The Thirsty Colossus: Fermi America's AI Empire and the Battle for Texas Water

Author’s Preface: A Nuclear Professional’s Perspective

Over my forty-year career in the nuclear industry, including fifteen years of public service as Chair of the Texas Radiation Advisory Board and inaugural Chair of the Texas Low Level Radioactive Waste Disposal Compact Commission, I have worked to advance the responsible deployment of nuclear technology.

Throughout this time, I have sought to build consensus among stakeholders for safe nuclear operations and environmentally sound waste disposal. I offer this analysis from the perspective of someone who believes deeply in nuclear power’s essential role in our clean energy future.

The global need for nuclear power has never been greater. As we face climate change and growing energy demands, nuclear energy offers a path toward abundant, carbon-free baseload power. After years of challenges, the nuclear industry stands at the threshold of a renaissance, with public acceptance growing as communities recognize nuclear’s importance. This progress, built on decades of operational excellence and transparent communication, represents an achievement worth protecting.

The resurgence in nuclear power depends on maintaining high standards of technical accuracy and environmental responsibility. Successful nuclear development requires experienced operators, proven technologies, and sustainable use of natural resources. Companies like Constellation, Duke Energy, and Southern Company have spent decades building their nuclear expertise through rigorous training and careful operations. Their experience shows that nuclear power, while complex, can serve communities reliably when properly implemented.

This analysis examines Fermi America’s proposed project in the Texas Panhandle with particular attention to water consumption claims and their implications for regional resources. As someone who has spent decades working to make nuclear power safe and beneficial to society, I believe we must carefully evaluate new projects to ensure they meet the high standards our industry requires. The technical and environmental questions raised here deserve thoughtful consideration by regulators, investors, and community members as they evaluate this significant undertaking.

Executive Summary

Fermi America’s proposed energy project in the Texas Panhandle presents significant technical and environmental questions that merit careful examination. The project centers on four AP1000 nuclear reactors that would supposedly use air-cooled condensers (ACCs) to reduce water consumption to approximately 16.3 million gallons annually. However, a 2007 engineering feasibility study conducted by Southern Company engineers for the AP1000 design found that implementing such technology would face substantial technical challenges, potentially requiring performance parameters beyond current engineering capabilities.

The complete project, including gas turbines and data centers, would require approximately 4.6 billion gallons of water annually from the Ogallala Aquifer, which University of Texas researchers project could become 70% unusable for irrigation within 20 years. Unlike traditional utility projects that provide electricity to the public grid, this project appears designed primarily to serve private data centers, raising questions about the allocation of limited water resources.

This analysis examines the technical feasibility of the proposed cooling systems, the total water requirements across all facilities, and the implications for agricultural communities dependent on the Ogallala Aquifer. These considerations are particularly important given the project’s $13.16 billion proposed valuation and its potential impact on regional water resources that support a $20 billion agricultural economy.

Technical Concerns: Understanding the Complete Cooling Challenge

The Fermi America project faces three distinct but interconnected cooling challenges across its nuclear, natural gas, and data center components. Each presents unique technical constraints that affect water consumption, and understanding these challenges helps explain why the project’s total water demand reaches 4.6 billion gallons annually despite claims of revolutionary conservation in one component.

Nuclear Cooling: The Physics of the Impossible

Fermi America’s Combined Operating License Application states that their AP1000 nuclear reactors will operate with air-cooled condensers, consuming only 50 acre-feet (16.3 million gallons) of water annually. To understand why this claim raises serious technical concerns, we must first understand how nuclear plant cooling works.

In a nuclear plant, the reactor core generates tremendous heat that produces steam to drive turbines. After passing through the turbines, this steam must be condensed back to water to complete the cycle. Traditional plants use water-cooled condensers where cooling water absorbs the steam’s heat, then releases it through evaporative cooling towers. This process consumes enormous amounts of water through evaporation—roughly 12.2 billion gallons annually for four AP1000 units.

Air-cooled condensers would theoretically eliminate most water consumption by using ambient air instead of water for cooling. However, air has fundamentally different thermodynamic properties than water. Water can absorb 4,000 times more heat per unit volume than air, and evaporation provides additional cooling that air systems cannot achieve. This means air-cooled systems must be exponentially larger and work much harder to achieve the same cooling effect.

