_____________________________________________________________________________________________
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
1
MEMORANDUM
To:
Paul
Shriner,
Shari
Goodwin,
Regno
Arulgnanendran
From:
John
Sunda
Date:
September
12,
2005
Subject:
Summary
of
Changes
in
Compliance
Costs
between
316(
b)
Phase
III
Proposed
Rule
and
NODA
This
memo
presents
the
underlying
reasons
for
the
changes
in
the
compliance
costs
between
the
Phase
III
proposed
rule
and
the
Phase
III
NODA.
As
described
in
the
NODA
and
in
the
record
supporting
the
NODA,
several
changes
were
made
in
the
calculation
of
compliance
costs
for
Phase
III
facilities.

The
focus
of
this
discussion
is
on
the
differences
between
the
costs
at
proposal
and
the
costs
at
NODA
for
the
>
50
MGD
option.
Generally,
the
same
approach
was
used
to
determine
the
costs
for
both
the
Proposal
and
NODA,
especially
with
regard
to
the
intake
flows
used
in
calculating
the
costs.
For
the
proposed
rule,
costs
were
based
on
the
design
intake
flow
(
DIF)
and
in
the
NODA,
costs
were
based
on
the
"
corrected"
DIF
that
reflected
updated
information
about
facility
intake
flows.

Variations
in
costs
between
the
different
options
(
i.
e.,
>
50
MGD,
>
100
MGD
and
>
200
MGD)
generally
reflected
the
fact
that
the
>
100
MGD
and
>
200
MGD
options
involved
a
fewer
number
of
facilities
than
the
>
50
MGD
option
and
thus
overall
changes
as
a
percentage
of
the
total
cost
are
more
greatly
influenced
by
the
inclusion
or
exclusion
of
individual
facilities,
with
a
corresponding
increase
or
a
decrease
in
the
various
cost
components.

For
the
Phase
III
NODA,
a
sensitivity
analysis
was
also
done
using
the
Maximum
Reported
Intake
Flow
(
MRIF)
and
the
Average
Intake
Flow
(
AIF)
as
alternate
intake
flows
for
developing
facility
costs.
A
description
of
the
reasons
for
difference
in
costs
between
the
proposed
rule
and
NODA
when
the
alternate
intake
flows,
i.
e.,
DIF,
AIF
and
MRIF
are
used
as
input
variables
in
the
cost
tool
is
included
below.

CAPITAL
COST
Proposed
Rule
vs
NODA
For
the
>
50
MGD
option
(
using
the
DIF
and
"
corrected"
DIF
for
calculating
the
costs
at
proposal
and
NODA,
respectively),
the
total
capital
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
variables
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.

