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Name:	LOCOonWater -	Reply
Subject:	ruling
Date:	10/29/2008 5:58:17 PM

Has there been any ruling on the water levels?

Name:	LOCOonWater -	Reply
Subject:	ruling
Date:	11/7/2008 10:06:32 PM

Nobody's talking

Name:	keyman -	Reply
Subject:	ruling
Date:	11/9/2008 12:38:01 PM

I am posting a letter that will soon be on the SLISA's website.

A brief introduction. The relicense proscess is very long and quite technical. The below letter contains references to the FERC website which can be accessed by any user at www.ferc.gov. My goal in the below letter is to update SLISA members on what is currently happening in the relicense. I will be happy to answer any questions and can be reached at jared@jaredkey.com or call me directly 205 516-2186.

Cooling Towers the Answer for Higher Smith Lake Levels

Alabama Power Company Admits.

Limiting the amount of water that may be released from Smith will prevent Gorgas Steam Plant from being able to operate. Alabama Power would be required to design, construct and operate cooling towers at the
Gorgas Steam Plant.

A Big Hello to all from SLISA.

To keep you updated on Alabama Powers (APC) relicensing process we are noting several significant items that have occurred.
Back in March of 2008 The Federal Energy Regulatory Commission (FERC) issued an Environmental Assessment (EA). SLISA responded to this EA and from those comments FERC decided to issue an Additional Information Request (AIR) to Alabama Power Company (APC) on July 2nd 2008. The complete document an be viewed at

http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=11732027 .

Part of this AIR was to model the SLISA Alternative. This Alternative is maintaining the lake between the 510’ msl to the 505’ msl between Memorial Day and Labor Day. Thence fom Labor Day to December 1st to lower the lake level from the 505’ msl to the 502’ msl. The 502’ msl would be the lower limit except in times of extreme drought.
FERC originally gave APC 45 days to respond to this request and later gave APC an additional 45 days. APC submitted their response on October 3rd, 2008. The complete document can be viewed at

http://elibrary.ferc.gov/idmws/common/OpenNat.asp?fileID=11821635 .

Since that time SLISA’s staff of experts has been analyzing the submitted information. SLISA submitted comments detailing the discrepancies in APC’s AIR response. The Full response can be viewed at

http://elibrary.ferc.gov/idmws/common/opennat.asp?fileID=11843701 .

A brief breakdown on APC’s response. The response from APC contained numerous mischaracterizations and therefore inaccurate conclusiions.

This is an excerpt from SLISA’s comments.

APC incorrectly assumed that under the SLISA Alternative, water would be discharged in exactly the same manner as APC actually operated in each of the three years it evaluated until the lake was drawn down to 505 feet msl, at which point all releases would stop. Clearly, the Project could not be operated in this manner without significant adverse consequences to many interests. This is not what SLISA intended, and APC’s attempt to characterize our alternative as such is disingenuous. Except during periods of exceptional drought, we expect that under the SLISA Alternative the elevation of Smith Lake will be very close to 502 feet msl at the beginning of each year.

Although APC mischaracterized our alternative there was one very important admission made by APC.

Limiting the amount of water that may be released from storage at Smith during the important summer and fall seasons will prevent Gorgas Steam Plant from being able to operate and meet its NPDES temperature requirements.
In order to provide assurance that water is available for steam condenser use, Alabama Power would be required to design, construct and operate cooling towers at the Gorgas Steam Plant.

After numerous public reports by APC denying that Gorgas was dependent upon Smith Lake the truth was finally told. SLISA has on every occasion stated that Gorgas Steam Plant was the driving force of water releases and feels vindicated with this admission.

Among the mischaracterizations were the accusations by the Warrior –Tombigbee Association. This group with data provided by APC knowingly misrepresented the SLISA Alternative. The Warrior-Tombigbee association led by Charles Haun (Parker Towing) and Bill Satterfield (Lawyer Balsh and Bingham APC’s legal council) made accusations that many of the water works and navigational dependent businesses would have suffered due to lack of water supplied under the SLISA Alternative. This turned out to be completely false and is pointed out in the following paragraph.