A 2007 feasibility study by Southern Company engineers found that achieving the necessary cooling performance for AP1000 reactors would require an Initial Temperature Difference (ITD) of less than 20°F between the steam temperature and ambient air. Current technology achieves ITDs of 35°F at best, and this limit exists because of fundamental material science and heat transfer constraints, not simply engineering challenges that innovation might overcome. The study characterized this gap as “more than 40% less than the minimum ITD using current technology,” essentially describing a violation of practical thermodynamic limits.

The consequences of inadequate cooling cascade through the entire plant operation. The AP1000 turbine requires specific backpressures (averaging 2.92” HgA) to function properly. If cooling is insufficient, backpressure rises, reducing power output and potentially forcing shutdown. In Texas summer heat exceeding 95°F, even theoretically perfect air cooling would push operating parameters to the edge of design limits, and the additional pressure losses from routing steam to external cooling units could exceed safety margins entirely.

Gas Turbine Cooling: The Hidden Water Demand

While Fermi emphasizes their nuclear cooling innovation, the project includes 2,000 MW of Siemens F-class gas turbines that would consume approximately 2 billion gallons annually using conventional cooling methods. Understanding why these turbines require such massive water volumes reveals important choices Fermi made about where to innovate and where to accept standard practice.

Combined-cycle gas turbines, which Fermi plans to use, operate through two interconnected processes. First, natural gas combustion drives a gas turbine directly. The exhaust from this turbine, still extremely hot at over 1,000°F, then generates steam to drive a second steam turbine. This combined cycle achieves high efficiency—up to 60% compared to 35% for simple cycle plants—but requires cooling for both the steam condenser and various auxiliary systems.

The cooling water serves multiple critical functions in these plants. The steam turbine condenser, similar to nuclear plants, requires cooling water to condense exhaust steam. Inlet air cooling systems use water to cool combustion air, increasing its density and improving turbine performance—especially crucial in hot climates like Texas. Various heat exchangers throughout the plant cool lubricating oil, generator windings, and other components that would fail without temperature control. The total water requirement typically ranges from 180-250 gallons per megawatt-hour generated.

Alternative cooling technologies exist for gas turbines that could dramatically reduce water consumption. Hybrid wet-dry cooling systems can reduce water use by 30-50% by using air cooling when ambient conditions permit and switching to water cooling only during peak heat periods. Full dry cooling, while reducing efficiency by 2-4% and increasing capital costs by $50-100 million for a 2,000 MW installation, could eliminate water consumption entirely. The fact that Fermi chose conventional water cooling for their gas turbines, while claiming revolutionary air cooling for their nuclear units, suggests that water conservation took a back seat to economics for the components that wouldn’t generate headlines.

The placement of gas turbines in this project also raises questions about their intended role. While Fermi describes them as providing grid stability and backup power, their 2,000 MW capacity and planned 60% capacity factor suggest they’re intended for regular operation, not just emergency backup. This baseload operation would guarantee the continuous consumption of 2 billion gallons annually, regardless of nuclear plant performance.

Data Center Cooling: The Exponential Growth Challenge

The most overlooked yet potentially largest water consumer in Fermi’s project is the 18-million-square-foot data center campus, projected to consume 2.6 billion gallons annually. To understand why data centers require such enormous water volumes, we need to examine the fundamental challenge of cooling concentrated computing power.

Modern data centers pack tremendous computing power into small spaces. A single server rack can consume 20-40 kilowatts of power, with nearly all of that energy converted to heat. High-performance computing and AI training clusters, which Fermi’s facility would likely host, can reach 50-100 kilowatts per rack. With thousands of racks in an 18-million-square-foot facility, the heat generation equals that of a small city compressed into a few buildings. Every watt of computing power becomes a watt of heat that must be removed to prevent equipment failure.

Traditional data center cooling uses a system similar to giant air conditioners. Computer Room Air Conditioning (CRAC) units blow cold air under raised floors and through server racks, collecting hot exhaust air and cooling it through chilled water systems. The chilled water systems typically use evaporative cooling towers, consuming approximately 1.8 gallons of water per kilowatt-hour of cooling. For a facility of Fermi’s proposed size operating at typical power densities, this translates to millions of gallons daily.

