COUNTRYMARK
COOPERATIVE,
LLP
1200
Refinery
Road
Mt.
Vernon,
Indiana
47620
March
29,
2004
Mr.
John
Fox
US
EPA
Washington,
DC
20510
Re:
Pre­
Rulemaking
Comments
Phase
III
Cooling
Water
Intake
Structures
Dear
Mr.
Fox,

Countrymark
appreciates
the
opportunity
to
be
a
part
of
the
regulatory
process
and
comment
on
the
Phase
III
Cooling
Water
Intake
proposals.

As
you
know,
Countrymark
Cooperative,
LLP.
is
a
regional,
farmer
owned
cooperative
which
owns
and
operates
a
24,000
barrels
per
day
petroleum
refinery
located
in
Mt.
Vernon,
Indiana.
Countrymark
Co­
op
employs
approximately
300
people.
Countrymark
is
a
small
refinery
as
defined
by
the
Small
Business
Administration.

Our
refinery
has
the
ability
to
withdraw
approximately
2
million
gallons
per
day
of
surface
water
from
the
Ohio
River.
This
water
is
treated
and
used
to
supply
both
process
and
cooling
water
for
our
refinery.
The
cooling
water
intake
structure
is
mounted
within
a
permanent
barge
structure
and
consists
of
submerged
basin
with
passive
water
inlet
holes.
The
water
is
then
screened
prior
to
entering
the
pump
well
area.
The
pump
basin
area
is
protected
with
screens
that
are
inspected
and
cleaned
daily.
Typical
debris
includes
vegetation
(
sticks,
leaves,
etc.)
and
river
trash
(
bottles,
plastic,
foam,
etc.).
Only
rarely
would
fish
or
other
water
life
enter
this
area.
In
any
case,
it
does
not
appear
to
become
impinged
upon
the
screens.

With
this
design,
direct
impingement
does
not
generally
occur.
The
next
step
is
sedimentation
and
chemical
treatment
where
silts
and
other
suspended
material
are
removed.
Clean
water
then
moves
from
the
reservoir
into
the
water
supply
system.
After
the
water
is
used,
it
runs
through
an
NPDES
wastewater
treatment
system
and
is
discharged
downstream
at
essentially
ambient
temperatures.

Countrymark
feels
that
our
current
water
intake
structure
design
minimizes
impingement
and
entrainment.
It
is
our
opinion
that
no
further
upgrades
are
warranted.
With
that
said,
we
assume
that
EPA
would
agree.
If
not,
Countrymark
would
question
the
severity
and
necessity
of
further
mandated
controls.
Proposed
Cooling
Water
Intake
Structure
Rules
Page
2
of
2
March
29,
2004
Given
the
previous
statements,
Countrymark
offers
the
following
comments:

1.
Additional
environmental
regulations
applying
to
smaller
cooling
water
intake
structures
should
not
be
dictated
unless
there
are
compelling
reasons.
EPA
has
not
shown
that
impingement
and
similar
local
issues
impact
the
environment
/
fish
in
a
significantly
adverse
way
in
all
but
limited
examples.
Perhaps
EPA
should
consider
prohibiting
certain
designs
or
susceptible
locations
(
those
with
endangered
fish,
etc.)

2.
The
Phase
III
regulations
if
warranted,
should
have
a
minimum
flow
threshold
of
no
less
than
20
million
gallons
per
day,
unless
there
are
source
stream
/
lake
considerations
that
add
a
compelling
reason.

3.
EPA
should
not
consider
just
cooling
water
intake
structures.
Consider
all
sources
of
water
intake
structures
and
don't
target
specific
industries
or
activities.
Drinking
/
recreational
/
agricultural
water
withdrawal
intake
structures
also
cause
impingement
/
entrainment.
It
is
either
a
universal
problem
or
not.
It
does
not
seem
fair
to
regulate
specific
users
and
not
all
entities
with
water
intake
structures.

4.
A
registration
process
with
each
regulated
entity
would
include
some
requirement
for
description
of
the
water
withdrawal
intake
structure.
Structure
with
designs
less
likely
to
contribute
to
impingement
or
entrainment
need
not
have
any
other
requirements.

5.
EPA
should
provide
some
level
of
significance
in
terms
of
harm
caused
by
excessive
impingement
or
entrainment.
This
could
be
in
terms
of
number
of
the
fish
entrained
per
day
or
other
easily
gauged
metric.
Water
users
could
then
estimate
the
potential
harm
caused
by
a
poorly
engineered
design.

6.
EPA
should
make
available
detailed
water
intake
designs
that
minimize
impingement
or
entrainment
and
are
easy
to
clean.
There
is
a
strong
incentive
for
the
water
users
to
use
designs
that
minimize
daily
or
periodic
maintenance.
Being
friendly
to
the
environment
is
an
added
benefit.
Countrymark
appreciates
the
opportunity
to
comment
on
this
proposed.
Please
contact
me
(
horning@
countrymark.
com
or
812­
838­
8133)
if
you
have
any
questions
or
comments.

Sincerely,

Donald
M.
Horning,
REHS
Regulatory
Compliance
Manager