Year 2007 was the driest year on record in Central Alabama.
As such, the Corps’ requirement to release 245 cfs for navigation would certainly have applied. Despite this requirement, from Memorial Day through Labor Day, Smith Lake's average discharges averaged 1230 cfs, more than five times the navigational requirement. This left little storage, resulting in APC’s inability to comply with the navigation flow requirement later in the year. Instead of acknowledging this, APC provided its mischaracterization of the SLISA Alternative to the Warrior-Tombigbee WaterwayAssociation.

“With data provided by APC , a preliminary analysis of the SLISA Alternative was performed. It demonstrates that by conserving storage earlier in the summer and fall of 2007, required minimum navigation flows and water for all consumptive downstream withdrawals could have been provided every single day of 2007. Further, the flows during the summer and fall would have been more consistent than those under the APC’s actual and proposed method of operation. Under the SLISA Alternative, although the summer full pool target of 510 feet msl would not have been achieved, at no time would the Smith Lake water elevations have fallen below 502 feet msl.”

This data was based on actual conditions experienced in 2007. The Warrior-Tombigbee accusations were based upon flawed assumptions while the SLISA Alternative upon facts.

We are now awaiting FERC to process both APC's response and SLISA's response and model. FERC at some point in the future will issue another EA which will stipulate the rules and regulations for APC' next license. According to FERC that may be as early as late November 2008 through February 2009.

In closing we would like to thank everyone for their continued support of SLISA.
We have known all along that this was going to be a difficult undertaking. Armed with the facts we are resolved to change Smith Lake for the better. We want to start with stabilizing Lake Levels in a manner that is beneficial not only to the land owners and the public but also to the aquatic wildlife. We are more determined than ever to complete this goal. We ask that you would check back soon to view a complete model of Smith Lake.

Sincerely

Jared Key
President, SLISA

Name:	alston -	Reply
Subject:	ruling
Date:	11/20/2008 3:16:31 PM

Can someone explain to me (or point me to an explanation on the Web) of what is cooled at the Gorgas Steam Plant by Smith Lake water, and why it needs to be cooled? Thanks.

Name:	keyman -	Reply
Subject:	ruling
Date:	11/23/2008 12:56:58 PM

alston

The Gorgas Steam Plant uses coal to heat water that turns into steam. The steam goes through a steam generator that produces electricity. The steam then has to be cooled through a condenser. The water used to cool the condeser comes from the Black Warrior River. The water is drawn from the river through the condenser and back to the river. There are limits to what the temperature can be when it is returned to the river. During late fall through spring the river temperature is cold enough to go through Gorgas and back into the river without exceeding this limit. During the summer months the river temperatures rise and without the cool waters of Smith lake cooling the river down, Gorgas would exceed these temperature limits. Cooling towers would replace the need for Smith Lake having to cool the river temperatures. Typically cooling towers reduce the amount of water drawn from the river by 95%.

keyman

Name:	Bill -	Reply
Subject:	ruling
Date:	11/24/2008 4:14:43 PM

alston,

Keep in mind however that cooling Gorgas is not the only reason water is drawn from Smith Lake.

Name:	waterph -	Reply
Subject:	ruling
Date:	11/25/2008 6:57:40 PM

Question - If the massive amounts of cooling waters were not required for Gorgas in the hot months (ie, Cooling Towers installed), what would the fluctuations be on Smith Lake with normal rainfalls? During the past several week with cooler days and nights (cooler infeed water for Gorgas), water fluctuations have been small.

Name:	alston -	Reply
Subject:	explanation
Date:	12/1/2008 11:08:25 AM

Thanks.

Name:	alston -	Reply
Subject:	explanation
Date:	12/2/2008 6:22:42 PM

Last night I thought of a question. If the water APC is discharging into the river is already heated to some extent (having just condensed from steam to water), why not just recycle this already-heated water to create more steam, rather than cooling it with lake water? Since it's already heated, it would take less energy to turn it into steam again. Thanks.

Name:	keyman -	Reply
Subject:	explanation
Date:	12/7/2008 10:02:33 AM

Alston

You have a very good question. The recycling of the water as you suggest is the definition of cooling towers. One of the things SLISA has been fighting for is the installation of cooling towers.
Cooling towers do recycle the water over and over again. Currently Gorgas needs 978 million gallons per day in the summer, with cooling towers it could be reduced by 95% down to almost 50 million gallons per day. That is what the fight is about. It is unfortunate that no one else will talk specifics (facts) on this forum. We have the facts and the facts will win with FERC or in Federal Court.

