The US Nuclear Energy Institute has sent a letter to the US Environmental Protection Agency objecting to its proposals to reduce fish kills in cooling water intake structures.
The NEI argued: "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.
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.
EPA is expected to finalize the proposed rule in July 2012.