The Edison Electric Institute (EEI) today expressed support for certain elements of the U.S. Environmental Protection Agency’s (EPA’s) proposed new rule governing cooling water intake structures at existing power plants, but also urged the agency to modify other parts of the blueprint that EEI believes are unnecessary, infeasible and excessively costly.
“Our member utilities are unified in their strong commitment to reduce potential harmful effects of impingement and entrainment and to protect the environment as an integral component of generating electricity for the nation,” said EEI President Tom Kuhn. “But we also believe strongly that EPA can and should produce a final rule that is reasonable, streamlined and imposes only requirements whose costs are commensurate with expected benefits.”
EEI’s comments were filed today in response to a sweeping, complex EPA proposal to establish national requirements applicable to the location, design, construction, and capacity of cooling water intake structures at existing U.S. power plants. The proposal is intended to minimize adverse environmental impacts that may be occurring. EEI has worked diligently with the agency’s leadership and water program staff to provide detailed, technical information about the unique characteristics of generation facilities and opportunities for safeguarding aquatic populations and ecosystems potentially affected by cooling water intake structures.
Among EEI’s main concerns is that the agency’s proposal to develop two independent standards, one for impingement and another for entrainment, for which compliance is required during different time frames, would create uncertainty and wasted investment. EPA should allow state environmental agencies to evaluate impingement and entrainment requirements jointly, incorporating site-specific factors and cost-benefit analysis when deciding whether additional technology is needed at an existing facility.
EEI endorsed the agency’s decision that utilities not be required in every case to install “closed-cycle cooling” facilities at power plants, because such facilities may not be feasible or cost-effective in many cases, and can cause other environmental and energy problems that outweigh benefits.
EEI also supported EPA’s decision to direct state environmental agencies to safeguard fish from entrainment after consideration of each site’s unique characteristics, weighing costs and benefits and taking into account information provided by facility owners/operators.
And, EEI welcomed EPA’s proposal to treat rebuilt, repowered, and replacement units at existing power plants as “existing facilities,” thus allowing companies to make environmental and energy efficiency upgrades at their facilities without being subject to requirements that are not feasible or cost effective.
However, the proposal would also impose a uniform, nationwide mandate to meet rigid “impingement” standards. These standards are based on the false assumption that they are achievable at all existing facilities. EEI expressed concern that there is no valid environmental or biological justification for precluding the use of the same site-specific flexibility for impingement that the proposed rule provides for entrainment. Calling such one-size-fits-all impingement requirement a “prescription for failure,” EEI encouraged EPA to modify the proposal to provide permit writers the same flexibility to determine the need for additional impingement measures the proposal provides for entrainment measures.
EEI further encouraged EPA to provide fuller recognition that existing protection measures already in place at many facilities, including closed-cycle cooling used at a number of existing facilities, may provide sufficient environmental protection and do not warrant the need for utilities to conduct further review or add new technology.
“We urge EPA to address the technical issues raised in industry’s comments in order to contain costs to electricity consumers and avoid potential reliability impacts in some areas,” Kuhn said.