As
a
result
of
these
changes,
29
of
the
92
intake
systems
costed
for
the
>
50
MGD
option
had
changes
in
the
compliance
technology.
Table
1
presents
the
number
of
facilities
where
the
assigned
technology
module
at
proposal
were
changed
at
NODA.
_____________________________________________________________________________________________
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
2
Table
1.
Changes
in
Technology
Module
Allocation
Between
Proposal
and
NODA
Number
of
Facilities
Technology
Module
Assigned
in
Proposed
Rulea
Technology
Module
Assigned
in
NODAa
8
9
1
2
2
2a
2
9
8
1
12
2a
1
9
2a
1
9
0
1
4
0
1
2a
0
1
1
0
1
3
9
1
0
9
1
0
2a
1
0
2
2
0
1
1
4
3
1
2a
1
1
4
9
1
8
1
1
3
11
a.
Descriptions
of
the
technology
modules
are
presented
on
Exhibit
5­
5,
page
5­
6
of
the
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule
and
Attachment
1
of
this
memo
In
addition
to
the
above
changes
in
assignment
of
technology
modules,
the
costs
for
six
facilities
were
calculated
at
an
intake­
specific
level
instead
of
being
calculated
at
a
facility­
specific
level.
This
is
because
each
of
these
six
facilities
had
intakes
with
distinctively
different
attributes
in
either
the
type
of
water
body
from
which
they
withdraw
cooling
water,
the
type
of
intake
screen
used,
and/
or
the
location
and
depth
of
intake
with
respect
to
the
shoreline
or
the
intake
screen
velocity.
This
separation
of
intakes
enabled
distinguishing
intakes
with
qualified
impingement
or
entrainment
technologies
from
those
intakes
that
have
none
of
the
required
technologies.
These
changes
in
attributes
for
a
portion
of
the
intakes
often
resulted
in
a
change
to
the
technology
module.
The
resulting
changes
in
capital
costs
from
these
changes
are
mixed
because
in
some
cases
a
facility
costed
as
having
a
single
intake
may
have
been
determined
as
qualified
for
existence
of
impingement
or
entrainment
technologies
at
proposal
and
determined
as
having
none
of
the
impingement
or
entrainment
technologies
at
NODA,
due
to
the
separation
of
the
intakes.
_____________________________________________________________________________________________
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
3
Capital
costs
for
a
few
facilities
increased
slightly
when
a
fish
return
was
assigned
as
the
technology
module
for
the
facility.
For
facilities
with
intake
canals,
the
cost
for
any
additional
added
length
of
fish
return
sluice
was
included
as
an
input
variable
to
the
technology
module,
thus
increasing
the
capital
costs
for
these
facilities.

Another
change
in
the
technology
modules
was
the
use
of
a
different
set
of
equations
for
technology
module
3
(
Addition
of
a
new,
larger
intake
with
fine­
mesh
and
fish
handling
and
return
system
in
front
of
an
existing
intake
system)
that
applied
to
facilities
with
a
total
compliance
screen
width
of
>
10
ft.
This
change
resulted
in
a
substantial
reduction
in
the
capital
costs
for
one
facility.

In
a
few
cases,
the
DIF
flow
values
used
at
proposal
were
revised
because
portions
of
the
reported
intake
flow
was
not
used
for
cooling
purposes
or
was
already
in
compliance.

For
the
>
100
MGD
and
>
200
MGD
options,
the
changes
in
compliance
costs
comprised
of
a
subset
of
the
changes
for
the
>
50
MGD
option
with
different
combinations.
One
facility
in
the
>
200
MGD
option
included
the
module
9
to
module
1
change.
One
facility
in
each
of
these
options
changed
from
not
requiring
technologies
(
module
0)
to
requiring
technologies
and
one
facility
in
the
>
100
MGD
option
and
two
facilities
in
the
>
200
MGD
option
changed
from
requiring
technologies
to
requiring
none
(
module
0).
As
such,
the
changes
in
capital
costs
increased
for
the
>
100
MGD
option
but
decreased
slightly
for
the
>
200
MGD
option,
with
the
overall
change
being
subject
to
the
different
combinations
of
facilities
and
compliance
technology
changes.

DIF
vs
MRIF
or
AIF
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)
1
did
not
involve
using
the
existing
traveling
screens.
Because
technology
modules
1,
2,
2a,
and
11
involve
modifying
or
replacing
exiting
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.

PILOT
STUDY
COST
Proposal
vs
NODA
For
the
>
50
MGD
option
(
using
DIF
and
"
corrected"
DIF),
the
total
pilot
study
costs
for
the
NODA
also
decreased
approximately
ten
percent
from
the
proposal
costs.
The
pilot
study
costs
are
calculated
as
ten
percent
of
the
capital
costs,
with
a
minimum
pilot
study
cost
of
$
150,000.
Hence
pilot
study
costs
vary
in
a
similar
manner
as
the
capital
costs.
Also,
changes
in
the
selected
compliance
technology
module
will
affect
whether
pilot
study
costs
are
required
for
a
particular
facility.
Thus,
changes
in
pilot
study
costs
mirror
changes
in
capital
costs
for
the
>
50
MGD
option,
but
to
a
lesser
extent
for
the
>
100
MGD
and
>
200
MGD
option.

