Nuclear energy industry files comments on EPA’s proposed rule on cooling water systems

Source: Nuclear Energy Institute

A proposed US Environmental Protection Agency rule governing cooling systems at thermoelectric power plants and other industrial facilities has some sensible features, but also has serious flaws that lack a sound technical basis and would be unnecessarily difficult and costly to implement, the nuclear energy industry told the agency today. 

Hundreds of natural gas- and coal-fired power plants and 62 of the nation’s 104 commercial reactors are affected by the proposed rule. Without changes, the agency’s proposed requirements could force costly, multi-year plant modifications at many of America’s power plants, and may even lead to premature closure of some facilities. Moreover, these measures will not necessarily achieve the overall environmental gains that EPA seeks in this phase of its implementation of Section 316(b) of the Clean Water Act. 

EPA issued the proposed rule last March and has received tens of thousands of comments from interested parties, including 14,000 from members of Congress, governors, state lawmakers, state utility commissions, labor unions, water authorities, and others who share the nuclear energy industry’s concerns about the potential economic impact on consumers from higher electricity prices and other unintended consequences that would result from the proposed regulation. Today is the deadline for filing comments on the rule governing existing power plants that use water to cool key systems. 

In comments filed by the Nuclear Energy Institute, the industry said the rule should allow greater flexibility in how companies reduce the trapping or “impingement” of fish against cooling water intake screens. The industry cited the proposed provisions aimed at preventing fish from passing through cooling water intake systems (i.e., “entrainment”) as an example of such flexibility. While the entrainment provisions could be improved, they provide a holistic environmental approach for site-specific decisions on how best to reduce entrainment. Moreover, they rightly leave such decisions to the permitting authority, NEI argued. The permitting authority is often a state environmental regulator intimately familiar with the water body in question.

Numerous scientific studies demonstrate that in many cases cooling water intake structures have had no adverse impact on the overall health of the fish populations near nuclear power plants. These include independent studies that have been reviewed and accepted by state environmental permitting agencies.

EPA is expected to finalize the proposed rule in July 2012.

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