The Honorable Gina McCarthy
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave, N. W.
Washington, DC 20460
Dear Administrator McCarthy,
We are writing in support of the Environmental Protection Agency's (EPA) proposed Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Source Category. We encourage EPA to expeditiously move to finalize a toxic water pollution rule that would lead to zero discharge of dangerous pollution like arsenic, mercury, lead and selenium into our country's rivers, lakes and streams.
Updated rules are needed because Steam Electric Power Plants are responsible for at least 50 to 60 percent of the toxic pollutants discharged annually into waters of the U.S. -- more than the other top nine polluting industries combined. Despite the scope of this pollution problem, the existing standards have not been updated since 1982 and fail to set discharge limits on a long list of dangerous pollutants toxic to humans and aquatic life. According to EPA, this failure has led to over 160 water bodies not meeting state water quality standards, 185 waters with fish consumption advisories and the degradation of 399 water bodies across the country that are drinking water supplies.
The Clean Water Act requires states to set strong discharge standards for polluters in the absence of federal standards. Unfortunately, most state permitting agencies have failed to set limits in discharge permits for individual plants that reflect the best available treatment technology and protect water quality. Treatment technologies are available today that can achieve near zero discharge of pollution at a cost that is affordable to the industry as a whole; in fact, 80 percent of plants no longer discharge fly ash wastewater and 42 percent of plants have eliminated bottom ash wastewater discharges. The remaining plants that rely primarily on "settling ponds" to treat fly ash and bottom ash wastewater or sludge from flue gas desulphurization ("FGD") systems, are decades behind updating to the best available technology. Absent a strong federal rule, the amount and toxicity of this waste stream is expected to increase as more plants install much needed smokestack "scrubbers" - systems that prevent toxic metals from going into the air. Use of these scrubbers can result in a concentrated, wet, toxic sludge that is typically placed in settling ponds that are ineffective at treating dissolved metals.
We encourage EPA to act swiftly to finalize a strong rule that will require power plants to drastically reduce the amount of toxics and other harmful pollutants they discharge into rivers, lakes, streams and bays. A strong rule resulting in zero discharge would eliminate billions of tons of unnecessary pollution a year, resulting in thousands of river miles that are safer to swim and fish in, and thousands of miles of cleaner drinking water sources.