MEMORANDUM
DATE:
September
28,
2005
TO:
Paul
Shriner,
USEPA
Shari
Goodwin,
Tetra,
Tech
Inc.
Regno
Arulgnanendran,
Tech
Inc.

FROM:
John
Sunda,
SAIC
REVISIONS
FOR
PHASE
III
COMPLIANCE
COST
ESTIMATES
As
part
of
the
review
of
the
Phase
III
Proposal
compliance
costs
estimation
methodology,
EPA
performed
the
following:

°
Revise
compliance
costs
based
on
updated
facility
input
data
including
updated
Design
Intake
Flow
(
DIF);
update
cost­
test
tool,
including
incorporating
additional
input
variables
in
cost­
test
tool
°
Revise
O&
M
costs
°
Review
and
revise
estimates
of
net
downtime
duration
°
Conduct
sensitivity
analysis
on
compliance
costs
by
using
alternatives
to
DIF
such
as
Maximum
Reported
Intake
Flow
(
MRIF)
and
Average
Intake
Flow
(
AIF)

Based
on
the
above
revisions,
the
total
compliance
costs
and
net
O&
M
costs
for
the
NODA
decreased
approximately
ten
and
38
percent,
respectively,
from
the
costs
at
Proposal
for
facilities
under
the
>
50
MGD
option.

Details
of
the
above
listed
revisions
are
described
in
the
following
paragraphs.

1.0.
Revise
Compliance
Costs
1.1
Updating
Cost­
Tool
Input
Variables
and
Facility
Input
Data
A
detailed
engineering
review
of
the
cost­
test
tool
input
data
was
performed
for
Phase
III
Facilities
with
DIF
>
50
MGD.
The
316(
b)
survey
responses
and
written
comments
submitted
with
the
surveys
were
reviewed
to
ensure
that
the
correct
parameters
were
identified
and
incorporated
in
the
tool.
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
2
A
new
input
data
sheet
for
the
cost­
test
tool
was
created
that
incorporated
input
data
corrections
and
the
additional
input
variables
described
below.
In
addition,
the
input
data
for
six
facilities
were
divided
into
two
sets
by
designating
them
as
separate
intakes
to
account
for
substantial
differences
in
their
intakes.
These
separate
intakes
were
costed
individually
using
the
revised
cost­
test
tool
The
new
input
data
spreadsheet
[
DCN
XXXX]
includes
data
fields
for
the
following
additional
input
variables:
Facility
Type;
Offshore
Distance
for
Submerged
Intakes;
Canal
Length;
Intake
Flow
(
MRIF);
Intake
Flow
(
AIF);
and
Through
Screen
Velocity
Flow
Basis.
The
above
fields
were
also
populated
with
appropriate
data
from
the
surveys.
The
input
variables
in
the
updated
cost­
test
tool,
the
changes
made
(
if
any)
for
the
data,
and
the
overall
effect
of
these
changes
on
the
cost
estimates
are
briefly
discussed
below
for
each
input
variable.

Facility
Type
This
input
value
was
added
to
allow
for
proper
selection
of
input
default
values
to
the
cost­
test
tool
for
different
types
of
facilities.
Table
1
presents
the
two
options
available:

Table
1.
Facility
Type
Codes
Facility
Type
Code
Manufacturer
3
Electric
Generator
2
Facility
Type
is
a
required
input
variable
in
the
cost­
test
tool.

Cooling
System
Type
Few
changes
were
made
to
the
facility
data
for
this
input
parameter.
Data
for
two
facilities
were
changed
from
"
full
re­
circulation"
to
"
other"
because
the
schematic
diagram
showed
the
use
of
intake
water
for
non­
contact
cooling
purposes.
These
changes
would
increase
the
compliance
costs
for
these
facilities,
since
neither
facility
was
estimated
to
have
costs
at
Proposal.

State
Abbreviations
No
changes
were
made
to
the
facility
data
for
this
input
parameter.

Waterbody
Type
Few
changes
were
made
to
the
facility
data
for
this
input
parameter.
The
intake
data
for
one
facility
was
divided
because
multiple
intakes
were
withdrawing
water
from
different
Waterbodies,
and
two
waterbody
types.
Waterbody
Type
is
a
required
input
variable
in
the
costtest
tool.
Science
Applications
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11251
Roger
Bacon
Drive,
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VA
20190
3
Fuel
Type
No
changes
were
made
to
the
facility
data
for
this
input
parameter.

Capacity
Utilization
Phase
III
manufacturers
were
assigned
a
default
value
of
20
percent
as
the
capacity
utilization
to
ensure
that
they
were
above
the
threshold
of
15
percent.
No
changes
were
made
to
the
facility
data
for
this
input
parameter.

Intake
Location/
Description
Changes
were
made
where
appropriate.
Some
facilities
included
more
than
one
description
for
their
type
of
intakes.
The
description
that
best
described
the
situation
or
was
most
crucial
in
development
of
the
costs
was
selected.
For
example,
where
intake
canals
are
present,
this
attribute
took
precedence
over
others
because
of
the
limitation
in
technology
selection
and
added
costs
for
extra
fish
return
length.

Where
multiple
intakes
had
different
descriptions,
the
intake
with
the
largest
DIF
was
selected.
Numerous
changes
were
made
in
this
field
because
of
the
reassessment
of
values
previously
selected
for
multiple
intakes
and
where
multiple
items
were
identified
in
the
survey.
When
multiple
intakes
had
substantially
different
descriptions,
the
intake
data
were
separated
and
assigned
to
the
respective
intakes.
As
a
result,
intakes
for
three
facilities
were
separated
because
one
intake
from
each
of
these
three
facilities
withdrew
cooling
water
from
a
shoreline
location
and
the
other
intake
withdrew
water
from
a
submerged
offshore
location.
Intake
Location/
Description
is
a
required
input
variable
in
the
cost­
test
tool.

Distance
Offshore
for
Submerged
Intakes
In
the
Proposal
cost­
test
tool,
the
offshore
distances
were
selected
based
on
Phase
II
Facility
median
values
for
each
waterbody
type.
This
new
input
variable
data
field
was
populated
with
reported
survey
data
wherever
the
intake
description
was
identified
as
submerged
offshore.
Where
there
were
multiple
intakes,
DIF
flow­
weighted
average
value
was
used.

Canal
Length
At
Proposal,
the
cost­
test
tool
did
not
use
this
data.
As
part
of
the
cost­
test
tool
review
and
revision
for
the
NODA,
a
cost
component
was
added
to
account
for
the
additional
length
of
fish
returns
for
cost
modules
requiring
a
fish
return.
This
new
input
variable
data
field
was
populated
with
reported
survey
data
wherever
the
intake
description
was
identified
as
"
intake
canal."
Where
there
were
multiple
intakes,
the
DIF
flow­
weighted
average
value
was
used.

Navigation/
Waterbody
Use
No
changes
were
made
to
the
facility
data
for
this
input
parameter.
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
4
Mean
Intake
Water
Depth
This
value
is
used
in
the
calculation
of
estimated
total
existing
screen
width.
Many
of
the
corrections
resulted
in
reducing
the
water
depths,
which
in
turn
results
in
increased
estimated
compliance
costs,
as
wider
screens
are
required.
Where
there
were
multiple
intakes,
the
DIF
flow­
weighted
average
value
was
used.
Where
mean
intake
water
depth
was
not
reported,
the
mean
intake
water
depth
of
19
ft
as
reported
by
Phase
III
manufacturers
with
intake
flow
>
50
MGD
was
used
as
a
default
value.

Intake
Well
Depth
The
intake
well
depth
is
used
to
select
the
depth
of
the
required
screen.
For
a
given
screen
width,
deeper
screens
result
in
higher
capital
costs.
Where
facilities
reported
the
distance
above
and
below
the
mean
water
depth,
the
sum
of
these
two
values
was
used.
Where
mean
intake
water
depth
was
reported
but
intake
well
depth
was
not
reported,
the
intake
well
depth
was
assumed
to
be
1.2
times
the
mean
intake
water
depth.
Where
mean
intake
water
depth
was
not
reported,
the
mean
intake
depth
of
22
ft
as
reported
by
Phase
III
manufacturers
with
intake
flow
>
50
MGD
was
used
as
a
default
value.
Facility
data
for
this
input
variable
was
reviewed
and
revised
for
many
facilities.

