
1
MEMO
To:
Paul
Shriner,
EPA
From:
Kelly
Meadows,
Tetra
Tech
Date:
August
30,
2005
RE:
Estimates
of
Operating
Days
for
Phase
III
Facilities
Background
The
performance
standards
required
for
a
facility
subject
to
the
316(
b)
Phase
II
final
rule
was
in
part
based
on
the
facility's
capacity
utilization
rate
(
CUR).
CUR
is
defined
in
the
regulation
at
69
FR
41684:

"
Capacity
utilization
rate
means
the
ratio
between
the
average
annual
net
generation
of
power
by
the
facility
(
in
MWh)
and
the
total
net
capability
of
the
facility
to
generate
power
(
in
MW)
multiplied
by
the
number
of
hours
during
a
year."

Phase
II
facilities
with
a
CUR
of
less
than
15%
are
considered
to
be
peaking
facilities
and
are
not
subject
to
entrainment
requirements,
regardless
of
the
facility's
design
intake
flow
or
waterbody
type.

Of
the
543
Phase
II
facilities,
108
(
or
19.9%)
had
a
CUR
of
less
than
15%.
Of
these,
72
(
66.7%)
would
have
been
subject
to
entrainment
requirements1
absent
the
provision
for
capacity
utilization.

In
some
cases,
the
CUR
may
be
calculated
on
an
intake­
by­
intake
basis:

"
In
cases
where
a
facility
has
more
than
one
intake
structure,
and
each
intake
structure
provides
cooling
water
exclusively
to
one
or
more
generating
units,
the
capacity
utilization
rate
may
be
calculated
separately
for
each
intake
structure,
based
on
the
capacity
utilization
of
the
units
it
services."

Adaptations
for
Phase
III
In
November
2003,
EPA
asked
Tetra
Tech
to
perform
an
analysis
to
identify
which
facilities
in
Phase
III
might
also
fall
below
the
15%
CUR
threshold.
Electric
generators
1
Facilities
are
subject
to
entrainment
requirements
if
they
withdraw
from
a
tidal
river
or
estuary,
an
ocean,
or
one
of
the
Great
Lakes.
Facilities
located
on
freshwater
rivers
and
streams
that
withdraw
more
than
5%
of
the
mean
annual
flow
of
the
waterbody
are
also
subject
to
entrainment
requirements.

Of
the
108
facilities,
47
are
located
on
a
tidal
river,
3
are
located
on
a
Great
Lake
(
or
a
tributary),
4
are
located
on
an
ocean,
and
18
are
located
on
a
freshwater
river
and
withdraw
more
than
5%
of
the
mean
annual
flow.
2
(
not
subject
to
national
requirements
under
the
Phase
III
rule,
as
proposed)
would
use
the
same
approach
as
Phase
II
facilities.
For
manufacturers,
however,
electricity
generation
is
not
an
appropriate
metric,
as
some
facilities
are
net
consumers
of
electricity.
A
threshold
analogous
to
CUR
was
devised
using
15%
of
the
operating
days
per
year 
15%
of
365
days
is
roughly
equivalent
to
60
operating
days.
Using
this
approach,
facilities
that
operated
less
than
60
days
per
year
would
not
be
subject
to
entrainment
requirements.

Tetra
Tech
used
data
from
the
316(
b)
industry
survey
to
calculate
the
number
of
operating
days
for
each
manufacturer.
All
surveyed
manufacturing
facilities
that
provided
data,
including
those
that
may
not
be
subject
to
national
standards
under
the
Phase
III
rule
(
as
proposed),
were
included2.
Question
25
in
the
detailed
questionnaire
requested
monthly
data
on
intake
flows
and
operating
hours.
The
monthly
data
was
summed
to
calculate
an
annual
number
of
operating
hours
for
each
of
the
three
years
of
requested
data
(
1996­
1998).
The
three
annual
numbers
were
then
averaged
to
calculate
an
average
number
of
operating
hours
for
the
facility,
expressed
as
a
percentage
(
i.
e.,
a
facility
operating
8760
hours
per
year
is
operating
at
100%
of
its
operating
capacity).
For
facilities
with
more
than
one
intake,
all
of
the
data
for
each
intake
was
averaged
together.
(
It
should
be
noted
that
if
an
operating
hours
threshold
is
included
in
the
final
Phase
III
rule,
facilities
may
be
able
to
perform
an
intake­
by­
intake
calculation
as
in
the
Phase
II
rule.)

Results
The
analysis
yielded
results
for
254
(
unweighted
value)
manufacturing
facilities
(
641.9
weighted).
Of
these,
34
facilities
(
79.9
weighted)
did
not
supply
enough
information
to
complete
the
analysis.
Eight
facilities
(
23.8
weighted)
had
operating
thresholds
below
15%
or
60
days.
The
following
table
illustrates
the
distribution
of
operating
thresholds:

Range
of
Operating
Threshold
Number
of
Facilities
(
unweighted)
Number
of
Facilities
(
weighted)
0
to
15%
8
23.8
15.1
to
50%
10
31.5
50.1%
to
75%
10
21.4
75.1
to
90%
14
34.4
90.1
to
99.9%
54
137.8
100%
124
313.1
220
562
Of
the
eight
facilities
that
fell
below
the
60
day
operating
threshold,
one
has
since
been
removed
from
the
scope
of
the
Phase
III
rule.
Of
the
remaining
seven,
six
are
located
on
a
freshwater
river
or
stream.
None
of
these
facilities
withdraws
more
than
5%
of
the
2
Facilities
with
a
design
intake
flow
(
DIF)
of
less
than
50
million
gallons
per
day
(
MGD)
are
not
subject
to
national
requirements
in
the
proposed
Phase
III
rule,
as
the
lowest
intake
flow
threshold
among
the
proposed
alternatives
is
50
MGD.
Additionally,
some
facilities
may
have
been
removed
from
the
scope
of
the
regulation
if
further
research
demonstrated
that
the
rule
did
not
apply.
3
mean
annual
flow
of
the
waterbody
on
which
they
are
located.
Further,
under
the
proposed
Phase
III
rule,
none
of
the
six
facilities
would
be
subject
to
national
requirements.
3
The
seventh
facility
withdraws
from
an
ocean
and
has
a
DIF
above
50
MGD,
meaning
that
it
would
be
subject
to
entrainment
standards
absent
a
provision
for
operating
hours.

3
None
has
a
DIF
greater
than
16
MGD.