The inefficiency of traditional air cooling for data centers stems from air’s poor heat transfer properties and the mixing of hot and cold air streams. Modern alternatives could dramatically reduce both energy and water consumption. Liquid cooling, where coolant is brought directly to computer chips, can be 1,000 times more effective than air cooling and eliminates the need for energy-intensive air conditioning. Indirect evaporative cooling can reduce water consumption by 70-90% by using outside air when conditions permit. Raising operating temperatures from the traditional 70°F to 80°F or higher, as companies like Google have done, enables free cooling for much of the year even in warm climates.

The most puzzling aspect of Fermi’s data center plans is the apparent absence of these proven conservation technologies. Major technology companies have committed to water-positive operations by 2030, implementing aggressive conservation measures at all facilities. Microsoft’s Wyoming data centers use no water for cooling most of the year. Google’s Denmark facility actually produces fresh water while cooling servers. Yet Fermi’s application suggests conventional cooling consuming 2.6 billion gallons annually, raising questions about whether water conservation was ever a genuine priority for the profit-generating components of their project.

The Selective Innovation Pattern

When we examine cooling strategies across all three components, a clear pattern emerges. Fermi claims revolutionary but unproven technology for the nuclear component that generates positive publicity and regulatory advantages. They chose conventional, water-intensive cooling for gas turbines that could use proven dry-cooling alternatives. They apparently selected standard evaporative cooling for data centers despite numerous water-saving options used routinely in the industry.

This selective approach to innovation suggests that water conservation serves primarily as a marketing message rather than an operational commitment. The nuclear plant’s claimed air cooling, contingent on NRC approval and even if it worked, would save less than 0.5% of the project’s total water consumption. Meanwhile, proven technologies that could save billions of gallons on the gas turbine and data center components appear to have been rejected, presumably for economic reasons.

Water Resource Implications: Understanding the Complete Consumption Picture

The comprehensive water demand across all project components requires careful evaluation in the context of regional water availability and competing uses. When we examine the technical requirements for cooling nuclear reactors, gas turbines, and data centers simultaneously, the total consumption of 4.6 billion gallons annually becomes more understandable, though no less concerning for regional sustainability.

Based on industry standards and technical documentation, the complete water consumption profile breaks down as follows. The nuclear reactors, if Fermi’s air-cooled condenser claims prove feasible and are actually approved by the NRC, would consume 16.3 million gallons annually. However, this represents less than 0.4% of total project consumption and depends on unproven technology. The Siemens F-class gas turbines, operating at 60% capacity factor with conventional evaporative cooling, would require approximately 2 billion gallons annually. This consumption is well-documented in industry literature and represents standard practice for combined-cycle plants in hot climates. The 18-million-square-foot data center campus, using traditional cooling at typical power densities, would demand approximately 2.6 billion gallons annually, making it the single largest water consumer in the project.

The stark contrast between claimed innovation in nuclear cooling and conventional approaches for other components raises important questions about project priorities. Proven conservation technologies exist for both gas turbines and data centers. Hybrid cooling for the gas turbines could reduce their consumption by 30-50%, saving 600 million to 1 billion gallons annually. Modern data center cooling techniques could reduce consumption by 70-90%, potentially saving 1.8 to 2.3 billion gallons annually. Together, these proven technologies could reduce total project water demand by more than half, yet they appear absent from Fermi’s plans.

This consumption would occur in a region where water scarcity already threatens agricultural sustainability. The Ogallala Aquifer has lost 332 million acre-feet since the 1940s, with current depletion rates far exceeding the rate of recharge. The North Plains Groundwater Conservation District documents annual water level declines of 1-2 feet across much of the region, with some areas experiencing even steeper drops. Natural recharge rates of 0.25 inches annually cannot offset even current agricultural use, much less support new industrial demands.

The technical reality of cooling requirements helps explain why alternative locations might better suit this project. Regions with cooler climates would reduce cooling demands across all components. Coastal locations could utilize seawater for cooling, eliminating freshwater consumption. Areas with abundant surface water could support industrial cooling without depleting irreplaceable groundwater resources. The choice to locate in the water-scarce Texas Panhandle, while claiming water conservation as a priority, suggests other factors drove site selection.