River
Proportional
Flow
This
value
was
reviewed
only
for
facilities
that
reported
receiving
water
flow
rates
in
the
survey.
Few
changes
were
made
to
the
facility
data
for
this
input
parameter.

Intake
Flow
(
DIF)

This
input
value
represents
the
intake
flow
used
to
design
and
construct
the
existing
intakes.
Revisions
were
made
based
on
the
review
of
the
surveys.
In
one
case,
the
flow
volume
for
an
emergency
intake
dedicated
for
fire
fighting
was
removed
from
the
previous
total.
For
facilities
where
the
intakes
were
split
into
two
groups,
the
sum
of
the
individual
intake
design
flows
for
each
group
were
used.
Intake
Flow
(
DIF)
is
a
required
input
variable
in
the
cost­
test
tool.

Intake
Flow
(
MRIF)

This
input
value
was
added
to
conduct
a
sensitivity
analysis
by
using
alternative
intake
flow
to
the
DIF
for
certain
technology
modules.
This
value
is
intended
to
represent
on­
the­
ground
intake
flow
capacities,
as
opposed
to
the
DIF,
which
is
based
on
hypothetical
design
flow
capacities.
As
described
in
a
separate
section,
EPA
has
derived
estimates
for
the
MRIF
based
on
the
average
reported
daily
maximum
intake
flow
data.
In
most
cases,
the
MRIF
was
lower
than
the
DIF,
reflecting
an
apparent
trend
of
manufacturers
implementing
flow
reduction
measures.
As
a
result,
the
overall
effect
of
using
the
MRIF
for
developing
costs
for
certain
technologies
resulted
in
a
reduction
in
compliance
cost
estimates.
Details
of
the
sensitivity
analysis
on
using
alternate
intake
flows
are
presented
in
DCNXXXX.
(
Refer
the
line
item
explanation
memo
here)
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
5
Intake
Flow
(
AIF)

This
input
variable
was
added
to
allow
for
adjustment
of
the
variable
portion
of
the
O&
M
costs
to
reflect
actual
equipment
operating
costs.
In
addition,
this
input
value
was
also
used
to
conduct
a
sensitivity
analysis
by
using
an
alternative
intake
flow
to
the
DIF
for
certain
technology
modules.
Details
of
the
sensitivity
analysis
on
using
alternate
intake
flows
are
presented
in
DCNXXXX.
(
Refer
the
line
item
explanation
memo
here)

The
AIF
was
calculated
based
on
the
average
flow
over
a
three­
year
period
as
reported
in
the
surveys.
These
data
were
presented
at
Proposal,
but
were
not
used
in
developing
compliance
cost
estimates.
Few
changes
were
made
facility
data
used
at
Proposal.
The
overall
effect
of
adding
this
input
value
was
a
reduction
in
the
estimated
net
O&
M
costs.

Intake
Flow
(
AIF)
is
a
required
input
variable
in
the
cost­
test
tool.

Through­
Screen
Velocity
This
input
variable
is
used
to
estimate
the
existing
screen
width
as
well
as
for
selecting
the
appropriate
compliance
technology.
Few
changes
were
made
to
the
through­
screen
velocity
facility
data.
For
one
facility,
the
screens
for
three
of
the
six
intakes
had
velocities
below
0.5
fps.
The
input
data
for
this
facility
were
separated
in
order
to
account
for
the
fact
that
three
of
the
intakes
are
in
compliance
because
of
low
through­
screen
velocity
and
the
other
intakes
for
this
facility
would
require
a
different
technology
module
than
the
assigned
module
at
Proposal.

Through­
Screen
Velocity
Flow
Basis
This
input
variable
was
added
to
allow
for
greater
flexibility
in
the
cost­
test
tool
by
allowing
a
user
to
report
through­
screen
velocities
in
the
input
field
described
above
based
on
flow
values
other
than
the
DIF.
Only
one
facility
reported
screen
velocity
using
a
flow
basis
other
than
the
DIF,
and
the
proper
input
value
was
assigned.
Addition
of
this
input
value
should
have
no
effect
on
the
cost
estimates.

Water
Type
Few
changes
were
made
to
the
facility
data
for
this
input
parameter.
For
one
facility
with
separate
intakes
on
freshwater
and
saltwater,
the
input
data
were
separated
in
order
to
account
for
potential
differences
in
costs
and
compliance
technology
modules
required
for
the
different
waterbodies.

Debris
Loading
No
changes
were
made
to
the
facility
data
for
this
input
parameter.
Science
Applications
International
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11251
Roger
Bacon
Drive,
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20190
6
Impingement
Technology
In­
Place
Many
changes
were
made
to
the
facility
data
for
this
input
parameter.
The
engineering
review
focused
on
the
responses
to
several
survey
questions
along
with
the
review
of
schematic
diagrams
in
determining
the
technology
in­
place.
Where
multiple
impingement
technologies
existed,
traveling
screens
took
precedence
for
this
input
variable.
The
majority
of
the
changes
involved
changing
the
input
value
to
"
traveling
screens"
from
"
none"
or
"
other
technologies"
as
the
technology
in
place.
One
overall
effect
of
changing
the
input
value
to
traveling
screens
was
the
addition
of
baseline
O&
M
costs
for
traveling
screens
to
the
compliance
cost
calculation.
This
in
turn
resulted
in
lowering
the
overall
compliance
costs,
since
the
baseline
O&
M
costs
are
deducted
from
the
gross
module
O&
M
costs
to
calculate
net
compliance
O&
M
costs.
Impingement
Technology
In­
Place
is
a
required
input
variable
in
the
cost­
test
tool.

Qualified
Impingement
For
facilities
with
traveling
screens,
this
input
value
indicates
whether
a
fish
return
is
in­
place.
This
in
turn
affects
the
cost
module
selected,
as
well
as
baseline
O&
M
costs.
Corrections
resulted
in
many
facilities
being
coded
from
"
qualified"
to
"
not
qualified"
and
vice
versa.
Qualified
Impingement
is
a
required
input
variable
in
the
cost­
test
tool.

Entrainment
Technology
In­
Place
Changes
were
made
to
the
facility
data
for
this
input
parameter.
The
engineering
review
focused
on
the
responses
to
several
survey
questions
together
with
the
review
of
schematic
diagram
to
determine
the
technology
in­
place.
Where
fine
mesh
screens
coexisted
with
intakes
submerged
far
offshore,
fine
mesh
screens
took
precedence
for
this
input
value.
Again,
corrections
resulted
in
many
facilities
going
from
"
none"
to
"
passive
technology
in­
place"
and
vice
versa.
Entrainment
Technology
In­
Place
is
a
required
input
variable
in
the
cost­
test
tool.

Qualified
Entrainment
In
the
input
data
for
the
Phase
III
Proposal,
numerous
facilities
were
incorrectly
identified
as
having
"
qualified"
entrainment
technology
when
the
entrainment
technology­
in
place
should
have
been
coded
as
"
not
qualified,"
when
the
entrainment
technology
was
reported
as
"
none,"
in
the
survey.
In
most
cases,
this
input
data
was
corrected
from
"
qualified"
to
"
not
qualified."
The
impact
of
this
correction
on
compliance
costs
is
not
clear,
as
other
factors
in
selecting
compliance
technologies
would
also
contribute
to
the
change
in
costs.
However,
the
likely
effect
would
be
to
increase
the
overall
compliance
costs.
Qualified
Entrainment
is
a
required
input
variable
in
the
cost­
test
tool.

