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EPA Cooling System
Regulations
Hall of States Briefing
February 22, 2011
What is Clean Water Act Section
316(b)?
CWA Section 316(b) requires that cooling water
intake structures (CWIS) reflect the best
technology available (BTA) for minimizing
adverse environmental impact
Calls for national technology-based performance
requirements to govern the location, design,
construction, and capacity of CWIS
What Is EPA Doing?
Promulgating proposed rule for existing
electric generating (all fuels) and industrial
facilities
– Proposed March 2011; Final July 2012
New facilities rule completed in 2001
New rules would replace the site-specific
“best professional judgment” exercised by
state permit writers since 1977
EPA Stated Objective
Uniform, consistent, “easy” to implement
regulation of cooling water intake structures
Favor cooling towers (flow reductions) as
most effective technology – assumes 100
percent mortality of any entrained or impinged
organisms.
EPA believes that it is reasonable only to
consider the loss of aquatic organisms due to
impingement and entrainment as “adverse
environmental impact”.
– Magnitude?
Utility Concerns in 316(b)
> 400 steam electric generating facilities affected by
proposed rule
Approx 40% of existing fleet subject to proposal (312GW)
– 60% nuclear capacity; 23% fossil capacity
Revised regulations may require plants to be re-engineered
to replace once-through cooling systems with cooling towers
when alternative technologies are available
Implementation problematic: Each power plant configuration
and location is unique – as is the adjacent water body and its
aquatic resources. Site-specific analysis and cost-benefit
analysis is crucial
Once Through Plants
Adverse Consequences
Of Retrofit Requirement
Affects ALL steam electric facilities
Cost—$95 billion total, or $305 per person, $1220 for family of
four
Grid Reliability—national average reserve margin reduced 33%
due to less efficient cooling towers and premature plant
shutdowns (NERC)
– Agency studies conclude reliability impacts (NETL, NERC, DOE)
• 2008 DOE / NERC study found that 39,500 Mw would be prematurely
closed due to retrofit mandate
• Retrofits result in 2-4% lost capacity
Over-Regulation—scientific studies at power plants show oncethrough systems have little or no adverse impact on fish
populations (NPDES permits)
Cooling Tower Potential Impacts
Cost: Towers are prohibitively expensive; difficult to retrofit
Affects plant economics, efficiency and electricity prices
Water Use: Towers consume more water than once-through
systems (2x)
Emissions: Additional GHG, particulate emissions and salt
drift
– Permitting: Increase in particulate emissions may preclude
permitting
Efficiency: Less efficient, reducing electricity output,
requiring more power plants
Other environmental concerns: fogging, icing, space
consideration, noise, aesthetics
Energy & Price Consequences
Energy
– Capacity reduction due to efficiency losses (2-4%)
– Extended outages – vary, some companies report 40+
months
– Resource margin adequacy, reliability difficulties, load
balancing concerns
– NY ISO forecast 1/5 of generation resources may retire
– Insufficient compliance time may not allow for
development of replacement capacity
Price increases –
– CA: 6-9% increases
Preferred Regulatory Approach
Site-specific analysis to determine whether adverse
environmental impact is actually occurring,
considered at the fish population level
Range of proven fish protection technologies – e.g.,
fine mesh screens, fish return systems, barrier nets,
wedgewire screens, etc. as compliance options
Meaningful cost-benefit test. Includes:
1. Demonstration that technology is “effective” at site
2. Determine technology is “affordable” at site
3. Cost-benefit calculation to determine benefits
exceed costs (or is not “wholly disproportionate”)