Purpose and Public Benefit Considerations

Traditional nuclear power plants operate under regulated utility frameworks that ensure public access to generated electricity at fair rates. These projects justify their resource use through decades of public service, providing power to homes, hospitals, schools, and businesses. This relationship between resource use and public benefit has long been a cornerstone of utility regulation.

Fermi’s project structure appears to differ from this traditional model. According to their COLA application, the project involves “a vertically integrated framework combining Fermi America’s licensed nuclear operator with sovereign REIT-aligned subsidiaries responsible for non-regulated power and data infrastructure.” The generated power would primarily serve private data centers rather than the public grid.

This raises important policy questions for communities and regulators: Should limited water resources be allocated to projects that primarily serve private commercial interests? How should communities weigh temporary construction jobs against long-term impacts on agricultural sustainability? What precedent does this set for future industrial water use in water-scarce regions?

The Ogallala Aquifer: Balancing Development and Sustainability

The Ogallala Aquifer represents an irreplaceable resource that took millions of years to form. Current depletion rates far exceed natural recharge, creating what researchers describe as essentially mining ancient water. University of Texas projections suggest that 70% of the Texas Panhandle’s portion could become economically unusable for irrigation within 20 years under current consumption patterns.

Adding 4.6 billion gallons of annual industrial consumption would accelerate this timeline. For context, this amount of water could supply 35,000 households, irrigate 10,000 acres of cropland, or support significant agricultural production worth tens of millions annually. The economic implications extend beyond direct water users to entire rural communities dependent on the agricultural economy.

Climate change adds urgency to these considerations. Rising temperatures and changing precipitation patterns will likely increase dependence on groundwater resources. Surface water alternatives like Lake Meredith (currently at 48.2% capacity) face their own challenges, including evaporation losses and quality issues. These factors suggest the need for particularly careful evaluation of new large-scale water uses.

Regulatory and Oversight Considerations

The Nuclear Regulatory Commission’s review of Fermi’s application will need to address the technical feasibility of the proposed cooling systems. Given that no AP1000 reactor has been licensed or operated with air cooling, this review could require extensive analysis and potentially 5-7 years to complete. The absence of technical documentation addressing known engineering challenges in the initial application raises questions about the completeness of the submission.

Recent legislation, including the ADVANCE Act of 2024, has modified the NRC’s framework to ensure licensing “does not unnecessarily limit benefits” of nuclear technology. While supporting nuclear development is important, maintaining rigorous technical standards remains essential for public safety and industry credibility. How regulators balance promotional mandates with technical scrutiny will significantly impact project outcomes.

State and local authorities also play crucial roles. The North Plains Groundwater Conservation District has the authority to regulate pumping and protect aquifer sustainability. Local governments can impose water conservation requirements and structure economic development agreements to protect community interests. These tools provide important opportunities for local input into project development.

Economic Considerations and Community Impacts

The economic implications of Fermi’s cooling technology choices extend beyond simple cost-benefit calculations to fundamental questions about resource valuation and community sustainability. Understanding the economic drivers behind the selection of water-intensive cooling for gas turbines and data centers, while claiming revolutionary conservation for nuclear plants, reveals important tensions between private profit optimization and public resource stewardship.

The decision to use conventional evaporative cooling for gas turbines, despite available alternatives, appears driven by straightforward economics. Hybrid cooling systems would cost an additional $50-100 million in capital investment while reducing operating efficiency by 2-4%. For a project valued at $13.16 billion, this represents less than 1% of total cost, yet Fermi apparently deemed this investment unnecessary despite potential water savings of 1 billion gallons annually. This choice suggests that water is being valued at effectively zero in their economic model, treated as a free input rather than a scarce resource.

Similarly, the data center cooling strategy prioritizes minimizing capital costs over water conservation. Modern liquid cooling or indirect evaporative systems would require higher upfront investment but could reduce water consumption by 70-90%. Major technology companies routinely make these investments, recognizing both environmental responsibilities and long-term operational risks from water scarcity. Fermi’s apparent rejection of these technologies for their highest water-consuming component suggests a business model focused on rapid returns rather than sustainable operations.