Average
Annual
Generation
(
1996­
1999)

This
input
value
generally
does
not
apply
to
manufacturing
facilities
and
therefore
no
changes
or
additions
were
made
to
the
facility
data
for
this
input
parameter.
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
7
Assigning
Intake­
specific
Input
Data
At
Phase
III
Proposal,
a
single
set
of
input
data
was
used
for
each
facility,
regardless
of
how
many
intakes
are
used
by
the
facility.
In
developing
the
input
data
for
facilities
with
multiple
intakes,
including
some
with
different
attributes,
flow
data
were
summed.
In
addition,
either
flow­
weighted
averages
were
assigned
for
each
intakes
or
the
attributes
of
the
intake(
s)
that
had
the
largest
DIF
were
selected
In
some
cases,
the
differences
in
attributes
between
intakes
were
significant,
suggesting
that
assignment
of
intake­
specific
input
data
would
be
appropriate
to
obtain
more
reliable
cost
estimates.
During
the
engineering
review
of
this
data,
all
facilities
with
multiple
intakes
were
reviewed
and
as
a
result
of
this
review,
six
facilities
were
determined
to
have
intakes
with
different
attributes
that
warranted
dividing
them
into
separate
intakes,
or
groups
of
intakes
for
each
facility.
For
the
remainder
of
the
facilities
with
multiple
intakes,
the
intake
characteristics
were
similar
enough
that
it
was
determined
to
use
the
input
data
at
the
facility­
specific
level.

The
reasons
for
dividing
the
facility
input
data
for
the
six
facilities
are:
1.
Saltwater
and
freshwater
intakes
that
also
use
different
technologies
(
one
facility)
2.
Shoreline
and
submerged
offshore
intakes
(
three
facilities)
3.
Intakes
with
through­
screen
velocities
<
0.5
fps
and
intakes
with
through­
screen
velocities
>
0.5
fps
(
one
facility)
4
Intakes
with
fine
mesh
screen
and
without
fine
mesh
screen
(
one
facility)

Input
data
specific
to
the
divided
intakes
were
modified
accordingly.
River
proportional
flow,
however,
was
not
modified,
as
it
should
apply
to
the
sum
of
the
facility's
intakes.
For
the
facility
with
intakes
on
both
freshwater
and
saltwater,
the
total
intake
DIF
for
the
freshwater
portion
exceeded
5%
of
the
river
flow
(
same
determination
as
before).
In
addition,
capacity
utilization
was
not
modified,
since
it
is
based
on
a
facility­
specific
threshold
and
not
based
on
an
intakespecific
threshold.

The
impact
on
compliance
cost
estimates
that
results
from
the
divisions
made
regarding
facilities
listed
under
1
and
2
above
may
result
in
an
increase
in
compliance
costs,
because
at
Proposal
it
was
assumed
that
all
intakes
were
on
freshwater
or
all
were
submerged
offshore
intakes.
Changing
a
portion
of
the
intakes
to
saltwater
or
shoreline­
based
results
in
an
increase
in
compliance
costs.
The
impact
on
cost
estimates
that
results
from
the
divisions
made
under
3
and
4
above
will
likely
reduce
compliance
costs
for
the
individual
intakes
that
have
<
0.5
fps
throughscreen
velocities
or
have
fine
mesh
screens,
since
these
attributes
indicate
that
the
intakes
may
not
require
impingement
and
entrainment
technologies.

1.2
Updating
Cost­
Test
Tool
In
addition
to
the
above
updates
to
the
cost
tool
input
variables
and
facility
data,
several
revisions
were
made
to
the
cost­
test
tool
itself.
These
include:

°
Addition
of
default
values
to
the
cost­
test
tool
where
applicable
°
Addition
of
a
cost
component
for
the
added
length
of
fish
sluice
for
facilities
with
canals
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°
Revision
of
compliance
costs
for
technology
module
3
for
facilities
with
screen
widths<
10ft
Details
of
these
revisions
are
described
in
the
following
paragraphs.

1.2.1
Added
Default
Values
to
the
Cost­
test
Tool
EPA
revised
the
cost­
test
tool
to
assign
appropriate
default
values
where
facility­
specific
input
values
were
not
available.

The
default
values
assigned
are
as
follows:

Cooling
System
Type
If
the
entered
value
is
not
"
re­
circulating"
(
code
1),
then
assumes
"
all
others"
(
code
0).

State
Abbreviation
If
null
or
an
invalid
state
abbreviation
is
entered,
then
assumes
regional
factor
of
1.0
(
national
average).

Fuel
Type
If
the
entered
value
is
not
"
nuclear"
(
code
1),
then
assumes
"
nonnuclear
(
code
0).

Capacity
Utilization
If
null,
then
assumes
value
is
20
%.

Distance
Offshore
for
Submerged
Inlet
If
null,
then
applies
default
based
on
waterbody
type
using
Phase
II
data
as
follows:

Ocean
500
meters
Estuary/
Tidal
River
125
meters
Great
Lake
500
meters
Freshwater
Stream/
River
125
meters
Lake/
Reservoir
125
meters
Canal
Length
If
null,
then
applies
default
based
on
waterbody
type
using
Phase
II
data
as
follows:

Ocean
3370
ft
Estuary
Tidal
River
1650
ft
Great
Lake
1460
ft
Freshwater
Stream/
River
690
ft
Lake/
Reservoir
800
ft
Navigation
/
Waterbody
Use
If
null,
then
assumes
"
boat/
barge
traffic
near
intake"
(
code
1).

Mean
Intake
Water
Depth
If
null,
then
applies
default
values
based
on
design
flow
and
facility
type
using
values
in
Table
5­
6,
Technical
Development
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Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule
(
DCN
7­
004).

Mean
Intake
Well
Depth
If
null,
then
applies
default
values
based
on
design
flow
and
facility
type
using
values
in
Table
5­
6,
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule
(
DCN
7­
004).

River
Proportional
Flow
If
null,
then
assumes
"
others,"
code
0;
if
intake
>
5%
of
mean
annual
river
flow,
code
1.

Through
Screen
Velocity
If
null,
then
applies
default
values
based
on
design
flow
and
facility
type
using
values
in
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule,
Table
5­
7
(
DCN
7­
004).
Note:
Values
are
adjusted
based
on
selected
flow
basis
entered
in
"
Through
Screen
Velocity
Flow
Basis."

Through
Screen
Velocity
Flow
Basis
If
null,
then
assumes
basis
is
"
existing
equipment
intake
design
flow."
If
value
other
than
1
is
entered,
then
the
corresponding
intake
flow
value
must
also
be
entered.

Waterbody
Type
If
null
or
value
other
than
"
freshwater"
(
code
0)
is
entered,
then
assumes
"
saltwater"
(
code
1).

Debris
Loading
If
null
or
value
other
than
"
low"
(
code
0)
is
entered,
then
assumes
"
high"
loading
(
code
1).

In
addition,
the
following
data
fields
were
identified
as
required
fields
for
the
cost­
test
tool
to
estimate
the
compliance
costs.

Facility
Type
Waterbody
Type
Intake
Location/
Description
Existing
Equipment
Design
Intake
Flow
Average
Intake
Flow
Impingement
Tech
In­
Place
Qualified
Impingement
Entrainment
Tech
In­
Place
Qualified
Entrainment
1.2.2
Added
Cost
Component
for
the
Added
Length
of
Fish
Sluice
for
Facilities
with
Canals
A
comparison
of
the
cost­
test
tool
used
to
develop
the
Phase
II
compliance
costs
revealed
that
the
cost­
test
tool
did
not
add
costs
for
the
additional
length
of
a
fish
return
sluice
for
facilities
with
intake
canals
and
the
compliance
technology
required
the
addition
of
a
fish
return.
Although
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the
cost­
test
tool
output
contained
default
canal
lengths,
these
lengths
were
not
incorporated
in
the
calculations.
As
part
of
this
revision,
EPA
added
the
canal
length
to
the
input
data
spreadsheet
and
populated
it
with
survey
data
for
facilities
with
intake
canals.
Flow­
weighted
canal
lengths
were
used
where
facilities
had
multiple
intakes.
Default
values
already
provided
in
the
cost­
test
tool
were
applied
if
no
canal
length
was
reported.

An
equation
was
developed
for
calculating
the
costs
for
added
canal
length.
The
cost
of
additional
canal
length
was
included
in
the
compliance
costs
for
technology
modules
1,
2,
3
and
11
when
the
intake
description
is
identified
as
"
intake
canal"
(
code
2).

