1 Site Visit Report North Anna Power Station 1022 Haley

Drive Mineral, VA 23117 April 28, 2009 1.0 Background and Objectives The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requirements that r eflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generators and manufacturers to better understand th e cooling water intake structure (CWI S) technologies in use at ty pical facilities, including the site

- specific characteristics of each facility and how these affect the selection and performance of CWIS technologies. EPA is also visiting facilities to better understand cooling water use and specific issues or technologies that can affect 316(b) compliance. The North Anna Power Station (North Anna) was selected for a site visit due to its proximity to EPA Headquarters and its use of a freshwater reservoir. 2.0 Facility Description North Anna occupies a

bout a 1080 acre site in L ouisa County , Virginia on the southern shore of Lake Anna. The facility is owned and operated by Dominion Virginia Power (Dominion) . The North Anna facility is very similar in design to Dominion’s Surry

site. The site is surrounded by L ake Anna, a 9600 acre lake created b y impounding the North Anna River , and the Waste Heat Treatment Facilit y (WHTF), a 3400 acre series of three lagoon s designed for the removal of waste heat, both own ed by Dominion. Dominion owns up to 5 feet water elevation above the lake and WHTF and issues access rights to local home owners. The facilit y began operations in 1978 1 and employ s approximately 900 people. The facility ’s NPDES permit ( VA0052451 ) is due to expire October 24, 2012. In March 2003, the NRC extended licenses for both units 1 and 2 for an additional 20 y ears (April 2038 for unit 1 and August 2040 for unit 2). 3.0 Electricity Generation and Transmission North Anna was originally designed to hav e four nuclear reactors, but only two reactors 2 were built that currentl y operate with a total of 19 41 MW 3 (gross

1 For Unit 1; Unit 2 began operations in 1980. Both are Westinghouse pressurized w ater reactors (PWRs). 2 See S ection 8.0 for information on a proposed Unit 3.2 summer capacity). Both generating units are baseload units (with a capacity utilization rate [CUR] of over 90%) and provide power to over 450 , 000 homes in the Richmond and northern Virginia areas. In 2007, North Anna produced approximately

15 billion megawatt hours with a capacity factor of 87 percent. Unit 1 was last shut down March 2009 for the refueling outage. North Anna rotates refueling outages between the two units every 18 months. The transmission sy stem is owned by Dominion but is operated by a different business unit. 4.0 Cooling Water System and Intake Structure North Anna withdraws once

- through cooling water from a CWI S on the sho re of Lake Anna. The CWI S consists of a trash rack and eight intake bay s (four for each unit). Each bay

has a coarse mesh (1/8 x 1/2 inch) traveling screen 4 and one circulating pump. 5 The screens are rotated based on a head differential across the scree n and cleaned with a high pressure spray wash. There is no fish/debris return, as all materials are collected and transported to a landfill. The design through

- screen velocit y i s 2.7 feet per second (fps). 6 Modification of the existing intake to reduce the screen velocity down to 0.5 fps would require more than doubling the size of the existing intake bay s, even assuming dual

- flow (Passavant) ty pe screens were retrofitted. Facility representatives indicated a low pressure spray and fish return could pote ntially be retrofit for impingement mortality reductions if necessary

. The design intake flow (DIF) for North Anna is 2539 mgd. The average actual flow s (AIF) for the facility are: winter flow is 1325 MGD with 3 pumps in operation (throttled) per unit; s pring/ f all flow is 1872 MGD with 3 pumps in operation per unit; s ummer flow is 2376 MGD with 4 pumps in operation per unit . The ΔT across the condensers is approximately 14°F. Lake Anna was constructed for the specific purpose of providing cooling water for the North Anna facility . Dominion purchased over 18,000 acres and, in 1972, constructed an earthen dam on the North Anna River. 7 T wo distinct waterbodies were created : Lake Anna, (9600 acres) and the WHTF (3400 acres) for the removal of waste heat. 8 North Anna is the onl y facility permitted b y the state of Virginia to withdrawal water from Lake Anna.

