Public Involvement
On July 22, 2002, EPA and the Massachusetts DEPjointly
issued a new proposed National Pollutant Discharge Elimi-
nation System (NPDES) Permit to Brayton Point Station
and opened a public comment period on the permit. The
agencies held information meetings on August 5 and 6, 2002,
in Somerset, Massachusetts and Bristol, Rhode Island, re-
spectively, to explain the draft permit and answer ques-
tions. The agencies held public hearings in Somerset and
Bristol on August 26 and 27, 2002, respectively, to accept
comments on the draft permit. The comment period, origi-
nally scheduled to close on September 4, 2002, was ex-
tended to October 4, 2002.
During this 2 1/2 month comment period, EPA received
more than 150 comments from elected officials, federal,
state and local government agencies, private organizations,
individual citizens and the permittee. Careful consider-
ation was given to these comments in development of the
final permit.
EPA's response to these comments, published in a docu-
ment of the same name, specifies which provisions of the
draft permit have been changed in the final permit and the
reasons for the change, and summarizes and responds to
all significant comments on the draft permit submitted dur-
ing the public comment period. This document can be
reviewed at:
www.epa.gov/ne/braytonpoint
For More Information
Call EPA toll free at 888-372-7341 and ask for
the following extensions:
Damien Houlihan
Engineering Project Manager
Phil Colarusso
Biology
Mark Stein
Legal
Angela Bonarrigo
Community Relations
or call
81586
81506
81077
81034
MA Department of Environmental Protection
David Johnston, Deputy Regional Director
(508) 946-2708
What Impact will this Permit have on
Electricity Rates for New England
Consumers?
Even after its upgrades, Brayton Point Station's three
coal and one oil / gas units will continue to be capable
of producing more than 1500 megawatts of electricity
at full capacity, while remaining a low cost producer of
electricity for New England's energy market.
Using conservative (i.e., worst case) assumptions, the
average household, using 500 KWh per month, would
see long-term monthly increases of $0.06 to $0.18 in
electricity rates as a result of
the construction of a closed-
cycle cooling system. The
short-term impacts of unit
outages during the construc-
tion period could result in a
short-term rate effect of ap-
proximately $0.70 per;
month, but only for nine
months.
For More Detailed Information
The final requirements for Brayton Point Station's ther-
mal discharges and cooling water withdrawal are
stated in the Final NPDES permit issued to the plant.
The permit, along with EPA's response to comments,
is available for review at the following locations:
Somerset
Public Library
1464 County Street
Somerset, MA
Rogers
Free Library
525 Hope Street
Bristol, Rl
U.S. EPA
Records Center
1 Congress Street
Boston, MA
information is also available for review on the
world wide web at:
www.epa.gov/ne/braytonpoint
All documents may be downloaded and printed.
(Adobe Acrobat Reader is required)
Brayton Point
Somerset, MA
Final National Pollutant Discharge Elimination System (NPDES) Permit October 2003
EPA has developed a final permit for the Brayton
Point Station power plant together with the MA
Department of Environmental Protection (DEP) and
in close coordination with the Rl Department of
Environmental Management (DEM) to meet require-
ments of the Clean Water Act. This permit seeks to
substantially reduce the facility's impact on Mount
Hope Bay. Compliance with this permit will be an
essential complement to broader public and pri-
vate efforts to restore and maintain the health of
Mount Hope Bay and the greater Narragansett Bay
ecosystem. These other efforts include fishing man-
agement, projects to improve sewage treatment,
abatement of pollution from combined sewer over-
flows, and scientific research.
Brayton Point Station is the largest industrial source
affecting Mount Hope Bay. Based on the scientific analy-
ses to date, EPA, MA DEP and others have concluded
that stronger controls are needed on the power plant's
withdrawal of water from the bay and discharge of
heated water back to the bay in order to satisfy Clean
Water Act standards. These limits will help to protect
the bay and give the fishery a chance to recover. The
technology exists for Brayton Point Station to both meet
the performance standards required by this permit and
continue to produce reliable, inexpensive electricity
for New England.
Mount Hope Bay
Winter Flounder Abundance and Flow
versus Year
L_ w
o g
lei
600
500
400
300
200
100
1200
1000
800
600
400
200
03
Q
"•B. flJ
1 °-
EE »
c .o
'« O
•i-*
CO c
o
Year
Fish -X- Flow
Fish populations declined by more than 87% after 1984 when Brayton Point Station began a
45% increase in cooling water withdrawal from the bay. (It should also be noted that the
facility's thermal discharge increased by a similar percentage at that time). Despite decreased
fishing, many species have shown no signs of recovery. The above graph shows the decline of
winter flounder relative to the increase in cooling water use. Similarly dramatic declines can be
demonstrated for other fish species as well.