Compliance
cost
equation
used
for
technology
modules
1,
2,
and
11
is
as
follows:

Compliance
cost
=
canal
length
*
number
of
costing
units
*
(­
0.0135
*
baseline
screen
width/
unit
^
2
+
4.3648
*
baseline
screen
width/
unit
+
69.948)
(
Eq.
1a)
For
technology
module
3,
this
cost
equation
is
modified
slightly
to
reflect
the
fact
that
the
compliance
screen
width
may
be
different
from
the
baseline
screen
width:

Compliance
cost=
canal
length
*
number
of
costing
units
*
(­
0.0135
*
compliance
screen
width/
unit^
2+
4.3648*
compliance
screen
width/
unit
+
69.948)
(
Eq.
1b)

The
assumptions
used
in
deriving
these
equations
are
described
on
page
1­
46
of
the
Phase
II
Final
Technical
Development
Document
(
DCN
X­
XXX).
The
overall
effect
of
this
revision
will
result
in
an
increase
of
the
capital
compliance
costs
for
facilities
that
have
intake
canals
and
are
assigned
compliance
Modules
1,
2,
3
or
11.

The
above
does
not
apply
to
technology
modules
other
than
1,
2,
3
and
11
because
they
do
not
have
fish
return
systems.

1.2.3
Revised
Costs
for
Module
3
for
Facilities
with
Screen
Widths
<
10
ft
Technology
module
3,
as
developed
for
the
Phase
II
Rule,
included
two
sets
of
capital
cost
equations.
One
set
was
developed
for
compliance
screen
widths
>
10
ft
and
the
other
set
for
compliance
screen
widths
<
10
ft.
A
review
of
the
cost­
test
tool
found
that
the
same
compliance
cost
equations
applicable
to
>
10
ft
were
being
applied
to
all
compliance
screen
widths.
However,
this
error
did
not
affect
O&
M
costs,
as
the
same
O&
M
cost
equations
are
applied
for
technology
module
3,
irrespective
of
the
compliance
screen
widths.

The
cost­
test
tool
was
revised
to
apply
the
correct
capital
cost
equations
for
technology
module
3,
so
that
when
total
compliance
screen
width
is
<
10
ft,
a
different
set
of
capital
cost
equations
are
selected
for
deriving
compliance
costs
of
the
new
intake
structure.
For
the
various
Well
Depths
listed,
the
compliance
cost
equations
for
compliance
screen
widths
<
10
ft
are
as
follows:

Well
Depth
Equation
10
ft
12333
*
comp
screen
width
^
2
­
73000
*
comp
screen
width
+
376667
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(
Eq.
2a)

25
ft
29500
*
comp
screen
width
^
2
­
186500
*
comp
screen
width
+
795000
(
Eq.
2b)

50
ft
69167
*
comp
screen
width
^
2
­
447500
*
comp
screen
width
+
2000000
(
Eq.
2c)
75
ft
112000
*
comp
screen
width
^
2
­
734000
*
comp
screen
width
+
3000000
(
Eq.
2d)

100
ft
159500
*
comp
screen
width
^
2
­
1000000
*
comp
screen
width
+
4000000
(
Eq.
2e)

While
this
modification
will
not
affect
the
Phase
III
compliance
cost
estimates
(
since
all
Phase
III
facilities
using
technology
module
3
were
determined
to
have
compliance
screen
widths
>
10
ft),
it
will
allow
the
cost­
test
tool
to
provide
more
accurate
estimates
when
smaller
intakes
are
being
evaluated.

In
reviewing
the
cost­
test
tool
equations
for
technology
module
3,
it
was
also
found
that
the
costtest
tool
was
overestimating
the
capital
costs
for
module
3
at
high
flow
values,
corresponding
to
a
total
compliance
screen
width
>
140
ft.
When
the
total
compliance
screen
width
was
>
140
ft
(
the
upper
end
of
the
technology
module
3),
the
cost­
test
tool
instead
calculates
costs
based
on
the
total
compliance
screen
width,
rather
than
calculating
costs
based
on
multiple
units
of
equal
screen
widths
which
make
up
the
total
screen
width.
The
costs
presented
in
the
NODA
have
the
required
corrections
incorporated
for
this
for
technology
module
3.

1.3
Summary
of
Revisions
to
Compliance
Cost
Estimates
For
the
>
50
MGD
option,
the
total
compliance
costs
for
the
NODA
decreased
approximately
ten
percent
from
the
costs
at
proposal.
Because
there
were
few
changes
to
the
technology
modules
themselves,
the
changes
in
capital
costs
are
primarily
due
to
changes
to
the
facility­
specific
input
data
in
the
cost
tool.
These
changes
in
cost
tool
input
variables
resulted
in
changes
to
the
selected
compliance
technology
modules
for
nearly
a
third
of
the
facilities.
The
cost
tool
input
variables
that
likely
had
the
greatest
impact
on
costs
were
changes
made
to
the
intake
description,
impingement
technology
in­
place,
qualified
impingement,
entrainment
technology
in­
place,
and
qualified
entrainment.

2.0.
Revise
O
&
M
Costs
Revisions
to
the
compliance
O&
M
costs
included
(
i)
addition
of
baseline
O&
M
costs
for
passive
intakes
and
(
ii)
estimation
of
variable
O&
M
costs
based
on
AIF
instead
of
DIF.

2.1.
Baseline
O&
M
Costs
for
Passive
Intakes
The
Phase
III
Proposed
Rule
cost­
test
tool
included
two
baseline
O&
M
scenarios:
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1.
Traveling
Screens
without
Fish
Return
(
TSNF)
2.
Traveling
Screens
with
Fish
Returns
(
TSB)

These
scenarios
were
based
on
the
cost
methodology
developed
for
the
Phase
II
Rule,
which
did
not
include
O&
M
cost
estimates
for
existing
passive
intakes.
However,
passive
intakes
incur
some
O&
M
costs.
Hence
when
passive
intakes
are
replaced
by
other
compliance
technologies,
the
baseline
O&
M
costs
incurred
by
passive
intakes
should
be
deducted
from
the
O&
M
costs
incurred
by
the
compliance
technology
module.
During
the
NODA
process,
EPA
developed
baseline
O&
M
costs
for
passive
screen
technologies
that
will
be
deducted
from
the
gross
module
O&
M
costs
to
yield
net
compliance
O&
M
costs.

Passive
technologies
reported
by
Phase
III
facilities
with
a
DIF
>
50
MGD
comprise
of
the
following
technologies:

1.
Fixed
Coarse
Screens
2.
Perforated
Pipes
3.
Coarse
Mesh
Wedgewire
Screens
Depending
on
the
waterbody
conditions,
O&
M
costs
for
baseline
passive
intake
technology
vary
significantly.
The
technologies
listed
under
2
and
3
above
are
generally
installed
at
submerged
intakes,
while
fixed
coarse
screens
can
be
installed
at
both
shoreline
and
submerged
intakes.
The
316(
b)
surveys
did
not
specify
the
location
(
shoreline
vs.
submerged
offshore)
of
fixed
screens.
O&
M
costs
are
generally
higher
for
passive
T­
screens
with
backwash
systems
and
for
intakes
requiring
frequent
cleaning
and
inspection
by
divers.
Because
of
the
potential
for
wide
variations
in
baseline
costs,
the
costs
derived
below
are
intended
to
represent
the
low
end
of
the
range
of
O&
M
costs
for
passive
technologies,
resulting
in
a
conservative
compliance
cost
estimate
(
i.
e.,
higher
net
compliance
O&
M
estimate).

Two
approaches
were
used
to
derive
passive
technology
O&
M
costs.
The
first
approach
uses
actual
data
for
routine
cleaning
and
inspection
of
submerged
intakes
reported
in
the
Submerged
Intake
Survey
conducted
in
2002.
The
second
approach
is
based
on
paring
down
the
gross
O&
M
costs
derived
for
the
passive
T­
screen
modules
(
technology
modules
4,
7,
9)
so
that
they
include
only
routine
labor
and
dive
team
costs.
The
results
of
the
second
approach
are
presented
to
confirm
the
validity
of
the
cost
derived
through
the
first
approach.