3 In recent years, the facility has upgraded its turbines, moisture separators, and other equipment to provide an increase in capacity of over 100 MW. 4 The screens were installed in 2005. 5 Each pump has a capacity of 317 million gallons per day (mgd) (or 220,376 gpm). 6 The through

- device velocity at the trash rack is 1.2 fps. 7 The dam is maintained and permitted by Dominion. Dominion recently installed a small hydroelectric generator at the discharge of the dam; the pow er is sold to the grid. 8 In addition to providing for the removal of heat, Lake Anna has also been extensively developed as a recreational w aterbody. Waterfront homes and a state park occupy much of the 200 miles of shoreline,3 The WHTF is se parated from Lake Anna b y a series of dikes, inundating former creek watersheds upstream. It was expressly designed as a heat treatment technology

and was designed prior to the passage of the Clean Water Act (CWA) in 1972. The Virginia Department of Envi ronmental Quality (DEQ) has consistently

supported this design and its classification as a treatment sy stem rather than water s of the US; the state Attorney General also recently issued a formal legal opinion that detailed the state’s legal position in sup port of this classification

. Cooling water is withdrawn via the CWI S from Lake Anna. After passing through the facilit y, heated effluent is discharged to a 1/4 mile long discharge canal, which discharges into the first of a series of three treatment la goons that comprise the WHTF. Lagoon 1 (the smallest of the three) is separated from L ake Anna b y Dike 1 and is connected to Lagoon 2 b y a 1/2 mile long canal on its southern shore. Lagoon 2 is bounded by Dike 2 and connected to Lagoon 3 via another 1/2 mile long canal, also on its southern shore. Effluent in Lagoon 3 passes through a subsurface discharge weir 9 in Dike 3 into L ake Anna, near the dam. Facility

representatives stated that modeling results suggest that residence time in the WHTF is approxi mately one week. Water levels in the WHTF are ty picall y 1

- 1.5 feet higher than the level in Lake Anna, creating an induced current in the WHTF. The design discharge velocity at the weir is approximately 6 fps. Given the volume of effluent discharged fro m the WHTF and the volume of water discharged at the dam (usually 40 cfs 10 ), facility representatives stated that there is some circulation of effluent in a northerl y direction (i.e., towards the CWI S). 5.0 Impingement and Entrainment Information Lake Anna ha s numerous fingers from incoming streams and an average depth of 25 feet. 11 Facility

representatives stated that the North Anna River previousl y had very low flows and supported minimal biological activity . When the lake was formed, the species compositio n changed from riverine species (e.g., ye llow perch) to a distribution more ty pical of lakes (e.g., bluegill), but for over the past 10

- 15 y ears, the species composition has remained relativel y constant. The
including a long the WHTF. How ever, there is no public access or commercial enterprise in the WHTF

— access is strictly limited to those residents along the shores. Dominion owns the entire shoreline (from an elevation of 250 to 255 feet above sea level) and the lake bottom and regulates any uses, construction, and other activities in both the lake and WHTF. 9 The w eir is a controlled discharge structure that passes beneath the roadway spanning Dike 3. A curtain wall extends downward to approximately 13 feet below normal lake level, where a series of 6 discharge bays are located. Each bay is approximately 20 feet wide and 15 feet deep (extending to the lake bottom). Each bay can be fitted with up to three stop logs to block discharge flows; Dominion currently operate s the weir with 10 of the 18 stop logs in place, forming an open discharge area in the center of the weir. 10 Reduced to as low

as 20 cfs during drought conditions. 11 The deepest portion of the lake is near the dam, with 80 foot depths.4 Virginia Department of Game and Inland Fisherie s (DGIF) stocks Lake Anna with a variet y of fish; Lake Anna is widel y recognized as a prime recreational fishery

. 12 Dominion has conducted biological monitoring at multiple locations since before the facility

was constructed. They

have conducted electrofi shing at nine locations and gill net sampling at six locations spread out in L ake Anna and the WHTF in March, June, August, and November. As required by North Anna’s permit, Dominion reports the monitoring results to the state. Dominion has collected ove r 1700 electrofishing samples totaling 194,000 fish representing 39 species and 1100 gill net samples totaling 35,000 fish representing 37 species. Facility representatives added that the monitoring indicates a stable, sustainable fish population in both the lake and the WHTF and that the biological composition in Lake Anna and the WHTF are virtuall y identical in both density of organisms and distribution of species. 13 Dominion also conducts thermal and biological monitoring at several sites uplake and dow nlake of the facility and noted that the North Anna River (downstream from the facility) has been similarl y studied since the 1960s. From 1979

- 1983 Dominion conducted an impingement and entrainment study

. The most abundant species collected were gizzard shad, y ellow perch, and black crappie. The majorit y of impingement (approximately 75%) occurred in the winter and biologists determined that the impingement represented less than 1% of the standing stock of fish in L ake Anna. From July , 2005

