Eloise Kendy
656 N. Ewing
Helena, MT 59601
August 29, 2006
Kathleen Johnson
Department of Environmental Quality
P.O Box 200901
Helena, MT 59620-0901
Via e-mail to katjohnson@mt.gov, Richard.fristik@wdc.usda.gov
Dear Ms. Johnson,
I am writing to comment on the draft Environmental Impact Statement (EIS) for the proposed Highwood Generating Project. First, let me state that I concur with all of the concerns expressed by Montana Environmental Information Center (MEIC) regarding the proposed power plant. However, I wish to direct this letter to two concerns in particular: the impacts on the quantity and quality of water in the Missouri River, should the proposed power plant go on-line.
First, to introduce myself, I am a professional hydrogeologist with 20 years of experience, currently working as an independent scientist. The focus of my recent research is the interaction between ground water and surface water, and how past, present, and future land uses affect water availability. In my career, I have also dealt considerably with ground-water contamination problems. Much of my work has centered on the Missouri River basin. I am writing this letter as an individual, and not as a representative of any client or group.
According to the draft EIS (p. 4-22), Òthe plant would require a maximum of 3,200 gpm (7.8 cubic feet per second or 5,600 acre-feet per year) of Ômake-upÕ water to be pumped from the Morony Reservoir. The majority of this water (80 to 85 percent) would be a consumptive use of water.Ó I believe the EIS failed to examine the implications of this water consumption on MontanaÕs overall water supply.
The 5,600 acre-feet per year that the plant would use would meet the municipal demands of 28,000 people. The economic analysis in the EIS relies upon a substantial population increase to serve as a market for the power produced by the proposed plant. But water availability is already a major factor limiting population growth in Montana, as evidenced by the increasing difficulties encountered by subdivision developers in obtaining new water rights. Thus, the water rights claimed by SME for the power plant could conceivably preclude the population growth needed to make the same plant economically viable.
Competition for fresh water is already limiting energy production nationwide. For example, Georgia Power lost a bid to draw water from the Chattahooche River, the Environmental Protection Agency ordered a Massachusetts power plant to reduce its water withdrawals, Idaho has denied water rights requests for several power plants, Duke Power warned Charlotte, NC to reduce its water use, and a Pennsylvania nuclear power plant is being forced to use wastewater from coal mines. Montana, especially east of the Continental Divide, is inherently drier than any of those places. As a State, we need to consider how to balance energy and water demands while allocating these limited water resources.
Although the water right from Morony Reservoir is legally available for use by the proposed power plant, the EIS should consider whether that is really the most beneficial use of that water. In the early 1990s, the Montana legislature closed several basins, including the Missouri River basin above Great Falls, to new water rights due to over-allocation. The river flows had become too low. Thus began a rush on new ground-water permits. It was not until very recently that the Montana Supreme Court ruled that the DNRC could no longer allocate new ground-water permits in closed basins, since ground water and surface water are connected, and ground-water pumping depletes streamflow. We are only beginning to see the hydrologic impacts of a decade and a half of excessive ground-water pumping from already over-allocated basins. At the same time, climate change is limiting our water supplies even further. Hotter temperatures, more frequent droughts, and earlier spring snowmelt are already evident, and scientists predict that this trend will continue. Consequences include increased demand and decreased availability of water, especially during summer and fall. Conflicts over water in Montana are only just beginning.
The table below compares cooling water withdrawal and consumption rates for different types of power generating plants. Withdrawal rates indicate total water use, whereas consumption rates indicate only the amount of water that evaporates and does not return to the hydrologic system. Consumption is the rate at which a power plant depletes water from its source, which in the Highwood case would be the Missouri River.
As a comparison, the proposed Highwood facility would withdraw up to 0.77 gallons per kilowatt-hour (gal/KWh), and it would consume 0.61 gal/KWh[1]. Thus, the proposed facilityÕs water consumption rate would be among the highest of all fossil-fueled power generating plants. (As a sidenote, the proposed Silver Bow Generation Project, a 500-MW natural gas-fired combustion turbine plant, would consume about 0.29 gal/KWh and the proposed Roundup Power Project, a 780-MW pulverized coal-fired power plant, would consume about 0.08 gal/KWh.) Therefore, less water-consuming means of producing energy, even with fossil fuels, are readily available and ought to be prioritized in Montana, where water is not a plentiful resource.
In addition to water quantity, the EIS briefly addresses water-quality issues. In my opinion, the consideration of water-quality impacts in the EIS verges on cavalier. To say that clay soils and liners will protect water quality from leachate and runoff from boiler blowdown, coal piles, cooling process and boiler cleaning wastes, and fly ash is to ignore acres of grossly polluted ground water at Colstrip. But unlike Colstrip, which is located far from surface water, contaminants from the proposed Highwood facility would discharge almost directly into the Missouri River. Neither clay soils nor compacted clay liners have ever been shown to be leak-proof. On the contrary, fluids flow easily and rapidly through preferential flow paths such as root casts and cracks, which form especially in clay soils. Thus, although at a laboratory bench scale, the clay soils found onsite might be Òcharacterized by very slow water transmission rates and infiltration ratesÓ (EIS, p. 4-24), the same cannot hold true at the scale of the proposed facility. The EIS statement that Ògroundwater below the site would be monitored on a regular basis to ensure no contamination is occurringÓ (p. 4-24) is misleading. Monitoring will not determine whether or not contamination occurs; it can only indicate whether it has occurred, and then only at the points monitored, and only after the pollution has migrated to those points. If developed, the proposed facility would almost certainly pollute both ground and surface water Ð an inevitability that the EIS casually discounts.
In conclusion, the draft EIS for the proposed Highwood Generating Project is woefully inadequate in its treatment of water-resource issues. The project could seriously threaten water quality and unnecessarily exacerbate conflicts over water quantity.
Thank you for considering my comments on the proposed coal-fired power plant. Should you have any questions, including the sources of my data and statistics, please donÕt hesitate to contact me.
Sincerely,
Eloise Kendy, Ph.D.
Hydrogeologist