By Cathy Cash | ECT Staff Writer
As the Environmental Protection Agency prepares to revise guidelines for wastewater discharges from coal generation, NRECA is urging the agency reconsider the potential impact of the rule on small power plants.
EPA should rethink the cost effectiveness of these pending effluent limitations guidelines and revise them to reflect cost effectiveness experienced in other sectors, according to NRECA. Further the agency should provide more data to justify a final rule.
NRECA on Sept. 20 submitted comments to the agency on its proposed guidelines.
NRECA also suggests that EPA give water permit writers flexibility to allow time for plant modifications that may be required by the new guidelines.
“Such flexibility is particularly important if a facility owner/operator decides to close a coal combustion residue impoundment and implement an alternative dry ash management system,” said Dorothy Kellogg, NRECA’s senior principal for environment policy.
EPA proposed a menu of eight options for seven waste streams and plans to finalize guidelines by May 22, 2014.
NRECA’s generation and transmission members stand to be significantly affected by any rules regarding wastewater discharges since 70 percent of their generation in 2012 was coal-based.
Among the options under consideration by EPA, NRECA would support continued wet-handling of fly ash and bottom ash in surface impoundments or wastewater ponds.
The association also encourages the agency to continue and expand the practice of centralized wastewater treatment and recycling of water rather than impose various internal limits within power plants as proposed.
Further, NRECA recommends that the agency coordinate these effluent guidelines with its pending regulation for coal combustion residue so as to better coordinate sector compliance.
“We look forward to working with EPA as they move toward finalizing this in a way that makes sense for small generators, is cost-effective and flexible,” said Kellogg.