Use
of
Actual
Data
Provided
in
the
Submerged
Intake
Survey
EPA
received
a
limited
amount
of
passive
technology
O&
M
cost
data
in
the
Submerged
Intake
Survey
sent
to
selected
Phase
II
facilities
with
submerged
intakes.
Three
facilities
reported
O&
M
costs
associated
with
routine
cleaning
and
inspection
of
the
passive
intake
system
including
pipe
and
inlet.
These
costs
are
presented
in
Table
2
below,
along
with
the
facility
design
intake
flow.
Note
that
this
data
was
not
claimed
as
CBI.

None
of
the
submerged
intakes
reported
in
the
Submerged
Intake
Survey
used
fine
mesh
screens.
These
intakes
are
expected
to
involve
lower
costs
than
the
total
O&
M
cost
for
T­
screen­
based
compliance
technologies,
since
there
will
be
a
reduced
need
for
debris
removal.
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Table
2.
Data
from
the
Submerged
Intake
Survey
Design
Intake
Flow
(
GPM)
Annual
O&
M
for
Inspection
and
Cleaning
Inlet
38,200
$
3,800a
53,472
$
4,200b
318,000
$
10,000a
a.
Inspect
and
clean
underwater
pipe
and
inlet
structures.
b.
Costs
for
cleaning
inlet
screens
A
linear
equation
provided
a
good
fit
to
the
data
and,
considering
that
only
three
data
points
are
used,
the
selection
of
any
other
equation
type
would
result
in
a
curve
with
a
shape
that
would
be
highly
influenced
by
site­
specific
differences.
Figure
1
in
Attachment
A
presents
a
plot
of
the
data
in
Table
2
along
with
the
linear
equation
that
is
fitted
to
the
data.

The
equation
used
to
estimate
baseline
O&
M
costs
for
passive
technology
based
on
the
Submerged
Intake
Survey
data
is:

Annual
Baseline
O&
M
=
0.0223
X
"
Intake
Flow
DIF"
+
2977
Eq.
3
Since
the
above
equation
has
no
upper
bound
where
the
estimate
would
be
considered
as
erroneous,
it
can
be
applied
to
the
total
design
intake
flow,
rather
than
dividing
the
flow
into
cost
units
which
are
then
summed
together
as
was
done
for
many
of
the
cost
modules
and
for
traveling
screen
baseline
costs.

Paring
Down
the
Gross
O&
M
Costs
Derived
for
the
Passive
T­
screen
Modules
Since
the
passive
intake
costs
derived
above
are
based
on
limited
data,
the
O&
M
costs
for
the
passive
T­
screen
modules
were
reviewed
to
see
how
pared­
down
T­
screen
costs
(
reflecting
routine
labor
and
dive
team
costs
only)
compared
with
the
above
costs
based
on
the
Submerged
Intake
Survey
data.
The
total
O&
M
cost
for
EPA
cost
module
passive
T­
screen
intakes
includes:


Labor
for
monitoring
intake
system
involving
2
to
4
hours
per
week,
plus
1
or
3
weeks
of
24­
hour
monitoring
for
seasonal
high
debris
episodes
(
1
week
low
debris,
3
weeks
high
debris)


Cost
for
electric
power
to
run
air
backwash
system

Costs
for
annual
clean
and
inspection
by
a
dive
team
(
only
for
intakes
relocated
to
offshore).

The
passive
technologies
reported
by
facilities
did
not
appear,
in
most
cases,
to
include
active
systems
for
cleaning
or
backwash;
thus,
it
would
be
reasonable
to
consider
power
costs
to
be
negligible.
It
is
also
reasonable
to
assume
that
the
labor
costs
should
be
based
on
estimates
for
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routine
inspection
and
manual
cleaning.
The
T­
screen
labor
costs
included
two
components,
one
for
routine
labor
and
one
for
cleaning
and
inspection
by
a
dive
team.

In
both
the
passive
T­
screen
and
velocity
cap
cost
modules,
the
annual
inspection
by
dive
teams
was
not
added
for
facilities
with
existing
submerged
intakes,
as
it
was
assumed
that
these
types
of
operations
were
already
being
conducted.
Thus,
dive
team
costs
should
not
be
included
in
the
baseline
O&
M
costs
for
submerged
intakes
with
passive
technology.
Also,
the
surveys
did
not
specify
where
the
passive
technology
was
located;
thus,
for
facilities
where
fixed
screens
were
reported,
the
screens
could
easily
be
located
either
at
the
inlet
or
in
an
onshore
channel.
If
the
passive
technology
is
located
at
the
shoreline,
divers
may
not
be
necessary.
So
in
many
cases,
costs
for
use
of
a
dive
team
may
not
be
applicable.
Therefore,
minimum
O&
M
costs
based
on
the
T­
screen
technology
modules
should
include
the
equivalent
of
routine
labor
only.

It
is
assumed
that
the
passive
intake
technologies,
by
their
nature,
have
low
or
no
energy
requirements
and
so,
in
general,
O&
M
costs
will
involve
labor
associated
with
routine
cleaning
and
inspection.
For
other
costs,
such
as
material/
equipment
replacement
(
as
was
included
in
the
traveling
screen
costs),
it
would
be
difficult
to
estimate
a
dollar
value
considering
the
wide
variety
of
technologies
classified
as
passive
technology.
Wear
and
tear
on
passive
technologies
tends
to
be
low.
Thus,
these
potential
costs
are
not
included.

The
labor
estimates
for
routine
inspection
and
maintenance
for
passive
T­
screens
of
2
to
4
hours
per
week
for
flows
ranging
from
10,000
GPM
(
14.4
MGD)
to
163,000
GPM
(
235
MGD)
are
based
on
vendor­
supplied
information
and
are
close
in
value
to
the
dive
team
costs.
Either
set
of
costs
seems
reasonable
as
a
comparable
low­
end
estimate
for
a
variety
of
passive
technologies.
The
labor
hours
added
for
high
debris
episodes
are
not
considered
applicable
here,
because
the
baseline
passive
intake
technologies
generally
use
coarse
mesh
sizes
of
3/
8
inch
or
larger
and
thus
will
not
be
as
greatly
affected
by
presence
of
debris.
The
2
to
4
hours
per
week
of
labor
for
routine
cleaning
and
inspection
are
considered
to
account
for
overall
variations
in
debris.
Table
3
below
summarizes
the
O&
M
costs
using
the
2002
EPA
Phase
II
labor
rate
estimate
of
$
40.10/
hr.

Table
3.
O&
M
Costs
for
Different
Intake
Flows
Flow
(
GPM)
Annual
Routine
Labor­
Hours/
day
Annual
Routine
Labor
­
Costs
Annual
Dive
Team
Costs
2,500
2
$
4,274
$
5,260
15,800
3
$
6,412
$
7,250
81,500
4
$
8,549
$
11,230
These
costs
are
plotted
on
Figure
1
in
Appendix
A
for
comparison
to
the
costs
derived
from
the
Submerged
Intake
Survey.
Either
component
compares
well
with
the
costs
derived
from
the
Submerged
Intake
Survey,
considering
the
differences
in
mesh
size.

The
Submerged
Intake
Survey
approach
was
selected
for
estimating
passive
technology
baseline
O&
M
costs
because
this
approach
yielded
costs
that
are
lower
and
are
based
on
actual
reported
costs
for
coarse
mesh­
type
passive
technology.
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2.2
Estimation
of
Variable
O&
M
Costs
Based
on
AIF
Instead
of
DIF
Fixed
Versus
Variable
O&
M
Costs
When
developing
the
annual
O&
M
cost
estimates,
the
underlying
assumption
was
that
facilities
were
operating
nearly
continuously
with
the
only
downtime
being
periodic
routine
maintenance.
This
routine
maintenance
was
assumed
to
be
approximately
four
weeks
per
year.
The
economic
model
however,
considers
variations
in
capacity
utilization.
Lower
capacity
utilization
factors
result
in
additional
generating
unit
shutdown
that
may
result
in
reduced
O&
M
costs.
However,
it
is
not
valid
to
assume
that
intake
technology
O&
M
costs
drop
to
zero
during
these
additional
shutdown
periods.
Even
when
the
generating
unit
is
shut
down,
there
are
some
O&
M
costs
incurred.
To
account
for
this,
total
annual
O&
M
costs
were
divided
into
fixed
and
variable
components.
Fixed
O&
M
costs
include
items
that
occur
even
when
the
unit
is
periodically
shut
down,
and
thus
are
assumed
to
occur
year
round.
Variable
O&
M
costs
apply
to
items
that
are
allocable
based
on
estimated
intake
operating
time.
The
general
assumption
behind
the
fixed
and
variable
determination
is
that
shutdown
periods
are
relatively
short
(
on
the
order
of
several
hours
to
several
weeks).

