Message to EPA: Time to Modernize America’s Power Plants — Cooling Systems Included

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Steve Fleischli, Senior Attorney, Washington, DC

Last night, EPA announced a 413-page proposed rule for cooling water intake structures at U.S. power plants.  However, instead of moving toward modernizing America’s power plants and protecting our water resources, EPA’s new proposed rule on cooling water moves us backward.  Basically, EPA has chosen the path of least resistance by caving into industry pressure and punting this issue to state agencies – agencies that too often lack the resources and the will to stand up to industry on this issue.  That’s why, in a joint statement, NRDC and Riverkeeper denounce the proposed rule and call on EPA to do more to protect our waterways from power plants’ destructive impacts.

The proposed rule is in response to decades of litigation over the water-related impacts from power plants and the failure of both state and federal agencies to address these impacts.  With more than 500 U.S. power plants still relying on the most antiquated and destructive type of cooling system – known as once-through cooling – power plants are the largest water users in the country – ahead of agriculture and household use and accounting for an astonishing 41% of all freshwater withdrawn for human use. 

In a once-through cooling system, water is withdrawn directly from a body of water, diverted through a condenser where it absorbs heat from the boiler steam, and then discharged back into the water at higher temperatures.  None of the water is recycled.

This practice kills fish and aquatic organisms by the millions by “impinging” them on intake screens (i.e., trapping them against the screens by the pressure of the intake flow) and by “entraining” them through heat exchangers where they die due to physical, thermal and toxic stresses.  Over at OnEarth, Lake Erie Waterkeeper Sandy Bihn highlights the incredible local impacts these old plants can have.  The Bayshore power plant in her Maumee Bay community kills tens of millions of fish and over 2 billion juvenile and larval fish every year.  That’s why she calls power plants “incredible killing machines.”  And she’s right.  Around the country, this outdated technology kills billions of fish and destabilizes aquatic populations.

In addition, the use of once-through cooling can make cooling operations vulnerable in drought or low streamflow conditions.  EPA acknowledged as recently as yesterday that “at least 36 states are anticipating local, regional, or statewide water shortages by 2013, even under non-drought conditions.”  Moreover, a recent NRDC/TetraTech report highlights that, in many places in the U.S., water withdrawals already exceed sustainable water supply – and the number of areas vulnerable to future water shortages will only increase with increases in energy demand and with a changing climate.  In this respect, continuing to rely on such intensive water withdrawals can only jeopardize our energy grid and water resources.     

Better options exist, and the debate about how best to minimize harm was settled long ago.  For nearly 20 years, new U.S. power plants have relied on closed cycle cooling or dry cooling as an alternative to once-through cooling.  These systems either recycle the cooling water or hardly use any water at all.  But many older plants, typically those built more than 30 years ago, still rely on antiquated and damaging once-through cooling systems.  This new rule was supposed to stop that practice, but does anything but that.

Experience has shown that a case-by-case approach, as proposed by EPA, simply will not work.  Instead, it is guaranteed to mire the Clean Water Act permitting process in an endless cycle of paperwork and litigation that will continue to leave waterbodies across the country unprotected.  If any lesson has been learned in the nearly four decades since the Clean Water Act was enacted, it is that many state permit writing agencies lack the resources and expertise to permit power plant intake structures in the absence of national categorical requirements.

EPA has been getting a lot of heat from the power industry lately, but to its credit, EPA has shown strong leadership in addressing air pollution issues.  However, power plants cause harm to water as well as air, and these enormous water impacts from U.S. power plants cannot be ignored.

We will object to this weak EPA proposal in what are sure to be lengthy comments submitted during the 90-day public comment period.  It is time to modernize our power fleet – and that includes reducing the energy industry’s tremendous impact on our water resources. 

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