- July , 2006 Dominion collected impingement data in preparation for compliance with the now

- suspended 2004 Phase II rule. During the sampling periods, North Anna conducted impingement sampling two times a month for a ye ar for a total of 24 sampling events. During ea ch 24

- hour sampling event, the facility ran the screens continuously and collected impingement samples from each screen wash for 10 minutes each hour . The facility did not conduct entrainment sampling

. 14
The 2005

- 2006 data collection showed 1386 individua ls from 18 species, with bluegill as the predominant species. 15 Facility representatives noted they

12 It is not clear ho w the stocking affects overall fish populations or mitigates any potential changes to biology of the lake as a result of the plant intake structures. 13 There is also some evidence of movement of organisms between Lake Anna and the WHTF; a tagged walleye wa s released at the northern end of the lake and was caught by a fisherman at the discharge canal less than a year later. 14 The facility is located on a lake and would therefore not have been subject to entrainment requirements. 15 Threadfin shad and gizzard shad w ere the second and third most abundant; threadfin shad are stocked as a prey species for w alley e and largemouth bass.5 collected more fish at night and that many were y oung of the y ear. The estimated annual impingement rate was calculated as approximately 153,880 fish. 16
6.0 Co oling Tower Feasibility North Anna has not considered retrofitting cooling towers for the two existing units. Facility

representatives stated the heat exchangers on the existing units would need to be replaced to accommodate the higher back pressures of a cooling tower. Much of the available area near the power block (originally left for units 3 and 4) may

eventually

be occupied by

the proposed new Unit 3. 17 The new Unit 3 as proposed would be approximately 1600 MW (roughl y equal to the production of uni ts 1 and 2 combined) and would employ a hy brid of dry

- cooling and closed

cy cle wet cooling. The dry

- cooling unit would be used during the highest heat loads to reduce cooling water temperatures prior to the wet cooling tower, reducing evaporative losses an d reducing make

- up water requirements from L ake Anna

. Facility

representatives indicated Unit 3 , if constructed, could begin operation b y 2018. Facilit y representatives also stated that enclosing the WHTF (b y sealing the discharge at Dike 3) and adding a circulating pump to return water to the CWI S would be prohibitively expensive, given the long piping distance. 18
7.0 Debris Handling North Anna does not have significant problems with debris loading. Facility representatives did note that there are occasio nal problems with hy drilla or other debris (especiall y after storms), but these events do not significantl y affect operations. 8.0 Repowering/Future Uses As stated above, the original design plan for North Anna included four generating units. Dominion has received an Earl y Site Permit for the proposed Unit 3, which would come online in approximately 2018. The new unit as proposed would have a generating capacit y of 1600 MW and would be located adjacent to Units 1 and 2. Unit 3 would employ

a closed

- cy cle cooling s ystem; 19 it would not contribute any additional heat to the WHTF or Lake Anna.

16 This estimate was based on withdrawal rates at 100% of the DIF for the entire year, which is very rarely the case. Additionally, the impingement data did not exclude moribund fish (such as gizzard shad), w hich likely led to a larger estimate for annual impingement. 17 The early site permit (ESP) application for unit 3 wa s approved by the NRC in 2007. Application for a combined construction and operating license was submitted for a GE

– Hitachi Economic Simplified Boiling Water Reactor (ESBWR). 18 A straight line pipe w ould be approximately 8 miles long, but would require installing pipe across all three cooling lagoons; a land

- based route w ould be far longer. 19 Unit 3’s cooling system would be a hybrid system; a low profile natural draft cooling tower (w ith fan assistance and some dry cooling design features to minimize the visible plume) w ould be the primary6 There are currently

no plans to construct Unit 4, but facility representatives indicated that the site plans for Unit 3 would allow for addition of a fourth unit. 9.0 Coo ling Ponds As discussed in Section 4.0, the WHTF has been identified by the permitting authority as a treatment sy stem for waste heat . Lake Anna is classified as a water of the U.S. and is subject to water qualit y standards. 10.0 Ownership North Anna is ow ned b y Virginia Electric and Power Compan y d/b/a Dominion Virginia Power, a subsidiary of Dominion Resources, Inc., an investor

