1
MEMO
TO
PHASE
III
RECORD
Date:
April
28,
2004
RE:
Analysis
of
25%
Cooling
Water
Usage
Threshold
for
Phase
III
Facilities
This
memo
describes
an
analysis
of
cooling
water
usage
at
Phase
III
facilities
under
a
variety
of
scenarios.

Historical
Analyses
in
Phase
III
On
September
2003,
EPA
removed
11
facilities
from
the
Phase
III
master
list
due
to
the
withdrawal
of
less
than
25%
of
intake
water
being
apportioned
to
cooling
water.
These
deletions
were
the
result
of
a
change
in
the
interpretation
of
actual
intake
flow
(
AIF)
to
include
flow
data
from
1996
to
1998
(
3­
year
average)
instead
of
only
1998
data
(
1­
year
average).

Phase
III
Analyses
The
analyses
of
various
scenarios
for
measuring
compliance
with
the
25%
threshold
were
performed
for
Phase
III
facilities.
The
first
scenario
uses
a
facility­
level
analysis
of
cooling
water
usage,
where
the
total
intake
flow
of
a
facility
(
and
all
of
its
intakes)
is
considered
as
a
whole.
The
second
uses
an
intake­
level
analysis
whereby
if
one
intake
exceeds
25%
usage,
then
the
entire
facility
is
considered
to
be
in
scope.
The
third
scenario
is
purely
at
an
intake
level,
as
all
out
of
scope
intakes
are
excluded.

The
results
of
the
analysis
is
as
follows:

Scenario
No.
of
Facilities/
Intakes
>
25%
1,
3
Total
DIF
of
Facilities/
Intakes
>
25%
(
MGD)
2,
3
1
236
facilities
in
scope
19,112
2
241
facilities
in
scope
19,421
3
317
intakes
in
scope
18,443
1
A
total
of
299
facilities
and
425
individual
cooling
water
intake
structures
were
reviewed.
2
The
calculations
of
total
flow
exclude
any
flows
associated
with
the
hydroelectric
intakes
for
two
Phase
III
manufacturers,
as
these
flows
are
likely
to
be
excluded
from
consideration
for
316(
b).
3
The
numbers
of
facilities
and
the
intake
flows
reflect
unweighted
survey
data.
