Debbi
Hart
07/
18/
02
04:
20
PM
To:
Richard
Bozek
<
RICHABEE@
eei.
org>
cc:
Lynne
Tudor/
DC/
USEPA/
US@
EPA,
Deborah
Nagle/
DC/
USEPA/
US@
EPA,
Tom
Wall/
DC/
USEPA/
US@
EPA
Subject:
Re:
Questi
re:
Option
1
Rich­

My
apologies
for
this
delayed
response.
With
several
folks
out
on
leave,
the
rest
of
us
are
pulling
additional
loads.

Following
are
the
main
criteria
used
in
assigning
Phase
II
facilities
costed
with
cooling
towers
to
compliance
years.
Please
note
that
a
detailed
description
of
the
methodology
can
be
found
in
the
Appendix
to
Chapter
B1
(
pp.
B1­
20
and
B1­
21).

Compliance
years
for
nuclear
facilities:
**
during
the
first
post­
promulgation
permit
period
(
the
analysis
assumes
that
planning
will
take
one
year;
the
compliance
period
is
therefore
years
2­
5
after
the
first
postpromulgation
permit;
the
analysis
is
based
on
the
expiration
of
the
current
NPDES
permit)
**
during
year
of
an
in­
service
inspection,
ISI
(
assumed
to
take
place
in
5­
year
intervals
beginning
with
the
first
year
of
a
unit's
operation)
­­­>
In
all
but
one
case
this
methodology
identified
one
specific
compliance
year.
In
one
case
where
the
two
criteria
were
mutually
exclusive,
the
facility
was
assumed
to
comply
during
the
ISI
year
which
is
the
year
of
its
first
post­
promulgation
permit.

Compliance
years
for
non­
nuclear
facilities:
**
during
the
first
post­
promulgation
permit
period
(
the
analysis
assumes
that
planning
will
take
one
year;
the
compliance
period
is
therefore
years
2­
5
after
the
first
postpromulgation
permit;
the
analysis
is
based
on
the
expiration
of
the
current
NPDES
permit)
**
within
the
4­
year
period
(
and
given
the
distribution
of
compliance
years
of
nuclear
facilities,
as
determined
above),
compliance
years
were
assigned
so
that
the
total
amount
of
capacity
off­
line
in
each
NERC
region
is
distributed
as
evenly
as
possible.

Another
consideration
was
the
representation
of
facilities
costed
with
cooling
towers
during
IPM
run
years
(
2008,
2010,
and
2013).
Where
an
even
distribution
was
not
possible,
EPA
assigned
facilities
with
higher
compliance
costs
to
earlier
years
(
within
the
methodology
constraints),
to
provide
a
conservative
estimate
of
annualized
compliance
costs.

I
hope
this
is
helpful
to
you.
Debbi
_________________________________
Debbi
Hart
(
4303T)
U.
S.
Environmental
Protection
Agency
Cooling
Water
Intake
Task
Force
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
(
202)
566­
6379
hart.
debbi@
epa.
gov
Richard
Bozek
<
RICHABEE@
eei.
org
>

07/
12/
02
02:
25
PM
To:
Debbi
Hart/
DC/
USEPA/
US@
EPA
cc:
Subject:
Question
re:
Option
1
Debbi
­

Thanks
for
your
help.
I
am
trying
to
understand
the
manner
in
which,
for
modeling
purposes,
EPA
distributed
the
54
facilities
requiring
a
retrofit
of
a
cooling
tower
in
Option
1
(
Waterbody/
capacity­
based)
against
compliance
year.
In
other
words,
were
these
facilities
modeled
based
on
their
actual
permit
cycle,
simply
distributed
evenly
for
years
X­
Y,
or
in
another
manner?
Tom
suggested
the
54
were
evenly
distributed
among
compliance
years.
If
this
is
the
case,
can
someone
explain
how
that
falls
in
line
with
the
Tables
on
B1­
22,23?
I
am
having
difficulty
understanding
what
is
represented.
Thank
you.

Rich
C.
Richard
Bozek
Manager,
Environmental
Programs
Edison
Electric
Institute
701
Pennsylvania
Ave.,
N.
W.
Washington,
D.
C.
20004
(
202)
508­
5641
E­
mail:
Rbozek@
eei.
org
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