- owned compan y. 11.0 316(a) As discussed in Section 4.0 above, the WHTF was specificall y designed and constructed to dissipate waste heat from North Anna. F acility representatives stated that the water temperature at the discharge is within a few degrees of the lake temperature. North Anna has a heat rejection limit at the discharge canal from the facility that is based on BTUs per h our in its NPDES permit; temperature monitoring is conducted at the Dike 3 discharge. 20 The facility was granted a 316(a) variance for thermal discharges at Dike 3. 12.0 Ash Handling North Anna does not use coal as a fuel and therefore has no ash ponds. 13.0 Ai r Emissions Controls North Anna does not use any air emissions controls. 14.0 Additional Information The Blue Ridge Environmental Defense League (BREDL), a regional environmental group, appealed the NPDES permit renewal issued by the State Water Control Boar d to North Anna in 2007. A focal point of the suit concerned the point of application of the thermal discharge limits and the classification of
cooling mechanism. When lake levels become low and w ater consumption is a concern, the unit would switch over to a series of dry cooling towers. 20 Dom inion also collects temperature data from other locations (e.g., locations within the WHTF) but these are for informational purposes.7 the WHTF as a waste treatment sy stem. The state circuit court issued a final order in September 2009, finding that the Board’s classification of the WHTF as a waste treatment sy stem was contrary to law. Dominion and the Board appealed the decision to the Virginia Court of Appeals in October 2009, and a decision is expected in 2010

. Facilit y representatives indic ated that they had not reached a decision on how they would have complied with the 2004 Phase II existing facility rule on cooling water intakes . They

were evaluating technologies, restoration, and other alternatives when the rule was suspended. At that time, they were leaning towards the cost

- benefit alternative and/or restoration. Attachments Attachment A List of Attendees Attachment B Aerial Photos Attachment C PowerPoint Presentation (April 28, 2009) Attachment D North Anna Emergency Plan Map A ttachment E Impingement and Entrainment Studies for North Anna Power

Station (1978

- 1983)8

Attachment A
-- List of Attendees Paul Shriner, EPA Jan Matuszko, EPA Shari Goodwin, Tetra Tech Kelly Meadows, Tetra Tech Bill Bolin, Dominion Randy Markey , Dom inion Judson White, Dominion1 Site Visit Report Sunoco

—Philadelphia Refinery 3144 Passy

unk Avenue Philadelphia, PA 19145 July 14, 2009 1.0 Background and Objectives The Environmental Protection Agency (EPA) is in the process of developing 316(b) cooling water intake structure requir ements that reflect the best technology available (BTA) for minimizing adverse environmental impact for all existing power plants and manufacturing facilities. As part of this process, EPA staff is visiting electric generators and manufacturers to better understand the cooling water intake structure (CWI S) technologies in use at facilities, including the site

specific characteristics of each facility and how these affect the selection and performance of CWI S technologies. EPA is also visiting facilities to better understand cooling water use and specific issues or technologies that can affect 316(b) compliance. Sunoco’s Philadelphia Refinery was selected for a site visit because it utilizes cooling water in refin ing of petroleum products

. 2 .0 Facility Des cription Sunoco’s Philadelphia Refinery is located on a 1000 acre site in southwestern Philadelphia along the Schuy lkill River . The site originall y began operations in the 1860s (processing whale oil), began processing crude oil in 1900, and eventuall y m erged with an adjacent refinery ; accordingl y, Sunoco considers the site as two separate entities 1 from a water use perspective and has retained separate NPDES permits for each. 2 The site employs approximately 1000 people. 3 .0 Manufacturing Information T he Philadelphia Refinery processes petroleum into a variet y of fuels, chemicals, and other products. Point Breeze produces gasoline, diesel, and a small amount of other products, while Girard Point produces a similar mix of products plus benzene. 3 Accord ing to facility representatives, the facilit y is typical of a midsize refinery

.

1 Point Breeze (formerly the Atlantic Refinery) is the original refinery and was purchased by Sunoco in 1988; the adjacent Girard Point w as acquired in 1994. Since the facilities previously operated independently, each site has much of the same equipment, increasing operational flexibility. The site is generally operated as a single refinery (it has one central management/op erations center and single air em issions and solid waste permits) but is treated as separate sites for w ater