Basis
of
Calculating
Variable
O&
M
Costs
During
an
engineering
review
of
the
O&
M
cost
estimates
for
NODA,
it
was
noted
that
the
O&
M
costs
are
based
on
the
assumption
that
the
intake
technologies
were
operating
at
the
DIF.
The
data
reported
by
the
facilities,
however,
indicate
that
most
facilities
operate
at
an
average
flow
level
that
is
often
well
below
the
DIF.
Hence,
the
cost­
test
tool
was
revised
such
that
for
each
O&
M
estimate,
both
baseline
and
compliance
O&
M
costs
are
adjusted
so
that
the
variable
component
is
reduced
to
reflect
actual
use.
The
method
used
was
to
apply
a
factor
(
i.
e.,
AIF/
DIF)
to
the
variable
portion
to
arrive
at
the
revised
O&
M
cost.
The
cost­
test
tool
was
revised
to
add
AIF
as
an
additional
input
value.
O&
M
costs
were
adjusted
using
the
following
factor:

((
1­
fixed
factor)*
AIF/
DIF
+
fixed
factor)
(
Eq.
4)

2.3
Summary
of
Revision
to
O&
M
Costs
For
the
>
50
MGD
option
the
net
O&
M
costs
for
the
NODA
decreased
approximately
38
percent
from
the
net
O&
M
costs
at
proposal.
This
decrease
in
net
O&
M
costs
is
due
to
several
factors.
The
most
significant
reason
for
this
cost
decrease
was
the
use
of
AIF
instead
of
the
DIF
to
calculate
the
variable
portion
of
the
O&
M
costs.
As
noted
in
the
proposed
rule,
DIF
was
used
to
calculate
both
the
variable
and
fixed
portions
of
the
net
O&
M
costs.

The
second
factor
that
contributed
to
the
decrease
in
O&
M
costs
at
NODA
was
the
increase
in
baseline
O&
M
costs
due
to
the
addition
of
baseline
costs
for
passive
intake
technologies
in­
place
together
with
changes
to
the
input
variables
for
technologies
in­
place.
This
resulted
in
an
increase
in
the
number
of
facilities
identified
as
having
traveling
screens
in­
place.
Since
the
baseline
O&
M
costs
are
deducted
from
the
compliance
technology
O&
M
costs,
higher
baseline
O&
M
costs
will
yield
decreases
in
the
net
O&
M
costs.
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3.0
Review
and
Revise
Net
Downtime
Estimates
Estimates
of
downtime
durations
at
Proposal
for
manufacturing
facilities
were
based
on
downtime
durations
for
Phase
II
electric
generators.
EPA
initially
considered
reducing
downtime
duration
estimates
using
various
fractions
or
percentages
of
downtime
durations
used
at
Proposal.
EPA
then
reviewed
in
detail
the
basis
for
the
downtime
duration
estimates
originally
developed
for
electric
generators
to
determine
whether
these
estimates
were
appropriate
for
manufacturing
facilities,
and
whether
the
downtime
estimates
could
be
revised
to
reflect
sitespecific
features
applicable
to
manufacturers.

Basis
of
Downtime
Estimates
During
Phase
II
For
technology
module
3,
the
total
downtime
duration
estimate
of
6­
8
weeks
(
net
downtime
duration
of
2­
4
weeks,
assuming
4
weeks
scheduled
downtime
for
routine
maintenance
per
year)
were
based
on
a
scenario
modeled
after
an
option
described
in
a
316(
b)
Demonstration
Study
for
the
Salem
Nuclear
Plant
(
Page
3­
58,
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule,
DCN
7­
0004).
EPA
concluded
that
a
total
construction
downtime
estimate
in
the
range
of
6
to
8
weeks
was
reasonable
for
this
facility
and
other
similar
nuclear
power
plants
and
electric
generators.
However,
because
the
above
facility
is
a
nuclear
power
plant
with
multiple
generating
units
and
an
extremely
large
flow,
EPA
believes
that,
while
appropriate
for
power
generation
facilities,
this
downtime
duration
is
overly
conservative
for
manufacturing
facilities,
which
have
much
lower
flows
on
average
and
are
not
subject
to
the
same
security
concerns
as
a
nuclear
power
plant.
Thus,
EPA
believes
that
total
downtime
duration
of
4­
6
weeks,
or
a
net
downtime
of
0­
2
weeks
(
after
allowing
for
overlap
with
a
4­
week
routine
maintenance
period)
is
more
appropriate.

Similar
to
the
above
estimation
of
downtime
durations
for
technology
module
3,
for
technology
modules
4,
7,
12
and
14,
the
total
downtime
duration
estimate
of
13­
15
weeks
(
net
downtime
of
9­
11
weeks)
was
based
on
WH
Zimmer
plant,
a
power
generation
facility
that
EPA
had
identified
as
actually
having
converted
an
existing
shoreline
intake
with
traveling
screens
to
submerged
offshore
T­
screens
(
Page
3­
16,
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule,
DCN
7­
0004).
EPA
concluded
that
the
total
downtime
duration
should
be
in
the
range
of
13­
15
weeks
for
similar
electric
generator
facilities.
EPA
believes
that,
while
the
above
estimates
are
appropriate
for
power
generation
facilities,
the
estimate
is
overly
conservative
for
manufacturing
facilities,
which
have
much
lower
flows
on
average.
EPA
believes
that
it
is
appropriate
to
reduce
this
schedule
by
2
weeks
for
manufacturers
with
these
cost
modules,
yielding
total
downtime
durations
of
11­
13
weeks,
or
net
downtime
durations
of
7­
9
weeks
after
allowing
for
overlap
with
a
4­
week
routine
maintenance
period.

Based
on
how
the
downtime
duration
estimates
were
originally
estimated
for
electric
generators
and
how
the
downtime
durations
can
be
revised
for
manufacturers,
EPA
believes
that
it
is
more
appropriate
to
reduce
downtimes
by
a
set
number
of
weeks
than
to
reduce
them
by
a
fraction
or
percentage.
The
cost­
test
tool
has
thus
been
revised
to
reflect
this
reduction
in
net
downtime
duration
for
manufacturers;
the
tool
now
applies
the
appropriate
downtime
durations
(
net,
in
weeks)
based
on
the
Facility
Type,
Intake
Flow
(
DIF)
and
selected
cost
module.
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In
addition
to
the
general
reductions
in
downtime
durations
for
manufacturing
facilities
described
above,
EPA
also
adjusted
the
downtime
durations
for
some
manufacturing
facilities
with
multiple
intakes,
as
described
on
page
5­
41
of
the
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule.
Review
of
the
flow
diagrams
and
facility­
level
survey
data
for
these
facilities
indicated
that
they
had
multiple
intakes,
where
the
intakes
were
not
dedicated
intakes.
In
other
words,
these
facilities
could
decommission
any
one
intake
and
still
meet
their
average
intake
flow
without
exceeding
the
total
design
intake
flow
of
the
remaining
intakes.
EPA
therefore
assumed
that
these
facilities
could
retrofit
one
intake
at
a
time,
thereby
avoiding
downtime
costs.
As
such,
these
facilities
do
not
incur
any
downtime.

During
the
review
of
the
downtime
durations
for
manufacturing
facilities,
in
order
to
substantiate
the
above
determinations
EPA
contacted
six
manufacturing
facilities
during
NODA
to
obtain
information
on
practices
adopted
when
retrofitting
or
major
upgrades
are
required
at
these
facilities.
This
information
is
in
addition
to
the
two
manufacturing
facilities
contacted
regarding
their
downtime
practices
and
frequency
of
downtime
during
the
preparation
of
the
Phase
III
Proposal.
Details
of
these
contacts
are
presented
in
DCN
XXX{
Include
the
Downtime
calls
memo}

4.0
Conduct
Sensitivity
Analysis
of
Alternatives
to
Design
Intake
Flow
EPA
investigated
whether
alternative
intake
flows
other
than
the
DIF
would
be
appropriate
for
developing
compliance
technology
cost
estimates.
EPA
conducted
a
sensitivity
analysis
to
evaluate
the
impact
of
using
DIF,
MRIF,
or
AIF
as
the
intake
flow
input
variable
on
technology
compliance
costs.

