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EPA Cooling System Regulations

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

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EPA Cooling System Regulations

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  1. EPA Cooling System Regulations Hall of States Briefing February 22, 2011

  2. 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

  3. 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

  4. 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?

  5. 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

  6. Once Through Plants

  7. Adverse ConsequencesOf 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 once-through systems have little or no adverse impact on fish populations (NPDES permits)

  8. 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

  9. 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

  10. 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: • Demonstration that technology is “effective” at site • Determine technology is “affordable” at site • Cost-benefit calculation to determine benefits exceed costs (or is not “wholly disproportionate”)

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