DIF
vs
MRIF
or
AIF
When
MRIF
or
AIF
were
used
as
an
alternate
intake
flow
instead
of
DIF,
the
reduction
in
the
pilot
study
costs
are
larger
in
magnitude
than
the
changes
in
capital
costs.
One
reason
for
this
reduction
in
pilot
study
costs
is
that
when
the
estimated
capital
costs
are
below
$
500,000,
the
pilot
study
costs
default
to
zero.
This
is
because
of
the
assumption
that
pilot
studies
are
warranted
only
where
the
capital
costs
are
high
and
the
risk
of
failure
of
investment
is
also
high.
Moreover,
as
the
pilot
study
costs
are
derived
as
a
percentage
of
the
capital
costs,
a
reduction
in
capital
costs,
associated
with
the
use
of
a
lower
intake
flow
will
in
turn
cause
more
facilities
not
requiring
pilot
studies.

1
Descriptions
of
the
technology
modules
are
presented
on
Exhibit
5­
5,
page
5­
6
of
the
Technical
Development
Document
for
the
Proposed
Section
316(
b)
Phase
III
Rule
and
Attachment
1
of
this
memo
_____________________________________________________________________________________________
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
4
NET
O&
M
Proposal
vs
NODA
For
the
>
50
MGD
option
(
using
DIF
and
"
corrected"
DIF),
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.

DIF
vs
MRIF
or
AIF
The
slightly
greater
reduction
in
O&
M
costs
when
the
MRIF
or
AIF
are
used
is
due
to
the
fact
that
O&
M
costs
for
the
technology
modules
that
are
not
based
on
retrofitting
the
existing
traveling
screens
(
all
technology
modules
except
1,
2,
2a,
and
11)
are
based
on
the
selected
intake
flow,
and
thus
are
lower
when
smaller
intake
flows
(
i.
e.,
MRIF
or
AIF
instead
of
DIF)
are
used.
_____________________________________________________________________________________________
Science
Applications
International
Corporation.
11251
Roger
Bacon
Drive,
Reston,
VA
20190
5
Attachment
1.
Technology
Module
Codes
and
Technology
Module
Descriptions
Technology
Module
Codes
Technology
Module
Description
1
Addition
of
fish
handling
and
return
system
to
an
existing
traveling
screen
system
2
Addition
of
fish
handling
and
return
system
and
fine­
mesh
screens
to
an
existing
traveling
screen
system
2a
Addition
of
fine­
mesh
screens
to
an
existing
traveling
screen
system
which
has
a
fish
return
3
Addition
of
a
new,
larger
intake
with
fine­
mesh
and
fish
handling
and
return
system
in
front
of
an
existing
intake
system
4
Addition
of
passive
fine­
mesh
screen
system
(
cylindrical
wedgewire)
near
shoreline
with
mesh
width
of
1.75
mm
5
Addition
of
a
fish
net
barrier
system
6
Addition
of
an
aquatic
filter
barrier
system
7
Relocation
of
an
existing
intake
to
a
submerged
offshore
location
with
passive
fine­
mesh
screen
inlet
with
mesh
width
of
1.75
mm
8
Addition
of
a
velocity
cap
inlet
to
an
existing
offshore
intake
9
Addition
of
passive
fine­
mesh
screen
to
an
existing
offshore
intake
with
mesh
width
of
1.75
mm
10
[
Module
10
not
used]
11
Addition
of
dual­
entry,
single­
exit
traveling
screens
(
with
fine­
mesh)
to
a
shoreline
intake
system
12
Addition
of
passive
fine­
mesh
screen
system
(
cylindrical
wedgewire)
near
shoreline
with
mesh
width
of
0.76
mm
13
Addition
of
passive
fine­
mesh
screen
to
an
existing
offshore
intake
with
mesh
width
of
0.76
mm
14
Relocation
of
an
existing
intake
to
a
submerged
offshore
location
with
passive
fine­
mesh
screen
inlet
with
mesh
width
of
0.76
mm
