TO:
316(
b)
Phase
II
Docket.

FROM:
Timothy
Connor
SUBJECT:
Discussion
of
Technology
Efficacy
for
Regulatory
Options
DATE:
11/
29/
04
The
Agency
compared
the
results
of
its
NODA
analysis
of
the
waterbody
capacity­
based
option
to
that
of
the
preferred
option.
The
waterbody
capacity­
based
option,
which
would
have
required
flow
reduction
commensurate
with
recirculating
wet
cooling
at
54
existing
facilities,
showed
national
annual
costs
of
$
797
million
(
post­
tax,
2002
$).
The
preferred
option,
which
was
based
on
requirements
very
similar
to
those
of
the
final
rule,
showed
national
annual
costs
at
the
NODA
of
$
269
million
(
post­
tax,
2002
$).
The
costs
for
the
waterbody
capacity­
based
option
were
3
times
those
of
the
preferred
option
in
the
NODA
analysis.
However,
the
incremental
reduction
in
entrainment
efficacy
from
the
waterbody
capacity­
based
option
was
only
1.33
times,
in
the
widest
margin,
those
of
the
preferred
option.
At
the
national­
level
the
waterbody
capacity
based
option
would
achieve
an
entrainment
efficacy
improvement
of
37
percent
in
the
typical
scenario
(
ie,
a
90
to
92
percent
entrainment
reduction
efficacy
per
tower,
which
is
an
expected
performance
of
the
tower
regardless
of
waterbody
type).
The
preferred
option
would
achieve
a
28
percent
national
entrainment
efficacy
improvement
at
the
low
end
of
the
performance
range
(
ie,
assuming
a
worst­
case
60
percent
entrainment
reduction
efficacy
per
facility
with
entrainment
requirements).
Therefore,
for
every
percentage
point
in
entrainment
improvement
with
the
waterbody
capacity
based,
cooling
tower
option,
the
national
cost
would
be
approximately
$
100
million
(
pre­
tax,
2002
$)
annually.
The
Agency
further
notes
that
in
the
situation
where
facilities
would
comply
with
the
lower
end
of
the
performance
ranges
of
either
option
that
the
national
cost
per
percentage
improvement
in
entrainment
efficacy
would
be
$
133
milllion
(
pre­
tax,
2002
$)
annuallly.
In
the
case
where
facilities
would
comply
with
the
highest
expected
bound
to
the
performance
ranges
of
either
option
that
the
national
cost
per
percentage
improvement
in
entrainment
efficacy
would
be
$
752
million
(
pre­
tax,
2002
$)
annually.

The
following
table
presents
the
data
for
the
comparison
of
the
regulatory
alternatives.

NODA
Preferred
Option
NODA
Waterbody
Cap.
Based
Option
Ratio
­
WBC
to
Preferred
Annual
National
Costs
$
269,000,000
$
797,000,000
3.0
Min
Entrainment
Red.
28%
32%
1.1
Max
Entrainment
Red.
42%
42%
1.0
Min
Impimgement
Red.
74%
75%
1.0
Max
Impingement
Red.
87%
88%
1.0
The
cost
efficacy
percentages
presented
in
the
table
above
are
for
national
extrapolations
of
expected
minimum
and
maximum
entrainment
reductions.
This
accounts
for
the
technologies
to
be
installed
and
those
already
in
place.
It
is
flow­
weighted,
based
on
the
actual
flow
of
the
facility
(
annually).
The
underlying
calculations
supporting
this
analysis
are
presented
in
DCN
6­
3590
(
in
the
confidential
business
information
portion
of
the
docket).
