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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”)