The employment projections require careful analysis, distinguishing temporary from permanent impacts. The promised 9,000 construction jobs would last perhaps 4-5 years, providing important but temporary economic stimulus. The 600 permanent positions, while valuable, must be weighed against agricultural employment at risk from accelerated aquifer depletion. A single 2,000-acre irrigated farm supports not just the farming family but also creates additional jobs in equipment maintenance, grain handling, transportation, and local services. The cumulative employment impact of reduced agricultural production could exceed the permanent jobs created, particularly when multiplier effects are considered.

Property tax implications warrant special scrutiny, given the typical patterns of industrial development. Data centers, despite enormous valuations, often negotiate aggressive tax abatement packages, arguing that they create few jobs relative to their investment. Nuclear plants typically negotiate payments in lieu of taxes (PILOT) that provide stable but reduced revenue compared to standard property tax rates. Meanwhile, agricultural land that becomes unproductive due to water depletion generates no tax revenue, yet still requires county services for roads, law enforcement, and emergency response.

The existing agricultural economy generates over $20 billion in economic activity that ripples through rural communities. When farmers purchase equipment, they support local dealerships and mechanics. When they sell grain, they sustain elevators and processors. Their spending supports local businesses, schools, and hospitals. This economic ecosystem, built over generations, depends entirely on irrigation water from the Ogallala Aquifer. Every billion gallons diverted to industrial use accelerates the timeline toward agricultural collapse, with cascading economic consequences that no amount of temporary construction spending can offset.

The comparison between water productivity in agriculture versus data centers illuminates the economic trade-offs. An acre-foot of water applied to wheat production generates approximately $50,000 in crop value, supports multiple jobs along the supply chain, and produces food that meets essential human needs. That same acre-foot cooling data center servers might facilitate millions in revenue for technology companies, but that value flows primarily to shareholders in distant cities, not local communities bearing the cost of resource depletion.

Risk distribution between project developers and communities raises serious concerns. Fermi and its investors capture all upside from successful operations while communities bear the downside risk of aquifer depletion. If cooling systems fail to perform as claimed, requiring more water than projected, communities have little recourse. If the aquifer depletes faster than expected, forcing agricultural decline, no mechanism exists to compensate affected families. This privatization of benefits and socialization of risks represents a fundamental inequity in the project structure.

The long-term economic scenario facing the Texas Panhandle depends critically on water availability. University studies project that without industrial acceleration, the aquifer could support gradually declining irrigation for perhaps 20-30 more years, allowing managed transition to dryland farming or alternative economic activities. Adding 4.6 billion gallons of annual industrial consumption could reduce this timeline by 5-10 years, forcing abrupt rather than gradual adjustment. The economic disruption from rapid agricultural collapse would devastate rural communities, potentially creating economic refugees as families abandon farms their grandparents homesteaded.

Alternative economic development strategies could provide employment without massive water consumption. Wind energy development, which Texas leads nationally, creates construction and maintenance jobs while generating landowner royalties with zero water consumption. Solar installations offer similar benefits. Manufacturing, logistics, and technology operations that don’t require intensive cooling could leverage the region’s central location and low costs without depleting irreplaceable resources.

The decision to pursue water-intensive development when alternatives exist raises questions about whether decision-makers have adequately considered the long-term interests of the community.

The financial architecture of the project, with its REIT structures and plans for a $13.16 billion IPO, suggests a business model optimized for capital market exit rather than long-term operations. This creates concerning incentives where maximizing short-term valuation takes precedence over sustainable resource use. Venture capital investors typically seek returns within 5-7 years, a timeline that aligns poorly with infrastructure projects that affect resources communities will depend on for generations.

Questions for Further Investigation

The technical analysis of cooling requirements across all project components raises numerous questions that warrant investigation by regulators, investors, and community members. These questions span the feasibility of proposed technologies, the economics of water conservation choices, and the implications for regional resource management.

Nuclear Cooling Feasibility

The claimed implementation of air-cooled condensers for AP1000 reactors raises fundamental technical questions:

• What specific technological breakthroughs since the 2007 Southern Company study enable Fermi to overcome the thermodynamic limitations identified?

• Has any testing facility demonstrated ACC performance at the required ITD levels below 20°F?

