This report was funded by the U.S. Department of Energy's (DOE's) National Energy Technology Laboratory (NETL) Existing Plants Research Program, which has an energy-water research effort that focuses on water use at power plants. This study complements the Existing Plants Research Program's overall research effort by evaluating water issues that could impact power plants. Obtaining adequate water supplies for cooling and other operations at a reasonable cost is a key factor in siting new and maintaining existing thermoelectric power plant operations. One way to reduce freshwater consumption is to use alternative water sources such as reclaimed (or recycled) water, mine pool water, and other nontraditional sources. The use of these alternative sources can pose institutional challenges that can cause schedule delays, increase costs, or even require plants to abandon their plans to use alternative sources. This report identifies and describes a variety of institutional challenges experienced by power plant owners and operators across the country, and for many of these challenges it identifies potential mitigating approaches. The information comes from publically available sources and from conversations with power plant owners/operators familiar with using alternative sources. Institutional challenges identified in this investigation include, but are not limited to, the following: (1) Institutional actions and decisions that are beyond the control of the power plant. Such actions can include changes in local administrative policies that can affect the use of reclaimed water, inaccurate growth projections regarding the amount of water that will be available when needed, and agency workloads and other priorities that can cause delays in the permitting and approval processes. (2) Developing, cultivating, and maintaining institutional relationships with the purveyor(s) of the alternative water source, typically a municipal wastewater treatment plant (WWTP), and with the local political organizations that can influence decisions regarding the use of the alternative source. Often a plan to use reclaimed water will work only if local politics and power plant goals converge. Even then, lengthy negotiations are often needed for the plans to come to fruition. (3) Regulatory requirements for planning and developing associated infrastructure such as pipelines, storage facilities, and back-up supplies that can require numerous approvals, permits, and public participation, all of which can create delays and increased costs. (4) Permitting requirements that may be difficult to meet, such as load-based discharge limits for wastewater or air emissions limitations for particulate matter (which will be in the mist of cooling towers that use reclaimed water high in dissolved solids). (5) Finding discharge options for cooling tower blowdown of reclaimed water that are acceptable to permitting authorities. Constituents in this wastewater can limit options for discharge. For example, discharge to rivers requires National Pollutant Discharge Elimination System (NPDES) permits whose limits may be difficult to meet, and underground injection can be limited because many potential injection sites have already been claimed for disposal of produced waters from oil and gas wells or waters associated with gas shale extraction. (6) Potential liabilities associated with using alternative sources. A power plant can be liable for damages associated with leaks from reclaimed water conveyance systems or storage areas, or with mine water that has been contaminated by unscrupulous drillers that is subsequently discharged by the power plant. (7) Community concerns that include, but are not limited to, increased saltwater drift on farmers fields; the possibility that the reclaimed water will contaminate local drinking water aquifers; determining the 'best' use of WWTP effluent; and potential health concerns associated with emissions from the cooling towers that use recycled water. (8) Interveners that raise public concerns about the potential for emissions of emerging pollutants of concern to cause health or environmental problems. Mitigating solutions range from proactive communications with the local communities (which can be implemented by the power plants) to technical solutions, such as developing means to reduce the concentrations of total dissolved solids (TDS) and other contaminants in cooling water to maintain plant efficiency and while meeting discharge limits. These kinds of solutions may be appropriate for DOE research and development (R&D) funding
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