- related functions. The sites share some water and steam, but are largely independent for water usage. 2 Point Breeze’s permit number is PA0012629 and Girard Point’s is PA0011533. Girard Point’s permit is due to expire on February 28, 2011 and Point Breeze’s is due to expire on January 31, 2011. 3 Intermediate products can be shared betw een Point Breeze and Girard Point, as w ell as the Marcus Hook r efinery.2 Ty pically , the refinery

operates 24 hours a day

. 4 Production may fluctuate depending upon product demand, which can be impacted b y outside factors such as industry

capacity

. At the time of the visit, the site was producing at approximately

70

- 80% capacit y. Production does not vary greatly on a season al basis , but the mix of products may change. 5
Crude oil is supplied by

the Fort Mifflin Terminal Complex on the Delaware Rive r in Philadelphia to the Point Breeze Facility , and by Hog Island Wharf Dock in Tinicum Township and Fort Mifflin Terminal Complex to the Girard Point f acility where ships unload crude oil to storage tanks and pipelines. Point Breeze processes approximate ly

130,000 barrels per day (bpd), while Girard Point processes approximately

210,000 bpd. 4 .0 Cooling Water System and Intake Structure The site has 3 active CWI Ss, each with a shoreline intake. 6 Point Breeze operates one CWI S near the boat dock; it fee ds a full y recirculating cooling water system (CWS) with mechanical draft cooling towers. 7 The other 2 CWI Ss (on the shoreline of the inside bend of the river) service Girard Point ’s CWS; it uses both once - through cooling and recirculating cooling via mec hanical draft cooling towers. The following table summarizes the information for these intakes; more information is below.

Point Breeze Girard Point Total # CWI S 1 2 3 # traveling screens 0 3 3 Design Intake Flow ( DI F ) 20.7 MGD 31.7 & 15.8 MGD 68.2 M GD Actual Intake Flow ( AI F ) 4.2 MGD 11.8 & 0.4 MGD 16.4 MGD Through

- screen velocity 1.5 fps 1.5 fps

4 The entire refinery is never taken offline at the same time. Individual process units may close for maintenance, with sufficient storage of intermediate products to enable continued production at the other process units. Alternatively, the pro cess unit may share capacity or products w ith the adjacent equipment or the Marcus Hook refinery or may purchase the needed products commercially. Some unit closures may require that additional associated units also be closed. 5 For example, the facility may increase the production of heating oil in the winter. 6 Point Breeze’s North Yard CWIS is out of service. Girard Point also has one CWIS that has been out of service for decades. 7 Facility representatives noted that the cooling towers have been in pl ace for some time; they were una ware of the rationale for constructing them instead of using once

- through cooling.3 Point Breeze’s CWI S ha d coarse mesh fixed screens located in the bulkhead near the dock ( at a depth of approximately 15

- 20 feet) but they had been rem oved from service man y ye ars ago . The screens are periodically cleaned b y divers, as debris and silt are much less problematic at this intake. The only cooling water uses are for makeup water for the cooling towers. Girard Point’s CWI Ss are located on the shoreline of the inside bend of the river at a depth of approximately 14

- 16 feet. They

are fitted with rotating coarse mesh (3/8”) traveling screens. One CWI S is used to provide non

- contact, boiler, and process water to the plant and uses the intak e structure for a former onsite water treatment plant and has two 6 foot wide coarse mesh traveling screens. These screens were rebuilt in 1990 and facilit y representatives stated that they have proven to be expensive to operate. These screens are rotate d twice per shift and the combined fish/debris return trough discharges just outside the pumphouse into the river. A chain link fence submerged in the river acts as an additional lay er of screenin g in front of the trash racks. The other CWI S for Girard P oint (located just to the north of the CWI S described above ) is largely

used for supplemental (service water) flows and has one functional 6 foot wide traveling screen. (A second screen is non

- functional.) Two circulating pumps are installed, but ty pical ly only one is used. This screen is rotated once per shift. Dredging in front of both Girard Point intakes occurs on an occasional basis. The Girard Point intakes previously supplied a much larger volume of once

through cooling water before some process lines were converted to recirculating sy ste ms in the 1980s. (See Section 5 .0 below.) In sum, the DIF for the entire refinery is 68.2 MGD and the total AI F for both sites is approximately 16.4 MGD , according to facility representatives. At the time of the site visit, approximately 12.9 mgd was being withdrawn, with approximately

3.6 mgd as makeup water for the various cooling towers; the remaining flows are largely dedicated to boiler feed water. 8 Water usage varies seasonall y, as the capacity of the coo ling tower, evaporative potential, and drift change with the weather. In the summer, the facility ty picall y withdraws 15.0 MGD to 20.0 mgd, with approximately <5% being used as once - through non contact cooling water. Ty pically , one operator is charged wi th multiple duties at a process unit , including operating the cooling tower or operating the traveling screens. The worker may conduct visual inspections, basic chemical tests to ensure proper tower functioning, and manually triggering screenwash cy cles.