• Why does Fermi’s application lack technical documentation addressing the known engineering challenges?

• What contingency plans exist if ACC technology cannot achieve projected performance during Texas summer conditions?

• Who bears financial responsibility if the plant must shut down during peak heat due to cooling limitations?

Gas Turbine Design Choices

The selection of conventional, water-intensive cooling for gas turbines, despite available alternatives, requires explanation:

• Why weren’t hybrid wet-dry cooling systems, which could save 600 million to 1 billion gallons annually, incorporated into the design?

• What economic analyses justified rejecting dry cooling that would eliminate water consumption entirely?

• How does Fermi reconcile claiming water conservation as a priority while choosing the most water-intensive option for their second-largest consuming component?

• Would the 2-4% efficiency penalty from dry cooling significantly impact project economics, given the $13.16 billion valuation?

Data Center Cooling Strategy

The apparent use of conventional cooling for the massive data center campus raises perhaps the most puzzling questions:

• Why doesn’t the project incorporate liquid cooling, indirect evaporative cooling, or elevated temperature operations that major tech companies routinely use?

• How can Fermi justify using 2.6 billion gallons annually for data centers when Microsoft and Google achieve near-zero water consumption at similar facilities?

• What prevents the implementation of water recycling systems that could reduce consumption by 90%?

• Why locate water-intensive data centers in a water-scarce region when they could operate anywhere with adequate power and connectivity?

Regulatory and Compliance Issues

The unprecedented nature of several project aspects requires regulatory clarity:

• How will the NRC evaluate air-cooled condenser technology that has never been licensed or operated on AP1000 reactors?

• What additional studies or demonstrations might regulators require before approving unproven cooling systems?

• How should state water authorities evaluate industrial consumption that dwarfs municipal use while providing primarily private benefits?

• What mechanisms ensure compliance with water consumption projections, and what remedies exist if actual use exceeds permitted amounts?

Economic and Risk Analysis

The economic implications of cooling technology choices deserve thorough examination:

• What is the true cost differential between water-intensive and water-conserving technologies across all project components?

• How do temporary construction jobs compare economically to permanent agricultural production lost to aquifer depletion?

• Who bears financial liability if cooling systems fail to perform as claimed?

• What insurance or bonding protects communities if water consumption exceeds projections?

• How should stranded asset risk be evaluated if water becomes unavailable before the project’s planned lifetime?

Resource Allocation Framework

The fundamental question of resource allocation in water-scarce regions requires policy answers:

• Should industrial projects consuming billions of gallons receive equal priority with agricultural users who have relied on these resources for generations?

• What framework should guide decisions between water for food production versus water for data centers?

• How should the permanent nature of aquifer depletion factor into temporary economic development decisions?

• What precedent does this project set for future industrial water use in the region?

Environmental and Climate Considerations

The interaction between cooling requirements and climate change needs examination:

• How will rising temperatures affect cooling system performance across all components?

• What happens to water consumption projections if average temperatures increase by 2-3°F as climate models predict?

• How does accelerated aquifer depletion impact regional climate resilience?

• Should carbon-free nuclear power that requires massive water consumption be prioritized over renewable energy with minimal water requirements?

Technical Verification and Transparency

The lack of detailed technical documentation raises concerns about project feasibility:

• Why hasn’t Fermi published engineering studies demonstrating ACC viability for their specific application?

• What independent technical review has validated cooling system claims?

• Why are water consumption calculations not broken down by specific systems and operations?

• What prevents full transparency about water sources, consumption rates, and conservation alternatives?

These questions require answers before committing irreplaceable water resources to a project of this scale.

The technical complexity of cooling three different types of industrial facilities, combined with the unprecedented nature of some proposed solutions and the permanent consequences of aquifer depletion, demands thorough investigation and transparent documentation.

Communities, regulators, and investors all deserve complete information to make informed decisions about a project that would fundamentally alter regional water resources for generations.

Recommendations for Stakeholders

Based on the comprehensive technical analysis of cooling requirements across nuclear, gas turbine, and data center components, stakeholders should consider the following expanded recommendations that address the full scope of water consumption challenges:

For Regulators:

Nuclear regulators should require comprehensive technical documentation demonstrating not just the theoretical possibility but the practical feasibility of air-cooled condensers for AP1000 reactors under Texas climate conditions. This should include validated thermal modeling, materials testing data, and operational parameters across the full range of expected ambient temperatures.

