Will Clean Water Act 316b Regulations End Chemical Cooling Water Treatment Programs?

The implementation of EPA’s 316b cooling water intake rules for impingement and entrainment mortality certainly present formidable challenges to power plants and industrials. The effort becomes all the more daunting with uncertainty on the application of the regulations on a site-by-site basis by individual Federal and State permit writers, and the lingering potential for legal challenges that could modify the requirements in the future.  While pessimism about clearly defining Best Technology Available (BTA) may be justified, it is also possible to see the rules as an imposed opportunity to give attention to often overlooked cooling water systems whose performance can significantly impact plant efficiency.

Using the regulatory process as incentive, there is an opportunity to acquire resources necessary to rigorously review the current facilities and performance, future objectives, and evaluate the best options in light of the plant’s goals.  The process also provides for extensive consideration of non-environmental factors in determining BTA.  Some of the most important of these include: reliability and cost of electric service, plant efficiency impacts, technical feasibility, financial costs and benefits, age of the plant, and social costs.  BTA will not be an absolute number, but a demonstration of best overall environmental and other costs and benefits.  While assessing this for each 316b program option will demand significant effort, when approached as an exercise to improve plant and financial performance along with the environmental goals, the process can become a win-win rather than simply a regulatory burden.

To see a more detailed presentation with examples related to chemical treatment programs please click here!

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