8 Facility representatives stated that the facility produces less steam than in the past, as it is cheaper to buy electricity than to produce it onsite; as such the water withdraw als have decreased.4 Aside from the two halves of the refinery , there are no other major users of cooling water nearb y, thereb y reducing the viability of sharing steam, reclaimed water, or other approaches to reduce intake withdrawals. 5 .0 Flow Diagram The facility

withdraw s surface water for once - through non

- contact cooling, cooling tower makeup, boiler feed water, process water, and for fire suppression. A significant portion of the facilit y’s water withdrawals are dedicated to providing makeup water for cooling towers or for supply ing treated water for boiler feed or other process uses. The remaining <5% is used for non

- contact, once - through cooling.
F acilit y representatives noted that the refinery previously used much higher quantities of water

-- especially once - through cooling water. During the 1980’s, it significant ly reduc ed once - through cooling. For example, it added new cooling towers to handle cooling loads. The facility continues to reduce water usage. Facilit y representatives noted that engineers were making a concerted effort to recover condensate and identify other opportunities for process optimization, as the water recovered is of very high quality , has already been treated, or retains some amount of heat that can be recovered. S tripping steam is t ypicall y recycled as process water, largel y as wash water for desalters. The fluid cat cracking units also collect steam and reuse the water as sour water. Boiler water is treated and softened, and is then injected into the process unit as steam. However, the facility noted that while it strives to reduce water usage, some activities lead to increased water usage. For example, the facility recentl y constructed a wet gas scrubber to control air emissions, which increased water usage at the site b y ap proximately 10

- 15%. 6 .0 Electricity Generation and Transmission Point Breeze has a one 2.5 MW generating unit and Girard Point has three generators. 9 The Point Breeze generating unit operate s on gas produced b y offgassing and produce power to be used onsite

. The Girard Point generators operate on 680# steam. The units use river water for cooling. 7 .0 Impingement and Entrainment Information Facilit y representatives were unaware of an y source water characterization, impingement , or entrainment studies conducted a t the site. Neither NPDES permit contains requirements for 316(b). The facility does, however, have a water use permit with the Delaware River Basin Commission (DRBC), which assesses a fee for water withdrawals.

9 The turbines typically generate approximately 4 MW each, but have a capacity of 30 MW.5

8 .0 Cooling Tower Feasibility As noted in Section 3.0, the Sunoco Philadelphia site uses numerous mechanical cooling towers. The towers are built from either fiberglass or redwood , depending on the age of the tower . Facilit y representatives stated that there are no problems with drift, noise, o r plume/visibility , 10 as the towers are located well inside the plant propert y. They did state that two towers have been replaced in recent ye ars. O ne tower partially collapsed a few y ears ago and was rebuilt, 11 while the o ther was replaced 2

- 3 y ears ago. 12 The new tower has high efficiency fill and facility

representatives have not experienced any difficult y in operating the tower; it operates at approximately 4

- 5 cy cles of concentration. 13 An onsite vendor maintains the chemical additives (antifouling and antiscaling chemical feeds) and there has been no noticeable change in chemical usage over the previous cooling tower designs

. Four towers are process

- specific and can be taken out of service for maintenance when the associated process unit is also out o f service. Other towers serve more than one process unit and essentially never stop operating; individual cells are taken offline and serviced separately

. Point Breeze has 4 cooling towers that serve the entire cooling needs for the site. The towers are located at the crude unit, 14 the hy drogen desulfurizing unit, the fluid/cracking unit, and at the hy drogen complex. Girard Point has 4 cooling towers, including the largest tower at the refinery

. This tower has 20 cells and is 55 feet tall. A second tow er (serving the Girard Point crude unit) has 12 cells; facility representatives noted that this was amongst the least efficient towers on the site and may be upgraded or replaced in the future. A third tower was recentl y built at the fluid unit and cracke rs, a process line which is a large user of water at the refinery . The 14 cell tower is much

10 The facility also noted that some of the towers are located approximately 2 miles from the Philadelphia Air port. 11 The rebuilt tow er w as constructed w hile the facility continued to operate. Facility representatives stated that the facility operated w ith a temporary cooling water tower and at a low er production capacity, but did not experience any plant