Thanks

keyman

Name:	waterph -	Reply
Subject:	explanation
Date:	12/8/2008 10:47:31 AM

Alston

Good idea! Heat recovery can reduce operating cost in a significant manner if maximized. Most companies dedicate significant enginnering hours to find these opportunities and formulate projects to implement. You are correct in that it would take fewer tons of coal if recycled hot water is being used to make steam.

I would suspect that the Gorgas plant is recapturing very few BTUs via state of the art heat recovery systems. This process is probabably antiquated since it does not have cooling towers. Capital dollars would be required for energy cost reduction prrograms. However, this project would probably have a high ROI with a short pay off time. Most companies will find capital to reduce energgy cost. Once installed, the project pays for itself for many years.

The $64 question is -

What will APC do for Gorgas to bring it up to a state of the art energy plant? Or, will APC limit capitaal expenditures to meet environmental guidelines only and allow Gorgas to die a slow death?

Name:	alston -	Reply
Subject:	explanation
Date:	12/8/2008 7:00:46 PM

I hate to be dense, but I don't quite get the role of (proposed) cooling towers. Would the cooling towers be used to let hot water (foremerly steam, used to drive turbins) cool before it is discharged into the Black Warrior River? I had understood that cold Smith Lake water was need to cool hot water (formerly steam) before discharge into the River. I was wondering whether the hot water (formerly steam) needed to be cooled at all. I was wondering why they don't just take that hot water (formerly steam) and use it to make new steam - since it's already hot, less energy would be required (less coal) to turn it back into steam. Then, no hot water would be discharged into the River, and no extra cold water from Smith Lake would be needed to cool hot water. Thanks.

Name:	keyman -	Reply
Subject:	explanation
Date:	12/8/2008 10:02:47 PM

Alston

wikepedia steam generator for a pretty in-depth answer. The short answer is that it takes really clean water to be boiled over and over again. The water that is being boiled is in one loop called a closed loop(primary). It has to be very clean to keep the impurities from scaling the boiler tubes. That water that is boiled has to be cooled during the cooling process is when the steam changes state back to a liquid. This change causes a pressure change that makes the turbines spin producing power. The cooling water that we are speaking of is in another loop currently an open loop (secondary) out of river through condensor and back to river. A cooling tower would be a closed loop system that recirculates cooling water and is cooled by air. The primary water is heated to bioiling point and passes through condenser where it is cooled by the secondary. The secondary never reaches boiling point only the primary. The reason that you have to cool the steam is to extract all the energy that is produced when the steam changes into water the the process starts all over.

I hope this helps.

keyman

Name:	waterph -	Reply
Subject:	explanation
Date:	12/9/2008 8:31:58 AM

Alston

Just to add to what Keyman said.

I have been involved in boiler house operations in the chemical industry. Keyman is correct in describing the quality requirements of the water for steam. The water used to make the superheated steam is treated with certain chemical agents to reduce scaling. Control of scaling in a high pressure stteam system is a must.

Pressures of the superheated steam are normally in the 400 to 500 psig range with accompaning high temperaatures. This is a very dangerous operation. A bursted high pressure steaam line can be dedly. After used to turn the turbines, this hot condensate is returned back to the bolers to make steam again - a closed loop operation. Any losses in the process are made up using fresh chemically treated water.

The heat source for the superheated steam is normally coal. The operation that I was familiar with used over 1,000 tons per day. Multiply this number by a factor of ten and you have a Widows' Creek Power Plant in Stevenson, Alabama, owned by TVA. Cooling towers are part of the process with water supplied from the Tennessee River.

Smith lake comes into play in that water for condensing the steam does not have to be treated in tthe same manner as the water used to make steam. Without cooling towers, an exobrant amount of cooling water for the heat exchangers is reqquired to condense the steam. This is why the Smith Lake water levels change from 510 feet to 497 feet during the hot summer periods. I suspect that the permit temperature for water returned to the river is 92 degrees. This is normally the max for water returned to the Tennessee River. APC has zero flexibility in exceeding this temperature specification for Gorgas.

Hope this helps.

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