MEMORANDUM

Tetra Tech, Inc.

10306 Eaton Place, Suite 340

Fairfax, VA 22030

phone	703-385-6000

fax	703-385-6007

TO:			Record

FROM:		Christine Wong, Tetra Tech, Inc.

DATE: 		August 28, 2008

SUBJECT:	Notes from Beaudrey USA teleconferences

To complement existing information on cooling water intake structures
and intake technologies, EPA directed Tetra Tech (Tt) to research and
make contact with intake technology manufacturers, specifically
international intake technology manufacturers.

Tt began by searching the docket records and Internet for intake
technology manufacturers.  A 2007 Power-Technology.com web article
stated that over 90% of French nuclear plants use Beaudrey screens and
the Beaudrey Web site stated that:

Screens equipped with Beaudrey FPSTM will meet and/or exceed the 316b
fish impingement criteria of 80 to 95% mortality reduction in almost all
cases. System operational tests have demonstrated mean survival rates in
excess of 90% across a range of fish species.

Because Beaudrey, a France-based company, also has an American office,
Tt contacted the American office via email to discuss information on
their system operational tests.  On March 4, 2008, Tt spoke with Brian
Hittle, Director of Beaudrey’s USA projects, regarding the company’s
intake screening products and unusually large share of the French intake
technology market.

Tt learned that Beaudrey was founded in France in 1982 to develop
aquatic organism protection technologies for the Electricité de France,
and that there are no national regulation regarding aquatic organism
protection in France, Belgium, or Portugal (the countries where Beaudrey
has worked), or in the European Union.  Mr. Hittle likened the European
aquatic organism protection regulatory framework as similar to the U.S.
before the passage of the 316(b) regulations – site-specific,
locally-driven permits to protect aquatic organisms in specific,
high-value waterbodies.

While over 90% of France’s nuclear power plants use Beaudrey drum
screens, only two facilities use the patented Fish Protection System
(FPS); there are also systems installed at facilities in Belgium and
Portugal.  The company, both in its European and American offices,
remains extremely active in the in the intake technology market.

Tt found that the original Beaudrey screens were Ristroph screens
equipped with fish buckets.  The company’s newest fish protection
technology, the FPS, includes a Hidrostal® fish pumps and backwash
screens and works with all types of Beaudrey traveling screens, drum
screens, and W Intake Protection (WIP) screens.  The FPS also works with
fine mesh screens and can be installed at the same time as the screens
or added/retrofit later.  Fish are impinged for a maximum of one minute,
as the FPS operates at one revolution per minute.  With the FPS/WIP
screen combination (rotating screening wheel with no chains or sprocket
teeth), Beaudrey guarantees no carry-over of debris or fish.  The
company has found that this system works well for high, low, and
mid-range water levels.

Mr. Hittle explained that Beaudrey replaces other company’s screens
when installing its FPS; he did not specify whether the FPS could be
installed on or with other companies’ screens, only indicating that
the Beaudrey doesn’t, preferring instead to do a wholesale
replacement.  He also noted that the Hidrostal® fish pump is the only
technology approved by the U.S. Bureau of Reclamation in California to
move fish; there are many papers available discussing this technology.

Mr. Hittle stated that representatives from Beaudrey have previously met
with Martha Segall (USEPA) to discuss the applicability of Beaudrey’s
technology for 316(b) requirements; the meeting took place after the
Phase II Rule had been promulgated.  Mr. Hittle indicated that the
company has years’ worth of impingement and entrainment data at its
French sites and is willing to share this data upon request.

Mr. Hittle stated that Beaudrey has not had much presence in the U.S.
market, but is working on market penetration.  Beaudrey is currently
running an EPRI-funded pilot study to test its FPS; the pilot test has
been running since fall 2006.  The pilot study has been collecting data
on the effectiveness of the FPS on naturally-occurring fish species; the
pilot test moved on to introduced species in spring 2008.  The data
collection includes both numbers and types of fish impinged.  Mr. Hittle
reported that impingement survival holds steady at about 90% for the
naturally-occurring species, though the pilot study does not account for
fish that were weak or dead prior to impingement.  Beaudrey expects to
have even higher survival rates with the introduced fish.  In follow-up
communications, Mr. Hittle indicated that Beaudrey conducted a series of
native fish sampling events during March and early April, and conducted
the first of a series of hatchery fish introduction experiments (1,500
fish) on April 30th.  Mr. Hittle reported that much of this research is
sponsored or in partnership by/with EPRI, and an EPRI representative
(Doug Dixon) was to be present to observe the introduction experiment. 
On May 13, 2008, Mr. Hittle reported on the preliminary mortality study
results from the Beaudrey WIP screen fish introduction test after
holding the fish for 48 hours (Table 1, below) and noted that a full
statistical report will be issued upon completion of the summer warm
water test with more fish.

Mr. Hittle conducts power plant inspections up and down the Mississippi
River valley; he commented that a common concern among plant operators
is that a mandate for recirculating cooling towers will permanently
lower water levels in the Mississippi River basin, or possibly, in the
entire U.S., as large volumes of makeup water are taken up and never
returned. Mr. Hittle noted that a facility in Kansas City has dug deep
groundwater wells and begun using groundwater for cooling to avoid 316
intake water implications.

Table 1: Pilot Study Initial Results

Fish Species	Control Group Survival	Test Group Survival

Bluegill

	101 live/101 total = 100.0% survival	197 live/199 total = 99.0%
survival

Fathead Minnows

	81 live/100 total = 81.0% survival	165 live/208 total = 79.3% survival

Channel Catfish

	90 live/100 total = 90.0% survival	220 live/229 total = 96.1% survival