The NRC should consider requiring demonstration projects or prototype testing before approving commercial-scale deployment of unproven cooling technology.

State water authorities need to evaluate the total water consumption across all facility components, not just the nuclear portion highlighted in public presentations. This evaluation should include mandatory consideration of available conservation technologies for gas turbines and data centers, with requirements to justify why proven water-saving alternatives were rejected.

Permitting should include enforceable consumption limits with automatic curtailment provisions if water levels decline below specified thresholds.

Environmental regulators should require cumulative impact assessments that consider the acceleration of aquifer depletion caused by adding 4.6 billion gallons of new industrial demand to existing agricultural consumption. These assessments should model various climate scenarios and their effects on cooling system performance and water availability over the project’s intended 60-80 year lifetime.

For Investors:

Investment due diligence should go beyond accepting company claims about revolutionary cooling technology to demanding independent engineering validation from firms without financial stakes in the project. The 2007 Southern Company study, which identified thermodynamic impossibilities for ACC implementation on AP1000 reactors, requires a specific technical refutation, not just assurances that the technology has advanced.

Investors should particularly scrutinize why proven conservation technologies were rejected for the components consuming 99.6% of the project’s water.

Risk assessment must consider scenarios where cooling systems fail to perform as projected. Suppose ACCs cannot maintain the required nuclear plant backpressures during summer heat. In that case, the plant may operate at reduced capacity or shut down entirely during peak demand periods, which can devastate project economics.

If gas turbines and data centers consume more water than projected due to rising temperatures or extended drought, what mechanisms protect investor returns?

The business model’s dependence on continuous water availability from a depleting aquifer represents a stranded asset risk that could materialize well before the project’s planned lifetime. Investors should evaluate whether the rush to establish position in the AI data center market justifies the long-term risk of locating water-intensive operations in a water-scarce region.

For Communities:

Communities should demand complete transparency about water consumption, broken down by specific systems: nuclear condensers, gas turbine cooling, data center cooling, and auxiliary uses. Generic claims about “revolutionary cooling technology” should be met with requests for detailed engineering documentation.

Communities deserve to know not just what Fermi claims is possible, but what independent engineers confirm is achievable.

Economic development negotiations should include specific provisions addressing water conservation and management. If Fermi claims that water conservation is a priority, agreements should require the implementation of the best available conservation technology across all components, not just the nuclear plants.

This could include mandatory use of hybrid cooling for gas turbines and advanced cooling for data centers, with financial penalties for excess consumption.

Communities should establish independent technical review panels, including engineers without project connections, to evaluate cooling system claims and water consumption projections. These panels should have the authority to review operational data and require modifications if consumption exceeds projections.

Bonding requirements should be sufficient to cover the cost of alternative water supplies or compensation to affected agricultural users if industrial consumption accelerates aquifer depletion.

Local governments should consider moratoriums on new water-intensive development until comprehensive aquifer management plans are developed. These plans should prioritize existing agricultural users who have invested in the land for generations over speculative industrial ventures.

Water pricing structures should reflect the scarcity value of water, rather than treating it as a free resource for industrial consumption.

For Fermi America:

If Fermi genuinely intends to implement air-cooled condensers on AP1000 reactors, the company should immediately publish detailed engineering studies addressing the specific technical challenges identified in the 2007 Southern Company analysis. This should include thermal modeling, material specifications, and operational parameters that demonstrate how their design overcomes the thermodynamic limitations previously identified.

Vague claims about technological advancement without specific documentation undermine credibility and raise questions about project feasibility.

For gas turbine systems, Fermi should provide a clear economic analysis explaining why hybrid or dry cooling systems were rejected despite their proven ability to reduce water consumption by 30-50% or more. If a 2-4% efficiency penalty makes conservation uneconomical, this should be transparently acknowledged rather than hidden behind claims of revolutionary nuclear cooling that saves less than 0.5% of total project water use.

