

Apex Las Vegas 

Power 

Company

600 Natural gas 

combined 

cycle

2003 Dry 

cooling

Well

Las Vegas 

Cogenerati

on

SWG Nevada 297 Natural gas 

combined 

cycle

2003 Mechanic

al draft

Munici

pal

Harry 

Allen

Nevada 

Power

186 Natural gas 

combined 

cycle and 

combustion 

turbines

1995 Dry 

cooling

Munici

pal and 

well

Saguaro NRG Energy 127 Natural gas 1991 Dry Grey 

 

3

http://www.caslon.com.au/economyguide22.htm

4 Note that this is not intended to be an exclusive list. Some are small or similar to others listed. Others may 

only have combustion turbines, which typically do not use cooling water.
3

Facility 

Name

Owner Generating 

Capacity 

(MW)

Fuel Type Operational 

Year

Cooling 

System 

Type1

Water 

Source

and Paragon 

Assets

combined 

cycle

cooling water

Source: Energy Justice Network mapping tool. http://www.energyjustice.net/map/

1 Information confirming the cooling system type was difficult to locate; this assessment is based on aerial 

photos, available online information, and conversations with Nevada staff. Several facilities also appear to 

use cooling ponds.

Little information on the permitting process was readily available, but all indications are 

that many of the new plants were constructed in areas with very little water, making dry

cooling the only available option.

Additionally, many of these facilities would not be subject to national requirements under 

the proposed rule, as they do not meet the scoping criteria; withdrawals are not from 

surface waters and several facilities do not have NPDES permits.