In
order
to
conduct
the
sensitivity
analysis,
EPA
computed
values
for
MRIF
from
either
daily
maximum
flow
data
provided
in
the
surveys
or
using
regression
analysis
when
facilities
did
not
provide
the
data
in
the
surveys.
The
following
paragraphs
describe
the
methodology
used
by
EPA
to
calculate
as
well
as
impute
values
for
MRIF.

Unlike
daily
maximum
flow,
AIF
was
more
frequently
reported
in
the
surveys.
For
facilities
not
reporting
AIF
data,
DIF
were
used
to
impute
the
facility
AIF
values.
MRIF
Data
From
Survey
Responses
EPA
examined
at
the
monthly
average
and
daily
maximum
flow
reported
for
36
months
(
1996­
1998)
for
each
intake
of
the
manufacturing
facilities
in
the
detailed
surveys.
Quality
control
checks
of
flow
data
included
reviewing
and
updating
data
entry
errors
and
normalizing
units
of
measure.
For
facilities
that
reported
the
daily
maximum
flow
(
on
a
monthly
basis)
in
the
surveys,
the
average
of
the
36
months
of
this
data
was
calculated
as
the
MRIF
for
each
intake.
The
facility
MRIF
was
calculated
as
the
sum
of
the
individual
intake
MRIF
values.
For
most
facilities
the
MRIF
values
were
lower
than
the
DIF.
However,
for
facilities
with
higher
MRIF
than
DIF,
this
higher
MRIF
was
used
as
the
intake
flow
in
the
sensitivity
analysis.
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Estimation
of
MRIF
for
Facilities
That
Did
Not
Report
Daily
Maximum
Flow
When
the
survey
responses
did
not
provide
daily
maximum
flow
data,
EPA
developed
a
methodology
for
imputing
MRIF.
Using
calculated
MRIF
values
for
all
intakes
where
daily
maximum
flow
data
was
reported,
a
regression
analysis
was
performed
comparing
the
relationship
between
DIF
and
MRIF
to
the
relationship
between
AIF
and
MRIF.
The
best
correlation
was
found
to
be
a
linear
relationship
between
the
MRIF
and
the
AIF,
with
an
r2
value
of
0.903
for
the
relationship
between
DIF
and
MRIF
and
an
r2
value
of
0.9826
for
the
relationship
between
AIF
and
MRIF.
However,
when
the
DIF
was
used
as
the
independent
variable
to
derive
estimates
of
the
MRIF,
some
of
the
imputed
MRIF
values
were
estimated
to
be
lower
than
the
reported
AIF
values
in
the
survey.
This
is
technically
unacceptable,
because
the
MRIF
values
should
always
be
greater
than
the
AIF
values.
Conversely,
when
AIF
was
used
as
the
independent
variable
to
derive
estimates
of
the
MRIF,
some
of
the
imputed
MRIF
estimates
were
higher
than
the
reported
DIF
values
in
the
survey.
This
was
technically
feasible
and
was
supported
by
actual
survey
data
for
many
facilities
where,
reported
daily
maximum
intake
flow
values
were
higher
the
reported
DIF.
Hence
it
was
determined
to
use
the
relationship
between
AIF
and
MRIF
from
survey
data
to
impute
MRIF
values
when
such
data
was
not
provided
in
the
survey.

As
part
of
the
computation
of
MRIF,
quality
assurance
checks
were
performed
on
the
consistency
between
DIF,
MRIF
and
AIF.
When
the
reported
data
in
the
survey
were
inconsistent
with
individual
intake
flows,
the
data
were
eliminated
for
the
regression
analysis.
The
resulting
regression
equation
after
data
cleanup
resulted
in
the
following
relationship:

MRIF
=
1.1946*
AIF
+
902099
(
Eq.
5)

With
an
r2
of
0.9826.

A
plot
of
the
data
and
the
formula
line
are
presented
in
Figure
2
in
Attachment
B.
Using
the
above
linear
relationship,
MRIF
values
were
estimated
for
each
facility
intake
for
which
an
actual
daily
maximum
flow
data
was
not
available
in
the
survey.

In
the
updated
cost­
test
tool
(
DCN
XXXX),
a
toggle
was
added
so
that
the
user
could
select
between
(
i)
DIF
for
all
technologies,
(
ii)
DIF
for
Modules
1,
2,
2a
and
11
and
MRIF
for
the
remaining
technologies,
or
(
iii)
DIF
for
Modules
1,
2,
2a
and
11
and
AIF
for
the
remaining
technologies,
and
compare
the
compliance
cost
estimates
based
on
these
alternative
intake
flows.

Since
the
AIF
represents
an
overall
average
of
what
can
be
a
widely
varying
intake
flow
capacity,
the
use
of
this
value
for
development
of
compliance
cost
estimates
would
likely
result
in
an
undersized
system.
Thus,
while
EPA
has
revised
the
cost­
test
tool
to
allow
AIF
to
be
used
as
an
alternative
intake
flow
for
sensitivity
analysis,
EPA
considers
the
use
of
the
AIF
as
intake
flow
for
compliance
cost
estimates
as
not
technically
defensible.
In
addition,
the
limitations
of
using
MRIF
as
an
alternate
intake
flow
on
selected
technology
modules
is
described
in
detail
in
Attachment
C.
titled
Limitations
on
the
Use
of
Alternate
Intake
Flows
for
Computing
Compliance
Costs.
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19
4.1
Summary
Results
of
Sensitivity
Analysis
on
Compliance
Costs
with
Alternate
Intake
Flows
The
use
of
MRIF
or
AIF
as
an
alternative
intake
flow
to
the
DIF
resulted
in
a
general
reduction
in
the
capital
costs,
but
only
for
those
facilities
where
the
technology
module
(
all
technology
modules
except
1,
2,
2a,
and
11)
did
not
involve
using
the
existing
traveling
screens.
Because
technology
modules
1,
2,
2a,
and
11
involve
modifying
or
replacing
existing
traveling
screens,
the
costs
for
these
modules
are
based
on
an
estimate
of
the
total
screen
width
of
the
existing
intake.
As
the
existing
intake
cannot
be
easily
re­
sized
for
different
intake
flows,
the
costs
for
these
technology
modules
are
based
on
the
DIF
and
not
based
on
MRIF
or
AIF.
For
facilities
with
technology
modules
other
than
1,
2,
2a,
and
11,
the
capital
costs
at
NODA
are
significantly
lower
than
costs
estimated
at
proposal
when
MRIF
or
AIF
are
used
as
the
intake
flow
input
variable
instead
of
DIF.

References
AEC.
Lowman
Plant.
Noel,
Mike.
Response
to
offshore
intake
system
questions
concerning
design
and
costs
for
submerged
intakes
submitted
to
EPA
September
18,
2002.

Entergy
Environmental
Services,
Ritchie
Plant.
Holzer,
Annette.
Response
to
offshore
intake
system
questions
concerning
design
and
costs
for
submerged
intakes
submitted
to
EPA
August
20,
2002
Johnson
Screens.
Watson,
Mark.
Telephone
contact
report
with
John
Sunda,
SAIC,
regarding
their
experience
with
solutions
for
minimizing
plant
shut
down
at
manufacturers
when
installing
new
intake
technology.
August
23,
2005.
Sunda,
John.
Email
correspondence
with
Roy
Neal.
Cononco
Phillips.
Regarding
EPA
Request
for
Information
Regarding
the
New
Intake
at
the
TOSCO
Refinery.
September
8,
2004.