- wide sh utdowns as a result of the rebuilding process. The affected process unit wa s only taken fully offline during the tie

- in; the facility could not recall the length of the outage for the tie

- in. 12 The replacement tower was constructed to replace one of the o ldest and least efficient cooling tow ers on the property. Facility representatives noted that they were able to adjust production rates and share (or purchase) intermediate products to minimize any construction

- related downtime. The majority of construct ion took place during a major maintenance outage of 6

- 9 m onths (unrelated to the conversion to closed

- cy cle cooling). Major outages typically occur every 4

- 5 y ears and last approximately 6 w eeks, although a recent outage lasted 3 months due to low dem and. Facility representatives stated if the extended outage had not occurred, much of the construction of the replacement tower would have been done while the unit was operating; they stated that the standard 6 w eeks might not have provided enough time to com plete tie

- in and startup activities. 13 Other tow ers at the refinery typically operate at 4

- 8 cy cles, 3.2 cycles, and 3.8 cycles. 14 Facility representatives noted that this tower loses approximately 864,000 gpd to evaporation and 504,000 gpd for blow down, a nd can reject approximately 330 million BTUs of heat.6 shorter than the other towers due to the use of high efficiency fill material. It cost approximately

$10 million to construct. 15 The fourth tower is a small 4 ce ll tower at the Au

- 433 alk yl ation unit

. In considering a retrofit to cooling towers for the remaining once - through flows at Girard Poi nt, facility

representatives noted that these are relativel y small flows ( 0.4 mgd, as noted above), even compared to othe r process flows within the refinery . The process units also ty picall y result in a relativel y low delta T (10

- 15 °F)

. From a spatial perspective, the two process units are far from each other, making a single cooling tower problematic; the facility would likely

evaluate other options, such as reconfiguring the equipment in the process units . Facility representatives also noted that, for Girard Point, the realized benefit derived from conver sion to closed

- cy cle cooling is not justified by the cost. They

a dded that much of the flow is used to cool an air compressor; construction of a cooling tower would be far more expensive than the compressor itself. 9 .0 Future Activities Facilit y representatives were not aware of an y plans for major renovations, plant expansion, or production changes. Presently , the facility ’s onl y investments are for required upgrades or general maintenance. 10 .0 Cooling Ponds There are no cooling ponds onsite. 1 1 .0 316(a) The NPDES permit contains temperature discharge limits ( 1 10°F ) including requirements for a mixing zone. The facilit y has never had an y problems meeting its thermal limits. 1 2 .0 Ash Handling There is no as h produced onsite. 1 3 .0 Air Emissions Controls Aside from the increased water usage from the wet gas s crubber (see Section 2.0) , EPA did not collect any

data on air emissions.

15 Note that this tower w as able to use the existing piping and concrete basin, thereby significantly reducing the overall capital costs. Temporary cooling towers were brought in at the end of the produ ction period to allow construction workers to prepare for demolition of the old tow er.7

1 4 .0 Issues with Debris The Schu yl kill River carries a high debris load, especiall y after large storms , and has a high tidal variation (4

- 5 feet) . However, the facility did not d iscuss any problems with handling the debris loading, even though man y of its screens are older (i.e., less efficient at screening and removing material). Facility representatives did state that the screens are normally rotated once or twice per shift, but that the frequency of wash cy cles may

increase during high debris loading periods.

Attachments Attachment A List of Attendees Attachment B Aerial Photos8

Attachment A
-- List of Attendees Paul Shriner, USEPA Jan Matuszko, USEPA Steve Geil, Tetra Tec h Kelly Meadows, Tetra Tech Jim D i s ario, Sunoco Chuck Barksdale, Sunoco Bob Gallagher, Sunoco

# Copyrighted page/s removed. Copyrighted material is not available in Regulations.gov since it may not be reproduced without consent of the copyright holder. Please contact the EPA Docket Center, Public Reading Room to view this document. Address: 1301 Constitution Ave, NW Room 3334 Washington, DC 20004 Telephone: 202-566-1744 Fax: 202-566-9744 Email: docket-customerservice@epa.gov11

Attachment C
-- PowerPoint Presentation (April 28, 2009) Please see the attached materials. Attachment D
-- North Anna Emergency Plan Map Please see the attached materials. [oversize

— in har d cop y onl y] Attachment E
-- Im pingement and Entrainment Studies for North Anna Power Station (1978
- 1983) Please see the attached materials.