For data center operations, Fermi should explain why their facilities won’t incorporate the water conservation technologies that Microsoft, Google, and other major operators routinely implement. If the business model depends on minimizing capital costs by externalizing water consumption costs onto communities, this should be honestly acknowledged. Alternatively, if conservation technologies will be implemented, specific commitments with enforceable provisions should be included in all permits and agreements.

The company should develop and publish comprehensive contingency plans for various operational scenarios. What happens if ACCs cannot maintain required performance during heat waves? How will operations adjust if water availability becomes constrained? Who bears financial responsibility for consumption exceeding projections? What compensation mechanisms exist for agricultural users whose wells fail due to accelerated aquifer depletion?

Most fundamentally, Fermi should reconsider whether locating 4.6 billion gallons of annual water demand in one of America’s most water-stressed regions represents responsible development, regardless of cooling technology claims. Alternative locations with adequate water resources, cooler climates that reduce cooling demands, or access to seawater for cooling could achieve the same objectives without threatening irreplaceable groundwater resources that communities depend on for survival.

Conclusion: The Need for Careful Evaluation

The Fermi America project represents a significant undertaking with substantial implications for the Texas Panhandle’s water resources and economic future. The technical challenges associated with air-cooled condensers for AP1000 reactors, combined with the total annual water demand of 4.6 billion gallons, raise important questions that deserve thorough examination.

As someone who has spent four decades advancing nuclear power, I believe the industry’s future depends on projects that demonstrate both technical feasibility and environmental sustainability. The questions raised here are not opposition to nuclear development but rather a call for the careful evaluation that complex projects require. Nuclear power’s important role in our clean energy future makes it essential that new projects meet high standards for technical accuracy and resource stewardship.

The depletion of the Ogallala Aquifer represents an irreversible process with permanent consequences for agricultural communities. Once this ancient water is consumed, it cannot be replaced within human timescales.

This reality demands particularly thoughtful consideration of large-scale industrial water uses, especially when alternative technologies or locations might achieve similar objectives with less resource impact.

Ultimately, the communities of the Texas Panhandle must weigh the potential benefits of industrial development against the long-term sustainability of their water resources. This decision should be informed by complete technical information, transparent analysis of trade-offs, and careful consideration of both immediate gains and permanent consequences.

The questions raised in this analysis are offered in the spirit of ensuring that development serves the long-term interests of the region and its people.

The path forward requires open dialogue among all stakeholders, rigorous technical review, and commitment to sustainable resource use. Whether the Fermi America project can meet these standards remains to be determined through the regulatory process and community engagement.

What is certain is that decisions made today about water resources will shape the Texas Panhandle’s future for generations to come.

References

All information in this analysis is drawn from publicly available documents and technical studies:

1. Fermi America COLA Filing, NRC Docket No. 52-055, Section 2.3.1 (September 2025) - Claimed water consumption figures for nuclear plants

2. Cuchens, J. & Lazenby, C. (2007), “Feasibility of Air-Cooled Condenser Cooling System for the Standardized AP1000 Nuclear Plant,” Southern Company Generation Engineering & Construction Services, Revision 3 - Technical analysis of ACC challenges

3. Fermi America, LLC (2025), “Combined Operating License Application, Parts 1 and 3,” Revision 0 - Project structure and cooling system claims

4. EPA (2010), “Water Use in Combined Cycle Power Plants,” EPA-HQ-OAR-2008-0708-2409 - Gas turbine water consumption data

5. Siemens Energy (2023), “F-Class Gas Turbine Water Consumption in Combined Cycle Applications,” Technical Bulletin - Industrial cooling requirements

6. Uptime Institute (2024), “Data Center Water Usage Effectiveness Survey” - Data center consumption patterns

7. McGuire, V.L. (2023), “Water-Level Changes in the High Plains Aquifer,” USGS Scientific Investigations Report - Aquifer depletion data

8. Chaudhuri, S. & Ale, S. (2014), “Long-term trends in groundwater levels in Texas,” Science of The Total Environment - Projection models

9. North Plains Groundwater Conservation District (2024), “Annual Groundwater Monitoring Report” - Current water level data

10. Texas A&M AgriLife Extension (2023), “Economic Impact of Agriculture in the Texas High Plains” - Agricultural economy data

This analysis is based on publicly available information and technical studies. All stakeholders are encouraged to conduct their own due diligence and seek additional information as needed.