Wheelabrator
Westchester.
Maillet,
Thomas.
Plant
Manager.
Response
to
offshore
intake
system
questions
concerning
design
and
costs
for
submerged
intakes
submitted
to
EPA
August
9,
2002.
Science
Applications
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Corporation.
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Drive,
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VA
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20
ATTACHMENT
A
Figure
1
­
Passive
Technology
Baseline
O&
M
Minimum
Costs
y
=
0.0223x
+
2977
R2
=
0.9999
$
0
$
2,000
$
4,000
$
6,000
$
8,000
$
10,000
$
12,000
$
14,000
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
Design
Flow
(
gpm)

Annual
O&

M
Costs
Submerged
Intake
Actual
Cost
T­
Screen
Dive
Team
Cleaning
&
Inspection
T­
Screen
Routine
Inspection
Science
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21
ATTACHMENT
C
Limitations
on
the
Use
of
Alternate
Intake
Flows
for
Computing
Compliance
Costs
The
term
intake
flow
used
in
this
analysis
refers
to
the
flow
value
used
in
determining
the
size
of
compliance
technology.
The
design
intake
flow
(
DIF)
is
the
value
(
or
sum
of
the
individual
intake
values
for
multiple
intakes)
reported
by
a
facility.
It
generally
represents
the
maximum
flow
for
an
intake
at
the
time
it
was
constructed
or
modified.
There
are
probably
many
instances
where
the
DIF
no
longer
represents
the
maximum
flow
requirements
due
to
flow
reduction
measures
or
an
overestimation
of
future
flow
requirements
at
the
planning
and
design
stages
of
the
facility.
Conversely,
there
may
also
be
cases
where
the
reported
DIF
is
an
outdated
value
because
it
does
not
reflect
more
recent
expansions
of
the
intakes
and
corresponding
increases
in
intake
flow.

The
limitations
in
using
alternate
intake
flows
for
certain
technology
modules
due
to
site­
specific
restrictions
of
the
facility
intakes
is
described
below.

In
general,
the
technology
modules
can
be
categorized
as
follows:

1.
Modules
that
use
the
existing
intake
screens
and/
or
screen
slots.
2.
Modules
that
require
an
entirely
new
screening
system
and
that
can
be
sized
independently
of
the
existing
intake.

The
cost
modules
that
use
the
existing
screen
slots
involve
either
modifying
the
existing
screens
or
replacing
the
screens
using
the
same
screen
slots.
These
include
technology
modules
1,
2,
2a
and
11.
Cost
Module
3
(
add
larger
intake)
also
uses
traveling
screens,
but
these
are
placed
in
a
new
intake
structure
whose
size
is
not
predetermined
by
the
existing
intake
structure.

Technology
Modules
1,
2,
2a
and
11
For
technology
modules
that
involve
modifying
or
replacing
the
screens
in
the
existing
intake
structure
(
technology
modules
1,
2,
2a,
and
11),
the
costs
are
derived
by
estimating
the
existing
total
screen
width
and
combining
that
with
the
screen
well
depth
to
derive
the
screen
system
costs.
The
costing
methodology
for
traveling
screens
uses
design
intake
flow,
through­
screen
velocity
and
water
depth
to
estimate
the
size
of
the
existing
screens.
Because
the
size
of
the
existing
screens
is
fixed,
use
of
an
intake
flow
value
other
than
the
DIF
is
not
a
technically
viable
option.

One
possibility,
especially
where
the
new
flow
requirements
are
much
lower
due
to
flow
reduction
measures
implemented
by
the
facility,
would
be
the
closure
of
a
portion
of
the
existing
screen
system
(
e.
g.,
the
channel
for
one
out
of
four
screens
might
be
blocked
off
and
permanently
taken
out
of
service).
This,
however,
requires
knowledge
of
the
intake
configuration
that
is
very
limited
in
the
survey
data.
Thus,
for
Modules
1,
2,
2a
and
11,
the
use
of
any
flow
measure
other
than
DIF
is
not
recommended
unless
it
can
be
shown
that
the
existing
intake
could
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be
pared
down
by
eliminating
one
or
more
screens.
In
such
a
situation,
a
partial
DIF
could
be
derived
when
the
number
of
screens
required
is
known.
Such
a
value
would
need
to
be
greater
than
or
equal
to
the
alternate
intake
flow
to
be
used.

All
Other
Modules
The
remaining
cost
modules
all
involve
screen
or
filter/
net
systems
that
are
not
constrained
in
size
by
the
existing
intake
structure.
All
systems
are
sized
based
on
an
intake
flow
equal
to
the
maximum
expected
flow
value.
As
such,
alternate
intake
flows
other
than
DIF
can
be
used
to
calculate
the
compliance
costs.

Since
the
AIF
represents
an
overall
average
of
a
widely
varying
intake
flow,
the
use
of
AIF
for
compliance
cost
estimation
would
likely
result
in
a
potentially
undersized
system.
Use
of
the
AIF
as
a
design
input
value
for
any
of
the
cost
modules
is
not
technically
defensible.

Table
B­
1
presents
the
applicable
intake
flow
that
can
be
used
as
an
alternative
to
DIF.

Table
B­
1.
Applicable
Alternate
Intake
Flows
for
Various
Technology
Modules
Module
Description
Applicable
Intake
Flow
for
Capital
Cost
Estimation
Reason
1
Addition
of
fish
handling
and
return
system
to
an
existing
traveling
screen
system
2
Addition
of
fine­
mesh
screen
overlay
to
existing
traveling
screen
(
already
has
fish
return)

2a
Addition
of
traveling
screen
with
finemesh
screen
overlay
and
fish
handling
&
return
system
DIF
Size
based
on
existing
intake
structure
3
Addition
of
new
larger
intake
structure
with
fine­
mesh
traveling
screens,
fish
handling
and
return
4
Addition
of
passive
fine­
mesh
(
1.75
mm)
screen
system
near
shoreline
DIF
or
MRIF
New
screen
surface
can
be
sized
to
new
flow
requirements
5
Addition
of
fish
net
barrier
system
DIF
or
MRIF
Net
surface
area
can
be
sized
to
new
flow
requirements.

6
Addition
of
aquatic
filter
barrier
system
DIF
or
MRIF
Filter
barrier
surface
area
can
be
sized
to
new
flow
requirements.

7
Relocation
of
an
existing
of
intake
to
a
DIF
or
MRIF
New
screen
surface
can
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Module
Description
Applicable
Intake
Flow
for
Capital
Cost
Estimation
Reason
submerged
offshore
location
with
passive
fine­
mesh
(
1.75
mm)
screen
system
be
sized
to
new
flow
requirements
8
Addition
of
a
velocity
cap
inlet
to
an
existing
submerged
offshore
intake
DIF
or
MRIF
Velocity
cap
can
be
sized
to
new
flow
requirements
9
Addition
of
passive
fine­
mesh
(
1.74
mm)
screens
to
an
existing
submerged
offshore
intake
DIF
or
MRIF
New
screen
surface
can
be
sized
to
new
flow
requirements
11
Addition
of
dual­
entry,
single
exit
traveling
screens
with
fine­
mesh
to
an
existing
shoreline
intake
system
DIF
Size
based
on
existing
intake
structure
12
Addition
of
passive
fine­
mesh
(
0.76
mm)
screen
system
near
shoreline
13
Addition
of
passive
fine­
mesh
(
0.76
mm)
screen
to
an
existing
submerged
offshore
intake
14
Relocation
of
an
existing
of
intake
to
a
submerged
offshore
location
with
passive
fine­
mesh
(
0.76
mm)
screens
DIF
or
MRIF
New
screen
surface
can
be
sized
to
new
flow
requirements
_____________________________________________________________________________________________

Science
Applications
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Corporation.
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Roger
Bacon
Drive,
Reston,
VA
20190
ATTACHMENT
B
Figure
2
Imputation
Formula
y
=
1.1946x
+
902099
R2
=
0.9826
0
500,000,000
1,000,000,000
1,500,000,000
2,000,000,000
2,500,000,000
3,000,000,000
0
200,000,000
400,000,000
600,000,000
800,000,000
1,000,000,000
1,200,000,000
1,400,000,000
1,600,000,000
1,800,000,000
AIF
Flow
(
gpd)

Flow
(

gpd)
MRIF
DIF
Linear
(
MRIF)