Average annual losses of
fish eggs and larvae due
to existing cooling water
withdrawals at Brayton
Point Station include:
• 251 million
winter flounder
• 11.8 billion bay
anchovy
• 375 million
windowpane
flounder
• 3.5 billion
tautog
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Brayton Point Station s
Impact on Mount Hope Bay
Located in Mount Hope Bay at the confluence of the
Taunton and Lee Rivers, the Brayton Point Station power
plant produces about 6% of the electricity consumed in
New England. In producing this electricity, however,
Brayton Point Station destroys trillions of marine organ-
isms each year and significantly alters the temperature
of the bay.
Each day, the station withdraws nearly one billion gallons
of water from the bay and circulates it through the facil-
ity to condense the steam used to produce electricity.
The water is then discharged back to the bay at elevated
temperatures of up to 95° Fahrenheit. This "once
through" cooling system has contributed to the col-
lapse of the Mount Hope Bay fishery in the following
ways:
• Destroying trillions of organisms. Water
taken from the bay by the facility contains trillions of
organisms, including billions of fish eggs and larvae.
These organisms are pulled through (or "entrained")
in the facility and killed by severe physical and chemi-
cal impacts and extreme water temperatures. For ex-
ample, 251 million winter flounder larvae, 3.5 billion
tautog eggs and 375 million windowpane flounder eggs
are harmed in an average year.
Cooling water withdrawals also create a water velocity
at the intake pipes which traps (or "impinges") many
juvenile and mature fish against the intake screens. For
example, in 1999, more than 75,000 Atlantic Menha-
den were killed during a month long impingement event.
Altogether, trillions of organisms are lost to entrain-
ment and impingement each year, including species of
commercial and recreational importance, and forage fish
and other organisms integral to the food web.
• Dramatically altering the water tem-
perature in the bay. As a result of Brayton Point
Station discharges of heated water, the temperature in
the bay is about 1.5° Fahrenheit greater than other simi-
lar water bodies locally. This is a significant tempera-
ture difference in a fragile ecosystem. Altering the natural
temperature of the bay has degraded the habitat, mak-
ing areas inhospitable to native fish species, disrupting
normal fish migration, and undermining the balanced,
indigenous community offish that should exist in Mount
Hope Bay.
What Does EPA's Permit Require?
Consistent with the Clean Water Act, EPA is requiring thermal
discharge limits that protect the marine life that should thrive
in Mount Hope Bay. In addition, EPA is setting cooling water
intake flow limits so that Brayton Point Station's cooling sys-
tem reflects the best technology available to minimize the
facility's adverse environmental impacts. The permit specifi-
cally requires Brayton Point Station to:
• Reduce total annual heat discharge to the bay by 96%,
from 42 trillion British Thermal Units (BTUs) a year to 1.7
trillion BTUs a year, and
• Reduce water withdrawal from the bay by approxi-
mately 94%, from nearly 1 billion gallons a day to 56 million
gallons a day. This flow requirement is consistent with well-
established closed-cycle cooling technology using wet,
mechanical draft cooling towers for generating units 1
through 4.
Compliance with these permit limits will eliminate annual
fishery losses by an estimated 94% and improve habitat
quality, thereby helping to give the bay an opportunity to
recover.
Protecting Mount Hope Bay
While many federal, state and local efforts have been under-
way to protect Mount Hope Bay and the larger Narragansett
Bay estuary, Brayton Point Station has continued to operate
with nearly the same "once-through" cooling technology that
was installed almost 40 years ago. Requiring the power plant
to meet limits consistent with modern cooling system equip-
ment complements these other efforts, which include:
• Sewage treatment improvements in Fall River, includ-
ing a $115 million combined sewer overflow abatement pro-
gram, being implemented to meet state and federal water qual-
jty requirements.
Strict commercial and recreational fishing limits have
been imposed in Massachusetts and Rhode Island for Mount
Hope Bay in an effort to help restore fish stocks. Mount
Hope Bay, and most areas of upper Narragansett Bay, is closed
to commercial trawlers. In addition, recreational fishing for
winter flounder is closed for 10 months of the year. A small
recreational fishing effort is allowed for two months of the
year.
• At the regional level, the National Ma-
rine Fisheries Service has spent $160 million
in the last 10 years buying back fishing ves-
sels and licenses from fishermen in the north-
east to reduce fishing pressure on ground-
fish, including winter flounder. Moreover, ad-
ditional stringent federal fishing restrictions
are expected to be put in place next year.
• Enhancing knowledge about the
Narragansett Bay estuary and implementing
activities to protect and restore the estuary
and its resources through the Narragansett
Bay Estuary Program, which has spent ap-
proximately $15 million in federal and state
matching funds on this effort since 1984.
Brayton Point Station's cooling water system has contributed
to the collapse of the fishery and inhibited its recovery, even
as steps to reduce fishing pressure and improve pollution
controls are being taken to facilitate the bay's recovery. Up-
grading the facility's cooling system with modern technolo-
gies that cut water withdrawals and thermal discharges will
enable Brayton Point Station to reduce its harmful effects on
Mount Hope Bay while continuing to generate electricity for
New England. These improvements are expected to allow
the fishery to recover and restrictions on fishing to be eased.
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